Original Transcript
IN THE CIRCUIT COURT OF THE FIFrEENTII JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL, DIVISION
L.M.,
Plaintiff,
vs. CASE No.
502008CA0280513OOOCMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME H
October, 20, 2009
10:10 a.m.
515 N. Flagler Drive
Suite 200-P
West Palm Beach, Florida 33401
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
S Suite 600
4440 PGA Boulevard
ESQUIRE •n Al noel. Vall•Compny
Palm Beach Gardens, FL 33410
wvnv.esoulresolutIons.com
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•
•
•
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE No.502008CA028051XXXXMB AB
L.M.,
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
Tuesday, October, 20, 2009
10:10 - 3:30 p.m.
D15 N. Flagler Drive, Suite 200-P
West Palm Beach, Florida 33401
Reported By:
Teresa Whalen, RPR, FPR
Notary Public, State of Florida
West Palm Beach Office Job #118991
Toll Free: 866.709.8777
• 0 Facsimile. 561.394.2621
Suite 600
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE No.08-CV-80119-CIV-MARRA/JOHNSON
4 JANE DOE NO. 2,
Plaintiff,
-vs-
7 JEFFREY EPSTEIN,
Defendant.
Related cases:
08-80232, 08-80380, 98-80381, 08-80994,
10 08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
11 /
12
DEPOSITION OF
13 VOLUME II
14
Tuesday, October 20, 2009
15 10:10 - 3:30 p.m.
16
515 N. Flagler Drive, Suite 200-P
17
West Palm Beach, Florida 33401
18
19
20
21 Reported By:
Teresa Whalen, RPR, FPR
22 Notary Public, State of Florida
West Palm Beach Office Job 11118991
23 Phone:
24
25
Toll Free: 866.709.8777
Facsimile: 561.394.2621
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• APPEARANCES:
On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE
BURMAN CRITTON LUTTLER & COLEMAN, LLP
303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401
Phone:
7 On behalf of Plaintiff L.M.:
BRADLEY J. EDWARDS, ESQUIRE
CARA L. HOLMES, ESQUIRE
ROTHSTEIN ROSENFELDT ADLER
401 E. Las Olas Boulevard, Suite 1650
10 Fort Lauderdale, Florida 33394
Phone:
11
12 On behalf of the Witness:
13 BRUCE E. REINHART, ESQUIRE
LAW OFFICE OF BRUCE E. REINHART
• 14 250 S. Australian Avenue, Suite 1400
West Palm Beach, Florida 33401
15 Phone:
16
17 On behalf of Defendants/Jane Does 2 - 8:
18 STUART S. MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
19 18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
2C Phone:
21 On behalf of Plaintiff in related Case No. 08-80811
22 JACK HILL, ESQUIRE (Partially via speakerphone)
SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY
23 2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
24 Phone:
25
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1
2
3 INDEX
4
5
6 WITNESS: DIRECT CROSS REDIRECT RECROSS
7
8
9 BY MR. EDWARDS: 5 190
10 BY MR. MERMELSTEIN: 135 208
11 BY MR. HILL: 156
12 BY MR. CRITTON: 173
13
14
15 EXHIBITS
16
17
18 NUMBER DESCRIPTION PAGE
19 DEPENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103
20 DEFENDANT'S EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
21 DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 162
22
23
24
25
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• 1
2
PROCEEDINGS
- -
3 Deposition taken before Teresa Whalen,
4 Registered Professional Reporter, Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
7
8 (Mr. Hill joined the proceedings in person.)
9 CROSS (
10 BY MR. MERMELSTEIN:
11 O Good afternoon. Is it all right if I call you
12
13 A Yes.
• 14
15
Q Okay. My name is Stuart Mermelstein, I also
represent some plaintiffs in these cases, and it is my
16 turn to ask you some questions.
17 We were talking about when Mr. Epstein was in
18 jail, which was between June 30th of 2008 and July of
19 2009; correct?
20 A Yes.
21 Q Now, during that time you weal. Lu work your
22 regular schedule at 358 El Brillo Way; is that correct?
23 A Yes.
24 • So you were working basically --
25 MR. CRITTON: She's not finished.
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1 BY MR. MERMELSTEIN:
2 Q I'm sorry. Go ahead.
3 MR. REINHART: Do you need to expand on your
4 answer?
5 BY MR. MERMELSTEIN:
6 Q Were you finished?
7 A I worked regular hours, but sometimes there
8 are times that I report eight, sometimes I report
9 nine o'clock.
10 Q And I believe
11 A It's flexible.
12 Q Okay. And it was after he left jail that you
13 started working at 6:00 a.m., correct?
14 A Yee.
15 Q So whether you start work at eight or nine is
16 your choice? When you say "it's flexible," it means you
17 can chose whether to come at eight or nine?
18 A Yes. When he was not there.
19 Q Okay. It didn't matter whether you there at
20 eight or nine when he was not there, correct?
21 A No.
22 Q And what kind of things did you do at the
23 house -- let me ask the question this way.
24 How were your duties different when he was not
25 there during the time he was in jail from when he would
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• 2
come there before he went to jail?
A When he was in jail?
3 • Yes.
4 A I clean the house.
5 Q You had less to clean, is that fair to say,
6 because Mr. Epstein, I assume, based on your testimony,
7 there were much fewer people in the house than before,
8 correct?
9 A Yes. I made inventory of the linens.
10 Q I'm sorry?
11 A Of the linens, I made inventory of the linens.
12 Oh. Inventory of the linens?
13 A Inventory.
• 14
15
Q Okay.
do to fill the time?
So you did that. And what else did you
16 A Wash the clothes that was in storage, you
17 know.
18 Q You washed clothes in storage?
19 A Yes. Because it was right there, so I just
20 wash it and then press if it needs pressing.
21 Q So he has clothes stored outside of Lhe house?
22 A No. In the house.
23 Q In the house. Okay. So even if they hadn't
24 been worn, you washed them, correct?
25 A And press them.
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1 MR. CRITTON: Form.
2 THE WITNESS: Yes.
3 BY MR. MERMELSTE:N:
4 Q What other type of things did you do while he
wasn't there?
6 A If there are plants, I attend to the plants.
7 Q Okay. Is that something you didn't do before
8 he went to jail?
9 A I do that also when before he went to jail.
10 0 Okay.
11 A If there are orchids or plants in the house,
12 then I attend to it.
13 Q I guess my question is what kind of projects
14 did you work on when he was not there to fill your time
15 after he went to jail?
16 A Cleaning, tidying, just going around the
17 house. If I see something that needs painting, I tell
18 Janusz.
19 Q Now, are you paid on the basis of a yearly
20 salary, or are you paid weekly or monthly; how does that
21 work?
22 A We are paid twice a month.
23 Q Okay. That's when you receive your pay?
24 A Yes.
25 Q I guess my question is this: Say you have to
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take a half a day of work off, do you get paid for that?
A Yes. In my situation.
3 Q I'm sorry. In your what?
4 A In my situation I was paid.
5 Q Okay. So you're on like a fixed salary, if
6 you miss some time you still get the same amount of
7 money, correct?
8 A Yes.
9 Q And I take it that during the period in which
10 Mr. Epstein was in jail, you continued to receive the
11 same salary, plus a raise, I assume, at the beginning of
12 the year; correct?
13 A Yes.
• 14
15
Q So you continued to receive the same salary
that you did before Mr. Epstein went to jail, correct?
16 A Yes, sir.
17 Q Did Mr. Epstein ever pay bonuses or any extra
18 money to you?
19 A Yes.
20 Q What kind of bonuses did you receive?
21 A Yearly bonus.
22 Q You get a yearly bonus. When is that paid, is
23 that paid at holiday time, Christmas time?
24 A After the year.
25 Q At the end of the year?
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1 A At the end of the year.
2 Q At New Years?
3 A New Years.
4 Q And this past year, when 2008 became 2009, how
5 much of a bonus did you receive?
6 A I did not receive any.
7 Q And what about before that, what kind of bonus
8 did you receive?
9 A The yearly bonus.
10 • Okay. What would be the amount of the yearly
11 bonus?
12 A Oh. For me? The last one I receive was
13 5,000.
14 • Okay. So this would be in addition to your
15 salary of $42,000?
16 A Yes.
17 Q And this $5,000 bonus you would have received
18 in or about January 2008; is that correct?
19 A Not eight.
20 Q Pardon?
21 A Not eight. We did not get any bonus in 2008.
22 Q Okay. So when was the last time you received
23 a $5,000 bonus?
24 A I think 2007.
25 Q So it's been two years since you've gotten a
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1 bonus; is that correct?
2 A Let me see. Yes.
3 Q Okay. Did Mr. Epstein explain to you why he
4 wasn't giving you a bonus in the last two years?
5 A He did not personally told us.
6 Q Did someone tell you why you were not getting
7 a bonus?
8 A Janusz was informed, and Janusz informed me.
9 Q Okay. Did Janusz give you a reason why you
10 weren't getting a bonus?
11 A Because of the economy, that's what he said.
12 • Any other reason that he gave?
13 A No, sir.
14 Q Did you receive a $5,000 bonus for 2006 and
15 2005?
16 A It was different, it gradually increased.
17 • Okay.
18 A It was not the same amount.
19 Q What was the bonus in 2006 and 2005?
20 A 2005 was 2,000.
21 Q Uh-huh.
22 A And then the next is 5,000 and 5,000.
23 • Okay. So correct me if I am wrong, but in
24 January 2005 you received a $2,000 bonus?
25 A Yes.
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1 Q And at that point in time you had really just
2 started a month and a half before?
3 A No. I want to correct that. I receive a 500
4 after I started there November.
5 Q Yes. November of 2004 you started?
6 A At Christmas I receive, after Christmas I
7 receive $500.
8 Q Okay. So in January of 2005 you receive $500,
9 correct?
10 A Yes.
11 Q Then in January 2006 you received how much?
12 A 2,000.
13 Q And in January 2007 you received 5,000; is
14 that correct?
15 A Yes.
16 Q And in January 2008 you received no bonus?
17 A No.
18 Q Is that correct?
19 A Correct.
20 Q Correct, you received no bonus?
21 A No bonus.
22 Q And the same in January 2009, correct?
23 A Correct.
24 Q Has Mr. Epstein advised you, discussed with
25 you at all how much of a bonus you're going to receive
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• 1
2
after the holidays this year?
A No, sir.
3 Q Has anyone discussed with you what bonus you
4 will receive after the holidays this year?
A No.
6 0 Do you have any expectation as to what kind of
7 bonus you'll receive?
8 A I don't -- I did not expect anything.
9 Q You testified earlier about a who is the
10 housekeeper in New York, correct?
11 A Yes.
12 Q Now, when was the first time you met III in
13 person?
• 14
15
A
Q
In person? When I went to New York.
And when was the first time you went to
16 Now York?
17 A In 2006.
18 Q 2006. And was the reason you went to New York
19 in 2006 for Ms. Maxwell's party?
20 A No. It was III I think had a surgery.
21 Q Okay. And you were there to cover fur her
22 while she had surgery?
23 A Yes.
24 Q And how long were you there?
25 A I cannot remember, but after her surgery, then
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we left to Palm Beach.
2 Q Okay. You don't remember how long it was?
3 A I cannot remember, because I've been there
4 like four times, or more than four times.
5 Q More than four times?
6 A Yes.
7 Q Okay. So this first time when she had her
8 surgery, you were the housekeeper then in New York while
9 she was out, correct?
10 A Yes, sir.
11 Q But did she come into the house in New York
12 and that's how you met her while she was recovering, or
13 how was it that you met her at that time?
14 A We met her before her surgery, I met her
15 before her surgery.
16 see. Then she went and had her surgery.
17 Now, when you traveled to New York, did you go
18 on Mr. Epstein's plane?
19 A No, sir.
20 Q How did you travel to New York?
21 A Commercial.
22 Q So Mr. Epstein purchased you a ticket on an
23 airline to fly to New York?
24 MR. CRITTON: Form.
25 THE WITNESS: Yes, sir.
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• 2
BY MR. MERMELSTEIN:
O Now, let's talk about the other times that you
3 went, you traveled to New York. When was the next time
4 afLeL Lecover.ed fLum lies sulyety Uiat you went to
5 New York?
6 A I think when she went to the Philippines.
7 O Okay. She went for like a vacation to go to
8 visit her family?
9 A No. I'm not really good. There was time I
10 went there because I think I sometimes interchange, but
11 T went there one time herAuse to rover up for
12 Ms. Maxwell's housekeeper.
13 Q Okay.
• 14
15
A
Q
And when she was having a party.
Okay. So those are two separate times?
16 A Yes. Two separate times.
17 Q Both relating to Ms. Maxwell?
18 A No. The first one was -- first one to cover
19 up for III.
20 Q Right. I understood that. But after that,
21 when you came back --
22 A There was a time -- I don't know the sequence,
23 but you know, there was a time I have to cover up for
24 Ms. Maxwell's housekeeper.
25 Q I see. What's her name?
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1 A
2 Q And then there was another time where you went
3 to work for this party that she had, correct?
4 A Yes.
5 Q Okay. And the fourth time?
6 A When III went to the Philippines.
7 • Okay. About how long were these visits each
8 time?
9 A Sometimes a week, two weeks, then there was a
10 time I stayed there for like a month.
11 Q Which was that, when she had her surgery, III
12 had her surgery, or was this a different time?
