Original Transcript
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
Plaintiff,
vs. CASE No.
502008CA028051XXXXMB AD
JESTRF.Y EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
October, 20, 2009
1010 a.m.
Reported By: Teresa Whalen, RPR, FPR, Notary Public. State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE No.502008CA028051XXXXMB AB
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
Tuesday, October, 20, 2009
10:10 - 3:30 p.m.
Reported By:
Teresa Whalen, RPR, FPR
Notary Public, State of Florida
West Palm Beach Office Job #118991
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA •
CASE No.08-CV-80119-CIV-MARRA/JOHNSON
4
Plaintiff,
-vs-
7 JEFFREY EPSTEIN,
Defendant.
9 Related cases:
08-80232, 08-80380, 98-80381, 08-80994,
10 08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
11
12
DEPOSITION OF
13 VOLUME II
14
Tuesday, October 20, 2009
15 10:10 - 3:30 p.m.
16
17
18
19
20
21 Reported By:
Teresa Whalen, RPR, FPR
22 Notary Public, State of Florida
West Palm Beach Office Job #118991
23 Phone: 800.330.6952
561.659.4155
24
25
•
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1 APPEARANCES:
2
On behalf of the Defendant:
3
ROBERT D. CRITTON, JR., ESQUIRE
4 BURI4AN CRITTON LUTTLER & COLEMAN, LLP
303 Banyan Boulevard, Suite 400
5 West Palm Beach, Florida 33401
6
7 On behalf of Plaintiff III.:
B
9
10
11
12 On behalf of the Witness:
13
14
15
16
17 On behalf of Defendants/
18
19
20
21 On behalf of Plaintiff in related Case No. 08-80811
22
23
24
25
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2
•
3 INDEX
4
5
6 WITNESS: DIRECT CROSS REDIRECT RECROSS
9 BY MR. 190
10 BY MR. 135 208
11 BY MR. 156
12 BY MR. CRITTON: 173
13
14
15 EXHIBITS
•
16
17
18 NUMBER DESCRIPTION PAGE
19 DEFENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103
20 DEFENDANT'S EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
21 DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 162
22
23
24
25
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2
PROCEEDINGS
3 Deposition taken before Teresa Whalen,
4 Registered Professional Reporter, Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
7
8 (Mr. joined the proceedings in person.)
9 CROSS (
10 BY MR.
11 O Good afternoon. Is it all right if I call you
12 1111111?
13 A Yes.
• 14
15
Q Okay. My name is
represent some plaintiffs in these cases, and it is my
, I also
16 turn to ask you some questions.
17 We were talking about when Mr. Epstein was in
18 jail, which was between June 30th of 2008 and July of
19 2009; correct?
20 A Yes.
21 Q Now, during that time you wont Lu wurk your
22 regular schedule at 358 El Brillo Way; is that correct?
23 A Yes.
24 Q So you were working basically --
25 MR. CRITTON: She's not finished.
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2
BY MR.
• I'm sorry. Go ahead.
•
3 : Do you need to expand on your
4 answer?
5 BY MR.
6 O Were you finished?
7 A I worked regular hours, but sometimes there
8 are times that I report eight, sometimes I report
9 nine o'clock.
10 Q And I believe --
11 A It's flexible
12 Q Okay. And it was after he left jail that you
13 started working at 6:00 a.m., correct?
14
15 •
A Yee.
So whether you start work at eight or nine is
•
16 your choice? When you say "it's flexible," it means you
17 can chose whether to come at eight or nine?
18 A Yes. When he was not there.
19 o Okay. it didn't matter whether you there at
20 eight or nine when he was not there, correct?
21 A No.
22 • And what kind of things did you do at the
23 house -- let me ask the question this way.
24 How were your duties different when he was nuL
25 there during the time he was in jail from when he would
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come there before he went to jail?
A When he was in jail?
3 • Yes.
4 A I clean the house.
5 • You had less to clean, is that fair to say,
6 because Mr. Epstein, I assume, based on your testimony,
7 there were much fewer people in the house than before,
8 correct?
9 A Yes. I made inventory of the linens.
10 Q I'm sorry?
11 A Of the linens, I made inventory of the liners.
12 Q Oh. Inventory of the linens?
13 A Inventory.
• 14
15
Q Okay. So you did that.
do to fill the time?
And what else did you
16 A Wash the clothes that was in storage, you
17 know.
18 O You washed clothes in storage?
19 A Yes. Because it was right there, so I just
20 wash it and then press if it needs pressing.
21 Q So he has clothes stored outside La the house?
22 A No. In the house.
23 O In the house. Okay. So even if they aadn't
24 been worn, you washed them, correct?
25 A And press them.
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2
MR. CRITTON:
THE WITNESS:
Form.
Yes.
•
3 BY MR.
4 Q What other type of things did you do while he
5 wasn't there?
6 A If there are plants, I attend to the plants.
7 Q Okay. Is that something you didn't do before
8 he went to jail?
9 A I do that also when before he went to jail.
10 Q Okay.
11 A If there are orchids or plants in the house,
12 then I attend to it.
13 • I guess my question is what kind of projects
14
15
did you work on when he was not there to fill your time
after he went to jail?
•
16 A Cleaning, tidying, just going around the
17 house. If I see something that needs painting, I tell
18 Janusz.
19 Q Now, are you paid on the basis of a yearly
20 salary, or are you paid weekly or monthly; how does that
21 work?
22 A We are paid twice a month.
23 Q Okay. That's when you receive your pay?
24 A Yes.
25 • I guess my question is this: say you have to
•
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take a half a day of work off, do you get paid for that?
2 A Yes. In my situation.
3 Q I'm sorry. In your what?
4 A In my situation I was paid.
5 Q Okay. So you're on like a fixed salary, if
6 you miss some time you still get the same amount of
7 money, correct?
8 A Yes.
9 Q And I take it that during the period in which
10 Mr. Epstein was in jail, you continued to receive the
11 same salary, plus a raise, I assume, at the beginning of
12 the year; correct?
13 A Yes.
• 14
15
Q So you continued to receive the same salary
that you did before Mr. Epstein went to jail, correct?
16 A Yes, sir.
17 Q Did Mr. Epstein ever pay bonuses or any extra
18 money to you?
