EFTA01247530

0 9 — Igo Condensed Transcript • IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, vs. CASE No. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF • VOLUME I October, 20. 2009 10:10 a.m. Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard ESQUIRE Palm Beach Gardens, Ft. 33410 www.esqulresoluttons.com 3501.172-001 CONFIDENTIAL Page I of 38 EFTA_00070807 EFTA01247530 • • • 3501.172-001 CONFIDENTIAL Page 2 of 38 EFTA_00070808 EFTA01247531 - Volume I October 20, 2009 1 3 IR na chicory cceer OF TIM FIFTRI26111 JOICTAL CIRCUIT 1 APPEARANCES' 111 AND FOR PAlM SIAM CCM', FLORIDA • CIVIL DIVISION CASK No.5132COSCAOTSCD/XXX/30 AS Plaintiff, 2 3 4 On behalf of the Defoxlant: ROBERT 0. CRITTON, JR.. ESQUIRE BURIMN CRITTON LIMIER & COLEMAN. LLP 303 Banyan Boulevard. Suite 400 JRFIRIT errotte. West Riatairda 33401 Phoe: Defendant. 6 7 On behalf of PORNO : A DITPGItlal vel)P1R=- 9 111044411. October. 20. 2009 10110 - 1,10 p.a. 10 11 12 00 'WS 13 %sported Sy: 14 Teresa IabaIon, RPR. PPR Notary Public. Stab of Florida 15 Neat Palt leach Office Job 16 17 On behalf or Wanda 19 20 21 On behalf M PMaLMt in reWmd Cabe No 08-80811 22 23 24 35 2 4 1 UNITED STATES DISTRICT COURT 1 • • • 2 3 4 SOUTHERN DISTRICT OF FLORIDA CASE No.06-CV-60119-CIV•MARRAMOHNSON 2 3 WITNESS INDEX ' " DIRECT CROSS REDIRECT RECROSS PIIe I, 6 1 JEFFREY EPSTEIN, Deist 7 9 Related cases 0 BY MRIn i5 190 08-80232, 08-80380. 93-8038I. 08-80904. 9 BY LEL 135 208 10 08-80993. WSW 1. 004/0893. 0943469. :o BY ma= 156 09-80591. 0940656. memex.09-elos2 II 11 BY MR. 173 12 12 DEPOSITION OF VOLUME I 13 14 II EXHIBITS Tuesday. Ocfcbts 20. 2009 15 1010 - 3:33 p.m as 16 16 11 11 NUMBER DESCRIPTION PAGE IS DEFENDANTS EX. I COPIES, COMPOSITE PHOTOGRAPHS 103 1 19 19 DEFENDANTS EX. 2 COMPO9TE FICNE MESSAGE BOOK 147 20 20 DEFENDANTS EX 3 COPY OF PHOTOGRAPH 162 21 Reported By: TINOS. Whalen. APR, FPR 21 22 WINO PROC. STIDO of Fbrkla 22 West Palm Beech Office Job is116991 23 23 Phone: 800.330.6952 561 659 4155 24 24 21 25 • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com CONFIDENTIAL 3501.172-001 Page 3 of 38 EFTA_00070809 EFTA01247532 IMIIM MID - Volume October 20, 2009 5 7 1 PROCEEDINGS 1 0 How long have you been employed by 2 3 4 Deposition taken before Teresa Whalen: Registered Professional Reporter, Florida Professional Reporter, and Notary Public In and for 2 3 4 Mr. Epstein? A It will be live years this November 17th. 0 So you started November 17th, 2004? A Yes. sir. • 6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein? - - 7 A Through an agency. 8 Thereupon, 8 0 What agency? 9 10 MIS) having been first duly sworn or affirmed. was examined 9 A It's Regal Domestics. to 0 And what was your position that you were tired 11 and testified as knows: 11 by Mr. Epstein la? 12 THE WITNESS: I do. 12 A Housekeeper- 13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness 14 MR Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Aro you familiar with 15 record what case INS is bang taken in? I noticed 15 that name? 16 it ire. versus Epstein. I don't know if anybody 16 A Yes. 17 cares to say who your clients me, what the case 17 0 And that person. I believe he represented that 18 style is or hi else for when she types it up. 18 he was also maybe a house manager. IS that correct? 19 MR I don't have a problem with 19 A Correct. 20 that. Are we doing initials? 20 0 Would he have been, at some point in time, 21 MR Yeah. Initials. 21 your boss or your superior? 22 MRS Okay. 22 A Yes. 23 BY MR. 23 0 That's somebody who you answered to, 24 0 All right. Will you state your name for the 24 Alfredo Rodriguez? 25 record. 25 A (Nodang head). Sometimes 6 1 A Ma • 1 You have to say yes or no. you 2 2 card nod your hoed. 3 3 BY I.E. 4 4 0 Yes? 5 5 A Yes. 6 6 MR. CRITTON: No. no. Site said SOMNIMOS. 7 7 then yeingaijaper Muth. 8 MR. . laden put anything in her 9 9 mouth. I don't want the record - 10 10 MR. CRITTON: Let me take It back. You said 11 11 yes. but she started to say something before she 12 12 vas Interrupted. 13 13 BYMi 14 14 O That's line. You cal answer the question. 15 15 then well irettua On the deposition. 16 16 : Did you want to explain that 17 17 further? 18 18 THE WITNESS: Because we wore supposed towed( 19 O Have you ever lived at Jeffrey Epstein's 19 together. Nit he was bossy. he was bossy. 20 location of 358 El Brillo Way? 20 BY I.E. 21 A No, sir. 21 0 Okay. Have you ever had your deposition taken 22 0 Whore are you currently employed? 22 before Ike this? 23 A Mr. Epstein. 23 A No. 24 0 And what address do you report to work? 24 0 All right. Well, there is one oourt repater, 25 A 358 El Brae Way. 25 n very easy In casual conversation to nod your • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 • ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vnvw.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 4 of 38 EFTA 00070810 EFTA01247533 - Volume I October 20, 2009 9 11 I head or shake your head, and she can't take that down. 1 that it's clean and appropriately. what's this... • 2 3 4 5 A All right O It's also very easy to say uh-huh or huh-uh, but it kind of looks the same on paper, so you can't do that either. I'm going to wait until you finish your 2 3 4 O And as I understand this property, there is a main house and then there's also a staff house on the property. is that right? A Yeast 6 answer, and you have to wait until I finish my question, 6 O And when the guests would come over, would you 7 because if we talk over one another, then the court 7 stay in the main house. or would you go to the staff 8 reporter can't get it down. 8 house? 9 A Okay. Yes, sir. 9 Can we get a time frame to the 10 O All right. So if you don't understand the 10 question? n questiOn, sell me you don't understand and I'll try to 11 BY MR.- 12 ask a better question. 12 O Over the last five yews while you worked 13 A Yes. 13 there. 14 O Okay. So you were hired in November ol 2004 14 A I usually stay in the staff house and do the 15 to be the housekeeper for Mr. Epstein? 15 laundry, then I go to the kitchen and then tidy the 16 A Yes. 16 kitchen. 17 0 And when you were hired, who exactly hired 17 O You were hired in November of 2004. and what 10 you, who — let me strike that. 18 were your hours that you worked there back in November 19 When you were hired to be the housekeeper for 19 of 2004 when you were hired? 20 Mr. Epstein, who did you interview with? 20 A Eight to five. 21 A Ms. Maxwell. 21 O How many days a week? 22 O Is that Ghislaine Maxwell or just 22 A Depends. 23 Leine Maxwell? 23 O Flow would the schedule be relayed to you? 24 A Ghislaine Maxwell. 24 A When Mr. Epstein is there, then I'm supposed 25 O And where did the interview take place? 25 to report, but usually it's live days a week. 10 12 • 1 A At 358 El Belo Way. 1 O So am I correct in understanding that there 2 O And what did Ms. Maxwell and you speak about 2 was one schedule when Mr. Epstein was in town, and the 3 prior to your being hired as the housekeeper'? 3 schedule may be a little bit different it Mr. Epstein 4 A My duties. 4 was out of town? O And what did she tell you your duties would 5 A Yes, sir. 6 be? 6 O All right. Tell me the differences when 7 A To tidy, to make beds, do laundry 7 Mr. Epstein Is in town versus when Mr. Epstein was not 8 O Did she tell you what would take ptace in the in town. 9 house on a day-to-day basis? 9 A If he stays like three or four days, then I'm 10 A No. 10 supposed to be there. and then the house is to be 11 O So going into that position, you had no idea 11 cleaned. And then when they do not come, then I can 12 who the guests would be or who the people Coming in the 12 either go there, or I'm gven free days off. 13 house would be, or what would generally go on? 13 Cr Three days off? 14 A Can you simplify the question? 14 A No. A free day. 15 O Sure. When you talked about with 15 o Oh. okay. But typically back in 2004 when you 16 Ghlslaine Maxwell at this interview, your duties being 16 were hired, you worked an average of about five days a 17 you would make the bed and tidy up, did she also tell 17 week; is that correct? 103 you that there would be a lot of guests, there would be 18 A Yes. 19 a few guests, did she talk to you about that at all? 19 o All right. And I guess by the way that you're 20 A She mentioned Petri there are guests, we 20 explaining it, of Mr. Epstein was in town for a longer 21 have to, like, you know, prepare the room, and, what's 2L period of time, you may work more than five days. and if 22 this. attend to the guests. 22 Mr. Epstein was not in town, you may work less than five 23 O And what did you understand that to mean that 23 days? 24 you have to attend to the guests? 24 A YOS. 25 A You have to prepare the room and see to it 25 o Okay. Did you ever talk to Mr. Epstein prior Toll Free: 866.709.8777 Facsimile: 561.394.2621 • 0 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.eSqUiresOlutiOns.com 3501.172-001 CONFIDENTIAL Page 5 of 38 EFTYL00070811 EFTA01247534 - Volume I October 20, 2009 13 15 1 • 1 to being hired? 0 Did she tea what you would be paid at that 2 A No. sir. 2 time? 3 O Where did this meeting, within the house where 3 A Not yet. 4 did the meeting with Ghislaine Maxwell take place? 4 0 Did you show up that Saturday? I guess that's A In the living room. 5 November 17th of 2004? 6 O Aside from telling you that you were going to 6 A No, that's not. 7 be required to make the beds and just generally tidy up, 7 0 No. Was it prior to November 17th of 2004. or did she specify anything else that you would be required 8 after? 9 to do? 9 A After. 10 A No. 10 0 Okay. The interview that you first went to 11 11 was November 17th. 2004 with Ms. Maxwell; is that the 12 12 date that you gave us? 13 13 A I cannot remember. 14 14 0 The only reason I'm using that date is I 15 15 believe the question I asked was when did you start 16 16 working for Mr. Epstein, and I thought the date that you 17 17 gave me was November 17th. 2004. 18 18 A Yes. 39 19 0 Okay. And in the course of this whole thing. 20 20 it sounds like you interviewed with Ghislaine Maxwell. 21 21 there were other interviewees, you received a call and 22 22 you were asked to try out on a Saturday? 23 23 A Yes. 24 O And when you went to the interview. Obviously 24 0 And where does that Saturday fall in related 25 youtre going to this very big house and you talked to 25 to November 17th, 2004? 14 16 1 2 3 4 Ghislaine Maxwell. right? A Yes. 0 And did you decide right then that you Med this and that you were going to change professions and 2 3 4 A When I accepted the fob offer. 0 Okay. And did they tel you at that time sten you accepted the job offer how much you WOW Going to he paid? • 5 you were going to be his housekeeper? s A Yes. 6 A No. 6 0 What was that? 7 0 Okay. Then walk me through that, how did you 7 A It was 32.000 per annum. 8 go about eventually accepting the position? 0 And haS your salary increased ovor time? 9 A I didn't expect to be hired. because there 9 A Yes. sir. 10 were other interviewers (sic). interview people that 10 0 And can you walk us through the increments of 11 were to be interviewed. 11 increase n your salary? 12 0 Okay. 12 A It was PronliSed yearly increase' 13 A And then I receive a call from Ms. Maxwell it 13 0 By whom? 14 I like. I can do a try-out. 14 A Ms. Maxwell 15 0 Okay. Did the tell you how long this try-out 15 0 Was that at the lime whon you wore 16 period would last? 16 interviewed, or look the job? 17 A No. 17 A Yes. sir. 18 0 And what did you tell her when sho made that 18 0 Did the promise you what your yearly Increase 19 offer for you to try out? 19 would be? 20 A I told her that I am still taking care of this 20 A No. 21 patient, so she said if you like, you can come Saturday 21 0 And have you received a yearly increase every 22 and try it. 22 year? 23 0 Okay. And what did you tell her, did you 23 A Idid. 24 accept that? 24 0 And what has that yearly increase been? 25 A Yes,Idid. 25 A Up to 42. • Toll Free: 866.709.8777 Facsimile: 561.394.2621 0 Suite 600 ESQUIRE uMtGW.Cw 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquireSolutions.com 3501.172-001 CONFIDENTIAL Page 6 of 38 EFTA_00070812 EFTA01247535 - Volume I October 20, 2009 17 19 1 0 Today? 1 O Okay. So legs talk about lhat. Back in • 2 3 S A Yes. 0 So you're making $42,000 today. and that's the meet that you've made over the five-year period you've worked for Mr. Epstein? 2 3 4 5 November o12004, you were to working 8:03 a.m. to 5:00 p.m. And when Cod that schedule change from 8:00 5:00? A When? When the house was renovated. 6 A Yes, sir. 6 O When was that, do you remember the year? 7 O At the lime when you -- when we took 7 A 2006. 8 Alfredo Rodriguez's deposition, he described you as a a O Okay. 9 very religious Catholic woman. Does that accurately 9 MR. CRITTON: I'm sorry. '06? 10 describe you? 10 THE WITNESS: '06. 11 MR. CRITTON: Let me just object to the form. 11 BY MR. - 12 You can answer the question If 12 O So from November 2004 through '06, I'm correct 13 you understood it. 13 in presumi ng that your schedule was an average cativo 14 THE WITNESS: I am a Catholic and I go to 14 days a week from 8:00 a.m. to 5:00 p.m.? 15 mass. 15 A At that time I go nine o'clock. I go to the 16 BY MR. 16 house at nine o'clock. 17 O Is that something you go to regularly? 17 O Starting in 2006? 18 A III have time. I go regularly. 18 A Yes. 19 O When do you normally go to mass? 19 O So when your schedule changed from 8:00 ti 20 A Sunday masses and weekdays. 20 5:00. in 2006 you started going to the house, 21 o How many weekdays? 21 Jeffrey Epstein's house, at nine o'clock? 22 A 111 can, every day. 22 A Yes, sir. 23 o And in the five-year period that you've worked 23 O And you would stay until what time? 24 for Mr. Epstein, have you tried to go every day it you 24 A Sometimes 5:00, sometimes later. 