13 A Oh, what's this? Let me see. I cannot
14 really, what's this?
15 Q Take your time, take your time.
16 A Oh. When, what's this, Ms. Maxwell's
17 housekeeper, I was to cover up for her because tor jury
18 duty. And then she was not part of the jury, so my stay
19 there was, like, extended. That's how I was able to
20 help with the party.
21 • She did not get on the jury?
22 A Yes. she was called.
23 • But you stayed anyway to help with the party?
24 A Yes.
25 Q I think I understand. Now, have you ever,
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• 2
while you've been employed by Mr. Epstein, traveled
anywhere else for work?
3 A No, sir.
4 Q Those trips to New York was the only time
5 you've traveled?
6 A Yes, sir.
Q You've never gone to New Mexico or to the
8 Virgin Islands for Mr. Epstein?
9 A No.
10 (Plaintiff's Exhibit No. 2 was marked for
11 identification.)
12 BY MR. MERMELSTEIN:
13 Q Let me show you what's been marked Exhibit 2.
• 14
15
Does it look like the paper that you were talking about
earlier where you wrote the names and the time?
16 A Yes, sir.
17 Q Okay. So this is kind of a notebook or a
18 message pad notebook that was I think you said located
19 by the pantry?
20 A Yes, sir.
41 Q Can you look through this and Lell me if any
22 of these, point out any of those that are in your
23 handwriting?
24 MR. REINHART: Take your time, look at each
25 one, and just tell him if you see any that you
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1 recognize your handwriting.
2 MR. CRITTON: You asked her to identify if she
3 sees anything in her writing?
4 MR. MERMELSTEIN: Yes.
5 THE WITNESS: (Shaking head.)
6 BY MR. MERMELSTEIN:
7 Q Okay. I understand your response is that you
B reviewed the various message slips included in Exhibit
9 No. 2 and none of them are your writing, correct?
10 A Yes, correct.
11 • But you do recall writing messages on this
12 type of pad for Mr. Epstein, correct?
13 A Correct.
14 MR. CRITTON: Stuart, that was exhibit what at
15 Mr. Rodriguez's deposition?
16 MR. MERMELSTEIN: Exhibit 1 at Mr. Rodriguez's
17 deposition.
18 MR. CRITTON: Okay.
19 BY MR. MERMELSTEIN:
20 O In the period 2004 to 2008 before Mr. Epstein
21 went to jail, do you recall whether there were females
22 who were sitting at the pool in the home at 358
23 El Brillo Way who were topless?
24 A There was one time.
25 • One time you remember. Tell me what happened
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that time.
2 A I was tidying the living room, then not
3 really -- there was like part of the wall, so I saw one
4 female there but not really, I saw it like this side
5 (indicating), so...
6 Q She was at the pool, or inside the house?
7 A This side, not really frontal, but on the side
8 I saw only -- I saw her side, not really like...
9 MR. REINHART: His question was, was she
10 inside the house or out by the pool when you saw
11 her from the side.
12 THE WITNESS: The question -- they were in the
13 pool.
14 BY MR. MERMELSTEIN:
15 Q Okay. So she was not wearing a bathing suit
16 top, correct?
17 A Yes.
18 Q Was she wearing a bathing suit bottom?
19 A I did not know.
20 Q And how did you -- did you do anything in
21 response to this?
22 A No. I went to, what's this, to kitchen and I
23 told Alfredo not to go to the pool.
24 Q And this was the only time you ever remember
25 seeing a girl who wasn't wearing a top at the pool?
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1 A Yes.
2 Q Were there frequently females at the pool to
3 the house?
4 A No. Not frequently.
5 Q Not frequently. Sometimes?
6 A Sometimes.
7 Q Mr. Epstein would travel with some females, I
8 think they would come on the plane with him to the
9 house; is that correct?
10 MR. CRITTON: Form.
11 BY MR. MERMELSTEIN:
12 Q You can answer.
13 A I cannot remember if they -- let me see.
14 remember . Because when Mr. Epstein arrives, most
15 of the time I'm already off.
16 • Let me ask the question this way: Were there
17 females other than who would come with Mr. Epstein
18 on the plane and stay at the house?
19 MR. CRITTON: Form, predicate.
20 BY MR. MERMELSTEIN:
21 Q Stay overnight at the house?
22 MR. CRITTON: Same.
23 THE WITNESS: I did not know if they came with
24 Mr. Epstein, I did not see.
25
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BY MR. MERMELSTEIN:
2 Q Okay. There were females who would stay
3 overnight at the house, but you're not sure how they got
4 Lu Lite house; is that fait to say?
5 A Yes.
6 Q Did any of the females who came to the kitchen
entrance to give a massage, did any of them stay
8 overnight?
9 A No, sir.
10 Q Never, correct?
11 A Yes, sir.
12 MR. CRITTON: Did you say correct and she said
13 yes?
• 14
15
MR. MERMELSTEIN:
MR. CRITTON: Okay.
Yes.
Thank you.
16 BY MR. MERMELSTEIN:
17 Q The girl at the pool who was topless, do you
18 recall what her name was?
19 A No.
20 • Do you recall how she got to the house or, you
21 know, what her purpose was in being there?
22 A I cannot remember.
23 • Was she a girl who had come to give
24 Mr. Epstein a massage?
25 MR. CRITTON: Form.
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1 THE WITNESS: No.
2 BY MR. MERMELSTEIN:
3 Q The females who came to give Mr. Epstein a
4 massage, did they ever use the pool?
5 MR. CRITTON: Form, predicate.
6 THE WITNESS: I did not see.
7 BY MR. MERMELSTEIN:
8 Q You don't know?
9 A I don't know.
10 Q And again, this girl you saw topless was the
11 only one you ever saw who was in any stage of undress in
12 the pool area at the house; is that fair?
13 A Yes.
14 Q You mentioned in your testimony earlier that
15 there was a back massager that was in Mr. Epstein's
16 bedroom, correct?
17 A In the massage room.
18 Q In the massage room. It was what, on the
19 floor, on the massage table, where did you find it?
20 A Sometimes on the, what's this, the table,
21 sometimes on the floor.
22 Q So this would be a regular thing, you would go
23 in the room to tidy up and you'd find this massager,
24 correct?
25 MR. CRITTON: Form.
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• 2
THE WITNESS:
BY MR. MERMELSTEIN:
Yes.
3 Q You referred to it as a back massager,
4 correct?
5 A Yes.
6 Q And did you do anything to this, did you put
7 strike that.
8 Did you put away this massager?
9 A I return it to the drawer.
10 Q Was that a drawer in the armoire?
11 A No. In the bathroom.
12 Q In the bathroom cabinet?
13 A Yes.
• 14
15
Q
A
Were there other items in the drawer?
Lotions.
16 Q So those wore maccagc itemo
17 MR. CRITTON: Form.
18 BY MR. MERMELSTEIN:
19 Q -- that were in the drawer?
20 MR. CRITTON: Sorry. Form.
21 THE WITNESS: From Bodyworks, aroma massage
22 therapy.
23 BY MR. MERMELSTEIN:
24 Q So there was Bodyworks lotions and this back
25 massager; is that correct, in the drawer?
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1 A Yes.
2 • Anything else in the drawer?
3 A That's all. And I put some, like, hand
4 towels.
5 Q In the drawer?
6 A Yeah. On the side.
7 Q Was there any -- was there just one drawer
8 that was used for these massage materials, or was there
9 more than one drawer?
10 A There is only one drawer.
11 Q Would you do anything to this massager before
12 ycu put it in the drawer?
13 A No. I just return it there.
14 • Did you ever clean it?
15 A There was one time I clean it.
16 Q One time you clean it. About how many times
17 did this happen that you picked up the massager and put
18 it in the drawer; did it happen many times?
19 A Yes.
20 Q So on this one occasion why did you clean it?
21 A Because I thought it was, like, dirty, so I
22 clean it.
23 • Explain to me how it was dirty.
24 A There is -- the color is -- like you know
25 when -- like there is stains or something, you know,
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• 2
when something is not clean.
cleanliness, so I...
So I very particular about
3 O Did you believe that there was a sexual fluid
4 on it and that's why you cleaned it?
5 A No.
6 MR. CRITTON: Form.
7 THE WITNESS: No.
8 BY MR. MERMELSTEIN:
9 Q Mr. Rodriguez testified that you disliked the
10 task of putting away the massage items because you had
11 to clean them of sexual fluids and that was unpleasant.
12 Is that not true?
13 MR. CRITTON: Form.
• 14
15
THE WITNESS:
BY MR. MERMELSTEIN:
Not true.
16 Q So Mr. Rodriguez would be lying about that,
17 correct?
18 A Yes.
19 Q The way I asked that question was sexual
20 fluids, and that may be an ambiguous term. What if I
21 used the term "body fluids," does that change your
22 answer at all?
23 A No.
24 Q It's the same, you never cleaned body fluids
25 off of a massager, correct?
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I A No.
MR. CRITTON: Wait. You said -- when he said
3 correct, you said no. Does that mean he's not
4 correct?
5 MR. REINHART: Did you ever clean body fluids
6 off of a massager?
7 THE WITNESS: I don't know if it's fluid,
8 so.. .
9 BY MR. MERMELSTEIN:
10 Q Did you ever clean body fluid off of any
11 massager?
12 MR. CRITTON: Form.
13 THE WITNESS: No.
14 MR. MERMELSTEIN: I pass the torch.
15 CROSS (
16 BY MR. HILL:
17 Q I'm the mysterious voice that was on the phone
18 before, and now you get the privilege of seeing me in
19 person. I'm teasing, the privilege is mine. I won't be
20 very long with you, I promise.
21 I want to follow up on this line of
22 questioning, though. The single time of the many
23 instances in which you put back what you believed to be
24 some kind of massage implement into the bathroom drawer,
25 you only cleaned it one time?
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• 1
2
A
Q
One time.
All right. And you said that it appeared to
3 you to be stained?
4 A Yes.
5 Q Did you have any idea of what it was that
6 caused the implement which you believed to be a massager
7 to become stained?
8 A No, sir.
9 Q So when you were asked questions about whether
10 it was bodily fluid or not, you had no idea what it was
11 that you were cleaning off that item that you believed
12 to be a back massager?
13 A Correct.
• 14
15
Q Okay. How did you clean the item that one
time that you believed to be a back massager?
16 A I use a paper towel, wet the paper towel and
17 wipe it.
18 Q All right. Where was the item stained?
19 A On the tip of the massager.
20 Q All right. And if someone has asked you this
21 and I missed it, I apologize. Describe for us what the
22 item looked like that you believed to be a back
23 massager.
24 A It's an elongated piece with a thing
25 Q Elongated what?
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1 A Elongated thing, and then on the tip is like a
2 round part. So I thought it's used for massaging.
3 Q Did this implement have any kind of electrical
4 power, did it have a cord, did it have batteries, did it
5 move; do you know?
6 A I don't know.
7 • And the area that it was stained was where,
8 ma'am?
9 A On the tip of the, what's this.
10 • Can you describe for us what the stain looked
11 like?
12 A It looks like it's dirty, like brown thing.
13 Q Was there any kind of material other than --
14 did it look like it was some kind of dried liquid on
15 there?
16 MR. CRITTON: Form.
17 THE WITNESS: I really don't know. I just,
18 what's this, dirty, so I just clean it. Because I
19 thought it was lotion because he have lotion there
20 for...
21 BY MR. HILL:
22 Q And it's a true statement you never complained
23 to anybody about your responsibilities for having to put
24 back an item which you believed to be a back massager
25 into the cabinet drawer in the bathroom?
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• 2
A No, sir.
MR. REINHART: Hold on. I think your question
3 was, was it a true statement that.
4 BY MR. HILL:
5 • That you never complained to anybody?
6 MR. REINHART: Did you ever complain?
7 THE WITNESS: I never complain, because it's
8 my job to, so...
9 BY MR. HILL:
10 • Was it always the same item, did you put it
11 back these many many times but only cleaned it once?
12 A Yes.
13 • And you've never seen it in use, you had no
• 14
15
idea how it operates, if it operates at all?
A No.
16 • I want to talk to you about the folks, the
17 ladies, the young girls, the young ladies, the women,
18 however you want to describe them, and ask you if you
19 can sit here today, close your eyes, and remember the
20 face of any of the folks that would come over and give
21 your boss, Jeffrey Epstein, massages?
22 A If I remember?
23 • As you sit here today, if I asked you to close
24 your eyes, can you bring up in your mind's eye the faces
25 of any of the young ladies that would come over to
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1 Epstein's house and give him massages?
2 MR. CRITTON: Form.
3 BY MR. HILL:
4 • Do you understand the question?
5 A Yes.
6 • Okay.
7 A If you'll show me a picture then.
8 Q No, ma'am. What I'm asking you to do, as an
9 employee of Jeffrey Epstein's for many many years, and
10 for many many years these ladies, young ladies, these
11 females would come to his house and give him massages,
12 do you remember the faces of any of them?
13 A Maybe one or two.
14 • All right. Earlier you testified that
15 sometimes the same girl would come back, the same young
16 lady would come back more than one time?
17 A Yes.
18 • How many young ladies can you recall making
19 multiple visits to Jeffrey Epstein's house for the
20 purpose of giving him massages?
21 A Maybe two.
22 Q Maybe two?
23 A Yes.
24 • And you can recall certainly their faces?