19 A Yes.
20 Q What kind of bonuses did you receive?
21 A Yearly bonus.
22 Q You get a yearly bonus. When is that paid, is
23 that paid at holiday time, Christmas time?
24 A After the year.
25 Q At the end of the year?
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2
1 A
Q
At the end of the year.
At New Years?
•
3 A New Years.
4 • And this past year, when 2008 became 2009, how
5 much of a bonus did you receive?
6 A I did not receive any.
7 Q And what about before that, what kind of bonus
8 did you receive?
9 A The yearly bonus.
10 • Okay. What would be the amount of the yearly
11 bonus?
12 A Oh. For me? The last one I receive was
13 5,000.
14
15
• Okay.
salary of $42,000?
So this would be in addition to your
•
16 A Yes.
17 Q And this $5,000 bonus you would have received
18 in or about January 2008; is that correct?
19 A Not eight.
20 Q Pardon?
21 A Not eight. We did not get any bonus in 2008.
22 Q Okay. So when was the last time you received
23 a $5,000 bonus?
24 A I think 2007.
25 Q So it's been two years since you've gotten a
0 •
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1 bonus; is that correct?
2 A Let me see. Yes.
3 Q Okay. Did Mr. Epstein explain to you why he
4 wasn't giving you a bonus in the last two years?
5 A He did not personally told us.
6 • Did someone tell you why you were not getting
7 a bonus?
8 A Janusz was informed, and Janusz informed me.
9 Q Okay. Did Janusz give you a reason why you
10 weren't getting a bonus?
11 A Because of the economy, that's what he said.
12 Q Any other reason that he gave?
13 A No, sir.
14 Q Did you receive a $5,000 bonus for 2006 and
15 2005?
16 A It was different, it gradually increased.
17 Q Okay.
18 A It was not the same amount.
19 • what was the bonus in 2006 and 2005?
20 A 2005 was 2,000.
21 Q Uh-huh.
22 A And then the next is 5,000 and 5,000.
23 • Okay. So correct me if I am wrong, but in
24 January 2005 you received a $2,000 bonus?
25 A Yes.
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1
2
Q And at that point in time you had really just
started a month and a half before?
•
3 A No. I want to correct that. I receive a 500
4 after I started there November.
5 Q Yes. November of 2004 you started?
6 A At Christmas I receive, after Christmas I
7 receive $500.
8 Q Okay. So in January of 2005 you receive $500,
9 correct?
10 A Yes.
11 Q Then in January 2006 you received how much?
12 A 2,000.
13 Q And in January 2007 you received 5,000; is
14
15
that correct?
A Yes.
•
16 Q And in January 2008 you received no bonus?
17 A NO.
18 Q Is that correct?
19 A Correct.
20 Q Correct, you received no bonus?
21 A No bonus.
22 Q And the same in January 20U9, correct?
23 A Correct.
24 Q Has Mr. Epstein advised you, discussed with
25 you at all how much of a bonus you're going to receive
•
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after the holidays this year?
A No, sir.
3 Q Has anyone discussed with you what bonus you
4 will receive after the holidays this year?
A No.
6 Q Do you have any expectation as to what kind of
7 bonus you'll receive?
8 A I don't -- I did not expect anything.
O You testified earlier about Lyn, who is the
10 housekeeper in New York, correct?
11 A Yes.
12 Q Now, when was the first time you met Lyn in
13 person?
• 14
15
A
Q
In person? When I went to New York.
And when was the first time you went to
16 Now York?
17 A In 2006.
18 Q 2006. And was the reason you went to New York
19 in 2006 for Ms. Maxwell's party?
20 A No. It was Lyn I think had a surgery.
21 ✓ Okay. And you were there to UUVOL fox her
22 while she had surgery?
23 A Yes.
24 • And how long were you there?
25 A I cannot remember, but after her surgery, then
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2
we left to Palm Beach.
Q Okay. You don't remember how long it was?
•
3 A I cannot remember, because I've been there
4 like four times, or more than four times.
5 Q More than four times?
6 A Yes.
7 Q Okay. So this first time when she had her
surgery, you were the housekeeper then in New York while
9 she was out, correct?
10 A Yes, sir.
11 • But did she come into the house in New York
12 and that's how you met her while she was recovering, or
13 how was it that you met her at that time?
14 A We met her before her surgery, I met her
15 before her surgery.
16 Q i see. Then she went and had her surgery.
iv Now, when you traveled to New York, did you go
18 on Mr. Epstein's plane?
19 A No, sir.
20 Q How did you travel to New York?
21 A Commercial.
22 Q So Mr. Epstein purchased you a ticket on an
23 airline to fly to New York?
24 MR. CRITTON: Form.
25 THE WITNESS: Yes, sir.
0 •
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BY MR.
Q Now, let's talk about the other times that you
3 went, you traveled to New York. When was the next time
4 dfLeL Lyn LeevveLed ftoo het uuLyesy Lhal you weal Lo
5 New York?
6 A I think when she went to the Philippines.
7 Q Okay. She went for like a vacation to go to
visit her family?
9 A No. I'm not really good. There was time
10 went there because I think I sometimes interchange, but
11 I went they, nn, time herauee to rover up for
12 ms. maxwell's housekeeper.
13 Q Okay.
• 14
15
A
Q
And when she was having a party.
Okay. So those are two separate times?
16 A Yea. Two separate times.
17 Q Both relating to Ms. Maxwell?
18 A No. The first one was -- first one to cover
19 up for Lyn.
20 • Right. I understood that. But after that,
21 when you came back --
22 A There was a time -- I don't know the sequence,
23 but you know, there was a time I have to cover up for
24 Ms. Maxwell's housekeeper.
25 • I see. What's her name?
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2
1
Q
A Florena.
And then there was another time where you went
•
3 to work for this party that she had, correct?
4 A Yes.
Q Okay. And the fourth time?
6 A When Lyn went to the Philippines.
7 Q Okay. About how long were these visits each
8 time?
9 A Sometimes a week, two weeks, then there was a
10 time I stayed there for like a month.
11 Q Which was that, when she had her surgery, Lyn
12 had her surgery, or was this a different time?