5:30. 25 could? 25 o Would that depend on what needed to be done? 18 20 1 A Yes. • 1 2 3 4 A No. 0 In a typical week would you normally go on Sunday to mass? A Yes, sir. 2 3 4 O How have you received your money. has it been by Check, by cash, in terms of payment from Mr. Epstein? A It's directly deposited to my bank 5 0 And how many days during the week will you 5 O Do you know who directly deposits your money? 6 also attend mass? 6 A MP? 7 A If the schedule permits, then Igo, but if 7 O Yeah. Mother Its Ghislaine Maxwell or a not, then I don't go. 8 corporation or Jeffrey Epstein. do you knew who the 9 0 So is there a way that you could 9-IVO me an 9 direct depositor is of your check? 10 average of how many times a week that you go during the 10 MR. CRITTON: Form. 11 week to mass? 11 THE WITNESS: Mr. Epstein. 12 A This lime? 12 BY MR.- 13 0 Right. Yeah. I guess today, these days. 13 O Okay. Over the five years that you have been 14 A I attend Sunday masses only. 14 working at Mr. Epstein's house, how many conversations 15 0 And back in 2004, vmen you first started with 15 have you had directly with Mr. Epstein? 16 Mr. Epstein? 16 A What's this, what year? 17 A I filed to go it I have the time. sir. 17 O Wel. in the last five years, how many 18 O Was there ever a time that you went every day? 18 conversations have you had &cc* with Mr. Epstein? 19 A No. 19 MR. CRITTON: Form. 20 0 But your testimony is that if time permitted, 20 THE WITNESS: The past year it's just good 21 you tried to Go every day? 21 morning, how aro you. you're doing a good job. 22 A Yes. 22 BY MR. - 23 0 Is there a reason why now these days you only 23 O Okay. How was it prior to that, did you talk 24 attend on Sundays? 24 to him more? 25 A Because my time schedule has changed. 25 A This time more. • 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 31410 www.esquiresolutions.com CONFIDENTIAL 3501.172-001 Page 7 of 38 EFTA_00070813 EFTA01247536 - Volume I October 20, 2009 21 23 1 • O Now you talk to him more? 1 A Yes. 2 A Because I serve him breakfast. so... 2 O When did you talk to Lyn Fontanilla about 3 O And is that an additional responsibility that 3 4 you didn't have before? 4 A It was just through the conversation. A Yes. 5 O What would cause you to be in a conversation 6 O In the live-year penod that you've worked 6 with this person in New York? 7 there, can you name for me all of the other employees 7 MR. CRITTON: Form. 8 who have worked at the Jeffrey Epstein house? 8 THE WITNESS: She calls me, I call her. 9 A After Alfredo Rodriguez left, there was 9 BY MR. 10 Jerome. the gardener, and now it's Yanusz. 10 O You're friends? 11 O And those are the house managers'? 11 A Yes. 12 A Yes. 12 O Do you still talk to her today? 13 O And then you work there? 13 A Yes. 14 A Right. 14 O And does she work for Mr. Epstein as well, to 15 O Aside from yourself. Jerome. and Janusz. was 15 your knowledge? 16 there anybody else that you can remember working at the 16 A She does. 17 house in the past live years in any position? 17 O And does Jojo, her husband, also work for 18 A Yes. 18 Mr. Epstein as well? 19 O Who else? 19 A Yes, sir. 20 A 20 O Where do they work? 21 O That's 21 A In New York. 22 A Yes. 22 O At Mr. Epstein's house in New York? 23 O What does she do there? 23 A Yes, sir. 24 A She's the personal assistant. 24 O And have you talked with them about your 25 O Personal assistant to whom? 25 duties and has she talked to you about her duties? 22 24 • 1 A Mr. Epstein. 1 A YeSi sir. 2 O And as his personal assistant, what have you 2 O Arid your duties are similar to Lyn's duties in 3 observed her to do for him? 3 New York? 4 A Can you rephrase your question? 4 A No. Because that's a bigger house than... 5 O I can try. You sad that she's his personal 5 O Palm Beach? 6 assistant. What does that mean, what does she do? 6 A Yes, sir. 7 A Order things that I need. Ordi whats this. 7 O IS It your understanding that you know, 8 O So it's your testimony that has 8 we're going to gel into the past two years where 9 been. tor the past the years that you ve worked there. 9 Mr. Epstein has either been in jail or he's been on 10 has been somebody that you have observed to order things 10 house arrest in Palm Beach, so I'm going to ask you 11 that you reed? 11 first for the first three years that you worked there 12 A If I need something. than I go to ask MI 12 and Mr. Epstein was traveling, was Mr. Epstein spending 13 O Oka . What other things have you seen 13 the majority of his time in Palm Beach or in New Yolk or 16 do for Mr. Epstein? 14 elsewhere. il you know? 15 A I have not, that's the any thing I know. 15 A He comes we don't know the schedule, we 16 O Who told you that is 16 receive a call, then we prepare, he's coming. 17 Mr. Epste,rts personal assistant? 17 O You say we receive a call. Who receives the 18 A Coworker. 18 calf? 19 O Who is that? 19 A Esther Alfredo or Janusz. 20 A In New York. 20 O Depending on who the house manager is at the 21 O What's that person's rerne? 21 time? 22 A Lyn. 22 A Yes. 23 O Lyn who? 23 O And the call comes from whom, from Dhislaine 24 A Fcetanala. 24 or from Jeffrey Epstein? 25 O Is that Jojo's wife? 25 A I don't know. • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE •••Insw•erGaloCeeptay 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 8 of 38 EFTA_00070814 EFTA01247537 - Volume I October 20, 200c; 25 27 1 O Okay. What's your understanding of Lyn's role 1 MR. CRITTON Form. • 2 3 4 5 In Jeffrey Epstein's life up in New York? A She's housekeeper, too. O And your understanding of Jojo's role' A A driver. 2 3 4 5 BY MR. O BY MR.- Do you understand his question? 6 O Does he also serve as a house manager, similar 6 O Do you understand my question? 7 to the way Alfredo Rodriguez was in Palm Beach? 7 Do you know that is whim he's A No. 8 asking you? 9 O Whon you say a driver, who does he drive. it 9 THE WITNESS: Yes. 10 you know? 10 I think the question was do you 11 A Mr. Epstein. 11 know whether or not Mr. Epstein pled guilty to 12 O All right. Mr. Epstein obviously hasn't been 12 comes. 13 in New York for quite some time: isn't that your 13 Was Mal the Ion? 14 understanding? 14 MR. Sure. 15 A Yes. 15 MR. CRITTON: That was not his question. 16 O So Jcicts still employed up In New York as a 16 BY MR. - 17 driver for Mr. Epstein, right? 17 O Okay. Well, do you realize that Mr. Epstein 18 A He also does housework, helps Lyn. 18 pled guilty to crimes? 19 O Have you discussed with Lyn whether or not 19 A Plead guilty? From the news. 20 young girls visit the house in New York? 20 O Okay. So when you say you saw the news, which 21 MR. CRITTON: Form. 21 is whore this portion or our discussion began, aro you 22 You can answer that. 22 referring to the news related to Mr. Epstein and the 23 BY MR. 23 charges, the criminal charges or criminal investigation 24 O He didn't like the loan el my question so he's 24 surrounding him; is that the news you're talking about, 25 able to object. but you can still answer. 25 A Yes. 26 28 • 1 2 3 4 You can still answer If you understand the question. BY MR. THE WITNESS: No. 1 2 3 4 O Okay. So when that came out are we talking about 2005, 2008, something in that area? BY MR.- MR. CRITTON: Form. O YouVe never talked to Lyn about young girls 5 O Is that the first time you remember seeing the 6 being in the house in New York? 6 news on that subject? 7 A When the news came up, so that's how we 7 MR. CRITTON: Form. 8 talked. 8 THE WITNESS: I cannot remember. 9 O What do you mean, when the news came up? BY MR. - 10 A Whenever there was something on the news on 10 O All right Whenever it was, you bilked to Lyn 11 TV, then that's how we come to talk about it. 11 about that? 12 O Okay. When you say something came on the 12 A No. I don't usually talk about it She calls 13 news, you're talking about In terms of a criminal 13 and how aro you doing. then oh, like that. 14 investigation of Mr. Epstein? 14 O Okay. And what was the discussion as It 15 MR. CRITTON: Form. 15 related to girls in either the New York house or the 16 THE WITNESS: Criminal? 16 Palm Beath house between yoursetl and Lyn? 17 BY MR. 17 MR. CRITTON: Form. 18 O Well, you realize that Mr. Epstein went to 18 THE WITNESS: She talks to me when she read in 19 Jail, right? 19 the news or she saw on the computer. 20 A Yes. 20 BY MR.- 21 O And that was after pleading guilty to some 21 O Okay. And does she toll you about young girls 22 crimes. You realize that, right? 22 being in the New York house? 23 MR. CRITTON: Form. 23 MR. CRITTON: Form. 24 BY MR. 24 THE WITNESS: Sho did not 25 O I mean, that's why you go to jail. 25 Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 9 of 38 EFTA_00070815 EFTA01247538 - Volume I October 20, 2009 29 31 • 1 BY MR 1 0 All right. And when is the first time that 2 0 Okay. Have you talked to Jojo about that? 2 you saw these girls come to the house' And by 'these 3 MR. CRITTON: Form. 3 gins,' I'm talking about the girls that you were told 4 THE WITNESS No. 4 were here to give massages. 5 BY MR. MR. CAUTION: Form. In working there for live years. at least the 6 THE WITNESS: I cannot remember specifically 7 time period pnor to Mr. Epstein going to jail. while 7 the day and the time. 9 you were there you recognized a kit of young grks in 8 BY MR.- 9 the house. right? 9 0 These massages take place every day that 10 MR. CRITTON: Form. proticate. le Mr. Epstein's in town, right? 11 THE WITNESS. Young girls? 11 MR. CRITTON: Form, leading 12 BY MR. 12 THE WITNESS: Not always. 13 0 Are you asking -- 13 BY MR. 14 A They are females. 14 0 Okay. So it the testimony in this case by 15 0 Where rid the females come from, did you know") 15 other witnesses has been that Mr. Epstein has these 16 A I don't know. 16 gifts over at his house to give him a massage every day 17 Q Do you know why they were at tie house? 17 than you would disagree with that testimony? 19 A For massage. 18 MR. CRITTON: Fern. improper question. 19 MR. CRITTON: Form. 19 THE WITNESS: Because there are times that I'm 20 BY MR. 20 not there in the house. 21 0 When is the first time that you heard about 21 BY MR. • 22 females corning to Mr. Epstein's house for massages? 22 0 Okay. Every day that you are there in the 23 A Maybe two weeks after I started working. 23 house and Mr. Epstein is also there. girls come over m 24 0 Al light. Sol you started November 17th of 24 his house to give him massages, as you understand it? 25 2004, then sometime around early December of 2004. you 25 MR. CRITTON: Form, leading. 30 32 1 2 3 4 heard about young girls or girls coming to Mr. Epstein's house for the purposes of giving him a massage' BY MR. MR. CRITTON: Form. 1 2 3 4 BY MR. O Is trial a fair statement? MR. CRRTON: Form. loading. Also can we gel a time frame? • • 0 Is that right? 5 You mean now, or prior" 6 A Young girls? Theyre females. and I was told 6 BY MR. - 7 they come to do massages. 7 O Between 2004 and the lime that Mr. Epstein • Who told you that? a went to jail in 2008. 9 A Alfredo. 9 MR. CRITTON: Same objection. 10 0 Alfredo told you that the girls did massages? 10 Do you understand the question? 11 A Ho told me when I started there that there are 11 THE WITNESS: No. 12 massages to be done, and then that's when I heard it 12 BY MR.- 13 first from him. 13 O Okay. Between 2004 and the time that 14 0 And then did you witness the girls come over 14 Mr. Epstein went to jail in 2008, on occasions whore you 15 that you were told were there to give massages? 15 were in the house and Mr. Epstein was in town, is it a 16 MR. CRITTON: Form. That she actually saw, is 16 lair statement that girls came over to give him a 17 that what you're -- let me just object to the form. 17 massage every day? 18 MR. I said the word saw. so I mean. 18 MR. CRITTON: Form. 19 there's no. We. mixing words there. Yes. that 19 THE WITNESS: Between what year again? 20 she actually saw. 20 BY MR.- 21 MR. CRITTON. There's a distinction between 21 O When you started working and the time when 22 seeing the grls coming and seeing the massages. 22 Mr. Epstein went to grit 23 BY MR. 23 MR. CRITTON: Same objection. 24 a Did you See the girls come to the house', 24 THE WETNESS: Yes. 25 A Sometimes. 25 • T011 Free: 866.709.87 77 Facsimile: 561.394.262 1 0 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 10 of 38 EFTA_00070816 EFTA01247539 - Volume I October 20, 2009 33 35 1 BY MR. - 1 whets this, to their appearances or to their what their 2 O Al right. And Mien you wore in the house and 2 attre is. 3 Mr. Epstein was also in town, would there be usually one 3 0 All right. Haven't you made a comment lo 4 massage per day. or two massages, or more? 4 Alfredo Rodriguez in the past that those girls that are 5 A Maybe three. S coming over to give massages are too young? 6 O Okay. So on a typical day when you were in 6 MR. CRITTON: Form. 7 town, you were in the house and Mr. Epstein wash town. 7 THE WITNESS: I cannot remember. B irs your testimony that he would have an average of 8 BY MR.- three massages a day? 9 0 Isn't that something that you have believed? 10 A Not average. I'm I want to correct that. 10 MR. CRITTON: Form. 11 o Correct it. please. 11 THE WITNESS: What you mean. believe? 12 A What's this, average? Can you... 12 BY MR. 13 o Okay. I think I see what you're saying. 13 0 Isn't that something that you have thought in 14 Some days there would be two and some days 14 your head, these girls that are coming over to the house 15 there would be three, and you don't want to commit to an 15 that are supposedly giving Mr. Epstein massage are Soo 16 average? 16 young? 