25 MR. CRITTON: Form.
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• 2
1 THE WITNESS:
BY MR. HILL:
Yes.
3 Q Okay. So far there are at least two young
4 ladies who you can close your eyes and remember their
5 faces, right?
6 A Yes.
7 Q Are there more than two young ladies that you
8 can close your eyes and remember their faces?
9 A No. Maybe two.
10 Q Just two?
11 A Two.
12 • Do you recall the names of any of these young
13 ladies
• 14
15 Q
A No, sir.
-- who would come over?
16 A No.
17 • The name ( doesn't ring a bell
18 to you at all?
19 A Excuse me?
20
21 A NO, sir.
22 MR. HILL: Let me show you a photograph and
23 see if you
24 MR. CRITTON: Are you going to mark that
25 Exhibit 3?
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(Plaintiff's Exhibit No. 3 was marked for
2 identification.)
3 BY MR. CRITTON:
4 Q Pursuant to Mr. Critton's suggestion, we
5 marked that as Plaintiff's Exhibit 3, and ask you to
6 take a look at that photograph and tell me if you
7 recognize this individual depicted on Plaintiff's 3.
8 A I'm not sure.
9 Q All right. Earlier you were shown a binder
10 with a bunch of photographs in it?
11 A Yes.
12 Q Some of those photographs were of young
13 ladies, yes?
14 A I don't know their age.
15 Q Well, I didn't --
16 MR. REINHART: Listen to the question. He's
17 just asking if you saw a binder with pictures of
18 young ladies in it.
19 THE WITNESS: Yes.
20 BY MR. HILL:
21 Q Okay. And many of those young ladies you were
22 able to say without any kind of doubt that you did not
23 recognize them, right?
24 A Yes.
25 Q You don't have that same degree of certainty
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for the young lady pictured in photograph Plaintiff's
2 Exhibit 3?
3 A That's right.
4 Q You don't know whether you've seen her or not?
5 A No. Yes.
6 MR. REINHART: Hold on. She said no, yes.
7 THE WITNESS: I'm not so sure if I've seen
a her, but you know, the face seems familiar.
9 BY MR. HILL:
10 • You don't know how you would have met this
11 young lady anywhere else other than Jeffrey Epstein's
12 house, do you?
13 MR. CRITTON: Form, speculation.
• 14
15 BY MR. HILL:
THE WITNESS: What was the question again?
16 Q Sure. We were talking earlier about your
17 being unsure whether you had met this particular young
18 lady pictured in Plaintiff's 3, and my question is you
19 wouldn't have seen her someplace other than
20 Jeffrey Epstein's house, right?
21 A I'm not sure.
22 Q Okay. But she is someone who very well may be
23 familiar to you?
24 A Yes.
25 Q Okay. Describe for me the two young ladies
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1 that you can remember when you close your eyes as being
2 one of the young ladies that would come over to
3 Epstein's house and give him massages. What do they
4 look like? Let's start with number one, what did she
5 look like?
6 A The picture that he showed me, what's her
7 name, Haley or something? I recognize that one.
8 Q Let me ask you, the two young ladies that you
9 can imagine that you can see in your mind's eye that
10 provided Epstein massages when you were working there,
11 were those young ladies both in the binder that was
12 shown to you earlier that was Plaintiff's Exhibit No. 1,
13 or are we talking about different ladies?
14 A I remember that lady there.
15 MR. EDWARDS: Just so that you're clear, I
16 don't know that she said that the first time.
17 THE WITNESS: Not this one.
18 MR. REINHART: Not that one?
19 THE WITNESS: Not that one.
20 MR. EDWARDS: She said that.
21 BY MR. HILL:
22 Q She said that.
23 Which one is this, so we're clear?
24 MR. MERMELSTEIN: And for the court reporter.
25 MR. CRITTON: What did she refer to?
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• 1
2
MR. HILL: No, no, no.
number rather than provide names.
Let's get the exhibit
MR. REINHART: This should be 1-N from my
4 notes, "N" as in Nancy.
5 BY MR. HILL:
6 O So you recognize 1-N there?
7 A I recognize one, that's the one that...
8 Q So you recognize this one lady, 1-N?
9 A No. I did not say I recognize her.
10 Q You don't recognize her. Okay. So why don't
11 we go hack through the booklet and you can tell me who
12 it is that you recognize as the young lady who would
13 come over and give Epstein massages?
• 14
15
MR. CRITTON: Object to the form.
misstates her testimony. It was 1-P.
I think it
10 THE WITNESS: This one. What's her -- I
17 remember this one, but I don't know if she gives
18 massage.
19 MR. REINHART: Let's get a number for that
20 one.
21 MR. HILL: 1-F.
22 MR. REINHART: I'm showing you what has 1-F
23 next to it, right?
24 THE WITNESS: Yes.
25
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1 BY MR. HILL:
2 Q And you remember this person as someone who
3 would come over and give Mr. Epstein massages?
4 MR. CRITTON: Form.
5 THE WITNESS: I don't know if she give
6 massage, but I saw her in the house.
7 BY MR. HILL:
8 Q Okay. When I started the line of questioning
9 a few minutes ago, I asked you to close your eyes and
10 imagine the faces of any of the young ladies that would
11 come to Epstein's house and give him massages. You said
12 that you can recall two such young ladies, right?
13 A Yes.
14 Q All right. And so you don't remember whether
15 this lady in 1-F provided massages to Epstein, correct?
16 A Correct.
17 • So this 1-F lady isn't one of the two that you
18 can close your eyes and see as one of the young ladies
19 who would come over to provide massages, right?
20 MR. CRITTON: Form.
21 THE WITNESS: So I can only picture maybe one.
22 I thought this
23 BY MR. HILL:
24 Q I'm sorry. I cut you off, that was rude, I
25 apologize.
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• 2
A
persons?
Okay. Your question was if I can recall two
3 Q That was your testimony, yes, ma'am.
4 A I remember this one.
5 • You remember this one, pointing to 1-F, you
6 remember this young lady?
7 A Yes.
8 Q But you don't know whether this young lady
9 provided massages to Mr. Epstein, correct?
10 A Correct.
11 O And I guess back to my original line of
12 questioning, I asked you whether about young ladies you
13 can close your eyes and recall their faces as being
• 14
15
girls, young ladies, excuse me, who would provide
Epstein massages. Remember that?
16 MR. CRITTON: Form.
17 BY MR. HILL:
18 • And you said that there were two such young
19 ladies that you recall in your mind picturing their
20 faces as young ladies who would come over and give
21 Mr. Epstein massages? That's what you testified to,
22 right?
23 MR. CRITTON: Form.
24 THE WITNESS: I get confused, because there
25 are some visitors come or female come, and
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1 then -- so I get confused, so I can't remember
2 this, and I'm telling you that I don't know if she
3 gives massages.
4 BY MR. HILL:
5 Q Let me give you chance to answer it again.
6 Okay. If you close your eyes and think back, are you
7 able to see in your mind's eye the faces of any of the
8 young ladies that would come over to your boss,
9 Jeffrey Epstein, for the purpose of giving him massages?
10 MR. CRITTON: Form.
11 THE WITNESS: No.
12 BY MR. HILL:
13 Q And how many years are we talking about where
14 these women would come, excuse me, these females would
15 come to Mr. Epstein's house for the purpose of providing
16 him massages, how many years are we talking about?
l'/ MR. CRITTON: Form.
18 MR. REINHART: When she worked there.
19 BY MR. HILL:
20 Q When you worked there.
21 A If you show me pictures, then --
22 MR. REINHART: No. Listen and answer the
23 question you're being asked. How many years do you
24 remember females coming to give massages to
25 Mr. Epstein during the time you worked there?
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MR. CRITTON: Form.
2 THE WITNESS: Since I work? And then one
3 year.
4 BY MR. HILL:
5 Q You started work in 2005, right?
6 A Yes.
7 Q All right. And this happened up until the
8 time that Mr. Epstein went to jail where these young
9 ladies would come over?
10 MR. CRITTON: Form.
11 THR WITNESS: Before he went to jail?
12 BY MR. HILL:
13 Q Yes, ma'am.
• 14
15
A
Q
Yes.
So were talking about a period of years where
16 this would happen, right?
17 A Yes.
18 Q For the period of years that you were working
19 at Mr. Epstein's house where females would come to his
20 home for the purpose of providing him massages, you
21 don't remember the faces of any of them?
22 A You know, I just open the door and then I
23 cannot, I don't really, like, interact with them for a
24 long time.
25 Q But it is a true statement that you don't
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1 remember the faces of any of the females that would come
2 to your boss's house, Jeffrey Epstein's house, over the
3 period of years for the purposes of providing him
4 massages?
5 MR. CRITTON: Form.
6 THE WITNESS: No.
7 BY MR. HILL:
8 Q It's true that you don't remember any of the
9 faces?
10 A If you show me picture, then --
11 Q No, ma'am. I'm asking you what you remember.
12 A No.
13 Q You don't remember any of their faces?
14 A No.
15 Q All right. Earlier you were asked about the
16 folks that are at Mr. Epstein's house, and it sounds
17 like one or those individuals is named Igor, the
18 trainer?
19 A Yes.
20 Q All right.
21 MR. REINHART: Talking currently?
22 MR. HILL: Currently.
23 MR. REINHART: Thank you.
24 BY MR. HILL:
25 Q When was the last time you saw Igor?
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• 2
1
Q
A Today.
You saw him today?
3 A Yes.
4 Q When was Lhe time befuLe that the last time
5 that you saw him?
6 A The last time?
7 Q Yes, ma'am. You saw him today. When was the
8 time before that that you saw him?
9 A One week ago.
10 Q All right.
11 A Because T was on vacation.
12 Q So you've been off for a week?
13 A Yes, sir.
• 14
15
Q So what day was it a week ago that you saw
Igor the trainer?
16 A
17 Q You and I both looked Eor a calendar but there
18 isn't one up there. Today is Tuesday. You're talking
19 this past Friday or the Friday before that?
20 A I think 9th, October 9th.
21 • So that was the last day that you worked up
22 until Monday of this week?
23 A Yes, sir.
24 • And you worked October 9th and saw Igor,
25 correct?
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A Yes.
2 Q And what is Igor's last name, do you know?
3 A I don't know.
4 Q Does Zinoviev sound familiar?
5 A Because sometimes they called him Igor Z.
6 Q Igor "Z," is that what you're saying? Yes?
Igor then the letter "Z"?
A Yes.
9 Q So you saw him October 9th, the last day that
10 you worked. Where did you see him, at Mr. Epstein's
11 house?
12 A Yes, sir.
13 Q Then you worked yesterday, right?
14 A Yes.
15 Q And you saw him?
16 A No.
17 Q When was the last time you saw him? You saw
18 him today?
19 A Today.
20 Q Ah. Okay. And what was he doing today?
21 A He was waiting to drive Mr. Epstein.
22 • Okay. Do you have any understanding that
23 Igor, Mr. Igor Z., left after you saw him on Friday
24 October 9th and came back for you to see him at
25 Mr. Epstein's house today?
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A Can you rephrase the question?
2 O Sure. Do you know if he went anywhere in
3 between the last time you saw him before today and
4 October 9th?
5 A Janusz told me he will be on vacation.
6 • He will be on vacation? When will he be on
7 vacation.
8 A The time that I will not be there.
9 • Oh. You were both on vacation?
10 A Yes.
11 O So he's back now from what you believe to be
12 his vacation?
13 A Yes.
14 O No reason he can't show up for a deposition,
15 right?
16 MR. CRITTON: Form.
17 THE WITNESS: I don't know.
18 MR. HILL: I don't know, either. Okay.
19 That's all I have. Thank you.
20 THE WITNESS: You're welcome.
21 MR. CRITTON: can I switch with you?
22 CROSS
23 BY MR. CRITTON:
24 , my name is Bob Critton, I represent
25 Mr. Epstein. I have a few follow-up questions based on
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1 questions that have been asked to you.
2 If I understood your earlier testimony --
3 well, let me ask you this: Do you have any personal
4 knowledge that any female ever gave Mr. Epstein a
5 massage; that is, were you ever present when a massage
6 took place?
7 A No, sir.
8 Q So you've been asked a lot of questions about
9 females coming to the house to give Mr. Epstein a
10 massage, right? You've been asked a lot of questions
11 about that today?
12 A Yes, sir.
13 Q Okay. As to whether or not any female ever
14 gave Mr. Epstein a massage, do you have any personal
15 knowledge?
16 A No, sir.
17 Q All right You were asked a question by
18 Mr. Hill and others as how many faces of the females you
19 remember who came to Mr. Epctoin'o houoo to give him a
20 massage, do you remember any faces. Do you recall those
21 questions?
22 A Yes.
23 Q Okay. In fact, you're -- let me strike that.
n4 Would it be a correct statement that you're
25 unaware of any females that came to his house that you
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know actually gave him a massage?
A Correct.
Is that correct?
3 Q You were shown a document marked Exhibit 2
4 which was a bunch of message pads. Well, it was an
5 exhibit, a composite exhibit that included a lot of
6 message pads -- let me start again.
7 Exhibit 2 has a lot of message pads, I'm
sorry, a lot of papers. It looks like it has four
9 "Important Message" and then there's a place to list who
10 called, the date, and what the response should be;
11 correct?