13 A Oh, what's this? Let me see. I cannot
14
15
really, what's this?
• Take your time, take your time.
•
16 A Oh. When, what's this, Ms. Maxwell's
17 housekeeper, I was to cover up for her because tor jury
18 duty. And then she was not part of the jury, so my stay
19 there was, like, extended. That's how I was able to
20 help with the party.
21 • She did not get on the jury?
22 A Yes. she was called.
23 Q But you stayed anyway to help with the party?
24 A Yes.
25 Q I think I understand. Now, have you ever,
•
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1 while you've been employed by Mr. Epstein, traveled
•
2 anywhere else for work?
3 A No, sir.
Q Those trips to New York was the only time
a you've traveled?
A Yes, sir.
7 Q You've never gone to New Mexico or to the
8 Virgin Islands for Mr. Epstein?
9 A No.
13 (Plaintiff's Exhibit No. 2 was marked for
II identification.)
12 BY MR.
13 • Let me show you what's been marked Exhibit 2.
• 14
15
Does it look like the paper that you were talking about
earlier where you wrote the names and the time?
16 A Yee, sir.
17 Q Okay. So this is kind of a notebook or a
18 message pad notebook that was I think you said located
19 by the pantry?
20 A Yes, sir.
21 Q can you look through this and cell me if any
22 of these, point out any of those that are in your
23 handwriting?
24 : Take your time, look at each
25 one, and just tell him if you see any that you
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2
recognize your handwriting.
MR. CRITTON: You asked her to identify if she
•
3 sees anything in her writing?
4 MR. : Yes.
5 THE WITNESS: (Shaking head.)
6 BY MR.
7 Q Okay. I understand your response is that you
8 reviewed the various message slips included in Exhibit
9 No. 2 and none of them are your writing, correct?
10 A Yes, correct.
11 Q But you do recall writing messages on this
12 type of pad for Mr. Epstein, correct?
13 A Correct.
14
15
MR. CRITTON:
Mr. Rodriguez's deposition?
that was exhibit what at
•
16 MR. : Exhibit 1 at Mr. Rodriguez's
deposition.
18 MR. CRITTON: Okay.
19 BY MR.
20 O In the period 2004 to 2008 before Mr. Epstein
21 went to jail, do you recall whether there were females
22 who were sitting at the pool in the home at 358
23 El Brillo Way who were topless?
24 A There was one time.
25 One time you remember. Tell me what happened
0 •
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that time.
2 A I was tidying the living room, then not
3 really -- there was like part of the wall, so I saw one
4 female there but not really, I saw it like this side
5 (indicating), so...
6 Q She was at the pool, or inside the house?
7 A This side, not really frontal, but on the side
8 I saw only -- I saw her side, not really like...
9 : His question was, was she
10 inside the house or out by the pool when you saw
11 her from the side.
12 THE WITNESS: The question -- they were in the
13 pool.
• 14
15
BY MR.
• okay. So she was not wearing a bathing suit
16 top, correct?
17 A Yes.
18 Q Was she wearing a bathing suit bottom?
19 A I did not know.
20 Q And how did you -- did you do anything in
21 response to this?
22 A No. I went to, what's this, to kitchen and I
23 told Alfredo not to go to the pool.
24 Q And this was the only time you ever remember
25 seeing a girl who wasn't wearing a top at the pool?
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1
2
A
Q
Yes.
Were there frequently females at the pool to
•
3 the house?
4 A No. Not frequently.
5 Q Not frequently. Sometimes?
6 A Sometimes.
7 Q Mr. Epstein would travel with some females, I
8 think they would come on the plane with him to the
9 house; is that correct?
10 MR. CRITTON: Form.
11 BY MR.
12 Q You can answer.
13 A I cannot remember if they -- let me see. I
14
15
remember Because when Mr. Epstein arrives, most
of the time I'm already off.
•
16 Q Let me ask the question this way: Were there
17 Females other than who would come with Mr. Epstein
18 on the plane and stay at the house?
19 MR. CRITTON: Form, predicate.
20 BY MR.
21 Q Stay overnight at the house?
22 MR. CRITTON: Same.
23 THE WITNESS: I did not know if they came with
24 Mr. Epstein, I did not see.
25
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BY MR.
2 O Okay. There were females who would stay
3 overnight at the house, but you're not sure how they got
4 to the house; is Lhilt. Lai: W say?
5 A Yes.
6 Q Did any of the females who came to the kitchen
7 entrance to give a massage, did any of them stay
8 overnight?
9 A No, sir.
10 Q Never, correct?
11 A Yes, sir.
12 MR. CRITTON: Did you say correct and she said
13 yes?
• 14
15
MR.
MR. CRITTON:
:
Okay.
Yes.
Thank you.
16 BY MR.
17 • The girl at the pool who was topless, do you
18 recall what her name was?
19 A No.
20 • Do you recall how she got to the house or, you
21 know, what her purpose was in being there?
22 A I cannot remember.
23 O Was she a girl who had come to give
24 Mr. Epstein a massage?
25 MR. CRITTON: Form.
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1
2 BY MR.
THE WITNESS: No.
•
3 0 The females who came to give Mr. Epstein a
4 massage, did they ever use the pool?
5 MR. CRITTON: Form, predicate.
6 THE WITNESS: I did not see.
7 BY MR.
8 Q You don't know?
9 A I don't know.
10 • And again, this girl you saw topless was the
11 only one you ever saw who was in any stage of undress in
12 the pool area at the house; is that fair?
13 A Yes.
14
15
Q You mentioned in your testimony earlier that
there was a back massager that was in Mr. Epstein's
•
16 bedroom, correct?
17 A In the massage room.
18 • In the massage room. It was what, on the
19 floor, on the massage table, where did you find it?
20 A Sometimes on the, what's this, the table,
21 sometimes on the floor.
22 • So this would be a regular thing, you would go
23 in the room to tidy up and you'd find this massager,
24 correct?
25 MR. CRITTON: Form.
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THE WITNESS: Yes.
2 BY MR.
3 Q You referred to it as a back massager,
4 correct?
5 A Yes.
6 Q And did you do anything to this, did you put
7 strike that.