17 A Yes. Because sometimes I'm not aware. I'm in 17 MR. CRITTON: Form. 18 the staff house. is THE WITNESS: At my ago, these people are 19 O Okay. Al right. I understand what you're 19 young to me. so... 20 saying. 20 I'm past sixty. so they are young. 21 But the days when you are In the house and 21 BY MR. 22 Mr. Epstein is there. you see days when there are two 22 0 Well, haven't you also made the statement to 23 massages per day and some days when there are throe 23 Mr. - we'l come back to that statement. 24 massages per day? 24 When these girls would come in the house, you 25 A Yes. 25 said sometimes you would answer the door, right? 34 36 1 0 All right. And these people that are coming 1 MR. CRITTON: Form. 2 over that you were told by Atfredo Rodriguez are there 2 BY MR.- 3 to give Mr. Epstein a massage, isn't it typical that 3 0 And you would see these -- 4 they would arrive by taxicab' 4 MR. CRITTON: Wan. Can INA.. 5 MR. CRITTON: Form, leading. s II you use the word 'female,' I'm not gang to 6 THE WITNESS: I did not know about that. 6 object to most of your questions, as opposed to 7 BY MR. 7 'girls.' because I don't Mow what you mean by 8 O Oo you know how any of these one more that. So I'm going to keep objecting. 9 question before I ask the next one. 9 Whatever you want. I just... 10 Are they always female masseuses? 10 MR. Yeah, I know. I'm just talking 11 A Yes. 11 about the gds that wotid come over is give 12 O And are you aware of how these female 12 massages. 13 masseuses would arrive to Mr. Epstein's house between 13 MR. CRITTON. It you want to cal them 14 the time you started working and the time he went to 14 ferrules. I have no el:Section. It you call them 15 jail? IS gins, I don't know what that means. Ferrules, I 16 A No. Because I'm inside the house. 16 do 17 0 Okay. Can you describe these females for us? 17 MR. Okay. 18 MR. CRITTON: Form. 18 MR. CFUTTCN I m not telling you how to 07 19 THE WITNESS: I don't pay attention to their, 19 11. I'm just telling you -- 20 what's this, because I just do my job. open the 20 MR. No, no. I appreciate it. 21 door if I'm what's this. I hear the doorbell 21 BY MR. 22 rang. 22 0 The females that would come over to give 23 BY MR. 23 massages. calm times you would answer the MO( when the 24 0 Okay. 24 door rang? 25 A So I don't eke, really pay attention lo. 25 A Sometimes. • Toil Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com 3501.172-001 CONFIDENTIAL Page 11 of 38 EFTA_00070817 EFTA01247540 - Volume I October 20, 2009 37 39 0 Okay. And sometimes who else would answer the 1 that rotated. were talking about fifty, a hundred, two 2 3 4 • dew? A Altred0. 0 And what door would the females enter through? A The kitchen door. 2 3 4 5 hundred (afferent females that you saw? MR. CRITTON: Form THE WITNESS. I 00 not count • BY MRa 6 0 And is that the door that other guests would 6 0 You saw a lot of different female faces that 7 also enter through? • were supposedly there to give him a massage. nghl7 8 A Sometimes. a MR. CRITTON: Fern leading. 9 0 Why was that door chosen as the door for the 9 THE WITNESS: Sometimes the same female comes 10 female masseuses to enter through, do you know? 10 back. so... 11 A No. I don't. 11 BY MR 12 0 What would happen, what would be the next step 12 0 And other times It would be different females? 13 as these females would enter through the kitchen door? 13 A Yes. 14 A I don't know, because I just let them and then 14 0 All right. And can you approximate the age of 15 gelnish my work. is these females that would come over to the house/ 16 0 Okay. And then would their next contact be 16 MR. CRITTON: Form. 17 with 17 THE WITNESS: load not ask their age. 18 MR. CRITTON: Form. 18 BY MR. 19 THE WITNESS: If I see= then yes. But I 19 0 You saw they face and you saw their 20 just let them stay in the kitchen and then go to 20 appearance. Would you be surprised if some of these 21 the staff house and continue the laundry. 21 females were thirteen years Old? 22 BY MR. 22 MR. CRITTON: Form You're asking her to 23 0 Isn't it your understanding that these females 23 speculate and guess. 24 were on a schedule as to when 10 cone over to give 24 THE WITNESS: I did not see any thirteen years 25 Mr. Epstein a massage? 25 38 40 • 1 MR. CRITTON: Form. BY MR. 2 THE WITNESS: No. I don't know. 2 0 Okay. Would you be surprised if some of those 3 BY MR. 3 girls were fourteen years old? • 0 Okay. Well, each time that the girls would 4 MR. CRITTON: Same objection. 5 come over to give Mr. Epstein a massage, he would be up 5 THE WITNESS: Fourteen? I don't know. 6 in his master bedroom already: is that correct? 6 BY MR. 7 MR. CRITTON: Form. • 0 Could they have been fifteen years old? 8 THE WITNESS: I don't know. • MR. CRITTON: Same objection. 9 BY MR 9 THE WITNESS: Maybe more than that. 10 0 In the period of time between 2004 when you 10 BY MR. 11 started working and when Mr. Epstein went to jail. can la 0 Maybe more than that? 12 you approximate or estimate the number of these females 12 A Yeah. 13 that would come over to Mr. Epstein's house to allegedly 13 0 But maybe less than that? 14 give him a massage? 14 MR. CRITTON: Form. 15 A No. THE WITNESS: I don't know. 16 0 Are we talking more than fifty, more than a 16 BY MR. 17 hundred? 17 0 The truth is, you don't know how old these 18 MR. CRITTON: Form. 18 females were, but these females that were there to give 19 THE WITNESS I did not count. 19 him a massage were young, in your mind? 20 BY MR. 20 MR. CRITTON: Form. 21 0 But there were many cOtterent girls, right? 21 THE WITNESS: Some look young, but then they. 22 MR. CRITTON Form. 22 what's this? 23 THE WITNESS: Many females. 23 BY MR 24 BY MR. 24 0 You knew that something that was going on 25 0 It was not like there were only ten females 25 there was not right. isn't that true? Toll Free: 866.709.8777 0 Facsimile: 561.394.2621 Suite 600 • ESQUIRE 4440 PGA boulevard Palm Beach Gardens, FL 33410 www.esquIresolutIons.00m 3501.172-001 CONFIDENTIAL Page 12 of 38 EFTA_00070818 EFTA01247541 - Volume I October 20, 2009 41 43 1 MR. CRITTON: Form. argumentative 1 THE WITNESS: I did not find any sex toys. • 2 3 4 5 MR. coming over. BY MR. Jack. we're catching some music (Brief recess in proceedings.) 2 3 4 5 BY MR. 0 You never, in your employment with Mr. Epstein, found sex toys in the room after these females left from giving him a massage? 6 O As you saw these young females coming over to 6 A There was only this. like I thought it was for 7 Mr. Epstein's house to give him a massage. you knew in 7 massage. Mars il, Mars what I saw. 8 your heart of hearts that something was wrong? 8 0 Okay. Have you ever — are you familiar with 9 MR. CRITTON: Form. argumentative. 9 the armoire that is in Mr. Epstein's room, bedroom? 10 THE WITNESS: I was told that theyre going to 10 A Yes. 11 do a massage. 11 0 And have you ever put items away In that 12 BY MR. 12 armoire? 13 0 I realize you were told that. Okay. ISM it 13 A No. sir. 14 true that each of those girls was then led upstairs to 14 0 If Alfredo Rodriguez testified that you and he 15 Mr. Epstein's bedroom; that was the routine. right? 15 had a conversation about the sex toys in Mr. Epstein's 16 MR. CRITTON: Form. predicate 16 bedroom and your comment being it's not right -- 17 THE WITNESS: I don't know. When I'm there. 17 A No, sir. 18 then I most of the time I just go to the. what's 18 0 mars not something you would agree with? 19 this, to the staff house. 19 A We did not converse about sex toys. 20 BY MR. 20 0 Have you talked to Mr. Epstein today about you 21 0 When the girls would arrive — when the 21 having your deposition today? 22 females would arrive. you would go to the staff house? 22 A No, sit 23 MR. CRITTON: Form. 23 0 And this is your attorney who is hero next to 24 THE WITNESS: First sometimes I would offer 24 you? 25 them drinks, and then, whets this. 25 A Yes, sir. 42 44 O And is that somebody that you paid to be your • 1 2 3 4 BY MR. 0 MI right. So did you talk to some of these females? A No. Just like you care for water or some 1 2 3 4 attorney? A bleak. O That's somebody that Mr. Epstein has paid to 5 &inks, soda or something. 5 be your attorney? 6 0 All right. Cid you ever discuss religion with 6 A Yes. 7 any of these females? O When you were hired, did you sign any A No, sir. 8 agreement of oonfidentiakty that you wouldn't talk 9 0 When these females would go upstars, how long 9 about the matters that happened within the house? 10 would oath typically stay upstairs with It. Epstein? 10 A Yes, sir. 11 MR. CRITTON: Form, predicate. 11 O When did you sign that agreement? 12 THE WITNESS: I don't know, but I was told by 12 A When I received papers to sign for like my 13 Alfredo that it would take one hour. 13 evaluation, all the forms needed for employment. like 14 BY MR. 14 tax forms. 15 0 All right. And when the females would leave, 15 O Okay. And do you have a copy of that 16 wasn't one of your reSPonstilities to dean the room 16 agreement? 17 where the massage lack place? 17 A Maybe in my house. 18 A Yes, sir, to tidy. 18 O That's something that you think was provided 19 0 To bdy? 19 to you, or was the only copy kept with Mr. Epstein or 20 MR. CRITTON: Form. 20 Ms. Maxwell? 21 BY MR. 21 A We wore given duplicate, duplicate copy. 22 0 And In doing so, isn't it true that many CMOs 22 O Well, lot me toll you that I resent three 23 after these females lob, you found vibrators and sex 23 girls that in this case aro■ and 24 toys scattered on the floor and in the roan? 24 who were three of the girls that you and I have been 25 MR. CRITTON: Form. 25 talking about as females that went to Mr. Epstein's Toll Free: 866.709.8777 Facsimile: 561.394.2621 • Suite 600 ESQUIRE Aitast4tetiaiteCominr 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.corn 3501.172-001 CONFIDENTIAL Page 13 of 38 EFTA_00070819 EFTA01247542 - Volume I October 20, 2009 45 47 • 1 house to give him massages. Okay. Would it surprise 1 years old? 2 you to know that when they went to his house they were 2 MR. CRITTON: Form. 3 as young as thirteen, fourteen, and fifteen years old? 3 THE WITNESS' I do not know about that. 4 MR. CRITTON: Form. 4 BY MR. EDWARDS: 5 THE WITNESS: I didn't know, sir. 5 0 Okay. And after this line of questioning 6 MR. CRITTON. Asked and answered. 6 related to things that happened in Mr. Epstein's bedroom 7 BY MR. 7 dial were actually not massages at all, does this help 0 Would it surprise you to know that once inside 8 to refresh your recollection as to the sexual toys or 9 his bedroom, he instructed them each lo get naked? 9 devices that you have found in his bedroom? do A 111d not. 10 MR. CRITTON: Form. 11 MR. CRITTON: Let me just object to the form. 11 THE WITNESS: I only found one, that massage. 12 You're asking her to speculate on something she 12 I thought it was a massage thing. 13 knows nothing about. It serves no PuthoSe. It's a 13 BY MR. EDWARDS: 14 great argument, but it serves no purpose. 14 0 All nght. 15 MR. I know you're not happy with the 15 A You know that thing, and then I thought it's 16 line d questioning, you do this every time in 16 for -- that thing I only see. 17 deposition. 17 MR. CRITTON: Just so the record is clear, I 18 MR. CRITTON: But it serves no purpose, its is think we all agree that she look her hand and 19 never going to be admissible whether she's 19 like -- 20 surprised or not. It's like saying. you know, 20 MR. EDWARDS: She thought it was a back 21 would it - well, never mind. 21 massager. 22 You know, would it surpnse you that the 22 MR. CRRTON: Probably was a back massager. 23 Afghan election •- 23 MR. EDWARDS: Give me a break_ 24 MR. Are you trying to make this line 24 MR. CRITTON: No. You want to argue sex toys. 25 of questioning go on longer? 25 she's saying bath massager. Just let her testily 46 48 2 3 4 MR. CRITTON: No. But its just painful Ask her stuff that she knows. MR. I know it's painful. MR. CRITTON: I could care less one way or the 2 3 4 as distinct from argumentative BY MR MR. MR. CRITTON: Cathy. I'm letting her testily. • S other. It's just a waste of both our times. 5 0 The only thing that you found in his bedroom 6 MR. YOlffe Setting Paid lot it No 6 was in the shape of something that you believed to be a 7 defense attorney ever makes this argument on the 7 back massager; Is that fair? • record. a A Yes, sir. Yes. 9 MR. CRITTON: You know what. I get paid by a 9 0 Okay. Who was the deem° lady or 10 lot of people, and I don't need to do frivolous 10 housekeeper prior to you, do you knot?? 11 things in my mind, I'd rather just go home. 11 A They have a cleaning crew. 12 THE WITNESS: I don't know. 12 0 Prior to you? 13 MR. Okay. 3 A Yes. 14 Do you understand the question? 14 0 To your knowledge. has anybody ever left the 15 THE WITNESS: Yeah. I do net know anything is house, meaning left the employment or Mr. Epstein 16 about that part_ 16 because of anything that was taking place in the house? 17 MR. CRITTON: From the last time I objected, 17 A NO. Sir. La can you just mark that. I want that two pages 18 0 Have you ever thought of leaving the 19 marked so I can get that somehow separate and 19 employment of lee. Epstein because of what was happening 20 apart. 20 in the house? 21 THE COURT REPORTER: Okay. 21 MR CRITTON. Form. 22 BY MR. 22 THE WITNESS. No. sir. 23 0 Would It come a8 a surprise to you that 23 BY MR. 24 Mr. Epstein used sexual devices such as vibrators on 24 0 Have you ever prayed for Mr. Epstein 25 Oath of my clients when they were fourteen or fifteen 25 because of what was happening • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 14 of 38 EFTA_00070820 EFTA01247543 - Volume I October 20, 2009 49 Si 1 A I pray for my co-employees and for my, what's 1 THE WITNESS: Yes. I do not know what's • 2 3 4 5 this, employers. 