12 A Yes.
13 Q All right. You were asked earlier by
• 14
15
Mr. Edwards whether you took phone calls for Mr. Epstein
from any females who called about giving a massage. If
16 I understood your testimony, no conversation that you
17 ever -- well, let me strike that.
18 If I understood your testimony, you never had
19 a conversation with a female who called on the phone
20 where the word "massage" was used?
21 A NO, Sir.
22 Q Is that correct?
23 A Correct.
24 Q All right. And when you were you responding
25 to Mr. Edwards' questions about taking messages, did you
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1 just take -- that is, if a female called or a male
2 called or whoever called and you happened to answer the
3 phone, if they wanted to leave a message, did you fill
4 out a message pad?
5 A Correct.
6 Q All right. So it didn't have to be a female
7 who was giving a massage; it could have been a florist,
8 it could have been a friend, it could have been anyone
9 RS far an yrni know,
10 MR. MERMELSTEIN: Object to form.
11 MR. HILL: Object to the form.
12 THE WITNESS: Correct.
13 BY MR. CRITTON:
14 Q Well, did anyone ever say I'd like to come
15 over and give Mr. Epstein a massage to you?
16 A No.
17 MR. HILL: I don't know if we talked about it
18 yet, but is an objection by one good for all, or do
19 we need to repeat everybody °Ice's objection?
20 MR. EDWARDS: I think it's good for all.
21 MR. REINHART: I'm fine with that.
22 BY MR. CRITTON:
23 Q If I understand your testimony, in the
n4 approximately three years that you worked at
25 Mr. Epstein's house before June of '08, so it would have
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2
been the latter part of '05, '06, '07, and then '08
through June, on the rare occasion you might answer a
3 doorbell and someone might come in, that is, a female
4 might come in who purportedly was to give Mr. -- let me
5 strike that.
6 As to any of the females that came to the door
7 and punched the doorbell and you answered, do you know
8 why they were there; that is, do you have any personal
9 knowledge as to why they were there?
10 A Sometimes.
11 O Okay. And how would you know that?
12 A Either Alfredo will tell me that this one is
13 expected.
• 14
15
Q Who was going to give a massage?
something like that, or just that the person is
He might say
16 expected?
17 A No. Is expected.
18 Q All right. And so if in fact let me strike
19 that.
20 During '04 -- I'm sorry.
21 MR. CRIMON: what did she say, '05 when she
22 started?
23 MR. EDWARDS: She started November of 2004,
24 but then she just recently changed it to say she
25 started 2005, so I don't know.
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1 MR. CRITTON: That may have been me.
2 BY MR. CRITTON:
3 Q Did you start in 2004, November 2004?
4 A Yes. November.
5 Q When you started in November of 2004 and up
6 through 2005, on how many occasions would you have
7 answered the door where a female was coming that Alfredo
8 said you can expect such and such?
9 Does that make sense to you?
10 MR. EDWARDS: Object to the form.
11 BY MR. CRITTON:
12 Q Do you want me to rephrase that?
13 A Can you rephrase it?
14 Q If I understood your testimony, your business
15 is tidying, keeping the house tidy, laundry,
16 straightening up, things of that nature?
17 A Yes.
18 Q All right. And that's most of your day when
19 you're there?
20 A Yes.
21 Q And when you're off, you don't know what goes
22 on at the house?
23 A No.
24 Q Or for that matter any place else. If you're
25 not there, you have no personal knowledge what goes on
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• 2
1 at the mall if you're not there, right?
MR. EDWARDS: Form.
3 THE WITNESS: Correct.
4 BY MR. CRITTON:
5 Q All right. On approximately how many
6 occasions would you have ever answered the door during
7 the '04, '05 time period where a female came in and you
8 left them alone in the kitchen or offered them something
9 to drink? Are we talking three or four times, are we
10 talking five or ten times, or more or less?
11 MR. EDWARDS: Form.
12 THE WITNESS: That specific time?
13 BY MR. CRITTON:
• 14
15
Q Yeah. During '04 and '05 from the time you
started in '04 through the end of '05.
16 A I cannot remember how many times.
17 Q Okay. Was it often or rarely that you were
18 the one who actually let someone in the house?
19 A Rarely.
20 Q All right. And did you ever see a female
21 coming, and i'm not talking or , did you ever
22 see a female coming down the stairs into the kitchen
23 ever?
24 A Yes.
25 Q On how many occasions, your best recollection?
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1 MR. EDWARDS: What time frame? The whole time
2 she worked there?
3 BY MR. CRITTON:
4 • '04, '05, '06.
5 A Rarely. Maybe.
6 • Let me rephrase my question.
7 During the period '04 and '05, through the end
8 of '05; that is, November of '04 through the end of '05,
9 approximately how many times did you see someone, a
10 female, who would come from upstairs downstairs? And
11 I'm not talking about or or someone there
12 who was there regularly.
13 A Maybe three times.
14 • Okay. And on the three times that you saw
15 someone come down the stairs, you saw them where, in the
16 kitchen?
17 A Yes.
18 • Did anyone ever look upset?
19 A No.
20 • Did anyone look like they were crying?
21 A No.
22 • Did anyone look distraught?
23 A No.
24 • Did any those people cry for help?
25 A No, sir.
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• 2
Q During the entire time that you've been
working for Mr. Epstein, from November of '04 through
3 '05 did you ever hear a female cry for help?
4 A No.
5 Q Did you ever hear them yell out for help?
6 A No, sir.
7 Q Did you ever hear someone scream for help?
8 A No.
9 Q Did anyone ever ask you to call the police?
10 A No, sir.
11 0 Did anyone ever tell you that they were
12 molested?
13 A No, sir.
• 14
15 abused?
Did anyone ever tell you that they were
16 A No, air.
17 Q Did anyone tell you that they had received any
18 type of physical harm?
19 A No.
20 0 Okay. Did anyone appear to have, at least
21 from your observations of their facial features, to have
22 been in any way emotionally upset or distraught?
23 A No.
24 Q Okay. You were asked a number of questions
25 about what you observed or -- let me strike that.
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1 You were asked a number of questions by
2 Mr. Edwards about what was taken from the house by the
3 police. Do you remember those questions?
4 A Correct, I remember.
5 Q Were you present when the police took certain
6 items from Mr. Epstein's home?
7 A No sir.
8 Q Do you know what the police have in their
9 possession?
10 A No.
11 Q Did anyone ever tell you what the police took
12 from the house, other than I think you said Janusz said
13 they took computers?
14 A I cannot remember he said computers. I
15 remember pictures.
16 Q Okay. That's what Janusz told you?
17 A Yes.
18 Q But you have no personal knowledge?
19 A No, sir.
20 Q That's correct?
21 A Correct.
22 Q All right. You talked about a photograph of
23 what you described as an approximately four-year-old
24 girl and it looked like the back portion of a swimsuit
25 or some bottoms she had on was being pulled down a
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• 2
little bit?
A Correct.
3 Q Is that Mr. Epstein's Goddaughter?
4 MR. EDWARDS: Object to the form.
S BY MR. CRITTON:
6 Q Strike that.
7 Do you know whether or not that's a picture of
Mr. Epstein's Goddaughter?
9 MR. EDWARDS: Form.
10 THE WITNESS: I was told that.
11 AY MR. CRITTON:
12 Q By whom?
13 A By III.
• 14
15
Q
A
III up in New York?
Yes.
16 Q All right. You were asked about what you
17 described as a back massager. Do you recall that
18 earlier? Mr. Hill asked you and I think Mr. Edwards.
19 In fact, I think all the other lawyers asked you that
20 question.
21 A Yes.
22 Q Is the item that you describe as a back
23 massager, have you seen that like -- let me strike that.
24 Do you know what Brookstone is?
25 A Yes.
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1 Q Is the item that you saw similar to something
2 that you've seen at Brookstone?
3 MR. MERMELSTEIN: Objection to form.
4 THE WITNESS: Yes, sir.
5 BY MR. CRITTON:
6 Q You were asked a number of questions about
7 Ms. Maxwell. Do you recall that series of questions?
8 A Yes.
9 Q What was your relationship with Ms. Maxwell;
10 did you get along well with her, did you find her
11 difficult, easy going?
12 A I have a good relationship with Ms. Maxwell.
13 Q Okay. Did she always treat you with respect?
14 A Yes.
15 Q And i think you told us that she's the one who
16 actually hired you?
17 A Correct.
18 Q Was Alfredo Rodriguez the person responsible
19 for hiring you, or was it Ms. Maxwell?
20 A Ms. Maxwell.
21 Q And when you started, you first said that you
22 thought -- well, let me strike that.
23 In your earlier testimony you said that
24 Mr. Rodriguez was your boss, and then you said well,
25 really we work side by side.
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• 2
So my question to you is was Mr. Rodriguez
your boss, or were you co-equals in the house and you
3 each had your own job?
4 A We have our own job. He told me he is my
5 supervisor.
6 Q Okay.
7 A But Ms. Maxwell told us we have to work like,
8 you know, work together for the house.
9 Q For the good of the house?
10 A Yes.
11 Q So if he needed help you'd help him, if you
12 needed help he was supposed to help you?
13 A Correct.
• 14
15
Q Did Ms. Maxwell ever tell you that
Mr. Rodriguez was your boss, or only Mr. Rodriguez?
16 A Mr. Rodriguez tell me.
17 Q Okay. Was Mr. Rodriguez -- let me strike
18 that.
19 Mr. Rodriguez was working at the house when
20 you started?
21 A Correct.
22 Q And he continued for how long after you
23 started? That is, you started sometime in mid November
24 of '04, how many more months did he work?
25 A I think up to February.
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1 Q February of '05?
2 A '05.
3 Q And did he resign, or was he terminated?
4 A He was terminated.
5 Q Do you know why he was terminated?
6 A One reason I know is one time he did not buy
7 any food when Mr. Epstein came, the refrigerator was
8 empty.
9 Q Was that his job, to make certain there was
10 food in the house when Mr. Epstein came to town?
11 A It was his job.
12 Q All right. Did you consider Mr. Rodriguez an
13 honest person?
14 MR. HILL: Object to the form.
15 MR. EDWARDS: Form.
16 THE WITNESS: No.
17 BY MR. CRITTON:
18 Q Why not?
19 MR. HILL: Object to the form.
20 THE WITNESS: Because he used my name. He had
21 almost a fist fight with a gardener.
22 BY MR. CRITTON:
23 • Was that Jerome?
24 A Jerome. And he used my name that I am a
25 witness of the time that Jerome comes to work. So
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• 2
Jerome talked to me, and I told Alfredo not to use my
name, because I don't keep tab of people's time coming
3 in and out.
4 I told Alfredo, if you ask me if Jerome is
5 here, I say he's here; if he's not, he's not. But I
6 don't tell you he came this time and that time. So I
7 was upset too with Alfredo, because I said that's a lie,
8 don't use my name.
9 Q All right. Now, you were asked some
10 questions, a number of questions as to what
11 Mr. Rodriguez testified at his deposition that he said,
12 Mr. Rodriguez, that you were disgusted with cleaning sex
13 toys. Do you remember that question?
• 14
15
A
Q
Yes. I remember.
And I think your testimony is you never had
16 that conversation with Mr. Rodriguez; is that correct?
17 A No, sir.
18 Q So I think you --
19 MR. REINHART: Hold on. I think you said your
20 testimony is, she said no, sir. Can we be clear
21 what the question and answer was?
22 BY MR. CRITTON:
23 Q Did you ever tell Mr. Rodriguez that you were
24 disgusted with cleaning sex toys?
25 A No.
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1 Q All right. And if he said that, was he lying?
2 MR. HILL: Form.
3 THE WITNESS: He is. He was.
4 BY MR. CRITTON:
5 Q If I asked you to assume Mr. Rodriguez said
6 that you were upset because there were pictures of
7 partially-clothed or naked women near a picture of the
8 Pope, I ask you to assume that he said that, would that
9 be true?
10 A That's a lie.
11 Q All right. Was there a picture of the Pope in
12 Mr. Epstein's house?
13 A Yes.
14 Q All right. Was that near any picture of any
15 individual in some state of undress?
16 A No.
17 Q Did Mr. Rodriguez ever lie to you?
18 MR. HILL: Object to the form.
19 MR. EDWARDS: Form.
20 THE WITNESS: Using my name was a lie.
21 BY MR. CRITTON:
22 Q Okay. Did he ever ask you to lie for him?
23 A One time.
24 Q What happened?
25 A Mr. Epstein was not in his house, he's away,
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and I receive a call from Alfredo, and he told me not to
2 answer any call from New York.
3 Q Did he tell you why?
4 A He said I'm going to help you and you help me.
5 So I did not know what he means by that. And then I
6 receive a call from one of the secretary, so they said
7 where are you, , and I said the mall.
8 Q Were you in the mall?
9 A Yes.
10 Q All right. Was it your day off? Were you
11 working that day, did you have to pick something up?
12 A I was off.
13 Q Okay. So you said the secretary called you
• 14
15
and you told her exactly where you were?
A Yes.
16 Q Did oho ack you -- and then what happened
17 next? Let me ask you this question, did she ask you
18 where Mr. Rodriguez was?
19 A She did.
20 Q And what did you say?
21 A I don't know, but i think I mentioned that I
22 receive a call from him.
23 Q Did he want you to cover for him?
24 MR. HILL: Object to the form.
25 THE WITNESS: I did not tell Helen that he
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1 asked me to cover for him.