8 Did you put away this massager?
9 A I return it to the drawer.
10 Q Was that a drawer in the armoire?
11 A No. In the bathroom.
12 Q In the bathroom cabinet?
13 A Yes.
• 14
15
Q
A
Were there other items in the drawer?
Lotions.
16 • So thcoc were massage items --
17 MR. CRITTON: Form.
18 BY MR.
19 • -- that were in the drawer?
20 MR. CRITTON: Sorry. Form.
21 THE WITNESS: From Hodyworks, aroma massage
22 therapy.
23 BY MR.
24 • So there was Bodyworks lotions and this back
25 massager; is that correct, in the drawer?
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A Yes.
2 Q Anything else in the drawer?
3 A That's all. And I put some, like, hand
4 towels.
5 Q In the drawer?
6 A Yeah. On the side.
7 Q Was there any -- was there just one drawer
8 that was used for these massage materials, or was there
9 more than one drawer?
10 A There is only one drawer.
11 Q Would you do anything to this massager before
12 you put it in the drawer?
13 A No. I just return it there.
14
15
Q
A
Did you ever clean it?
There was one time I clean it.
•
16 Q One time you clean it. About how many times
17 did this happen that you picked up the massager and put
18 it in the drawer; did it happen many times?
19 A Yes.
20 Q So on this one occasion why did you clean it?
21 A Because I thought it was, like, dirty, so I
22 clean it.
23 Q Explain to me how it was dirty.
24 A There is -- the color is -- like you know
25 when -- like there is stains or something, you know,
0 •
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• 2
when something is not clean.
cleanliness, so I...
So I very particular about
3 Q Did you believe that there was a sexual fluid
4 on it and that's why you cleaned it?
5 A No.
6 MR. CRITTON: Form.
7 THE WITNESS: No.
8 BY MR.
9 Q Mr. Rodriguez testified that you disliked the
10 task of putting away the massage items because you had
11 to clean them of sexual fluids and that was unpleasant.
12 Is that not true?
13 MR. CRITTON: Form.
• 14
15 BY MR.
THE WITNESS: Not true.
16 Q So Mr. Rodriguez would be lying about that,
17 correct?
18 A Yes.
19 Q The way I asked that question was sexual
20 fluids, and that may be an ambiguous term. What if I
21 used the term "body fluids," does that change your
22 answer at all?
23 A No.
24 Q It's the same, you never cleaned body fluids
25 off of a massager, correct?
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1
2
A No.
MR. CRITTON: Wait. You said when he said
•
3 correct, you said no. Does that mean he's not
4 correct?
5 : Did you ever clean body fluids
6 off of a massager?
7 THE WITNESS: I don't know if it's fluid,
8
9 BY MR.
10 Q Did you ever clean body fluid off of any
11 massager?
12 MR. CRITTON: Form.
13 THE WITNESS: No.
14
15
MR.
CROSS (
: I pass the torch.
•
16 BY MR.
17 Q I'm the mysterious voice that was on the phone
18 before, and now you get the privilege of seeing me in
19 person. I'm teasing, the privilege is mine. I won't be
20 very long with you, I promise.
21 I want to follow up on this line of
22 questioning, though. The single time of the many
23 instances in which you put back what you believed to be
24 some kind of massage implement into the bathroom drawer,
25 you only cleaned it one time?
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• 1
2
A
Q
One time.
All right. And you said that it appearnl rn
3 you to be stained?
4 A Yes.
5 Q Did you have any idea of what it was that
6 caused the implement which you believed to be a massager
7 to become stained?
8 A No, sir.
9 Q So when you were asked questions about whether
10 it was bodily fluid or not, you had no idea what it was
11 that you were cleaning off that item that you believed
12 to be a back massager?
11 A Correct.
• 14
15
Q Okay. How did you clean the item that one
time that you believed to be a back massager?
1G A I use a paper towel, wet the paper towel and
17 wipe it.
18 Q All right. Where was the item stained?
19 A On the tip of the massager.
20 Q All right. And if someone has asked you this
21 and I missed it, I apologize. Describe Lot us what the
22 item looked like that you believed to be a back
23 massager.
24 A It's an elongated piece with a thing --
25 Q Elongated what?
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1
2
A
round part.
Elongated thing, and then on the tip is like a
So I thought it's used for massaging.
•
3 Q Did this implement have any kind of electrical
4 power, did it have a cord, did it have batteries, did it
5 move; do you know?
6 A I don't know.
7 • And the area that it was stained was where,
8 ma'am?
9 A On the tip of the, what's this.
10 • Can you describe for us what the stain looked
11 like?
12 A It looks like it's dirty, like brown thing.
13 • Was there any kind of material other than --
14
15
did it look like it was some kind of dried liquid on
there?
•
16 MR. CRITTON: Form.
17 THE WITNESS: I really don't know. I just,
18 what's this, dirty, so I just clean it. Because I
19 thought it was lotion because he have lotion there
20 for...
21 BY MR.
22 Q And it's a true statement you never complained
23 to anybody about your responsibilities for having to put
24 back an item which you believed to be a back massager
25 into the cabinet drawer in the bathroom?
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• 2
A No, sir.
: Hold on. I think your question
3 was, was it a true statement that.
4 BY MR.
5 Q That you never complained to anybody?
6 : Did you ever complain?
7 THE WITNESS: I never complain, because
8 my job to, so...
9 BY MR.
10 Q Was it always the same item, did you put it
11 back these many many times but only cleaned it once?
12 A Yes.
13 Q And you've never seen it in use, you had no
• 14
15
idea how it operates, if it operates at all?
A No.
16 Q I want to talk to you about the folks, the
17 ladies, the young girls, the young ladies, the women,
18 however you want to describe them, and ask you if you
19 can sit here today, close your eyes, and remember the
20 face of any of the folks that would come over and give
2i your boss, Jeffrey Epstein, massages?
22 A If I remember?
23 Q As you sit here today, if I asked you to close
24 your eyes, can you bring up in your mind's eye the faces
25 of any of the young ladies that would come over to
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1
2
Epstein's house and give him massages?
MR. CRITTON: Form.