0 Have you ever prayed for him related to these females that come over to the house? MR. CRITTON: Form. 2 4 3 ha. i ir side. BY MR. EDWARDS: Okay. O Okay. And have you ever asked what is going 6 THE WITNESS: I just lift his name to God, 6 on inside? 7 that's it. 7 A No. sir. 8 BY MR - 8 O Is that something that you have chosen just 9 0 Have you ever prayed for the females that come 9 not to Bid out about? 10 over to his house? 10 MR. CARTON: Form. 11 A !prayed for everyone. 11 THE WITNESS: I was told that he's going to 12 Q Do you know what Mr. Epstein does for a 12 have a massage. 13 lying? 13 BY MR. EDWARDS: 14 A I was told that he's an investor. 14 O Is that something that you believe? 15 0 Who told you that? 15 A That's what I was told, and what's this. 16 A Coworkers. 16 O You're aware of the allegations against 17 Q Which coworkers? 17 Mr. Epstein that each of these girls that was coming 18 A Lyn and Jojo. la over to his house — each of these females that was 19 0 Did Lyn and Joifoi -- 19 corning over to his house was engaging in sexual activity 20 A And Alfredo. 20 with Mr. Epstein. right? 21 0 And Alfredo. 21 MR. CRITTON: Form. 22 Did Lyn and Jcji ever tell you about 22 THE WITNESS: Could you read the question 23 Mr. Epstein getting females over to the house in 23 back? 24 New York for massages? 24 (A portion of Me record was read by the 25 MR. CRITTON: Form. 25 reporter.) 50 52 1 THE WITNESS: They have visitors, that's what 1 MR. CRITTON: Form. • 2 3 4 I was told. BY MR. O Were you ever told that he gets massages by 2 3 4 question? Did you understand the 5 females similar to the roamer in West Palm Beach? 5 Yes. you understand the 6 MR. CRITTON: Form. 6 question? 7 THE WITNESS: Yes. 7 THE WITNESS: Yes. S BY MR. 8 And I think the question was 9 0 And who told you that? 9 are you aware of the allegations. 10 A Lyn. 10 BY MR.- 11 O And did she say with what frequency - 11 Q Ate you aware of the allegations? 12 A No, sir. 12 A Through TV news. 13 O he has females come over? 13 O Have you talked to anybody else about these 14 A No. sir. la allegations being made against your employer? 15 Q You didn't continue the conversation after she 15 A With Janusz. 16 told you this? 16 O when did you talk to Janusz about trio 17 A No. I just listen, and then she talks and 17 allegations being made against your employee? 18 then that's it. We dont really, like, oh. no. 18 A There is the scenario whenever I -- what's 19 Q So is it your testimony that you don't know 19 this - I heard the news, its oh, the boss is on the 20 what happens in the bedroom behind dosed doors with 20 news. And that's it, to be honest. 21 Mr. Epstein and these females? 21 O And what would Janusz comment back to you, if 22 A No. sir. 22 anything? 23 One second. I want to make 23 A Oh, he% in the news. So we did not really. 24 sure you understand the question. 24 like, talk about... 25 MR. CRITTON: Form. 25 O But It's one thing when your boss is on the Toll Free: 866.709.8777 Facsimile: 561.394.2621 • 0 Suite 600 ESQ1J.IBE, 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com 3501.172-001 CONFIDENTIAL Page 15 of 38 EFTA_00070821 EFTA01247544 - Volume I October 20, 2009 53 55 1 news and its for accolades or for awards, it's another 1 like pry on other personal activities. 2 3 4 5 thing when your boss is on the news related to allegations that he is engaging in sexual activity with minor females. Wouldn't you agree with that? MR. CRITTON: Form, argumentative. 2 3 4 s 0 Crimes are being committed against these girls on a daily basis while you're wonting. And hypothetically let's say you knew about it would you report it? • 6 THE WITNESS: Of course there's a difference. 6 A If I knew about it, of course. 7 7 0 Sure. Uke if you walked in on it. then would BY MR. 8 you report it? 9 O So did you talk to Janusz about the fact that 9 MR. CRITTON: Form. 10 there are allegations that he is engaging in sex with 10 When you say 'le do you mean 11 these minor females that are coming over to the house 11 a cnme? 12 and you're told that they're giving massages? 12 BY MR 13 MR. CRITTON: Form, compound. 13 0 Yeah. If you walked in on a crime? 14 THE WITNESS: Not really. Like we don't 14 A A crime? Of course. If its a crime, I val. 15 really discuss-discuss. We just oh. he's in the 15 0 Okay. rm going to ask you if you've ever 16 news. and then that's it. and I go to work because 16 witnessed certain acts. First I'm going to read to you 17 were so busy, so. . 17 directly from the Florida Statutes related to a cnme 18 BY MR. - le called lewd and lascivious molestation. Okay. 19 O Do you talk to your fanny or anybody else 19 A Atingle. 20 about -- 20 0 Florida Statute 794.021. 21 A No. 21 Do you have a copy that she Can 22 O Let me finish my question. 22 read along with you perhaps? 23 about the fact that many minor females have 23 MR. EDWARDS: I don't have a copy, but 24 alleged that they have come over to Mr. Epstein's house 24 hand it to her as soon as Fve read it. 25 and engaged in sexual activity with hirn in his bedroom 25 Thank you. 54 56 1 2 3 4 while they were under the age of eighteen? BY MR. MR. CRITTON: Form. THE WITNESS: No. 1 2 3 4 BY MR.- 0 II reads as follows: A person who intentionally touches in a lewd and lascivious manner the breasts, genitals. • 0 Are you aware now that your employer, 5 genital area, or buttocks, or the clothing covering 6 Mt Epstein, is a registered sex offender? 6 them of a person less than sixteen years of age, or 7 A I heard about it. 7 forces or entices a person under sixteen years of 8 0 Does that bother you? 8 age to so touch the perpetrator, commits lewd or 9 A Sometimes, but I don't know if the allegations 9 lascivious molestation. An offender eighteen years 10 is true, so... 10 of age or older who commits lewd or lascivious 11 0 Because you don't know wtat's going on behind 11 molestation against a victim twelve years of age or 12 closed diten, right, you have no idea? 12 older but less than sixteen years of age commits a 13 MR. CRITTON: Form, argumentative. 13 felony of the second degree. 14 BY MR. 14 Have you ever observed — if you want to see 15 0 I hear you. 15 the law, you Can. Have you ever observed that crime 16 Have you ever asked your employer if the 16 committed in his house? 17 allegations being made against him are true or if they 17 A No, sir. 18 are not true related to his sexual activities with le MR. CRITTON: Form. 19 underage females? 19 What statute was that? 20 A No. 20 MR. It's 794.021, subsection five. 21 0 Isn't that something that you, as a religious 21 MR. CRITTON: Thank you. 22 person, would want to know, whether that's true that 22 BY MR. 23 that's what's going on in the bedroom every day while 23 0 Subsection seven of that same statute, lewd 24 you're at work? 24 and lascivious exhibition, indicates: 25 A Sir, I go there to work, not to, what's this, 25 A person who intentionally masturbates, • Toll Free: 866.709.8777 Facsimile: 561.394.2621 S Suite 600 C. , ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com 3501.172-001 CONFIDENTIAL Page 16 of 38 EFTA_00070822 EFTA01247545 - Volume I October 20, 2009 57 59 1 intentionally exposes the genitals in a lewd or 1 BY MR.- • 2 3 4 • lascivious manner, or intentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim in the presence Cl a victim who Is loss than sixteen years 2 3 4 O Have you ever worked for anyone that had this many young females come over to hS house every day? A No. sir. O Have you ever heard anybody say that these 6 of age commits lewd or lascivious exhibition. An 6 girls are making this up or that this did not happen, 7 offender eighteen years of ago or older who 7 these sexual acts did not happen in Mr. Epstein's fl commits a lewd or lascivious exhibition commits a bedroom? 9 felony el the second degree. 9 MR. CRITTON: Form, argumentative. 10 Have you seen that crime committed in 10 BY MR. 11 Mr. Epstein's house? 11 O By that I mean Mr. Epstein. Ghislaine Maxwell? 12 A NO. Sk. 12 A No. sir. No. 13 MR CRITTON: Form. 13 O Did ever say any of those sifts 11 BY MR. 14 were making this up? 15 0 Me of the allegations by multiple 15 A No. sir. 16 female girls that allege that these are the crimes that 16 MR. CRITTON: Form. 17 were taking place behind closed doors when they wore 17 BY MR. 18 just minor females; are you aware of those allegations? 18 O So those gins aro making these allegations, 19 MR. CRITTON: Form. 19 you work in Mr. Epstein's house? 20 Do you understand the question? 20 A Yes. 21 MR. CRITTON: Asked and answered. 21 O And you've never heard anybody deny these 22 Do you understand the question? 22 allegations, have you? 23 MR. CRITTON: And argumentative. 23 MR. CRITTON: Form. argumentative. 24 THE WITNESS: From the news, I heard that from 24 THE WITNESS: I do my lob, we don't. bko. 25 the news. 25 talk. 58 60 1 BY MR. 1 BY MR. • 2 3 4 0 And are you also aware that many Cl these girls did not know one another that 1112177 these ferrate masseuses. are you aware of that? 2 3 4 O So is that a no, you've never heard anybody deny Mat? MR. CRITTON: Form. • MR. CRITTON. Form. 5 THE WITNESS: No. sir. 6 THE WITNESS. I don't know. 6 BY MR. 7 BY MR. 7 O When was the last time you talked to 8 0 Okay. When those girls that said come a Ghislaine Maxwell? 9 where these females that would come eve' where 9 A I answer the phone when she... so you were told they were ovine massages would come over, 10 O Okay. When you first started working there la how many would come over at any time. meaning would they 11 back in November of 2004, she was the person who you 12 come over with twisty at time. or one teatime? 12 interviewed with, right? 13 MR. CRITTON: Form. 13 A Yes, sir. 14 THE WITNESS: Somedmes one at a fins. 14 O Was the somebody who you would regularly see 15 BY MR 15 at the house during that period of time? 16 0 And given the number el these females that are 16 A Not regular. 17 making these allegations. doesn't It cause you to 17 O How often would you see her in the house back 18 believe the allegations that there are so many of tarn 18 in the late 2004. when you wore hired. trough 2005? 19 and their stories are so strikingly sIrrSar as to what's 19 A Three limes. 20 laking place in Mr. Epstein's bedroom? 20 O Three times a week? 21 MR CRITTON: Form, predicate. speculation. 21 A No. During the period of that I was there. 22 argurnentabve 22 O Okay. During the entire live-year period you 23 THE WITNESS: I don't know what's happening in 23 were there you only saw Gtislaine Maxwell three times? 24 the bedroom. I did not see anything that case me 24 A Not five years. 25 alarm. 25 O Okay. From the end of 2004 through 2005 you • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 17 of 38 EFFA_00070823 EFTA01247546 - Volume I October 20, 2009 61 63 i saw her three times? MR. CARTON: But if you just asked her, say 2 3 4 5 A Yes. sir. 0 During -- A Maybe more a less three times. 0 During 2006 how often did you see her? 2 3 4 5 did you ever have a discussion with her about it, if she says yes, then well hnd out what it is. If she didn1have one. why ask the question? Go ahead • 6 A 2006? He was in New York so I Saw her. THE WITNESS: There was no discussion. 7 0 You worked for Jeffrey Epstein but you worked 7 There's no question pending. In New York? I'm sorry. 8 Wait for Mr. Edwards to ask his question and answer 9 A I saw Ms. Maxwell in New Yak. the question if Cu understand it 10 0 I think I understand. Primanty, though. you 10 BY MR. 11 ware WI working at the 358 El Brillo location? 11 O How long were you at Ghislaine Maxwell's hOuse 12 A Yes. 12 this time that you visited her in 2006? 13 0 However. at some point in time that yew you 13 MR. CAUTION: Form. 14 took a trip to the New York house and you saw her there? 14 THE WITNESS: I cannot remember, because I 15 A In her house. 15 16 0 In Ghislaine Maxwell's house? 16 BY MR. - 17 A Yes. 17 O Back and forth? 18 0 What was the occasion for you to go see her up 18 A Yes. 19 there? 19 O From West Palm Beach to New York? 20 A Lyn was having I think surgery. 20 A Yes. 21 0 And when was that? 21 O Why were you up in Ghislaine Maxwell's house 22 A I cannot recall the month, but it's I think 22 in New York? 23 2006. 23 A I help over there when she has a party. 24 0 So this is alter the criminal investigation 24 O Okay. And then after the party you would 25 into Mr. Epstein, or before, if you remember? 25 return to West Palm Beach? 62 64 • 1 MR. CRITTON: Form, predicate. 1 A Yes. 2 THE WITNESS: 2006? After. 2 O While you were up there, during any of the 3 BY MR. 3 times that you were up there, did you have any 4 0 Okay. And while you were up there with 4 conversations with Ghisleine Maxwell? 5 Ohislaine Maxwell. did you talk to her about the A I think once. But it was oh, and what's this, 6 criminal investigation of Mr. Epstein? 6 it was just oh. I'm sorry about the bad news. mars 7 A No. sir. 7 it. 8 0 At any point in time when you were up there. 8 O You said that? 9 did she say to you a you overheard let me ask yOu 9 A Because we have only, like, short 10 this way: Did she say to you that the allegations are 10 conversation, we just dent really, like, talk-talk. 11 false -- 11 O When you're saying that a statement was made 12 MR. CRITTON: Form. 12 I'm sorry about the bad news, who made the statement to 13 BY MR. 13 whom; she made it to you, Or you made it to her? 14 0 -- that are being made against him? 14 A She made it. But that was — I really cannot 15 MR. CRITTON: Form. There's no predicate that 15 remember how it was how, but it was, ake, sorry 16 a discussion ever took place about anything. 