2 BY MR. CRITTON:
3 Q Okay. And if I understood your testimony, he,
4 Mr. Rodriguez said if you get a call from New York,
5 simply don't answer it?
6 A Yes.
7 Q Because that way what, no one could ask where
8 you were or anybody else was?
9 A Yes.
10 Q That's what you understood?
11 A That's what I understand.
12 MR. CRITTON: That's all I have. Thank you
13 very much, ma'am.
14 THE WITNESS: You're welcome.
15 REDIRECT (
16 BY MR. EDWARDS:
17 • I have some follow-up questions.
18 Have you ever met with Mr. Critton before?
19 A Yes.
20 Q When was that?
21 A Yesterday.
22 • And where was that?
23 A In his office.
24 Q And who called that meeting?
25 MR. REINHART: That's privileged.
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2
BY MR. EDWARDS:
Q Okay. Was it your idea to meet with
3 Mr. Critton?
4 A No, sir.
Q Okay. So when Mr. Critton sat down and said
6 ma'am, I'm Bob Critton and I represent Mr. Epstein,
7 that's something you already knew from yesterday, right?
8 A Yes.
9 Q Okay. So that was just a show for everybody
10 else in this room to make it seem like you had not met
11 before?
12 MR. CRITTON: It was for the record.
13 THE WITNESS: No, sir.
• 14
15
BY MR. EDWARDS:
Q Okay. What did you talk about with
16 Mr. Critton?
17 MR. CRITTON: That's privileged.
18 MR. EDWARDS: You represent Ms. --
19 MR. CRITTON: She's my employee.
20 BY MR. EDWARDS:
2. • Do you understand this to be yuus attorney,
22 Mr. Critton?
23 MR. CRITTON: Well, I am her attorney. Bruce
24 is her personal lawyer, I'm her attorney vis-a-vis
25 her employment with Mr. Epstein, and that was a
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1 privileged communication.
2 MR. MERMELSTEIN: This case has got nothing to
3 do with employment.
4 MR. CRITTON: I don't care. Take it up with
5 the judge. If I'm wrong, I'm wrong.
6 MR. MERMELSTEIN: I assume you don't have
7 authority with you here?
8 MR. CRITTON: Pardon?
9 MR. MERMELSTEIN: I assume that means you have
10 no authority as we sit here today?
11 MR. CRITTON: What? Am I supposed to give you
12 authority? Take it up with the judge.
13 BY MR. EDWARDS:
14 Q Okay. At this meeting with you and
15 Mr. Critton, was Mr. Reinhart also there?
16 A He is. He was.
17 Q Who else was at the meeting, who else was in
18 the room with you?
19 A Only Mr. Reinhart and Mr. Critton and mc.
20 Q How long did the meeting last?
21 A About an hour.
22 Q Did you ever cry about a picture of the Pope
23 next to a girl in Mr. Epstein's house?
24 A No.
25 Q All right. Now, you testified that
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Mr. Rodriguez on one occasion asked you to cover for
him?
3 A Not to answer the phone call from New York.
4 Q You don't know why he told you not to answer
5 the phone call from New York?
6 A He mentioned -- he said that one day I'm,
7 like, help you, and the other day...
8 Q You help me?
9 A Yes.
10 • You don't know what that means, though?
11 A No.
12 • And the time where there was some
13 confrontation between, or there was some dispute over
• 14
15
Jerome the gardener being at work or not being at work,
that's something that Mr. Rodriguez tried to bring you
16 into?
17 A Yes.
18 • And was that with Mr. Epstein or with
19 Ms. Maxwell or Ms.
20 A Ms. -- again?
21 Q Okay. My understanding is that it was
22 Mr. Rodriguez who is saying is a witness
23 to whether or not Jerome was at work that day?
24 A Correct.
25 • And who was he saying that to?
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1 A To Jerome.
2 Q Okay. So he's telling Jerome hey,
3 is a witness to you not being here?
4 A Yes.
5 Q Okay. And you said don't use my name any
6 more?
7 A Because Jerome talked to me and he said, he
8 mention to me what Alfredo told him, so I went to
9 Alfredo and talked to Alfredo.
10 • Okay. And prior to the police coming to the
11 house, there was a massage table inside Mr. Epstein's
12 bedroom, right?
13 A Yes.
14 Q Was that massage table there after the police
15 came to the house?
16 A No.
17 Q Okay. So before when you told us all they
18 took were photographs, do you know whether or not the
19 police also took a massage table?
20 MR. CRITTON: Form.
21 Strike that, withdraw the form.
22 THE WITNESS: I cannot always remember,
23 like...
24 MR. REINHART: Hold on. Do you understand his
25 question?
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• 1
2
BY MR. EDWARDS:
Q Do you know if the police took the massage
3 table?
4 A No.
5 Q You don't know who took the massage table out
6 of the house?
7 A No.
8 Q Okay. We were talking about a time period
9 where you worked one day and then the following day you
10 came in in the afternoon because you had received a call
11 from Ghislaine Maxwell. Do you remember that scenario?
12 A Yes.
13 Q When you received the call from
• 14
15
Ghislaine Maxwell, you didn't know at that time that the
police had ever been to the house, right?
16 A NO.
17 MR. REINHART: Hold On.
18 She didn't answer the question that you asked.
19 MR. EDWARDS: I thought she had already said
20 no.
21 MR. REINHART: I think the wdy you asked it,
22 it may have been nonresponsive, so why don't you
23 ask it again so it's clear.
24 BY MR. EDWARDS:
25 Q Okay. At the time when Ghislaine Maxwell
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1 called you to tell you you didn't have to come in until
2 the afternoon, at that point in time you didn't know
3 that the police had ever been to the house, right?
4 A No.
5 Q You found out for the first time that the
6 police came to the house when you arrived in the
7 afternoon to show up for work, right?
8 A Correct.
9 Q Okay. That call from Ghislaine Maxwell, your
10 schedule at that time was to show up, at the time when
11 this telephone call is taking place, was to show up at
12 eight in the morning or so, right?
13 A Correct.
14 Q So that call from Ghislaine Maxwell was
15 actually the night before she called you and said don't
16 come in until the next afternoon, right?
17 A 1 think in the same day.
18 Q All right. You told me earlier that she
19 didn't call that early, but she obviously called
20 sometime before you got to work?
21 A Yes.
22 Q All right. What time did she call?
23 A I cannot remember. You know, I have problem
24 with remembering days and what's this.
25 Q I can understand problems with memory. But
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• 2
when you say that you show up at eight o'clock, were you
a punctual employee to where you showed up on time?
3 A I am.
4 Q Okay. And around the time when the search
5 warrant took place, where were you living, do you
6 remember?
7 A In townhouse in West Palm Beach.
8 Q How long would it take you to get from that
9 townhouse in West Palm Beach to Mr. Epstein's house?
10 A About thirty minutes.
11 O Thirty minutes?
12 A (Nodding head).
13 Q Sorry. The court reporter can't get the
• 14
15
nodding.
A That's my estimate, thirty minutes.
16 Q Okay. So what time would you leave your
17 townhouse in the morning to arrive to Mr. Epstein's work
18 by eight o'clock to start your shift?
19 A As I have mentioned, I sometimes work eight or
20 nine.
21 Q Okay. Do you remember that day if you were
22 scheduled to work eight or nine?
23 A I think nine.
24 Q Okay. I had understood your testimony, and we
25 can go back and look at the record some other time, I
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understood --
2 A I get confused, because during that time my
3 schedule was like sometimes eight -- I go nine,
sometimes I go eight.
5 Q How did you find out around that time whether
you were supposed to report at eight or nine?
7 A Because we were told that we don't don't
8 baby the house. So since Mr. Epstein is not there, so 1
9 report between eight or nine.
10 • Okay. So when you say that you were a
11 punctual employee, that means that if you were supposed
12 to show up at eight you showed up at least by
13 eight o'clock, and if you were supposed to show up at
14 nine, you showed up at least by nine o'clock, right?
15 A Yes.
16 Q All right. Did you have a cell phone at the
17 time?
18 A I do.
19 Q Did Ghislaine Maxwell call you on the cell
20 phone, or did she call you on your house phone?
21 A Cell phone.
22 Q Were you already in the car on the way to
23 Mr. Epstein's house?
24 A I was still in the townhouse.
25 Q And were you already ready for work, ready to
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• 2
go to work?
A Yes.
3 Q And what did Ms. Maxwell say on the telephone
other than you can show up in Lhe afternoon, anything?
A That's it.
6 Q All right. And did you ask why?
7 A No. I just thought that maybe she's giving me
8 like half a day off, so I was happy.
9 Q Was Ghislaine Maxwell calling you from
10 New York, or was she in West Palm Beach?
11 A I don't know where she was calling me.
12 Q When you arrived at the house in West Palm
13 Beach, was Ghislaine Maxwell there?
• 14
15
A No.
MR. REINHART: You mean the house in
16 Palm Beach.
17 BY MR. EDWARDS:
18 Q Well, that's the house you went to work to
19 that day, right?
20 MR. REINHART: I just don't want the record to
21 be confused between her house in west Palm beach
22 and Mr. Epstein's house in Palm Beach.
23 MR. EDWARDS: Okay. Understood.
24 BY MR. EDWARDS:
25 Q So does this conversation, you were either
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1 supposed to arrive at eight, in which case you would
2 leave your townhouse at 7:30 to arrive at Mr. Epstein's
3 house, right?
4 A If I go there eight.
5 Q And if you go there at nine, then you leave
6 your townhouse by no later than 8:30; is that right?
7 A Yes.
8 Q Okay. So Ghislaine Maxwell is calling you
9 that morning then sometime either just before 7:30 or
10 just before 8:30 in the morning to tell you don't have
11 to show up until the afternoon; is that right?
12 A Yes.
13 Q And as we sit here today, you don't remember
14 whether it was just before 7:30 or just before 8:30?
15 A To be honest, sir, I cannot remember.
16 Q All right. Is it fair to say that it might
17 have been even the night before?
18 MR. CRITTON: Form.
19 THE WITNESS: No.
20 BY MR. EDWARDS:
21 Q You're sure that it was that morning?
22 A I think I'm sure it was that morning.
23 Q Okay. You seem to remember specifically
24 getting a telephone call from her and it was early
25 morning before you showed up for work?
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• 2 call.
A I cannot remember if it was early, but I got a
I don't know the time.
Q All right. Your schedule, just so that we're
4 on the same page here, you were either supposed to show
5 up at eight or at nine o'clock, and you can't tell us
6 which one, right?
A Yes, sir. Because I don't how to explain
8 this.
9 Q And you were not in the car at the time when
10 you received the telephone call from Ghislaine Maxwell,
11 right?
12 A Yes. I was still in the townhouse.
13 Q So we can all presume, it's a very safe
• 14
15
presumption at this point that the telephone call from
Ghislaine Maxwell was made to you prior to 8:30 in the
16 morning on that particular morning, right?
17 A Yes.
18 Q Okay. Do you punch a clock so that we could
19 figure out what time you were supposed to be at the
20 house?
21 A No.
22 Q Anybody keep a track of time?
23 A No.
24 Q You've been asked a lot of questions about the
25 various females that showed up to the house to give
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1 massages, and the only reason you ever knew that they
2 were allegedly giving massages is that somebody told you
3 that, right?
4 A Correct.
5 Q These females that showed up didn't show up --
6 MR. CRITTON: Form.
7 BY MR. EDWARDS:
8 Q -- with massage cards or hand you cards or
9 give you any other indication that they were giving a
10 massage other than somebody else told you that?
11 MR. CRITTON: Form.
12 THE WITNESS: Correct.
13 BY MR. EDWARDS:
14 Q Okay. And when these females would show up,
15 they were of very young age; wouldn't you agree with
16 that?
17 MR. CRITTON: Form.
18 THE WITNESS: They may look young, but I did
19 not ask their age.
20 BY MR. EDWARDS:
21 Q You know what a thirty year old looks like or
22 a forty year old or a fifty year old, and that's not
23 this classification of females that we're talking about,
24 is it?
25 MR. CRITTON: Form, argumentative,
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• 2
repetitious.
THE WITNESS: Yes.
3 BY MR. EDWARDS:
4 Q You think that there were thirty year olds
5 that showed up to give massage?
6 A No. Because there are people that look young
7 but, you know, they may be older than what they, how
8 they look.
9 Q And in the period of time from November 2004
10 through the time that Mr. Epstein went to jail, which is
11 2008, you testified that he received from these females
12 two to three massages or visits from these females per
13 day every day, right?
• 14
15
MR. CRITTON:
THE WITNESS:
Form.
I said not every day. I
16 remember that, my answer.
17 BY MR. EDWARDS:
18 Q Okay. But almost every day, fair?
19 MR. CRITTON: Form.
20 THE WITNESS: Yes.
21 BY MR. EDWARDS:
22 Q Okay. We're talking about -- and two of those
23 females that you remember over this four-year period you
24 remember being repeat visitors and that came more than
25 one time, correct?
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1 A Yes.
2 MR. CRITTON: Form.
3 BY MR. EDWARDS:
4 Q The other ones --
5 MR. CRITTON: Hold on. I want to put one
6 thing on the record.
7 MR. EDWARDS: / don't break you up like this
8 every time.