•
3 BY MR.
4 Q Do you understand the question?
5 A Yes.
6 Q Okay.
7 A If you'll show me a picture then.
8 • No, ma'am. What I'm asking you to do, as an
9 employee of Jeffrey Epstein's for many many years, and
10 for many many years these ladies, young ladies, these
11 females would come to his house and give him massages,
12 do you remember the faces of any of them?
13 A Maybe one or two.
14
15
Q All right. Earlier you testified that
sometimes the same girl would come back, the same young
•
16 lady would come back more than one time?
17 A Yes.
18 • How many young ladies can you recall making
19 multiple visits to Jeffrey Epstein's house for the
20 purpose of giving him massages?
21 A Maybe two.
22 Q Maybe two?
23 A Yes.
24 Q And you can recall certainly their faces?
25 MR. CRITTON: Form.
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• 1
2 BY MR.
THE WITNESS: Yes.
3 Q Okay. So far there are at least two young
4 ladies who you can close your eyes and remember their
5 faces, right?
6 A Yes.
7 Q Are there more than two young ladies that you
8 can close your eyes and remember their faces?
9 A No. Maybe two.
10 Q Just two?
11 A Two.
12 Q Do you recall the names of any of these young
13 ladies
• 14
15
A
Q
No, sir.
-- who would come over?
16 A No.
17 Q The name doesn't ring a bell
18 to you at all?
19 A Excuse me?
20
21 A No, sir.
22 MR. : Let me show you a photograph and
23 see if you --
24 MR. CRITTON: Are you going to mark that
25 Exhibit 3?
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2
(Plaintiff's Exhibit No. 3 was marked for
identification.)
•
3 BY MR. CRITTON:
4 Q Pursuant to Mr. Critton's suggestion, we
5 marked that as Plaintiff's Exhibit 3, and ask you to
6 take a look at that photograph and tell me if you
7 recognize this individual depicted on Plaintiff's 3.
8 A I'm not sure.
9 Q All right. Earlier you were shown a binder
10 with a bunch of photographs in it?
11 A Yes.
12 Some of those photographs were of young
13 ladies, yes?
14 A I don't know their age.
15 Q Well, I didn't --
16 : Listen to the question. He's
17 just asking it you saw a binder with pictures of
18 young ladies in it.
19 THE WITNESS: Yes.
20 BY MR.
21 Q Okay. And many of those young ladies you were
22 able to say without any kind of doubt that you did not
23 recognize them, right?
24 A Yes.
25 You don't have that same degree of certainty
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for the young lady pictured in photograph Plaintiff's
2 Exhibit 3?
3 A That's right.
4 Q You don't know whether you've seen her or not?
A No. Yes.
6 : Hold on. She said no, yes.
7 THE WITNESS: I'm not so sure if I've seen
8 her, but you know, the face seems familiar.
9 BY MR.
10 Q You don't know how you would have met this
11 young lady anywhere else other than Jeffrey Epstein's
12 house, do you?
13 MR. CRITTON: Form, speculation.
• 14
15 BY MR.
THE WITNESS: What was the question again?
16 Q Sure. We were talking earlier about your
17 being unsure whether you had met this particular young
18 lady pictured in Plaintiff's 3, and my question is you
19 wouldn't have seen her someplace other than
20 Jeffrey Epstein's house, right?
21 A I'm not. sure.
22 Q Okay. But she is someone who very well may be
23 familiar to you?
24 A Yes.
25 Q Okay. Describe for me the two young ladies
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that you can remember when you close your eyes as being
2 one of the young ladies that would come over to
3 Epstein's house and give him massages. What do they
4 look like? Let's start with number one, what did she
5 look like?
6 A The picture that he showed me, what's her
7 name, Haley or something? I recognize that one.
8 Q Let me ask you, the two young ladies that you
9 can imagine that you can see in your mind's eye that
10 provided Epstein massages when you were working there,
11 were those young ladies both in the binder that was
12 shown to you earlier that was Plaintiff's Exhibit No. 1,
13 or are we talking about different ladies?
14
15
A I remember that lady there.
MR. : Just so that you're clear, I
•
16 don't know that she said that the first time.
17 THE WITNESS: Not this one.
18 : Not that one?
19 THE WITNESS: Not that one.
20 MR. : She said that.
21 BY MR.
22 Q She said that.
23 Which one is this, so we're clear?
24 MR. : And for the court reporter.
25 MR. CRITTON: What did she refer to?
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MR. : No, no, no. Let's get the exhibit
2 number rather than provide names.
3 : This should be 1-N from my
4 uuLes, "N" as in Nancy.
5 BY MR.
6 Q So you recognize 1-N there?
7 A I recognize one, that's the one that...
Q So you recognize this one lady, 1-N?
9 A No. I did not say I recognize her.
10 Q You don't recognize her. Okay. So why don't
11 we gn hark thrnugh the hnnklet and ycal ran tell me whn
12 it is that you recognize as the young lady who would
13 come over and give Epstein massages?
• 14
15
MR. CRITTON:
misstates her testimony.
Object to the form.
It was 1-F.
I think it
16 THE WITNESS: This elle. What's her -- I
17 remember this one, but I don't know if she gives
18 massage.
19 Let's get a number for that
20 one.
21 MR. : 1-F.
22 : I'm showing you what has 1
21 next en ir, right?
24 THE WITNESS: Yes.
25
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1
2
BY MR.
Q And you remember this person as someone who
•
3 would come over and give Mr. Epstein massages?
4 MR. CRITTON: Form.
5 THE WITNESS: I don't know if she give
6 massage, but I saw her in the house.
7 BY MR.
8 Q Okay. When I started the line of questioning
9 a few minutes ago, I asked you to close your eyes and
10 imagine the faces of any of the young ladies that would
11 come to Epstein's house and give him massages. You said
12 that you can recall two such young ladies, right?
13 A Yes.
14
15
Q All right. And so you don't remember whether
this lady in 1-F provided massages to Epstein, correct?
•
16 A Correct.
17 • So this 1-F lady isn't one of the two that you
18 can close your eyes and see as one of the young ladies
19 who would come over to provide massages, right?
20 MR. CRITTON: Form.
21 THE WITNESS: So I can only picture maybe one.
22 1 thought this
23 BY MR.
24 Q I'm sorry. I cut you off, that was rude, I
25 apologize.