16 about the news. 17 THE WITNESS: There was no discussion about 17 O Okay. What news was she referring to when she 18 that. 18 said to you I'm sorry to hear about the bad news? 19 MR. Mr. Clifton. it you could just 19 A She not say anything. I just I do not say 20 object to the form. Obviously this witnesses just 20 anything about what the bad news is. 21 takes your wads and she's going to recite them to 21 O Okay. I guess what I'm asking is did you have 22 me. II you want to say lack of predicate. okay, 22 a death in the family or something happen to you 23 fine. But to say no discussion 100k place and then 23 personally? Or why would she say this to you, d you 24 she says no discussion took place, we're leading 24 know? 25 the witness here, its obvious. 25 A No. • Toll Free: 866.709.8777 Facsimile: 561.394.2621 S Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquintSolutions.com CONFIDENTIAL 3501.172-001 Page 18 of 38 EFTA_00070824 EFTA01247547 - Volume I October 20, 2009 65 6 .7 1 0 You have no idea why she said that statement? 1 0 What did she say when you answered the phone? • 2 3 4 5 A I think fiat it was about the news that was going On about Mr. Epstein- BY MR. MR CRITTON: Move to strike as speculation 2 3 4 S A Oh, she was happy. I was happy to hear her voice. And then she said oh, she was also happy to — she was so nice on the phone. 0 What did she say? 6 0 And did she elaborate on the news about 6 A Oh, rice talking to you, 7 Mr. Epstein? 7 0 Then did She ask to speak to somebody &se? A No, sir. 8 A To Mr. Epstein. 9 0 During that conversation where she makes a 9 0 Aside from Me telephone call one month ago. 10 statement that she's sorry about the news. did she ever 10 how many limes has she called the house In the last 11 tell you that the allegations being made against him are 11 year? 12 false or unfounded Or untrue? 12 A That was my only. what's this. my -- the time 13 MR. CRITTON: Form. 13 that I was answer the phone and it was Ms. Maxwell. 14 THE WITNESS: Our conversation was short. 14 0 Do you know why She called Mr. Epstein? 15 BY MR 15 A I do not know, sir. 16 O So the answer is no? 16 0 Have you ever seen scheduling logs, either on 17 A No. 17 a computer or on paper. with girls' names on n and 18 0 What is your understanding of 18 numbers? 19 Ghislaine Maxwell's role In Jeffrey Epstein's life back 19 A No. No, sir. 20 In 2004 and 2005 and 2006? 20 0 Have you ever seen the names of these females 21 MR. CRITTON: Form. 21 that are alleged to have been masseuses written on 22 THE WITNESS: She told me he was his bodnend 22 anything? 23 WO. 23 A Yes, sir. 24 BY WI. 24 0 What have you seen them written on? 25 O Ghislaine Maxwell told you that 25 A I lust saw names, and that's it. 66 68 • 1 2 3 4 Jeffrey Epstein was her boyfriend? A When I was hired. O And then over the next year and a half when Jeffrey Epstein was in West Palm Beach, you only saw 1 2 3 4 O Just the names. or the telephone numbers as wel? MR. CRITTON: Form. THE WITNESS: I cannot remember. 5 Ghislaine Maxwell at the house approximalely three 5 BY MR. 6 times? 6 O Where did you see thls? A Yes, sir A We have like butters party and there's a 8 O Did you still believe that Ghislaine Maxwell 8 telephone there. 9 and Jeffrey Epstein were boyfriend and girlfriend? 9 O Is this in the staff house or the main house? 10 MR. CRITTON: Form. 10 A No. The main house. 11 THE WITNESS: At that time or what lime? 11 O And do you know who wrote the names? 12 BY MR 12 A No. sir. 13 O Yeah. Back then in 2004, 2005. 13 O How do you know that these were the names of 14 A Yes. 14 the females that were alleged to have been masseuses? 15 O All right. Is it your understanding that they 15 A Because there is time. 16 are still boyfriend and girlfriend today? 16 O What do you mean, there is time? 17 A I don't know. 17 A Sometimes name and then the time. that's it. 18 O Ghislaine Maxwell and Jeffrey Epstein, do they 18 O What does the time indicate? 19 att talk to one another today? 19 A I cannot remember. 20 A I do not know, sir. 20 O The time to you you know, I'm watching what 21 O What Is the last time that you talked to 21 you're doing, but the court reporter is not able to draw 22 Ghislaine Maxwell? 22 a pictured it. So I guess what I'm asking is you're 23 A She called the house and I answered the phone. 23 saying there is on the tell-hand side there is a 24 O How long ago? 24 name. and on the right.hand side corresponding to that 25 A About a month ago. 25 name there is a time written down? Is that what you • 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutions.corn 3501172-001 CONFIDENTIAL Page 19 of 38 EFTA_00070825 EFTA01247548 - Volume I October 20, 2009 69 71 • incicated? 1 BY MR. 2 A Yes. 2 O and you would answer the phone? 3 O And that time is incbtatNe of the appointment 3 A Again, can you... 4 time when that female was supposed to be al o What would they say? Hi, this Is Mary, I'd Me. Epstein's house? 5 like to come work, is there a lime available for me. 6 MR. CRITTON: Form. 6 Fm making this up. What would they say? 7 THE WITNESS: I realty don't know if that's 7 MR. CRITTON: Form. the one that incbcate who is coming. I just see a BY MR. - 9 names there and then time. 9 O If you know. 3.0 BY MR. 3.0 A They just say the, what's this. The female 11 O Desaibe for me what this book looks like, or 11 will just telt Mr. Epstein I called. 12 what this piece of paper looks like. 12 o Okay. Just tell him I called? 13 A Someplace there are like white paper we write 13 A Uh-huh. 14 the names. ill hear — if somebody receives a call, and 14 O And you would write down the name of the 15 then we write the name of the person and the time. 15 person and the time the person called? 16 O It sounds like you've answered the phone for 16 A Yes. sir. 17 when one of these females has called? 17 When you get to a convenient 18 A Sometimes. 18 breaking point. 19 MR. CRITTON: Form. 19 MR. Let's break. 20 BY IC. 20 (Brief recess in proceedings.) 21 O How many tunes in the last five years have you 21 It may De obvious to us in the 22 answered the telephone when one of these females has 22 room, but it may not be apparent in the cold record 23 called? 23 that English is not Ms. first language. 24 MR. CRITTON: Form. 24 So that's why I've interrupted a couple of times 25 THE WITNESS: I cannot remember. 25 and asked her if she understands the question, 70 72 1 2 3 4 BY MR O PJI right. I asked this question that way because you said sometimes we take the message. A YeS. 1 2 3 4 because it's apparent to me sometimes that her English isn't as eloquent as W. ■ BY MR. - 0 What is your first language. Ms. • 5 0 And when you say we, you're inducing A Visayan and Tagalog. 6 yourself? 6 0 Do you feel comfortable with taking this 7 A Yee. 7 deposition in English; meaning do you understand my 8 0 Okay. And when the female would call to 8 questions and are you giving me answers that are 9 sthedne I mean. when the female could call. what 9 truthful and accurate? 10 exactly would she say where you would write &yin a name 10 A Sometimes I have to ask you to rephrase 11 and a time? 11 because. you know. 12 A I d2n1 know if receive a call and 12 0 Okay. And when you've asked me to rephrase 13 then I get the message and mite the name and the time 13 and I've rephrased the question. have you understood it 14 0 Okay. It's just a message from whom? 14 and given me an answer that you feel is accurate? 15 A For Mr. Epstein. 15 A Yes. 16 0 And who Is the Call that - the calls that 16 0 Okay. Did you ever talk to the police? 17 you're referring to. who are they, who is calling? 17 A No. is A They are fernele voices. is 0 Have you ever talked to the FBI? 19 0 And are they asking to come over to give a 19 A No. 20 =Seaga, to work, to -- 20 0 Were you ever asked to talk lo the State 22 A To work. 21 Attorney's Office? 22 0 And what Is the language that the females 22 A No. 23 would typically use when they would call -- 23 0 Were you ever asked to talk to the United 24 W. CRITTON': Form. 24 States Attorneys Office? 25 25 A No. 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 • ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esqulresolutlons.com 3501.172-001 CONFIDENTIAL Page 20 of 38 EFrA_00070826 EFTA01247549 - Volume I October 20, 2009 73 75 1 0 Did you ever talk to any law enforcement type A Yes. • 2 3 4 • related to the Jeffrey Epstein aiminal investigation? A No, sir. 0 Did you remain employed from November 2004 through today continuously with Jeffrey Epstein? 2 3 4 5 0 Where? A hail. 0 How do you know that? A Through Janusz or, what's this, through the 6 A Yes, sir. 6 news. 7 0 Was it dscussed as to how your employment 7 0 SO you cid you work at his house during the 8 would be altered, if at all, while Mr. Epstein was going s time period ^ 9 to be either while Mr. Epstein was going to be in 9 A Yes. 10 jail or away from the house? 10 0 Wait until I finish. 11 A No. sir. 11 A Sony. 12 0 Did you know, did you have any prior warning 12 0 Did you work at his house during time pored 13 before Mr. Epstein plod guilty and wont to jail? 13 when Mr. Epstein was in jail? 14 A No, sir. 14 A I cid. 15 0 All right. So it was just one day he's there 15 0 Dicl you see Mr. Epstein during that year time 16 and the next day he's not. as fax as you knew? 16 period? 17 A Janusz. we discuss it with Janusz, he received 17 A No. 18 a call, and then oh, Mr. Epstein is coming so is how I 18 0 What was your schedule during that year t,me 19 know. 19 period that Mr. Epstein was in jail? 20 0 I'm sorry. Maybe we miscommunicated there. 20 A Flexible. No. Wait. The time that he was in 21 You're saying that Janusz received a call that 21 jail? 22 Mr. Epstein was coming to the house? 22 0 Mont. June 30th, 2008 through sometime in 23 A Your first question was? 23 July. 2009 24 0 Were you made aware of the date or time period 24 Do you understand the question? 25 that Mr. Epstein would be going to court to plead guilty 25 THE WITNESS: Yes. 74 76 1 Okay. Go ahead and answer it • 1 2 3 4 to criMOS and then gong to jail so that he would no longer be at the house, were you made aware that that was going to take place? A Not directly. 2 3 4 then. THE WITNESS: I usually come nine o'clock. BY MR. - • 0 Okay. IndirectAy then, did you knew that that 5 O Md you would leave? 6 was taking place? 6 A At 5:00 a5:30. 7 A No. Janusz and I talked, so... 7 O Md whO else would be in the house during that 8 0 Md what old Janusz tell you about Pk. Epstein 8 year time period from June 2008 through July 2009? 9 (ONO court and after court he would be In jail and 9 A Only Janusz and me: and the gardener, he 10 nO longer at the house? 10 passed away. 11 A We really don't know when he's gang there to 11 O Who? 12 jail or Is going to art. It's just a discussion like 12 A The gardener. 13 oh, he's going to court or something, but the date and 13 O Jerome? 14 the time, no. 14 A Jerome. is 0 rm not concerned with the date and the time. 15 O And you said he said passed away? 16 I guess what I'm getting at just is were you told that 16 A Yes. 17 there was going to be a time period he was going to be 17 O When was that? 18 In jail? 18 A I remember right we came from New York, I 19 A No. 19 cannot remember. but I remember when we came from 20 0 All right. There was a period of time that 20 New Yak, we attended his not burial, the ceremony in 21 was just over a year where Mr. Epstein was not in the 21 church. 22 house, that being from June 30th, 2008 through sometime 22 O Do you know how he passed away? 23 In July of 2009. correct? 23 A Janusz told me that he has a heart attack or 24 A Yes. 24 something. 25 0 And do you know where he was during that erne? 25 O Okay. But it wasn't col the property while he • 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 21 of 38 EFFA_00070827 EFTA01247550 - Volume I October 20, 2009 77 79 1 was working? • 1 O Was it somebody from New York? 2 A No. 2 A What, you mean when he was jail? 3 0 Owing that year time period that Mr. Epstein 3 O When he was In jail. 4 was in jail, what did you do on a day-to-day basis Mien 4 A Story. 5 you were there from 9:00 to 5:00? 5 O It was Story? 6 A I dean the house, I made inventory of the 6 A it was Story- 7 linens, and what's this, started inventorying, making an 7 O This is Story Cowles? Do you know the last 8 inventory of the silverwares. B name? 9 0 Okay. Did you talk to during A Ideal know his last name. 10 that time period he was in jail? 10 O And when you say she came with a person, you 11 A Yos. 11 mean she came to the house with a person namedM? 12 0 And -went to visit him in jail numerous 12 A Yes. 13 times; are you aware of that? 13 O AndoStu know if that person named Story 14 MR. CRITTON: Form. 14 flew in with =II rom elsewhere? 15 THE WITNESS: No. sir. 15 A I don't know. 16 BY MR. 16 O And did Story slay at the house with 17 18 0 And did stay in the house during the time period where Mr. Epstein was in jail? 17 IIIIIIP 1a A No. se. 19 A Yes. 19 O All right So tNs is during the da he came 20 0 Permanently, or did she fly in town and fly 20 over. Story came over and visited with 21 back somewhere else? 21 A Visited? I think so. 22 A (Noddi head.) 22 O Okay. Do you know the purpose for Mr. Cowles, 23 MR. You have to say yes or no. 23 or St as referred to him, meeting with 21 25 THE WITNESS: Yes. MR Yes she flew in, or yes she 24 25 at at the house during the year time period Mien Mr. Epstein was in jail? 78 80 • 1 stayed permanently? 1 A No. 2 THE WITNESS: Not for a longer period. 2 0 What did you watch them do together, it 3 BY MR.- 3 anything? 4 O Okay. Who would she fly into town with, it 4 A Do the computer. anyone? 5 0 All right How many computers were here in 6 A Alone. I don't know, because she just come to 6 the house during the year time period Mr. Epstein was in 7 the house and that's how she's there. I didn't know who 7 jail? she came with. A They have their own personal computers 9 e oome to the house alone, she being 9 0 Who is 'they? 10 10 A If you're asking about MI and Story? 