9 MR. CRITTON: Well, this is the testimony that
10 you covered for almost three hours earlier today,
11 it's the same, it's not recross, it doesn't cover
12 anything that everybody else touched on in their
13 cross. I'm sorry, 1 mean it's not redirect. It's
14 the same material that you covered before.
15 MR. EDWARDS: Mark this point in the
16 deposition, too.
17 MR. CRITTON: Please do.
18 MR. EDWARDS: Thank you.
19 BY MR. EDWARD£:
20 Q The other girls that are coming on nearly an
21 everyday basis as females under the idea that they're
22 going to give Mr. Epstein a massage, besides the two
23 that you've described as repeat masseuses, are different
24 faces every day, right?
25 MR. CRITTON: Form.
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• 2
THE WITNESS:
BY MR. EDWARDS:
Yes.
3 Q So if you're only seeing them one time, that
4 could be the reason why you can't think back and
5 remember these particular faces of every single one of
6 these female girls, right?
7 MR. CRITTON: Form, leading.
8 THE WITNESS: Yes.
9 BY MR. EDWARDS:
10 Q Okay. So did you ever wonder how it was that
11 so many different young-looking female girls arrived at
12 Mr. Epstein's house, how he got in touch with this many
13 girls?
• 14
15
MR. CRITTON:
BY MR. EDWARDS:
Form.
16 Q Did you ever wonder?
17 MR. CRITTON: Form.
18 THE WITNESS: It was strange, but that's his
19 life, so I was there to work, to do my job.
20 BY MR. EDWARDS:
21 Q Okay. But while you were duiuy your job, you
22 knew -- look, you didn't witness anything, like
23 Mr. Critton said, what was going on behind closed doors,
24 but you knew that there was sex going on between
25 Mr. Epstein and these young girls?
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1 MR. CRITTON: Form, argumentative.
2 THE WITNESS: I did not see, I did not go
3 upstairs and notice.
4 BY MR. EDWARDS:
5 Q I know you didn't see. You're still employed
6 by Mr. Epstein, right?
7 A I am.
8 Q Mr. Epstein has hired you an attorney,
9 obviously?
10 A Yes.
11 Q You want to keep your employment with
12 Mr. Epstein, right?
13 MR. CRITTON: Form.
14 THE WITNESS: If he'll fire me, I -- you know,
15 they told me to tell, to be honest, to tell the
16 truth, my lawyers.
17 BY MR. EDWARDS:
18 Q Yeah. You know that I represent three girls,
19 Mr. Mermelstein represents seven girls, Mr. Hill one,
20 and that's just the lawyers that are here.
21 A bunch of these girls are all alleging that
22 Mr. Epstein was upstairs having sex with them and/or sex
23 acts with them, and that these were not massages taking
24 place. You're aware of those allegations now, right?
25 A Now I'm aware.
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MR. CRITTON: Form.
2 BY MR. EDWARDS:
3 Q And had you ever heard that during these sex
4 sessions that Mr. Epstein would then offer these young
5 girls money, cash money to be subjected to sex; had you
6 ever heard that?
7 MR. CRITTON: Form.
8 THE WITNESS: I heard now.
9 BY MR. EDWARDS:
10 Q And that if they agree to bring their friends
11 who are also of that same age group, that each friend
12 they brought over to his house he would then pay them
13 for recruiting a new friend. Did you know that?
• 14
15
MR. CRITTON:
THE WITNESS:
Form.
No.
16 BY MR. EDWARDS:
17 Q Now it all kind of makes sense how he gets all
18 these young little girls over to his house, right?
19 MR. CRITTON: Form, argumentative.
20 BY MR. EDWARDS:
21 Q And nobody in the house has ever denied any of
22 what I'm saying, have they?
23 MR. CRITTON: Form. She didn't even answer
24 the last question and you're continuing on with
25 your argument.
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1 BY MR. EDWARDS:
2 Q Has anybody?
3 A I did not hear them talk about it, so I
4 cannot.
5 Q So now that you know what's going on in your
6 boss's house, are you still going to stay employed with
7 him?
B MR. CRITTON: Form, argumentative, serves no
9 purpose.
10 THE WITNESS: Yes.
11 MR. EDWARDS: Okay. Perfect. I don't have
12 anything else.
13 THE WITNESS: But if he fires me, you know.
14 MR. MERMELSTEIN: Just a couple of questions.
15 RECROSS (
16 BY MR. MERMELSTEIN:
17 • This meeting that you had with Mr. Critton and
18 Mr. Reinhart yesterday, where did it take place?
19 A In Mr. Critton's office.
20 Q Mr. Critton's office?
21 A Yes, sir.
22 Q And was it Mr. critton's office who called you
23 to advise you of the time and where to go for the
24 meeting?
25 A
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• 2
0
A Yes.
3 Q Is that Mr. Critton's assistant?
4 Mr. Reinhart's assistant? You don't know.
5 MR. EDWARDS: •
6 BY MR. MERMELSTEIN:
7 Q I'm sorry. told
8 you where to go for the meeting?
9 A Yes.
10 Q You testified that Mr. Rodriguez was
11 terminated, according to your understanding, for not
12 buying groceries when Mr. Epstein came into the house;
13 is that correct?
• 14
15
A
Q
Yes.
Who told you that that was the reason?
16 A Ms. Maxwell told me that Alfredo should --
17 Ms. Maxwell told me that Alfredo should not -- Alfredo
18 should always like, I don't know.
19 MR. REINHART: Answer the question you were
20 asked. Who told you that?
21 THE WITNESS: Ms. Maxwell.
22 I'm sorry.
23 BY MR. MERMELSTEIN:
24 Q Why did Ms. Maxwell tell you about the reasons
25 for terminating?
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A Because there was one time that I called the
2 agency that I'm going to quit.
3 Q Okay. And why was that?
4 A Because Alfredo was not listening to my
5 complaints.
6 Q What were you complaining about?
7 A Like my hand was already -- like I have to
8 help in the kitchen and then, like, iron. So I said my
9 hand is numb already, and Alfredo did not even pay
10 attention. So I called the agency to find another job.
11 Q I'm confused. I thought you were employed --
12 so you weren't employed by the agency at this point, you
13 were going to go back to the agency to find another job;
14 is that fair to say?
15 A Yes.
16 Q And this is before you even complained to
17 Ms. Maxwell?
18 A I did not complain to Ms. Maxwell.
19 Q And that was because Mr. Rodriguez was your
20 supervisor, correct?
21 MR. CRITTON: Form.
22 THE WITNESS: At that time, yes.
23 BY MR. MERMELSTEIN:
24 Q Did that ever change, before Mr. Rodriguez
25 left the employment?
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• 2
A
Q
Yes.
When did it change?
3 A Because I was told that we have to work
4 together, but he was like, you know, like very bossy.
5 Q You didn't like Mr. Rodriguez, did you?
6 A No. I, what's this, I like him first, but
7 then he keeps on talking and talking and talking and
8 criticizing. And then he lied, there was one instance I
9 want to tell you that he also lied.
10 • Other than what you testified to before?
11 A Yes.
12 Q Okay. Go ahead.
13 A There was one time I was still new, and
• 14
15
then --
Q I'm sorry. You were what?
16 A Still new. You don't understand my English.
17 0 That's okay. Take your time.
18 A What's this? Before I leave, I always, like,
19 go around tidy. And then that time the master bedroom
20 was closed, so I told Alfredo it's closed, so I went
21 back to him. He said no, no, no, they went to the
22 movies. And I went back again, but then I feel that
23 it's not proper, so I knock again. No. I did not
24 knock, I went down again to talk to Alfredo. So I went
25 back again and knock, and then Mr. Epstein was in the
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1 bedroom.
2 And the next day Alfredo told me that
3 Mr. Epstein will fire me. And Alfredo, I was, what's
4 this. I was disappointed in Alfredo because he should
5 have told Mr. Epstein if he is like a good boss that it
6 was his fault because I'm still new there and I don't,
7 what's this, he was telling me that nobody is there in
8 the bedroom.
9 Q And so Mr. Epstein was going to fire you for
10 knocking on the bedroom door while he was in the
11 bedroom?
12 A That's what Alfredo said, told me.
13 Q Okay. But Mr. Epstein didn't fire you,
14 correct?
15 A No.
16 Q What was Mr. Epstein doing in the bedroom when
17 you knocked on the door?
18 A Maybe taking a nap. I don't know.
19 Q Was he in the bedroom with anyone at the time?
20 A I don't know.
21 Q You never heard anything else from anyone
22 about whether you'd be fired, is that basically what
23 happened after this?
24 A No. That was only from Alfredo.
25 Q Okay. So you were waiting to hear something
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• 2
from Mr. Epstein or Ms. Maxwell but you never heard
anything else; is that it?
3 A No.
4 Q Yuu cunLiuued wiLli youL jub, cuLLecL?
5 A Yes, sir.
6 Q Well, why did you speak to Ms. Maxwell about
7 the reasons that Mr. Rodriguez was terminated?
8 A Why I talk to Ms. Maxwell?
9 Q Yes.
10 A I think she called me to be in the house when
11 Alfredo comes.
12 Q To be in -- what do you mean?
13 A Because Alfredo at that time was on vacation.
• 14
15
Q Okay.
came back?
And they were terminating him when he
16 MR. CRITTON. Form.
17 BY MR. MERMELSTEIN:
18 Q I'm not understanding.
19 A Alfredo told me that he asked for a vacation,
20 so he was on vacation at that time.
21 Q Okay. That's when Ms. Maxwell spoke to you
22 about why she's terminating Alfredo?
23 A She didn't tell me that she's going to
24 terminate Alfredo, but she told me to stay in the house
25 because Alfredo will come and pick up his things.
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1 Q Oh. So she wanted you to watch Alfredo when
2 he came to pick up his things?
3 A Yes. And to get something, like a folder from
4 Alfredo.
5 Q okay. And at that time the reason that she
6 gave you, according to your testimony, for terminating
7 him was that he had failed to buy groceries?
8 A She did not tell me that time that she is
9 going to terminate Alfredo because he did not buy, but
10 she was upset also that Alfredo did not guy groceries.
11 Q But that wasn't the reason she was terminating
12 him?
13 A I don't know.
14 Q Did she give any other reasons that she was
15 unhappy with Alfredo's performance?
16 A No.
17 MR. MERMELSTEIN: Nothing further.
18 MR. HILL: I don't have anything.
19 MR. EDWARDS: Ma'am, can you just put your
20 telephone number on the record just so that we can
21 get in touch with you if we need to find you for
22 trial or something?
23 MR. REINHART: You can contact me.
24 MR. EDWARDS: Even if, you know, God forbid,
25 the trial is a year from now and she's not an
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• 2
Epstein employee and you don't have it?
MR. REINHART: I will be -- I'm her lawyer,
3 you can contact her through me and I'll find her.
4 MR. EDWARDS: Perfect. Good enough for me.
5 All right. Read or waive?
6 MR. REINHART: Read.
7 THE COURT REPORTER: Do you need to order?
8 MR. EDWARDS: Yes.
9 THE COURT REPORTER: Who needs copies?
10 MR. CRITTON: Are you getting it typed?
11 MR. EDWARDS: Yes.
12 MR. CRITTON: I'll take a copy, front page
13 only, mini, with a text.
• 14
15
MR. HILL: No.
MR. MERMELSTEIN: Yes.
16 (witness excused.)
17 (Deposition was concluded.)
18
19
20
21
22
23
24
25
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1 THE STATE OF FLORIDA)
2 COUNTY OF PALM BEACH)
3
4 I, the undersigned authority, certify that
5 personally appeared before me on the
6 20th of October, 2009, and was duly sworn.
8 Dated this 30th day of October, 2009.
9
10
11
12
13 Teresa Whalen, RPR, FPR
Notary Public - State of Florida
14 My Commission Expires: 4/25/11
My Commission No.: DD 644533
15 Job # 118991
16
17
18
19
20
21
22
23
24
25
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• 1
2
CERTIFICATE
THE STATE OF FLORIDA)
3 COUNTY OF PALM BEACH)
I, Teresa Whalen, Registered Professional
Reporter and Notary Public in and for the State of
6 Florida at large, do hereby certify that I was
authorized to and did report said deposition in
7 stenotype; and that the foregoing pages are a true
and correct transcription of my shorthand notes of
8 said deposition.
I further certify that said depouiLion was
taken at the time and place hereinabove set forth
10 and that the taking of said deposition was commenced
and completed as hereinabove set out.
11
I further certify that I am not attorney or
12 counsel of any of the parties, nor am I a relative
or employee of any attorney or counsel of party
13 connected with the action, nor am I financially
interested in the action.
. 14
The foregoing certification of this transcript
15 does not apply to any reproduction of the same by
any means unless under the direct control and/us
16 direction of the certifying reporter.
17 Dated this 30th day of October, 2009.
18
19
20
21 Teresa Whalen, RPR, FPR
22 Job # 118991
23
24
25
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DATE: October 30, 2009
TO!
C/o BRUCE E. REINHART, ESQUIRE
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
IN RE: L.M. I. EPSTEIN
5 CASE NO.: 502008CA028052XXXXMB AD
Please take notice that on Tuesday, the 20th of
October, 2009, you gave your deposition in the
above-referred matter. At that time, you did not
waive signature. /t is now necessary that you sign
your deposition.