•
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A Okay. Your question was if I can recall two
2 persons?
3 Q That was your testimony, yes, ma'am.
4 A I remember this one.
5 Q You remember this one, pointing to 1-F, you
6 remember this young lady?
7 A Yes.
8 But you don't know whether this young lady
provided massages to Mr. Epstein, correct?
10 A Correct.
11 0 And I guess back to my original line of
12 questioning, I asked you whether about young ladies you
13 can close your eyes and recall their faces as being
14 girls, young ladies, excuse me, who would provide
15 Epstein massages. Remember that?
16 MR. CRITTON: Form.
17 BY MR.
18 Q And you said that there were two such young
19 ladies that you recall in your mind picturing their
20 faces as young ladies who would come over and give
21 M . Epstein massages? Thac's what you testified to,
22 right?
23 MR. CRITTON: Form.
24 THE WITNESS: I get confused, because there
25 are -- some visitors come or female come, and
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1
2
then -- so I get confused, so I can't remember
this, and I'm telling you that I don't know if she
•
3 gives massages.
4 BY MR.
5 Q Let me give you chance to answer it again.
6 Okay. If you close your eyes and think back, are you
7 able to see in your mind's eye the faces of any of the
8 young ladies that would come over to your boss,
9 Jeffrey Epstein, for the purpose of giving him massages?
10 MR. CRITTON: Form.
11 THE WITNESS: No.
12 BY MR.
13 Q And how many years are we talking about where
14
15
these women would come, excuse me, these females would
come to Mr. Epstein's house for the purpose of providing
•
16 him massages, how many years are we talking about?
17 MR. CRITTON: Form.
18 : When she worked there.
19 BY MR.
20 Q When you worked there.
21 A If you show me pictures, then --
22 : No. Listen and answer the
23 question you're being asked. How many years do you
24 remember females coming to give massages to
25 Mr. Epstein during the time you worked there?
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• 2
MR. CRITTON:
THE WITNESS:
Form.
Since I work? And then one
3 year.
4 BY MR.
5 Q You started work in 2005, right?
6 A Yes.
7 Q All right. And this happened up until the
8 time that Mr. Epstein went to jail where these young
9 ladies would come over?
10 MR. CRITTON: Form.
11 TMR WITNESS: Refnra ha wpnr rn jail''
12 BY MR.
13 Q Yes, ma'am.
• 14
15
A
Q
Yes.
So we're talking about a period of years whore
16 this would happen, Light?
17 A Yes.
18 Q For the period of years that you were working
19 at Mr. Epstein's house where females would come to his
20 home for the purpose of providing him massages, you
21 don't remember the faces of any of them?
22 A You know, I just open the door and then I
23 cannot, I don't really, like, interact with them for a
24 long time.
25 But it is a true statement that you don't
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1
2
remember the faces of any of the females that would come
to your boss's house, Jeffrey Epstein's house, over the
•
3 period of years for the purposes of providing him
4 massages?
5 MR. CRITTON: Form.
6 THE WITNESS: No.
7 BY MR.
Q It's true that you don't remember any of the
9 faces?
10 A If you show me picture, then
11 Q No, ma'am. I'm asking you what you remember.
12 A No.
13 Q You don't remember any of their faces?
14
15
A
Q
No.
All right. Earlier you were asked about the
•
16 folks that are at Mr. Epstein's house, and it sounds
17 like one of those individuals is named Igor, the
18 trainer?
19 A Yes.
20 Q All right.
21 : Talking currently?
22 MR. Currently.
23 : Thank you.
24 BY MR.
25 Q When was the last time you saw Igor?
•
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A Today.
2 Q You saw him today?
3 A Yes.
4 Q When was Lhe time before that the last time
5 that you saw him?
6 A The last time?
7 Q Yes, ma'am. You saw him today. When was the
8 time before that that you saw him?
9 A One week ago.
10 Q All right.
11 A Because T was on vacation.
12 Q So you've been off for a week?
13 A Yes, sir.
• 14
15
Q So what day was it a week ago that you saw
Igor the trainer?
16 A
17 • You and I both looked for a calendar but there
18 isn't one up there. Today is Tuesday. You're talking
19 this past Friday or the Friday before that?
20 A I think 9th, October 9th.
21 • So that was the last day that you worked up
22 until Monday of this week?
21 A Yen, Air.
24 • And you worked October 9th and saw Igor,
25 correct?
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A Yes.
2 Q And what is Igor's last name, do you know?
3 A I don't know.
4 Q Does Zinoviev sound familiar?
5 A Because sometimes they called him Igor Z.
6 Q Igor "Z," is that what you're saying? Yes?
7 Igor then the letter "Z"?
8 A Yes.
9 • So you saw him October 9th, the last day that
10 you worked. Where did you see him, at Mr. Epstein's
11 house?
12 A Yes, sir.
13 Q Then you worked yesterday, right?
14 A Yes.
15 Q And you saw him?
16 A No.
17 Q When was the last time you saw him? You saw
18 him today?
19 A Today.
20 Q Ah. Okay. And what was he doing today?
21 A He was waiting to drive Mr. Epstein.
22 • Okay. Do you have any understanding that
23 Igor, Mr. Igor Z., left after you saw him on Friday
24 October 9th and came back for you to see him at
25 Mr. Epstein's house today?
0 •
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A Can you rephrase the question?
2 Q Sure. Do you know if he went anywhere in
3 between the last time you saw him before today and
4 October 9th?
5 A Janusz told me he will be on vacation.
6 Q He will be on vacation? When will he be on
7 vacation.
8 A The time that I will not be there.
9 Q Oh. You were both on vacation?
10 A Yes.
11 Q So he's back now from what you believe to be
12 his vacation?
13 A Yes.
14 Q No reason he can't show up for a deposition,
15 right?
16 MR. CRITTON: Form.
17 THE WITNESS: I don't know.
18 MR. : I don't know, either. Okay.
19 That's all I have. Thank you.
20 THE WITNESS: You're welcome.
21 MR. CRITTON: Can I switch with you?
22 CROSS (
23 SY MR. CRITTON:
24 Q , my name is Bob Critton, I represent
25 Mr. Epstein. I have a few follow-up questions based on
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1
2
questions that have been asked to you.