11. : Again. we're talking during the 11 0 Right. They brought laptops with them, you're 12 time period when Mr. Epstein is in jail? 12 Saying? 13 THE WITNESS: Yes. 13 A Yes. 14 Thank you. 14 0 Okay. For the period of time between 15 THE WITNESS: So one time she came with male 15 November 2004 through June of 2008. when — sorry. 16 friend. 16 Were you working at the house when the police 17 BY MR. 17 executed a search warrant on the house? 10 O With a male friend? 18 A No. 19 A Yes. 19 0 You were not working at the house? 20 O Do you knew his name? 20 A I wasn't 21 A I forgot it. 21 0 Were you aware of a search warrant being 22 O Was it Igor? 22 executed on the house? 23 A No. 23 A No. 24 O Wash Story? 24 0 Did you know that a search warrant was ever 25 A No. 25 executed on the house at 358 El Bello Way? 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 • ESQ...w UIRE ...” 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com CONFIDENTIAL 3501.172-001 Page 22 of 38 EFrA_00070828 EFTA01247551 - Volume I October 20, 2009 81 83 1 A When I came back to report. that's how I 1 0 So are we talking about the day the police • 2 3 4 5 learned. 0 Elaborate on that for me. What do you mean. when you came back to report that's how I learned? A I reported in the afternoon. and then that's 2 3 4 went to Jeffrey Epstein's house you did not go in the morning. but you went after lunch and the police had already left? A Oh. No. When I went there nobody was there. 6 how I learned that the police came. 6 no policemen were around. 7 0 All right. And when were you you're now 7 0 Who was at the house then? saying you came back to report and you reamed that the 8 A Janusz, and Douglas, the architect. 9 police had already come to the house, right? 9 0 Schoettle? 10 A Yes, slr. to A Yes. 11 0 Prior lethal occasion, when was the previous 11 0 And did you have a discussion with them? 12 time that you were at the house? 12 A No. 13 A The day before. 13 0 How did you know the poke had been to the 14 0 Olay. And the day before you left your shift 14 house? 15 at roughly love o'clock? 15 A Janusz told me. 16 A I cannot remember. I usually leave 5:00 or 16 0 When? 17 510. 17 A When I arrive. 18 0 But sometime late in the afternoon? 18 O That's what I was asking you when I said did 19 A Yes. 19 you have a discussion with them, moaning Janusz and 20 0 And as of that time, the day before the search 20 Douglas. 21 warrant was issued. you had seen no police officers in 21 A Okay. Being because them -- with Janusz only. 22 or around the house? 22 0 what did he say? 23 A No. 23 A He said the police came and, what's this, took 24 O And then the next day you reported to the job 24 away some stuff. 25 at what time? 25 0 Did he say what they took? 82 84 • 1 2 3 4 A The next day? O The next day. A I report in the afternoon. 0 Was there a reason why you reported in the 1 2 3 4 A He said pictures. O Did he tell you which pictures? A No. sir. O Aside from pictures, what else did the police 5 afternoon? 5 take, as Janusz told you? 6 A Ms. Maxwell called me. 6 A He did not elaborate. 7 0 When did she call you? 7 O All right. Prior to the police going to the A During that day, she said M. you can a house and taking pictures, do you remember seeing 9 report in the afternoon. 9 pictures around Mr. Epstein's house? 3.0 0 She called you earty in the morning? 10 A Yes. 11 A Not early. 11 o Do you remember seeing pictures of naked or 12 0 Normalfy you would report to the house between 12 nude females around Mr. Epstein's house? 13 eight and nine o'clock, right? 13 A Not around, in his closet. 14 A Yes. sir. 14 O In Mr. Epstein's closet you would see -- 15 0 So in order for you not to arrive at the 15 describe what you would see related to females in 16 house, she had to have called you before eight or 16 pictures. 17 nine o'clock. right? 17 A Some have topless. 18 A Yes. 18 O Is this a big closet? 19 0 Okay. So approximately what time does 19 A No. Not really big. it's just this big, not 20 Ms. Maxwell call you to tell you you can report to the 20 so big. 21 house later on that thy? 21 O Okay. Were these pictures that could be seen 22 A I cannot remember really the time. 22 by — strike that. 23 0 Okay. What time did you actually report to 23 Do you know of any other pictures of females 24 the house? 24 that were confiscated by the police that did not come 25 A After lunch, about — maybe after lunch. 25 from Mr. Epstein's closet? Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE e•Alen•InCrall•C•spar 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 23 of 38 EFTA_00070829 EFTA01247552 - Volume I October 20, 2009 85 8v 1 MR. CRITTON: Form. • 1 MR. CRITTON: Form. 2 THE WITNESS: Nude picture? 2 BY MR. 3 BY 3 O You were able to tell me the approximate age 4 O CWe:tures ny WI that were taken by the 4 o4 the child in the photograph, but you're unable to police that were not taken from his closet. 5 tell me the approximate age -- 6 MR. CRITTON: Form. 6 A It was just a guess for four, because I could 7 THE WITNESS: One. hardy, like. toll the ago. It was just maybe four. 8 BY MR. 8 O Where was that picture? 9 O Okay. Was there anything else in the house 10 A The hallway leading to the master bedroom. 10 that you were told was taken by the police? 11 O And what was that picture of? 11 A No. sir. 12 A ICs like advertisement, small child. 12 O Pnor to the day when the Poke came to the 13 O A small child. When you say 'small child,' 13 house. how many computers did Mr. Epstein have in his 14 what age range are you talking about? 14 house? 15 A Maybe four. 15 MR. CRITTON: Form. predicate. 16 O What is that child in that picture who is 16 THE WITNESS: One -- three. 17 maybe four doing? 17 BY MR. 18 A I cannot really. like -- I don't know what's 18 O Where were those three computers located? 19 this, but I think the underwear was (indicating), like 19 A In the cabana, in one of the desks, and one in 20 pulled down. 20 the little office. 21 MR. CRITTON: Just for the record, she's 21 O And after the police came to the house do you 22 pointing to her rear-end, derriere. 22 remember seeing those computers any more" 23 BY MR. - 23 A No. I really did not focus on what was 24 O So in this picture that was taken by the 24 missing. only the picture that was big, and in the 25 police or confiscated by the police, it was in the 25 bedroom. 86 88 1 2 3 4 hallway and It was of a child roughly four years old that was pulling down her underwear and exposing her buttock area; is that fairly accurate? A Yes. Not really full, just like slightly, 1 2 3 4 O Okay. But you're aware, as you told me. that there were these computers -- A Yes. O Let me finish. • 5 that's what I remember. A Sorry. 6 0 Okay. Are there any other photographs that 6 O You where aware, as you told M. that there 7 were confiscated by the police, to your knowledge? wore those computers that you described as being three A No. 8 computers In Mr. Epstein's house, fight? 9 0 So how many photographs had you seen peer to 9 A `leash:. 10 the police going into Mr. Epstein's house in 10 O And do you know whether those were taken out 11 Mr. Epstein's closet? 11 of Mt. Epstein's house by Mr. Epstein or somebody 12 MR. CRITTON: Form. 12 associated with Mr. Epstein. or by the police? 13 THE WITNESS: Loss than ten. 13 A I'm not aware. 14 BY MR. 14 O So to the best 01 your knowledge, the police 15 0 Okay. So there were less than ten photographs IS lock less than ten photographs from Mr. Epstein's house. 16 lo Mr. Epstein's closet that you remember? 16 and that should be allot the evidence or objects that 17 A Yes. 17 were taken by the police from Mr. Epstein's house, to 18 0 And what were those photographs of, these less 18 your knowledge? 19 than ton? 19 MR. CRITTON: Form. predicate. 20 A Hall nude women. 20 THE WITNESS: I don't know. 21 0 Do you know the ages of those women? 21 BY MR.- 22 A No. sir. 22 O I'm only asking what you do know. 23 0 Do you know the approximate ages of those 23 To your knowledge, what you described to me 24 women 8110050 photographs? 24 as -.Must want to know a list ol all the things that 25 A No. 25 you know were taken by the police. And you've dasonbed • Toll Free: 866.709.8777 Facsimile: 561.394.2621 0 Suite 600 ESQVII3E 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vnywiesquireSolutions.com 3501.172-001 CONFIDENTIAL Page 24 of 38 EFTA_00070830 EFTA01247553 - Volume I October 20, 2009 89 91 1 to me I believe one photograph of this lour-year-old 1 A Yes. • 2 3 4 5 child as well as less than ten photographs that were previously in Mr. Epstein's closet. A Yes. MR. CRITTON: Form. 2 3 • 5 0 So you know what bedrooms need to be tided up and look like SOnleOne slept there? A Yes. 0 And does it appear that slept in the 6 BY MR.- 6 same bedroom as Mr. Epstein, Or some Other bedroom? 7 0 Is there anything else that you know was taken 7 A Sometimes the other bedroom is also, like. by the police? a slept in. 9 A No. 9 0 Okay. So sometimes -- 10 0 Since Mr. Epstein has been out of jail. 10 A Sometimes one bed is the master, and sometimes 11 guess this Is since July of 2009. what has your schedule 11 the Other, what's this. is slept in. 12 been? 12 0 What is your understanding or the relationship 13 A My schedule has changed. 13 betweenMand IA. Epstein? • 0 To what? 14 A Relationship? 15 A From 8:00 to 3:30. is 0 Yeah. What is your understanding of 16 0 6:00 a.m.? 16 rote in Mr. Epstein's life? 17 A Yes, sir. 17 MR. CRITTON: Form. 18 0 And why the sctedule change? 18 THE WITNESS: She did not tell me that She's 19 A Because I was chosen to give breakfast. 19 his girlfriend, sO she stays there, s0... 20 0 To wtorn? 20 BY MR. 21 A Mr. Epstein. 21 0 She didn't tell you, or she thd? 22 0 By whom? 22 A She did not. 23 A Because it was Janusz was there usually gives 23 0 She did not tell you. 24 the breakfast, but there was a change. it was me. 24 How long haSM been around Mr. Epstein. to 25 0 Okay. You don't know why that change 25 the best of your memory? 90 92 1. • 2 3 4 occurred? A No. 0 Well, do you know why that change occurred? A Because so that somebody because Janusz has 1 2 3 4 A Since a few months I started working there 0 Okay. So that's late 2005 you're talking about, or 2004? Sorry. A 2005, I mink. 5 to stay later, so... • MR. CRITTON: 2005? 6 0 Every monling now you serve breakfast to 6 MR She said 2005. 7 Mr. Ecetet? 7 MR. CRITTON: Okay. 8 A Yes, sir. 8 BY MR. 9 0 So that's why you're required to be there at 9 0 And what was your understanding back then why 10 6:00 a.m. Is that what time he eats? 10 she was at the house with Mr. Epstein? 11 A 6:30. 11 A Understanding? I thought she is his • 0 Tell me since Mr. Epstein has been out of jail 12 girlfriend. 13 and bath at the house, what other people have frequently 13 0 Ghislaine Maxwell, when she hired you or 14 visited and/or stayed at house? 14 Interviewed you, told you that she, Ghislaine. was 15 A Who? 15 Mr. Epstein's girlfriend. right? 16 0 Who. 16 A Yes. 17 A la Story. 17 0 And then a month or two after you began 18 0 And where does NC Epstein sleep in the house la working at Mr. Epstein's house= is also around the 19 since he's been out of jail? 19 house and you believed that she was Mr. Epstein's 20 A Where? In the master bedroom. 20 girlfriend? 21 0 All right. And where doesMsleep? 21 A I want to before I did not know that. she 22 A I'm not aware if IOW not see d they 22 was just a visitor. 23 sleep together or... 23 0 Okay. When was it that you started, you were 24 0 Well, you tidy up the house the following day. 24 led to believe. Or based on your observations you 25 correct? 25 believed thatEllwas a girlfriend of Mr. Epstein? Toll Free: 866.709.87 77 Facsimile: 561.394.2621 • 0 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 25 of 38 EFTA_00070831 EFTA01247554 - Volume I October 20, 2009 93 95 • 1 A 2006. No. Wait. When he was in jail. 1 A Yes, 2 Q All right. When Mr. Epstein was in jail 2 0 Have you ever been told that was 3 between June 2008 and July of 2009 is the first time 3 purchased from her family by Mr. Epstein? 4 that you began to believe that was a girlfriend of 4 A No. Mr. Epstein? • Q Have you ever been told that serves as a 6 A Yes. That's just my own, but she did not tell 6 lesbian sex slave for Jeffrey Epstein? 7 me that she's the girlfriend. 7 A No. a O Did anybody tell you that? • Sum Mr. Epstein has been out of Far .You A No. 9 indicated that the frequent visitors are 10 O Prior to that period of time when Mr. Epstein 10 and Story; right? 11 was in jail, what was your understanding as to 11 A Yes, sir. 12 relationship to Mr. Epstein or role in Mr. Epstein's 12 0 And does Story stay at the house? 13 life? 13 A No. 14 A A Mend. 14 0 How often is Story at the house? 15 Q What did she do when she was at the house 15 A Often. Like they come in the morning, they 16 prior to Mr. Epstein going to jail, = what did 16 gay a few hours, then leave. 17 17 0 Who is 'they'? 18 A What did she do? 18 A and Story. 19 O What did IMIo around the house prior to 19 0 And is that on a daily basis? 20 Mr. Epstein going to jail? 20 A Not always. 21 A Go shopping. 21 0 Do you know it or Story do you know 22 O Anything else? 22 if is staying at Mr. Epstein's house now? 23 A That's what I know only. 23 A No. 24 O Do you remember a person named 24 0 You don't know, or she's not? 25 25 A No. she's not. 94 96 1 2 3 4 A 0 A Yes. I remember a name name. n0. but the family 1 2 3 4 o A Do you know where she is Staying, Not now. no. • • 0 Md Aral did ti.o at Mr. Epstein' 5 6 house, if anything? 6 7 A Alfredo told me that a personal 7 • assistant. 8 9 0 Similar to ==', 9 10 A Yes. 10 11 0 Was there an hi that you observed that 11 12 would distinguish from terms of 12 13 the role that they played In Mr. Epstein's life? 13 14 A Nol really. 