As previously agreed to, the transcript will be
furnished to you through your counsel. Please read
the following instructions carefully:
10 At the end of the transcript you will find an
errata sheet. As you read your deposition, any
11 changes or corrections that you wish to make should
be noted on the errata sheet, citing page and line
12 number of said change. DO NOT write on the
transcript itself. Once you have read the
13 transcript and noted any changes, be sure to sign
and date the errata sheet and return these pages to
14 me.
If you do not read and sign the deposition
15 within a reasonable time, the original, which has
already been forwarded to the ordering attorney, may
16 be filed with the Clerk of the Court. If you wish
to waive your signature, sign your name in the blank
17 at the bottom of this letter and return it to us.
18 Very truly yours,
19
Teresa Whalen, RPR, FPR
20 ESQUIRE DEPOSITION SERVICES, INC.
515 North Flagler Drive, Suite 200-P
21 West Palm Beach, Florida 33401
I do hereby waive my signature
22
23
Cc: Via transcript: STUART S. MERMELSTEIN, ESQUIRE
24 ROBERT D. CRITTON, JR., ESQUIRE
Job # 118991 BRADLEY J. EDWARDS, ESQUIRE
25
0 Toll Free: 866.709.8777
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ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, Fl. 33410
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EFTA00182565
- Volume II October 20, 2009
219
• 1
2
CERTIFICATE
3 THE STATE OF FLORIDA)
4 COUNTY OF PALM BEACH)
5 I hereby certify that I have read the foregoing
6 deposition by me given, and that the statements
7 contained herein are true and correct to the best of
8 my knowledge and belief, with the exception of any
9 corrections or notations made on the errata sheet,
10 if one was executed.
11
12 Dated this day of
13 2009.
• 14
15
16
17
18
19
20
21
22
23
24 Job # 118991
25
• 0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
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EFTA00182566
- Volume II October 20, 2009
220
ERRATA SHEET
2 IN RE: L.M. I. EPSTEIN CR: TERESA WHALEN
3 DEPOSITION OF:
4 TAKEN: 10/20/09 JOB NO.: 118991
5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
PAGE # LINE # CHANGE REASON
10
11
12
13
14
15
16
17 Please forward the original signed errata sheet to
this office so that copies may be distributed to
18 all parties.
19 Under penalty of perjury, I declare that I have read
my deposition and that it is true and correct
20 subject to any changes in form or substance entered
here.
21
22 DATE:
23
24 SIGNATURE OF
DEPONENT:
25
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
WWW esquiresolutions.corn
EFTA00182567
•
X3ONI 0210M
•
•
EFTA00182568
I'
•
EFTA00182569
- Volume II October 20, 2009
221
• AB
131:3
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TON Free: 866.709.8777
• 0 Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA00182570
- Volume II October 20, 2009
222
204:21 binder bottoms calendar 132:9 135:15
bathing 162:9,17 182:25 171:17 cash
149:15,18 164:11 Boulevard call 207:5
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• Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquIresolutions.com
EFTA00182571
- Volume II October 20, 2009
223
• citing
218:11
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• Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beath Gardens, FL 33410
www.esquiresolutions.com
EFTA00182572
- Volume II October 20, 2009
224
162:3 209:3 196:24 134:18 212:10,17
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days DESCRIPTION 163:16
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, Fl. 33410
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EFTA00182573
- Volume II October 20, 2009
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• 164:12
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218:24
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• 0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
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EFTA00182574
- Volume II October 20, 2009
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F 175:19 215:3 fluid 178:10
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174:4,13 214:21 176:7 176:10,11 217:21
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
IRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
vnvvi.esquiresolutions.com
EFTA00182575
- Volume II October 20, 2009
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• 218:19
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EFTA00182576
- Volume II October 20, 2009
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EFTA00182577
- Volume II October 20, 2009
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EFTA00182578
IIIIIIIIIIIIII - Volume II October 20, 2009
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EFTA00182579
- Volume II October 20, 2009
231
• needed
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- Volume II October 20, 2009
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- Volume II October 20, 2009
234
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EFTA00182583
- Volume II October 20, 2009
235
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EFTA00182584
- Volume II October 20, 2009
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- Volume II October 20, 2009
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• 182:12
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• Toll Free: 866.709.8777
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EFTA00182586
- Volume II October 20, 2009
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EFTA00182587
- Volume II October 20, 2009
239
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EFTA00182588
- Volume II October 20, 2009
240
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Palm Beach Gardens, FL 33410
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EFTA00182622
SS •• v.%.. •• . • J• • ••=•••.01••••• • %NS Sow
FOR •14*. "5 - •
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TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
GAME 70 SEE YOU WILL CAU.AGAIN CAME TO SEE YOU WILL CALL AGAIN
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MESSAGE MESSAGE
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SIGNE "I- NED 1184
a
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ron , Mt; ' . 'E b FOR MAir•
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SILINEU II 94 SIGNED 1184
EFTA00182623
VOK IAN I MESSAQ£
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DATE Iv) 6/o 4 TIFIE 41
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EFTA00182624
FOR 1.1 1^19.,J.t.. FOR
DATE 0 • TIMEMa_. PAC DATE II 7/04 yomE Too 4:5Pet
111
M '1•1 M P 14 ay lc -et CASN
OF OF Fi Vle IOW k / N5
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WANTS TO SEC YOU RUSH WANTS TO SEE YOU RUSH
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r MESSAGE MESSAGE
Te4-414A):2 Ve v v rillaasG ce,u,tmw,
1
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14
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FOR V. - 3
DATE_ - '1t TIME . /O er
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musILE -a2c.%) 'nt -%s9 FAH451 0•0;7:g 64— -1Soo
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WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
Ck5 tinxicj to kg' 9kGes 4 Cedth Vote
.seexcw AciboIrroW
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SIGNED SIGNED R at
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1184
EFTA00182625
IMPORTANT MESSAGE IMPORTANT MESSAGE I
roR I' l 'IN". Fon v -Jr • 1,Lcal
Da_
time
DATE TIME t 1 Id DA I E _ a . _
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WANTS 70 SEE YOU RUSH WANTS TO SEE YOU RUSH
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MESSAGE MESSAGE
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DATE IIMEi I Ct Se P.M DATE
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a
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EFTA00182626
IMPORTANT MESSAGE I
FoR - At
DATE 0/(1104
M CDS tie
of W V Oliva
PHONE/ PHONE/
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TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
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WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
11 call lade-
La
SIGNED lilt
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR 14 lc% sE FOR
DATE III 1404 TIME 6 76-*/- DATE TIME
A M.
PM
. c ._r -k J— M
OF OF
PHONE) PHONE/
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TELEPHONED Pi EASE CA.L TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
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MESSAGE MESSAGE it
r.T9 ‘Cpasth sziol
A-k34- 7 c_blkcjit i
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SIGNED CAZ" .......... }IN SIGNED nu
EFTA00182627
v.,.,
IMPORTANT MESSAGE
tt[ It lad
IMPORTANT MESSAGE
FOR CIj
DATE TIME 0O PM
M
•
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PHONF/ PHONE/
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TELEPHONED PLEASE CALL lliLePFK7t4tO PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
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MESSAGE MESSAGE
\Painjam
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&trier
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SIGNED
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DATE TIME .--
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CAME TO SEE YOU Wit L CALL AGAIN CAME TO SEE YOU WILL CALL MAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
a
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SIGNED ION SIGNED Dm.
EFTA00182628
tmeciktiN-fritT:04sSi..4EI IMPORTANT MESSAGE
TIME
ZACt " c\r‘.0 Try
pHoNEJ-zA
M061LE CV? - 44 e
TELEpHOTIED ei-r-AseCAW- TELEPHONED PLEASE CALL
CAnIE TO SEE104.4 wiLicALLkw* CAME TO SEE YOU WILL CALL AGAIN
WANTS TOSEC .Y4) iiusH WANTS TO SEE YOU RUSH
PETUHNED VOW CALL 4 SPECIAL ENHOW RETURNEDYOUR CALL SPECIAL ATTENTION
MESSAGE
CA-)‘ (2‘2,1'6 c,p,iA
;:SIGN,EI:t • mak SIGNED
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR lkiv • Th • A; FOR
DATE I I/ 7'0/04 TIME •A M DATE If 7 0 ol) To& 2j'acai '
M% --i eln ny FA v• 3 C- eft-, Lid c--
OF OF
PHONE/ PHONE,
MOBILE (4 k I1 ) 330.-- kO 3 3., MOBILE
TELEPHONED PLEASE CALL TELEPHONED PI EASE CAI I
CAME 'KT SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
Cell. \--‘; vv..
S:GNED 1014 41GNED
a.
NM
EFTA00182629
FOR
DATE
Al,.k
IMPORTANT MESSAGE I
Ui ha 0 4 TIME
A.M.
FOR
DAT
IMPORTANT MESSAGE
TIME
AA
M 5 8 Y 1 A -e.
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OF OF
:Z E (5 ‘ 1) 547 - Z4 IC HOTTE7 9 .nr
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TELEPHONED PLEASE CALL TELEPHONED PI FARE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU Will CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION _ RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE TAFeSAI-F
to Hi 10J y au b-
4
S or:F-; /
ai SIGNED
IMPORTANT MESSAGE IMPORTANT MESSAGE
.e .
I-OH FOR
AI/
DATE 1 0 TIME. 10.11 CND DATF ALii.s TIME P.M
M C• 'L v Vey WO I n.-I 6i vl M
Of OF
time'
(3. 0a) 11 kg 5‘
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TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU ■ WLL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
PETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL, SPECIAL ATTENTION
MESSAGE SSAGE I. "1 t
yovv. veil
SIGNED It SIGNED 18
EFTA00182630
IMPORTANT MESSAGE
FOR 1. —3
DATE
II 7t/o4 TIME :L.Ft PM
M
OF OF
PHONE/ PHONE;
MOBILE 235- - 5555 MOBILE
-
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MEteat1F
k -ct kY•yObk7.AAI L-1.
SIGNED 1184ai
IMPORTANT MESSAGE I IMPORTANT MESSAGE
FOR FOR •
DATE cluAirvi
TIME i 0 P.M. DATE_ . TIME 12S P.M.
M CjaANKt -t • M C bi t& DUb i l
OF OF
PHONE/
MOBILE, a ) i_D•e ) MOBILE (5 te
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WIU. CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL' SPECIAL ATTENTION
MESSAGE MESSAGE N1,
(
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EFTA00182631
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR • • FOR M [ a . Tc . •
DATE
M ✓
OF
ti-/0104
60
TIME Z4.
a 3 vv•S\
3 .46 DATE
IA
OF
104 lIME eirza
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TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
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WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SpECuLLATTENTioN RETURNED \tun GALL OrtCtAL ATTCNTION
MESSAGE MESSAGE
\C32-t OeAA Viet-.
YV\
DI
SIGNED 1181at SIGNED I
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR .t . r9FI
DATE r7 el TIME 3 en DATE TIME
m -S. - Mesne Watt . M
OF OF 6)
PHONE/
MOBILE acirLE el i 4— 054
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CµL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
-P e-z se, evil 1-)ale
` ( lam ‘a-ala cati 1,10 l'
SIGNED )."• i alea SIGNED
cis?. ili
1164
EFTA00182632
I IMPORTANT MESSAGE I IMPORTANT MESSAGE
FOR Sqf (9.k Fon Oki aid 9
DATE I I _`I TIMEz' at DATE -04< TIAG:2thbg
OF -rroat 56.%kaki
MOW C0H (4 • 7C2C° PHONE/
MOBILE
TELEPHONED TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAiN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
Loot_a-trt
a -44tiche 6( 3 .1 N.Or t
kj-w c1 4: DO
NLitt3k.tte
'60Y - it ) DO teCiaLil
SIGNED it SIGNED' IN& ••. Iit
7. 3
I IMPORTANT MESSAGE IMPORTANT MESSAGE
OR ntil.N. FOR
DATE rt.-- a / c:24 TIME . Ca & DATE Itr i g. 7 0 7 TIME .
m M 0 R-A.y vy 'alls,-
•
O= c IA kiiNG ‘1 . OF
/AOBIL Si) 9 6 5 --, G2 57
PH PIP
750 •^ I 1741
Man
TELEPHONED PLEASE CAI.I TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
CP I 6., (e Ceti
tt
(,)6 4'- r 20.-14f y vti n yov V-
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SIGNED 1184
a SIGNED SNA mit
EFTA00182633
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR -1 • .
DATE TIME 10‘.(5- DATE 11/7/04 masa
m ry STPLAI,AL M tb r, (3.1. re-ck
OF OF
WI 770 Sit— too° $73c7 L'?-t1_-) 5214 144 0
I EltilluNtu PLEASE CALL I eLtPHONEO PLEASh all
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU HUSH
RETURNED YOUR CALL SPECIAL ATTENTION WORMED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
Tel cati
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SIGNED 084 SIGNED 1184
IMPORTANT MESSAGE
FOR IA ' .11E_
DATE 12 04 Time tz :do &A
kr va
OF NY C. OF
PHONE/ PHONE/
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TELEPHONED PI FARE CALL TELE
CAME TO SEE YOU WILL CALL AGAIN CAME T IL IA;
WANTS TO SEE YOU RUSH WANTS T R ,
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED WE N. ATTENTION
MESSAGE
PTA (5.) fro 7 Ain&ti.5
ti
Tevy;t5 yew% div, e,t 40.r
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SIGNED 5 .1
e:_ .P. Hsi 1184
EFTA00182634
I IMPORTANT MESSAGE I I IMPORTANT MESSAGE
M FOR lir -3 .f
DATE 17 / 7 1 ° -4- TIME r
m L coidy Wax ne—
OF
PHONE/
MOBILE
TELEPHONED PLEASE CALL TELEPHONED I PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MEQsAGE
QIo2JG C41 kik %A.