If I understood your earlier testimony --
•
3 well, let me ask you this: Do you have any personal
4 knowledge that any female ever gave Mr. Epstein a
5 massage; that is, were you ever present when a massage
6 took place?
7 A No, sir.
8 Q So you've been asked a lot of questions about
9 females coming to the house to give Mr Epstein a
10 massage, right? You've been asked a lot of questions
11 about that today?
12 A Yes, sir.
13 Q Okay. As to whether or not any female ever
14
15
gave Mr. Epstein a massage, do you have any personal
knowledge?
•
16 A No, sir.
17 Q All right You were asked a question by
18 Mr. and others as how many faces of the females you
19 remember who came to Mr. Epctoin'o houoo to give him a
20 massage, do you remember any faces. Do you recall those
21 questions?
22 A Yes.
23 • Okay. In fact, you're -- let me strike that.
24 Would it be a correct statement that you're
25 unaware of any females that came to his house that you
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know actually gave him a massage? Is that correct?
2 A Correct.
3 Q You were shown a document marked Exhibit 2
4 which was a bunch of message pads. Well, it was an
5 exhibit, a composite exhibit that included a lot of
6 message pads -- let me start again.
7 Exhibit 2 has a lot of message pads, I'm
8 sorry, a lot of papers. It looks like it has four
9 "Important Message" and then there's a place to list who
10 called, the date, and what the response should be;
11 correct?
12 A Yes.
13 Q All right. You were asked earlier by
• 14
15
Mr. whether you took phone calls for Mr. Epstein
from any females who called about giving a massage. If
16 I understood your testimony, no conversation that you
17 ever -- well, let me strike that.
18 If I understood your testimony, you never had
19 a conversation with a female who called on the phone
20 where the word "massage" was used?
21 A NO, sir.
22 Q Is that correct?
23 A Correct.
24 • All right. And when you were you responding
25 to Mr. ' questions about taking messages, did you
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2
just take -- that is, if a female called or a male
called or whoever called and you happened to answer the
•
3 phone, if they wanted to leave a message, did you fill
4 out a message pad?
5 A Correct.
6 Q All right. So it didn't have to be a female
7 who was giving a massage; it could have been a florist,
8 it could have been a friend, it could have been anyone
9 as far as ymn knnw7
10 MR. : Object to form.
11 MR. : Object to the form.
12 THE WITNESS: Correct.
13 BY MR. CRITTON:
14 Q Well, did anyone ever say I'd like to come
15 over and give Mr. Epstein a massage to you?
16 A NO.
17 MR. : I don't know if we talked about it
18 yet, but is an objection by one good for all, or do
19 we need to repeat everybody cloc'e objection?
20 MR. I think it's good for all.
21 : I'm fine with that.
22 BY MR. CRITTON:
23 Q If I understand your testimony, in the
24 approximately three years that you worked at
25 Mr. Epstein's house before June of '08, so it would have
•
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been the latter part of '05, '06, '07, and then '08
2 through June, on the rare occasion you might answer a
3 doorbell and someone might come in, that is, a female
4 might come in who purportedly was to give Mr. -- let me
5 strike that.
6 As to any of the females that came to the door
7 and punched the doorbell and you answered, do you know
8 why they were there; that is, do you have any personal
9 knowledge as to why they were there?
10 A Sometimes.
11 O Okay. And how would you know that?
12 A Either Alfredo will tell me that this one is
13 expected.
• 14
15
Q Who was going to give a massage?
something like that, or just that the person is
He might say
16 expected?
17 A No. Is expected.
18 • All right. And so if in fact -- let me strike
19 that.
20 During '04 -- I'm sorry.
21 MR. CR1170M: What did she say, '05 when she
22 started?
23 MR. She started November of 2004,
24 but then she just recently changed it to say she
25 started 2005, so I don't know.
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1
2
MR. CRITTON:
BY MR. CRITTON:
That may have been me.
•
3 Q Did you start in 2004, November 2004?
4 A Yes. November.
5 Q When you started in November of 2004 and up
6 through 2005, on how many occasions would you have
7 answered the door where a female was coming that Alfredo
8 said you can expect such and such?
9 Does that make sense to you?
10 MR. : Object to the form.
11 BY MR. CRITTON:
12 Q Do you want me to rephrase that?
13 A Can you rephrase it?
14
15
Q If I understood your testimony, your business
is tidying, keeping the house tidy, laundry,
•
16 straightening up, things of that nature?
17 A Yes.
18 Q All right. And that's most of your day when
19 you're there?
20 A Yes.
21 • And when you're off, you don't know what goes
22 on at the house?
23 A No.
24 Q Or for that matter any place else. If you're
25 not there, you have no personal knowledge what goes on
0 •
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• 1 at the mall if you're not there, right?
MR. : Form.
THE WITNESS: Correct.
4 BY MR. CRITTON:
5 Q All right. On approximately how many
6 occasions would you have ever answered the door during
7 the '04, '05 time period where a female came in and you
8 left them alone in the kitchen or offered them something
9 to drink? Are we talking three or four times, are we
10 talking five or ten times, or more or less?
11 MR. Form.
12 THE WITNESS: That specific time?
13 BY MR. CRITTON:
• 14
15
Q Yeah. During '04 and '05 from the time you
started in '04 through the end of '05.
16 A I cannot remember how many times.
17 • Okay. Was it often or rarely that you were
18 the one who actually let someone in the house?
19 A Rarely.
20 Q All right. And did you ever see a female
21 coming, and i'm not talking or , did you ever
22 see a female coming down the stairs into the kitchen
23 ever?
24 A Yes.
25 Q On how many occasions, your best recollection?
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2
1 MR.
she worked there?
What time frame? The whole time
•
3 BY MR. CRITTON:
4 Q '04, '05, '06.
5 A Rarely. Maybe.
6 Q Let me rephrase my question.
7 During the period '04 and '05, through the end
8 of '05; that is, November of '04 through the end of '05,
9 approximately how many times did you see someone, a
10 female, who would come from upstairs downstairs? And
11 I'm not talking about or or someone there
12 who was there regularly.