14 15 0 Is that somebody who you believe scheduled 15 16 Mr. Epstein for massages with the females. 16 O Do you know, have you witnessed stay talking 17 A I donl knOw. 17 with Mr. Epstein al Mr. Epstein's house? 18 0 Md were you ever told that by anybody that 18 A Yes. 19 _was also involved in sex acts with minor females 19 Q And where do those conversations bike place? 20 at Mr. Epstein's house? 20 A In the breakfast room. 21 A No. 21 O And when those conversations are taking place 22 MR. CRITTON: Form. 22 in the breakfast room between Story and Mr. Epstein, is 23 BY MR. 23 also there? 24 0 Am I the first person that has said that In 24 A There are times when she's Mere, there is 25 your presence? 25 times that she's not there. • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 • elat. ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.corn 3501.172-001 CONFIDENTIAL Page 26 of 38 EFTA_00070832 EFTA01247555 - Volume I October 20, 2009 9"/ 99 1 0 All right. So there are times that Story mean do you know if she flies in from New York or flies • 2 3 4 5 talks directly with Mr. Epstein in the breakfast room and is just two of them? A Yes. 0 All right. And there are times when Story 2 3 in from LA, or where she lives down the street in Palm Beach? 0 What does She do when she's In Palm Beach? 6 talks with Mr. Epstein in the breakfast room and 6 A Go to the beach. is also there? 7 0 Did you know her prior to — had you seen her A Yes. 8 prior to Mr. Epstein going 10 jail? 9 0 Are there limes when= is also involved in 9 A No, sir. 10 conversations Mier° Story and Mr. Epstein are talking to 0 Other than are there any other 11 with one another In the breakfast roan? 11 visitors that you have witnessed or observed? 12 A Yes 12 A Sultan. 13 0 Are there times when all four of them, that 13 0 Who is that? 14 meanin2M, `Story. and Mr. Epstein, are WI 14 A Sultan. 15 conversing together in the breakfast roan? 15 0 S-U-L-T-A-N? 16 A Yes. 16 A Yes. 17 0 Have you overheard the conversations? 17 0 Is that a female? IS A No. 18 A A male. 19 0 Do you know or have you been made aware of 19 0 Do you know what Sultan does? 20 them talking about the allegations concerting 20 A No, slr. 21 Mr. Epstein and female masseuses? 21 0 Do you know why he's ever at the house? 22 A No, sir. 22 A No. 23 0 Since Mr. Epstein has been out of jail in July 23 0 How often Is Sultan there? 34 012009. have you seen any females coming over to give 24 A I saw him two times. 25 Mr. Epstein a massage? 25 0 And is that somebody that you saw prior to 98 100 1 A No, sir. 1 Mr. Epstein going to jail? • 2 3 4 0 Do you know why that is? A I don't know, sir. 0 Does `have you seen keeping a 2 3 4 A No. sir. 0 So the Ilml time you saw him was sometime after Mr. Epstein got out ol jail? s schedule of females or masseuses? 5 A Yes, sir. 6 A No, sir. 6 0 Any other visitors that you've seen since 7 0 Since July of 2009, has Jeffrey Epstein spent 7 Mr. Epstein's been out of jail in July? a every night at the Palm Beach house, to your knowledge? A Rosa. 9 MR. CRITTON: Form. predicate. 9 0 And who is Rosa? 10 THE WITNESS. I leave at 3:30. So... 10 A She's also a friend. 11 BY MR. 11 0 A friend of whom? 12 0 When you arrive every morning at 6:00 a.m., 12 A Mr. Epstein. 13 has Mr. Epstein been there every day? 13 0 And where does she come Iran? 14 A Yes, sir. 14 A I did not ask her, I NO not know. 15 0 Aside from =,= and Story, have there 15 0 M right. Is it somebody that a driver has 16 been any other visitors that are regular visitors of 16 to go pick up from the airport, or she flew from 17 Mr. Epstein since he's been out ol jail? 17 somewhere? 18 A Some female friends. 18 A Yes. Janusz. 19 0 Who would those people be? 19 0 Janusz picks these people up from the airport? 20 A Difficult names. 20 A Yes, sir. 21 0 who? 21 MR. CRITTON: Form. 22 A I don't know their... 22 BY MR. 23 0 Do you know where she comes from? 23 0 And when I say %hese people.' I'm talking 24 A No. 24 abouts Sultan, and Rosa all are driven by 25 0 And I don't mean her country of origin. I 25 Janusz to the house? • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutionS.COM 3501.172-001 CONFIDENTIAL Page 27 of 38 EFT/C00070833 EFTA01247556 - Volume I October 20, 2009 101 103 massage from any of these females? • MR. CARTON: Form. a 2 THE WITNESS: I !lid not see Janusz dnve, but 2 MR. CRITTON: Form. 3 what's this. 3 THE WITNESS: I do not know. 4 BY MR. 4 BY MR. 0 But that's what you understand? 5 0 I'm just going to ask you it you can identify 6 A Yea. 6 any GI these people in this book. If you can, okay, if 7 MR. CRITTON: Form, speculation. .7 YOU carrot, It's line. 8 BY MR e MR. CRITTON: I want to mark thine, please. 9 0 Any other visitors? 9 MR. Wel. if she can identify them 10 A mars all can remember. 10 I'll mark them. 11 0 Do you know hew Old Rosa IS? 11 MR. CRITTON: No. no. I want them identified, 12 A She. what's this. 12 because if She Can't lelenbly them that's 13 0 Excuse me? 13 significant to me as well. So can we mark those as 14 A I don't knew her age. but she looks 5ke, 14 a composite? 15 what's this. 15 MR. I can mark them as a composite. 16 0 Did you say 'whets this*? 16 and we can either copy them hem as black and white 17 A What? 17 or whatever. 18 0 rm sony. We're just I think le MR. CRITTON: That's fine. 19 miscommunicating here. 19 (Plaintiff's Exhibit No. I was marked for 20 A Okay. 20 identification.) 21 0 I was asking the age of the person that you've 21 BY MR. 22 described as Rosa 22 0 Do you know who this is. have you ever seen 23 A I did not ask her age. 23 her before? 24 0 How do you know the names of Sultan. 24 A No. 25 and Rosa? 25 MR. CRITTON: And we'll call this Exhibit 1.A. 102 104 1 2 3 4 A What's this? Janusz. 0 Okay. Any other visitors aside from those three people that you have just Wed. and the frequent Nsilors: i== and Story? 2 3 4 BY MR. MR "C.—D1 MR. CRITTON: Yeah. And then the next page will be • A That's all I can remember. 5 0 What was your response? 6 0 Has Ohislaine Maxwell come to visit since 6 A No. 7 Mr. Epstein's been out of jail? 7 0 Never seen her before? A No. sir. e A No. 9 0 Do you know if they frequently talk with one 9 MR. CRITTON: Can you tell us who they are? 10 another? 10 MR. Can I tel you? 11 A I don't know, sir. a MR. CRITTON: Yes. 12 0 Do you know what the relationship is or has 12 MR. No. 13 been between Ghislaine Maxwell and Mr. Epstein? 13 MR. CRITTON: Okay. 14 A No. 14 MR. She may be able to tell you. 15 MR. CRITTON- Form. Is BY MR. 16 BY MR. 16 0 Have you ever seen her before? 17 0 In the five years or so that you've worked at 17 MR. CRITTON. That's 1.8. 18 Mr. Epstein's house. what other persons besides is BY MR. 19 Mr. Epstein have received massages from these females. 19 0 This is 1.B. 20 from these female masseuses? 20 A No. 21 MR. CRITTON: Form. 21 0 That's not somebody that you recognize as 22 THE WITNESS: I don't know. 22 anybody working on Mr. Epstein's staff. pointing at 23 BY MR. 23 picture 1-B? 24 0 Do you know of any other visitors whO have 24 A No 25 frequented Mr. Epstein's house that have also received a 25 0 Okay. I.C. is that somebody that you • Toll Free: 866.709.8777 Facsimile: 561.394.2621 S EsQuIBE Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com 3501.172-001 CONFIDENTIAL Page 28 of 38 EFFA_00070834 EFTA01247557 - Volume I October 20, 2009 105 107 I recognize -- 1 A I cannot remember. • 2 3 4 5 A No. Q as anybody who has ever boon lo Mr. Epstein's house in the pest five years? A No. 2 3 4 5 MR. CRITTON: This is 1-I now? MR. This is I-1 THE WITNESS: I cannot remember. BY MR. - 6 0 1.O. do you lux3wW4I0 that is? 6 O By Mat I moan you've been able to tell me no, 7 A No. 7 no. no. no, no. When you say I don't remember, does B Q You don't remember seeing her come to a that mean maybe you have? 9 Mr. Epstein's house? 9 A Maybe, because the eyes. 10 A No. 10 Q Okay. So that's somebody who may look 11 0 1-E, do you know who that is? 11 'smiler to you but you don't know why? 12 A No. 12 A Yes. 13 0 In the live years Mat you worked there, you 13 O Okay. Is that somebody you remember seeing al 14 never remember seeing her come to Mr. Epstein's house? 14 Mr. Epstein's house; I mean, Is that where the 15 A No. 15 famibarity comes from? 16 0 Do you know who this is? 16 A Maybe. 17 A I remember this. 17 O Okay. Do you recognize that person? 18 0 You remember her? 18 A TharsM 19 MR. CRITTON: Are you talking I -F? 19 O And that's the person that you've been 20 BY MR. 20 describing as= throughout this deposition? When 21 0 Let's make sure we're right. 1-F. 21. you've talked aboutM that's the person you're 22 A Yes. 22 talking about? 23 0 Al right. when do you remember seeing her? 23 A Yes. 24 A I cannot remember the dates, you know, but I 24 What mother are we on now? 25 remember seeing her. 25 MR.CRITTON: 106 108 1 0 Do you remember her name? 1 • 2 3 4 A No. 0 Does the name as to who this person is? ref resh your recollection 2 3 4 BY MR. Ma MS 'J.' 0 Do you know who that Is, have you ever seen 5 A s that person? 6 0 You remember a 6 A Yes. 7 A I remember a names but I don't know if 7 0 Where have you seen him? Walls a A In the house. 9 0 Okay. And where do you tHnk that you saw 9 MR. CRITTON: This is IV now? 10 this person? 10 BY MR. 11 A In the house. 11 0 This is 1-K 12 0 Do you know why she was there? 12 What have you seen him doing in the house? 13 A No. 11 A He came with his family. 14 0 Is that one of the people that was giving a 14 0 Every time that he's been in the house he's 15 massage, or Is that somebody else? 15 come with his family? 16 A I do not know. I do not !mow. 16 A No, no, no. He came with his family to spend 17 MR. CRITTON: I'm sorry. 17 a week. le THE WITNESS: No I do not see this. 18 0 Okay. And did his family come to the house as 19 BY MR. 19 well? 2o 0 1-G. that's not somebody you remember seeing? 20 A Yes. They stay there. 21 A No. 21 0 They stayed at the house? 22 0 I -H. do you remember seeing that person? 22 A This is Mr. Dershowitz? 23 A No. 23 0 Right. And hew many times have you seen 24 0 This is a hard picture to decipher maybe, but 24 Mr. Dershowitz at the house in the time period that you 25 do you remember seeing that face? And that's I -I. 25 were them? • flo Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 wvnitesguiresolutions.tom 3501.172-001 CONFIDENTIAL Page 29 of 38 EFTA_00070835 EFTA01247558 - Volume I October 20, 2009 109 111 1 in the house? • 1 A Two times. 2 O AM one of the times he was with his family? 2 A I cannot remember. 3 A Yes. 3 0 Do you know if Mr, Dershowitz has ever been in 4 0 And the other time is it safe to presume then 4 the houSe when the females would ume to the house to that he was alone? s give Mr. Epstein a massage? 6 A Yes. 6 A I told you, I do not lincnv. 7 0 During the tine that he was with his family. 7 0 You don't remember that? do you remember it Mr. Epstein received any massages $ A I don't remember that. 9 from females? 9 0 Okay. Do you know it Mr. Dershowitz has 10 A No. 10 received a massage while staying at Mr. Epstein's house? 11 0 You dont remember, or he did not? 11 A No. 12 A Oh. he was there when Mr. Epstein was not in 12 0 You don't know? 13 the house. 13 A I don't know. 14 0 Mr. Dershowltz and his family were in the 14 0 Do you know who that is? 15 house when Mr. Epstein was not in the house/ 15 MR. CRITTON: Let's get a letter now. or this 16 A Yes. They spend a week there. 16 is going to be a mess. 17 0 And Mr. Epstein was not in South Florida, you 17 MR. Not really, they're all in 18 moan. not in Palm Beach? Is order. 19 A No. 19 MR. CRITTON: For the record, you're going how 20 MR. CRITTON: That's correct? 20 about this person, and nobody is going to know who 21 BY MR. 21 you're talking about. This Is 'L.* 32 0 That's correct, my statement is correct? 22 MR. Yeah. 23 A Correct. 23 BY MR. 24 So no, he was not in the house? 24 0 Who Is i-L? 25 THE WITNESS: He was not in the house. 25 A 1-L? 110 112 1 2 3 4 BY MR. 0 So Mr. Dershowitz and his family were occupying the house in Palm Beach. and during that period of time Mr. Epstein was not staying at tie 1 2 3 4 0 A 0 A Who is this? Oh. Thars Ms. Maxwell. That's Ghislaine Maxwell? Yes, sir. • Palm Beach house? 5 0 That's somebody who you know? 6 A No. 6 A Yes, sir. 7 0 That's correct? 7 0 And you've seen her at the house before? A I think he was in Nil. B A Yes. 9 0 Oh. okay. This is a time period when 9 0 All right. And that's the same Ms. Maxwell 10 Mr. Epstein was in Mir? 1ci that hired you into the position, correct? 13. A (Nodding head). 11 A Yes. 12 0 That Mr. Dershovntz was at the house? 12 0 Do you remember seeing this person? 13 A Yes. 13 A Mars Igor. 14 0 Okay. Other than that time period there 14 MR. CRITTON: 15 was another lime period when Mr. Dershowltz was at the 15 BY MR. 16 house and he was not with his famay? 16 0 This is 144. 17 A Yes. 17 And how do you know Igor? 18 0 And how long ago was that? 18 A He's now in the house. 19 A Ch. I cannot remember when. 19 0 He's now in the house? 20 0 All right. Was it before Mr. Epstein went to 20 A Yes. 21 jal? 21 0 But when we listed the people, I wanted you to 22 A I think after. 22 list for me all of the people 23 0 So you think again Mr. Epstein was not in the 23 A I forgot. rm sorry. I forget Igor. 24 house. To the best of your memory. has Mr. Dershowitz 24 0 Is there anybody else that you think you 25 been in the house at the same time Mr. Epstein has been 2s forgot? • Toll Free: 866.709.8777 Facsimile: 561.394.2621 0 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vmmesquIresolutIons.com 3501.172-001 CONFIDENTIAL Page 30 of 38 EFTA_00070836 EFTA01247559 - Volume I October 20, 2009 113 115 1 A I think this is the only one I forgot. 