SIGNED
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR El kg • 3 .1E •
-1
FOR Hy.
AM.
DATE 12 i a llb‘l TIME 10 1 QI:rt DATE It/erg/0e;
Mv IA an i t\r-Lik6 1- AI li r • CIns‘“
OF OF
PHONE/ 4I-z_
MOBILE NYC_ Oa( 6 PEICSSEI L ./CD
MOB/LE 113
TELEPHONED Pt FASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WIU. CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION REIURNEI) YOUR CALL SPECIAL ATTENTION
MESSAGE T&SSAGE 'L"n 2_
lt atl COrt Yt0Uy \3/4 -SlowMIA
S- to to kko 147.
ill
SIGNED S l 1184 SIGNED DEA
EFTA00182635
I IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
FOR A -241,1 FOR V
DATE 9 /Oil TimEja la DATE PI o ToiE_..ist_Lat
M Vr) m A-rz_ m Y. • nirlaw)j•kk
OF CO'KA, OF
PHONE/
(55)709-. 73 % qq I - ICMO
ti
MOBILE MOBILEI
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALI.
CAME TO SEE YOU . WILL CALL AGAIN CAME TO SEE YOU r WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL , SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAG, MESSAGE
S c 1164/Trs 4.1H:SO ;!:_•J
\-1\cea CA titivk
ree I rn jk,e,elt
fa.
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SIGNED
a
SIGNED
a
I IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR fri V•• 1 -F— FOR
DATE igonkei TIME t14) G
PM DATE
" I° C)
TIME g.rnoc) CA
MS Sve A- krin 2. M PS tuTatir TAG "4---
OF OF
PHONE/ (prip iier _ 3 Ds i PHONE/
MOBILE •
MOBILE
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
_
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
.. SI)co tit/0 cztil
Tall Ism kle.2 \ T -
106t:0
CetteA '
BIT.
SIGNSD-r 1164 SIGNED 1184
EFTA00182636
9.I ,Iytt,>P4. ....st 1 IMPORTANT MESSAGE
FOR /Tv 3 FOR
GATE.....). "A
1?4?4%;:tr
.1..-4 i,... ,.. rwc 0 -LSC \i erl
. v.
DATE TNE S.; p.A.
OF
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TELEPHONED PLEASE CALL
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.._., WANTS TO SEE YOU RUSH
RETURNED YOUR CALL _ SPECIAL ATTENTON
MESSAGE
. ..
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; ' +'.-7 II- \-`' ' 1— L 'INN KW' v ccj(ed
rh:56}-1
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SIONEO , .,a . SIGNED-
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR -V A ,E
DATE
I
TIME —..... PM. DATE it 16 OBI TIME 2:3
M -1:4101"/14S , I,i
OF
PHONE/
MOBILE
M0BPHONE/
ALE 5 61 379 44 7
MEN iONED PLEASE CALL TELEPHONED PLE E CALL
CAME 10 SEE YOU r WILL CALL MOW CAME TOSFF YOU I.l CALL AOMM
WANTS TO SEE YOU RUSH WANTS TO SEE YOU SH
'RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SP IAL ATTENTION
MESS$3E MESSAGE
0 ) ii C (-"( 1 -0 c11LLvwL
L. CAL 0 1- \ 1 ii i S - 62 ç
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SIGNED I li SIGNED MN
EFTA00182637
Lbil.f.SSAGE I
I IMPORTANT j_
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14 -a•-r_ • ._ .- _____ i-oR
,,,,..;...v,. _ ! /6 _o /1 „Nit_ -c-''....2.q.6'1 . TIME7 A 10 _ 44
n. • tas,. p......
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‘louJG_f ro -6,:of., 0v '
c17 ,2__..,___
a.. 85
sIcNEQ— BEA SiGNED us/
IMPORTANT MESSAGE I—IMPORTANT MESSAGE
FOR - 11
DATE 12 3a TIME g: 15 P-m-
IAMS .e._ la
OF
PHONE/
MOBILE
TELEPHONED I iinse c.ku_ TELEPHONED ;7 46 CALL
CAME TO SEE YOU WILL CAU.AGATTI CAME TO SEE YOU ll. CALL AGMN
WANTS TO SEE YOU RUSH • WANTS TO SEE YOU RUST
RETURNED YOUR cola e SPECIAL ATTENTION RETURNED YOUR CALL ECIAL ATTENTION
MESSAGE
I : US% 7/1.1r413 S11 146'llo I
WINED _ A . at.
1184 SIGN
•
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EFTA00182638
[ IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR_ FOR
-P •
DATE I2 I°) oil TIME (0:1 14 pti ;
? DATE %-t-inotaEna
M 2N1 Corftli i6)d r. liev yen
off OF
tprooac) o PHONE/
MOBILE ~315t7-11@7`
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WE. CALL AGAIN
WANTS TO SEt YOU RUSH WANTS TO SEE YOU RUSH
RETUNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE
.. leeje 115I,t
So/ rano I 1 4,2), ceileci
..
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IMPORTANtAittss>cdt" I IMPORTANT MESSAGE
F 41 8 cr -3 7-E FOR
DATE. __ t ? ? I/04 1•7 4E. le t Z-2 Vlr' DAT/ I . pmE_ZA5S)
IA ir ct-SA_. St?nkmay__
OF
riill...TLEJ,c2,1_4_,SI1- 7,--.31 PHONE/
MOBILE
iamioneo. - 1pi FA CF rat • , Ti TELCINIONCD PLEASE GALL
) WILI-414-i.M3A114 . .'., • CAME TO SEE YOU WILL CALE AGAIN
CMPii T4).5"4:itP
. ..
11/ANTS TO SEE YclO I RUSH (
WANTS TO SEE YOU RUSH
BEINANCIP Cc/CRP/11 -PTt ialisi..-kritippri RETURNED Y3 CALL SPECIAL ATTENTION
W.5SAG.6 , MESSA
it.
"
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EFTA00182639
IMPORTANT MESSAGE I IMPORTANT MESSAGE I
I-OR
DATE
M 1.
Y.
CIOC
Z.
3
1n fa
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Yr. L.
FOR
DATE
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•
mimfaa
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OF r OF
=El (56 644 -1635 MO
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TELEPHONED PLEASE CALL TELEPHONED PLEASE CM.!.
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU YAU.CALL AGAN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CAU. SPECIAL ATTENTION
MESSAGE MESSAGE
r9Nets a ciatA Pk stse
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SIGNED
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SIGNED
a
1184 HIM
IMPORTANT MESSAGE IMPORTANT MESSAGE
4* •
FOR Vey '3.7 FOR
DATE C. TIME _6515_1 0 DATE_11 -7 in TIME 45PM
M r. Ltiv ?Chat kile?Vti M e %.
OF
33144 \8 15-1r Las
OF
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TELEPHONED PLEASE CALL TELEPHONED PLEASE CAI I
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RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION .--
MCSSAGE MESSAGE
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EFTA00182640
IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
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RETURNED YOUR CALL SPECIAL ATTENTION RETURNEDYOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
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IMPORTANT MESSAGE IMPORTANT MESSAGE
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MESSAGE MESSAGE
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EFTA00182641
I IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
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EFTA00182642
I IMPO ANT MESSAGE I IMPORTANT MESSAGE
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MESSAGE ,.. MESSAGE
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EFTA00182643
IMPORTANT MESSAGE
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MESSAGE
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TIME 4 • itAM
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EFTA00182644
IMPORTANT MESSAGE
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DATE _a II I 0 TIME co,i
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MESSAGE MESSAGE
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SIGNED 1184 1184
I FOR
IMPORTANT MESSAGE
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DATE I I I lib i c e' TarEA :C7 c
a: DATE 417 / 71 r- TAE °3
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MESSAGE MESSAGE
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EFTA00182645
I IMPORTANT MESSAGE I IMPORTANT MESSAGE
FOR. FOR
DATE TIME DATE . _ p
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TELEPHONED PLEASE GALL TELEPHONED PLEASE CALL
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WANTS To SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
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SIGNED e4 SiGNcc. • -
IMPORTANT MESSAGE IMF? TANT MESSAGE
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RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL MENTION
MESSAGE MESSAGE
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EFTA00182646
IMPORTANT MESSAGE IMPORTANT MESSAGE
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OF OF
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MESSAGE MESSAGE •
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IMPORTANT MESSAGE IMPORTANT MESSAGE
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,
DATE TIME....j
I • (:) ° & DATE liki4inC I :47 s1TIME
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MESSAGE MESSAGE
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EFTA00182647
n IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR Mb. te.
DATE (ilege-.)c TDAE 710
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MESSAGE MESSAGE
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SIGNED Ile< SIGNED
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR i•Av --.3 • FOFI
DAT 14 TIME 43: e 5 DATE I 7 0,7° IC TIME. dd.
Mr 6311r IAANe V1t2‘r M . m a vt t
OF OF
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RETURNED YOUR CALL SPECIAL ATTENTION AETUFNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
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SIGNED
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EFTA00182648
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR •T-
A
0 DATE 1127 inc '
M
C-11
OF pheitotivA OF
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UFFIED YOUR CALL SPECIAL ATTENTION' RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
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SIGNED 1154 SIGNED 1154
IMPORTANT MESSAGE IMPORTANT MESSAGE
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MESSAGE MESSAGE
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EFTA00182649
I IMPORTANT MESSAGE IMPORTANT MESSAGE]
FOR FOR
TIMEa.m.
DATE TIME DATE
M v M ve Vk
OF 1K v k..AL. 1-LAA) OF
MOBILE (56 6 - Gnc-1O )(ales PHONE/
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TELEPHONED PLEASE CALL TELEPHONED PI Pea CALL
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RETURNED YOURCALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL Anninom
MESSAGE MESSAGE
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IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR
A.M. AM
DATE 1 Z 0 TIME M DATE TIMF
1.4 t• ...C. :‘, C CONO le . 6.11
OF OF_
Ze
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MESSAGE MESSAGE
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EFTA00182650
I„, IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
FOR -Z - 1 • FOR
DATE
M
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TIME PM
OF OF Sa,f2.1, r•
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RETURNED YOUR CALL SPECIAL ArrefreoN RETURNED YOUR CALL SPECIAL ATTENIICN
S
MESSAGE MESSAGE
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C21.1
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SIGNED
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IMPORTANT MESSAGE IMPORTANT MESSAGE
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a MESSAGE MESSAGE
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EFTA00182651
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR
/ DATE t12 1 /O) TINE
1
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OF Of
PHONE/
MOBILE cx) \chow 44, v‘wy, jartY
P c4.3 I 7) 174 -4451
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION FIERJRNED YOUR CALL •SPECIAL ATTENTION
MESSAGE MESSAGE
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5:3o Ptik
SIGNED
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IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOB
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DATE TIME 4'zio es DATE
M \\C\ Z. M
OF Cf
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e E V 1) 274 -efirci- PHONE/
MOBILE 5 n 174 -4452-
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALI. SPECIAL ATTENTION
MESSAGE MESSAGE
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Ali , \ T. CO 61.1 \AAA S c4li.cj
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SIGNFD H04 SIGNED 118d
EFTA00182652
I IMPORTANT MESSAGE 1 IMPORTANT MESSAGE
FOR Mi.• .r
DATE 1/7 or TIME 10' lo
M 1 C C-11 Z.
OF gtVLZ
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P1
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TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MEteallr
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CA VI 6 I-
SIGNED la
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR
DATE I ..7
3 ..
0S.-.. TojE 491..00 Ctikt
I :
FOR
DATE TIME
2-%AM
M re lc t, b M _.
OF OF
PHONE( e ‘ 6 ;‘)
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661 --• I 51 L
P108R.
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TELEPHONED 'PLEASE CALL TELEPHONED PLEASE CALL -
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CAL:mutt/
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
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SIGNE
EFTA00182653
(IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR J E FOR e •
DATE
l aploC
In 4 v,e
TIME
M o sty
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DATE 217 /OS
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PHOBONE/
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PLEASE CALL TELEPHONED PLEASE CALL t-,
CAME TO SEE YOU WIU. CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CACALL _SPECIALATTENTION RETURFED YOUR CAU. SPECIAL ATTENTION
MESSAGE MESSAGE
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In 3108
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SIGNED 1184 SIGNED__Z -7 1184
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR
.T. L' t FOH P
DATE Z/31 05 TIME /9:12 6.m DATE 7/ 470 S TIME 5 citi
M M r"..77., A/ 0.2..id ..r/.//2
/
oF (.5 eq of /g/4/ 66.7- 46s/
PHONE/ PHONE/
MOBILE MOBILE
TELEPHONED PLEASE CAM TELEPHONED 4 PLEASE cAu.
CAME TO SEE YOU WILL CALL AGAIN CAME TOSEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL '--1 ;PECIAL ATTENTION
MESSAGE 1 7//0/e / r a g }if MoSSAft
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•
SIGNED it SIGNED
EFTA00182654
EFTA00182655