1 A Because he aged. • 2 3 4 5 O And what is his role in Mr. Epstein's life, if you know? A He's a [Miter and he is trainer. O Trainer? 2 3 4 5 MR. CRITTON: He aged? THE WITNESS: He aged. MR. CRITTON: Okay. And this is *P.- 6 A (Nodding head). 6 BY MR O What do you mean by that? 7 O This is 1›.• 8 A Because I saw him telling Mr. Epstein, one e And this is, just so that you know. a fairly 9 more lap. 9 recent photograph of him, and you haven't seen him in 10 O One more lap where? 10 how long? 11 A In the swimming pool. And he said he's a 11 A After he left Mr. Epstein's employ. 12 trainer. 12 O So It's been numerous years since you've seen 13 O Who said he's a trainer? 13 this person? 14 A Igor. 14 A Yes. is O Igor toil you dial he's a trainer? 15 O So in fairness to you, that may be the reasor 16 A Yes. 16 why you didn't recognize this particular person? 17 O Okay. Do you know who that is? 17 A Yes. 18 A No. 18 O Okay. And if any of these preVious 19 O Never seen her before? 19 photographs were taken recently and you hadn't seen the 20 A Never. 20 person for five years. then that would be a possibility 21 O All fight. 21 as to why you don't recognize that person anymore? 22 MR. CRITTON That's It' 22 MR. CRITTON: Form 23 BY MR. 23 (Telephone ringing.) 24 O That's . 84.* 24 MR. 25 Do you ever remember a gil namedl=reming 25 MR. 11.4 116 • 1 to the nOuSe? MR. MI Hey, guys. I got cut off. Sorry. 2 A =I? I heard= 2 BYMIIMMEMMI: 3 O But you never remember seeing somebody M the O This is T.* That was Alfredo Rodriguez. 4 house that somebody referred to as=? 4 you've seen him In the house? 5 A No. I don't know their names if they come, I 5 A Yes. 6 don't know their names. 6 O How many months was Alfredo Rodriguez working 7 O But the name in this photograph, which is It' 7 there overlapping your employment? 8 you don't remember seeing her? 8 A I started November, December, and then — 9 A No. sir. 9 about three months. L0 O Do you know vtho Mat is? 10 O Okay. Do you know who that is? 11 A Yes. sir. 11 A Oh. You got that from my Facebook? 12 O Who is that? 12 O Do you know who that Is? 13 A My employer. 13 A That's me. 14 O And that is Mr. Epstein? 14 O Okay. You recognIze that. 15 A Mr. Epstein. 15 MR. CRITTON: That was *O.' 16 O All right. So Mr. Epstein is 'Or 16 THE WITNESS: Thank you. 17 A Correct. 17 a You made the book 18 MR. CRITTON: Right. 18 THE WITNESS: My niece made it for me. 19 BY MR. 19 MR. CRITTON: Next is 'R.' 20 O Do you know who that is? 20 BY MR... 21 A I don't know. 21 O you who this person is who is labeled 22 O Do you remember Alfredo Rodriguez? 22 1-R? 23 A Oh. That's Atredo? Oh. yes. 23 A No. 24 O Now that you look at the photograph. does it 24 O Never seen that person before? 25 look like Alfredo Rodriguez? 25 A No. • 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 CONFIDENTIAL Page 31 of 38 EFTA_00070837 EFTA01247560 . „ - Volume I October 20, 2009 I17 119 • 1 0 Has Mr. Epstein had anyone in the house that 1 0 Okay. Other than on the news. anybody around 2 you remember by the name of Martin? 2 the house ever say that? 3 A No. 3 A President Clinton? No. Lyn and Jojo. 4 0 Have you ever been on Mr. Epstein's planes? 4 0 Lyn and Jojo. What did they say? 5 A No. A Oh. not him. It's Kerry, Senator Kern'. they 6 0 Do you know this person who we are labeling 6 have a picture. 7 1-S? 7 0 Senator Kerry? 8 A No. A Yes. Clinton? Let me see. Oh, no. 9 0 You've never seen that person before? 9 0 So Lyn and Jojo, at some point In time, told 10 A Never. 10 you that Senator Clinton (sic) was at the New Yak al 0 Do you know the name Leslie Wexner? 11 house? 12 A I heard that one. 12 MR. CRITTON: No. Senator Kerry. 13 0 When did you hear about Leslie Wexner? 13 BY 14 A In the news, it was in the news. 14 0 or Kerry. Sorry. 15 0 Other than in the news, you have no idea who 15 ARemember when I was in New York she showed 16 Leslie Wexner is? 16 me a picture of them with Senator Kerry or Clinton, I 17 A No. 17 don't know, you know. 18 0 Have you seen that person before? 18 0 So either Kerry or Clinton was in a picture 19 MR. CRITTON: This Is 1-T. 19 with who? 20 BY MR. 20 A With Lyn and Jojo. 21 0 1-T. 21 And this picture was PaPatiedlY taken at the O 22 A This is the Duke of. what's this? 22 New York house of Mr. Epstein? 23 0 Prince Andrew. Have you ever seen 23 MR CRITTON: Form. 24 Prince Andrew in Mr. Epstein's house? 24 THE WITNESS: I don't know if it's In the 25 A No. 25 house, but they showed me a picture. 118 120 1 2 a 4 BY MR. 0 A MR. CRITTON: Next one is 'U.* I -U, have you ever seen this person? No. No. sir. 1 2 3 4 BY MR. 0 BY MR.- Oka This is 'W.* • 5 0 That's not somebody you recognize as ever 5 0 1-W, have you ever seen this person? 6 being at Mr. Epstein's house? 6 A No. 7 A No. 7 0 No? a 0 Do you know who this is? A No. 9 A President Clinton. 9 0 Do you know anybody by the name of 10 0 Have you ever seen President Clinton in the 10 Cecelia Stein? 11 house? 11 A Cecelia Stein? I heard about it. 12 A No. 12 0 How have you heard about her? 13 MR. CRITTON That was 'V'? 13 A Cecelia Stein. I know Cecelia that works in 14 MR. That's eV.- 14 the Office. 15 MR. CRITTON: 1-V is Clinton. 15 O Works in what office? 16 MR. *V' was Clinton. 16 A New York. 17 BY MR. 17 0 You think she still works in that office? 15 0 Have you ever seen him at the house? 18 A I don't know. 19 A No. 19 0 When was the last time you remember her 20 0 Have you ever seen him at all in person, 20 working in that office? 21 Mr. Clinton? 21 A I don't know. I just heard her name. 22 A No. 22 0 Okay. Through whom? 23 0 Have you ever heard that Mr. Clinton was ever 23 A Sometimes I think when I was in New York I 24 at Mr. Epstein's house? 24 answer a phone call, so that's... 25 A On the news. 25 0 You remember a time -- did you ever hear of • Toll Free: 866.709.8777 Facsimile: 561.394.2621 0 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolubons.com 3501.172-001 CONFIDENTIAL Page 32 of 38 EFTA_00070838 EFTA01247561 - Volume I October 20, 2009 12 1 12.3 1 her being relocated to some other location? 1 0 Do you know if he's a business associate or • 2 3 5 A No. MR. CRITTON: We an at 1-X now. BY MR O So 1-X is MM? 2 3 4 5 partner of Mr. Epstein? A No. 0 Had you seen him prior to this time that you recentty saw him alter Mr. Epstein was out of jal? 6 A Yes, sir. 6 MR. CRITTON: Form. 7 0 And you recognize-? 7 THE WITNESS: I cannot remember. A Yes. BY MR. 9 0 Okay. Do you know who that is? 9 0 Okay. Do you think that the first time that 10 A I saw him on magazines. 10 you ever saw this person was recently, when Mr. Epstein 11 0 David Copperfield, do you know who that is? 11 got out of jail? 12 A Oh. yes. 12 A Yes. 13 O And have you seen him at Mr. Epstein's house 13 0 Okay. 14 ever? 14 MR. CRITTON: So this is AA. 15 A No, sir. 15 BY MR. 16 0 Do you know Mr. Epstein to be friends with 16 0 Do you know who this is? 17 David Copperfield? 17 A No. 18 A No. IS 0 Have you ever seen him before? 19 0 If Alfredo Rodriguez remembers him performing 19 A No. 20 magic in Mr. Epstein's living room, you weren't at the 20 0 All right. 21 house at that time? 21 A He's an actor? 11 MR. CRITPON: Form. 22 0 Have you ever heard of the name Todd Meister? 23 THE WITNESS: No. Because I did not see him. 23 A No. 24 BY MR. 34 0 That's not somebody you've ever taken a 25 0 y. you ever remember anyone patenting 25 message for that's called? 122 124 1 A No. • 1 3 4 a Mgt show In Mr. Epstein living room? A No. MR. MR. CRITION: Z. What are we at? 2 3 4 0 Okay. The next one is Be. Do you know who that is? A That's Story. BY MR 0 Story Cowles? 6 0 Do you know this? 6 A Yes. I don't know Ns family name, but Story. 7 A Yes. What's his name. 7 0 When is the first time that you remember 8 0 Jean Luc Brunel. Do you know who that is? 8 seeing Story? 9 A Yes. 9 A First time? Mr. Epstein was in jail. 10 0 How do you know hirn? 10 0 Okay. And was than as a result of him bein 11 A He comes to the house. 11 at the house with , Story and Ms. 12 0 He comes to the house. When you say -he canes 12 A No. I don't think so. He came without 13 to the house' you've worked since November of 2004. 13 he came first without M. 14 five years when has he Come to the house? 14 0 And did he knock on the door? 15 A He came after At Epstein got out of jail. 15 A Yes. 16 0 And what 64 he do there? 16 0 Or does he have a key? 17 A He talked to Mr. Epstein, had breakfast. 17 A I think he knows the combination. 18 0 How long did he stay? 18 0 There is a combination to one of the doors to 19 A About a day. 19 gel access to the house? 20 0 Okay. So he stayed overnight at the house? 20 A Yes. 21 A Yes. 21 0 And Story Cowles is one of the people who has 22 0 And was he accompanied by any females? 22 the combination? 23 A No. 23 A Yes. 24 0 Do you know what he does for a living? 24 0 Who are the other people that have the 25 A No. 25 combination to get in Mr. Epstein's house? Toll Free: 866.709,8777 • Facsimiie: 561.394.2621 Suite 600 ESQUIRE Alota•44 GODS Cafes> 4440 PGA Boulevard Palm Beach Gardens, FL 33410 wyny.esquIresolutionS.Com 3501.172-001 CONFIDENTIAL Page 33 of 38 EFFA_00070839 EFTA01247562 MIMI Min - Volume I October 20, 2009 125 127 1 A Me 1 2 3 4 0 A Excuse me? Mc. O Okay. A Janusz 2 3 4 • 6 0 Okay. 6 7 A le7f. 7 MR. All right. 8 MR. CRITTON Are you done? 9 (P2' aga 9 MR Probably. 10 0 Who is that? 10 Do you need a second? Do you 11 A 11 need a break? 12 0 And when Story came to Mr. Epstein's house 12 Can we take a break? 13 weevil., how long ago was that, do you remember? 13 (Brief recess in proceedings.) 14 MR. CRITTON: Form. 14 MR. do you have questions. 15 THE WITNESS: How long ago? 15 too? 16 BY MR. 16 THE WITNESS: I'm hying to get a photograph 17 0 Yes. Was Mr. Epstein in lad, was it before 17 of somebody over there. I don't know if Esquire s 18 he went to jail? 18 going to be able to pant d, if they've got a 19 A Ch. The other day ho carne 19 color copier, or if I've lust got to run it over. withOtta. 20 0 But the other day Is not the first time you've 20 How much longer do youall plan on going, do 21 seen Story. right? 21 you know? 22 A Yes. 22 MR. CRITTON: About another fifteen minutes. 23 0 The other day was the first time you'Ve seen 23 I don't know. How long have you got, about 24 Story? 24 ten? 25 A No, no, no, na lead he on eilhoutMl. 25 About ten, fifteen. 126 128 • 1 O Right. This whole back and forth staled with 1 MR. CRITTON: I may have ten minutes worth of 2 me asking you when is the first time that you ever saw 2 questions. 3 Story. And I thought you responded by telling me that 3 MR. Well be another thirty minutes 4 he came to the house for the first time without. 4 at least. 5 I don't want to put words in your mouth. we'll start MR.. I might just get in the car and 6 over. 6 shoot over there. 7 A Okay. 7 MR. I think we're taking a break 8 O When Is the first time you saw Story? 8 right now anyway. A When Mr. Epstein was in jail. MR. CRITTON: Well, if we're going to lake a 10 O Do you know why he came to the house? 10 break, then I want to do a lunch break. Fve got 11 A No. 11 some stuff I have to do. If we're only going to be 12 O Do you know who he talked to when he was 12 fifteen or twenty minutes, that's fine. But if 13 there? 13 we're going to go another half hour, let's take a 14 A MB. 14 lunch break. 15 O And what did he talk Ict= about? 15 MR. It's going to lake a while. 16 A I do not know. 16 MR. CRITTON: So lets take a lunch break. 17 O Did he talk to about Jeffrey being in 17 (Brief recess in proceedings.) 18 Ian 18 (Continued to Volume 19 MR. CRITTON: Form. She said she didn't know. 19 20 THE WITNESS: I did not hear anything. 20 21 BY MR. 21 22 O Where did they talk? 22 23 A In the kitchen. 21 24 24 25 25 • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 WWW.eSquireSOlution5.COM CONFIDENTIAL 3501.172-001 Page 34 of 38 EFTA_00070840 EFTA01247563 I - Volume I October 20, 2009 129 1 STATE OF FLORIDA • 2 3 4 S COUNTY OF PALM BEACH I the fakirs good authority. certify that 6 personally appeared before me al the 20th 7 Cif October, 2009, and was duty Sweat 9 Dated this 30th day of October. 2009. 10 11 12 13 14 Teresa Whalen, APR. FPR 15 Notary Pubic Slate of Flonda My Commission Expires. 4/25/11 16 My Commission No.: DD 644533 17 Job # 118991 16 19 20 21 22 23 24 25 130 • 2 3 4 CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH Teresa Whalen. Regstcrad Protessfonal Reporter and Notary Public in and tor the Stale of 6 Flonda at Large. do hereby candy that the afctemenocned withess was by me Scst duly sworn to testify the whole truth that I was sues:M/0010 and ad report said depostiOn in stenotype, and 8 that the foregoing pages are a true and correct transcription Of my shorthand notes of said 9 deposition. 10 I further codify that said deposition was taken at the time and place hereinabove set forth 11 and trial the taking of said deposition was commenced and completed as hereinabOve Set Out, 12 I further certify that lain not attorney or 13 counsel of any of the parties. nor am I a relative or employee of any attorney a counsel of party connected 14 with the action. nor am I Mena* interested in the action. 15 The foregoing canniest= of this transcript 16 does not appty to any reproduction of the same by any meare unless under the direct control andfor drectIon 17 0l the certrlyng repater. 16 19 Dated this 30th day of October, 211:03 20 21 22 Teresa Whalen, RPR, FPR 23 Job 6 118991 24 25 • 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vnvw.esquiresoludons.com 3501.172-001 CONFIDENTIAL Page 35 of 38 EFTA_00070841 EFTA01247564 • • • 3501.172-001 CONFIDENTIAL Page 36 of 38 EFTA_00070842 EFTA01247565 • 3501.172-001 CONFIDENTIAL Page 37 of 38 EFTA_00070843 EFTA01247566 • • • 3501.172-001 CONFIDENTIAL Page 38 of 38 EFFA_00070844 EFTA01247567