13 A Maybe three times.
14
15
Q Okay. And on the three times that you saw
someone come down the stairs, you saw them where, in the
•
16 kitchen?
17 A Yes.
18 Q Did anyone ever look upset?
19 A No.
20 Q Did anyone look like they were crying?
21 A No.
22 Q Did anyone look distraught?
23 A No.
24 Q Did any those people cry for help?
25 A No, sir.
0 •
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• 2
• During the entire time that you've been
working for Mr. Epstein, from November of '04 through
3 '05 did you ever hear a female cry for help?
4 A No.
5 Q Did you ever hear them yell out for help?
6 A No, sir.
7 • Did you ever hear someone scream for help?
8 A No.
9 Q Did anyone ever ask you to call the police?
10 A No, sir.
11 Q Did anyone ever tell you that they were
12 molested?
13 A No, sir.
• 14
15
Q
abused?
Did anyone ever tell you that they were
16 A No, cir.
17 Q Did anyone tell you that they had received any
18 type of physical harm?
19 A No.
20 Q Okay. Did anyone appear to have, at least
21 from your observations of their facial features, to have
22 been in any way emotionally upset or distraught?
23 A No.
24 Q Okay. You were asked a number of guest- nr
25 about what you observed or -- let me strike that.
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1
2 Mr.
You were asked a number of questions by
about what was taken from the house by the
•
3 police. Do you remember those questions?
4 A Correct, I remember.
5 Q Were you present when the police took certain
6 items from Mr. Epstein's home?
7 A No sir.
8 Q Do you know what the police have in their
9 possession?
10 A No.
11 Q Did anyone ever tell you what the police took
12 from the house, other than I think you said Janusz said
13 they took computers?
14
15
A I cannot remember he said computers.
remember pictures.
I
•
16 Q Okay. That's what Janusz told you?
17 A Yes.
18 Q But you have no personal knowledge?
19 A No, sir.
20 Q That's correct?
21 A Correct.
22 Q All right. You talked about a photograph of
23 what you described as an approximately four-year-old
24 girl and it looked like the back portion of a swimsuit
25 or some bottoms she had on was being pulled down a
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• 2
little bit?
A Correct.
3 0 Is that Mr. Epstein's Goddaughter?
4 MR. : Object to Lhe form.
5 BY MR. CRITTON:
6 Q Strike that.
Do you know whether or not that's a picture or
B Mr. Epstein's Goddaughter?
9 MR. : Form.
10 THE WITNESS: I was told that.
11 BY MR. CRITTON:
12 Q By whom?
13 A By Lyn.
• 14
15
Q
A
Lyn up in New York?
Yes.
16 Q All right- You were asked about what you
17 described as a back massager. Do you recall that
18 earlier? Mr. asked you and I think Mr.
19 In fact, I think all the other lawyers asked you that
20 question.
21 A Yes.
22 Q Is the item that you describe as a back
23 massager, have you seen that like -- let me strike that.
24 Do you know what Brookstone is?
25 A Yes.
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1
2
Q Is the item that you saw similar to something
that you've seen at Brookstone?
•
3 MR. : Objection to form.
4 THE WITNESS: Yes, sir.
5 BY MR. CRITTON:
6 Q You were asked a number of questions about
7 Ms. Maxwell. Do you recall that series of questions?
8 A Yes.
9 Q What was your relationship with Ms. Maxwell;
10 did you get along well with her, did you find her
11 difficult, easy going?
12 A I have a good relationship with Ms. Maxwell.
13 Q Okay. Did she always treat you with respect?
14
15
A
Q
Yes.
And I think you told us that she's the one who
•
16 actually hired you?
17 A Correct.
18 Q Was Alfredo Rodriguez the person responsible
19 for hiring you, or was it Ms. Maxwell?
20 A Ms. Maxwell.
21 • And when you started, you first said that you
22 thought -- well, let me strike that.
23 in your earlier testimony you said that
24 Mr. Rodriguez was your boss, and then you said well,
25 really we work side by side.
•
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So my question to you is was Mr. Rodriguez
2 your boss, or were you co-equals in the house and you
3 each had your own job?
4 A We have our own job. He told me he is my
5 supervisor.
6 • Okay.
7 A But Ms. Maxwell told us we have to work like,
8 you know, work together for the house.
9 Q For the good of the house?
10 A Yes.
11 • So if he needed help you'd help him, if you
12 needed help he was supposed to help you?
13 A Correct.
• 14
15
• Did Ms. Maxwell ever tell you that
Mr. Rodriguez was your boss, or only Mr. Rodriguez?
16 A Mr. Rodriguez tell me.
17 Q okay. was Mr. Rodriguez -- let me strike
18 that.
19 Mr. Rodriguez was working at the house when
20 you started?
21 A Correct.
22 Q And he continued for how long after you
23 started? That is, you started sometime in mid November
24 of '04, how many more months did he work?
25 A I think up to February.
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2
Q
A
February of '05?
'05.
•
3 Q And did he resign, or was he terminated?
4 A He was terminated.
5 Q Do you know why he was terminated?
6 A One reason I know is one time he did not bu•:
7 any food when Mr. Epstein came, the refrigerator was
8 empty.
9 Q Was that his job, to make certain there was
10 food in the house when Mr. Epstein came to town?
11 A It was his job.
12 Q All right. Did you consider Mr. Rodriguez an
13 honest person?
14 MR. : Object to the form.
15 MR. : Form.
16 THE WITNESS: NO.
17 BY MR. CRITTON:
18 Q Why not?
19 MR. Object to the form.
20 THE WITNESS: Because he used my name. He had
21 almost a fist fight with a gardener.
22 BY MR. CRITTON:
23 Q Was that Jerome?
24 A Jerome. And he used my name that I am a
25 witness of the time that Jerome comes to work. So
•
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Jerome talked to me, and I told Alfredo not to use my
2 name, because I don't keep tab of people's time coming
in and out.
I told Alfredo, if you ask me if Jerome is
here, I say he's here; if he's not, he's not. But I
6 don't tell you he came this time and that time. So I
7 was upset too with Alfredo, because I said that's a lie,
8 don't use my name.
9 Q All right. Now, you were asked some
10 questions, a number of questions as to what
11 Mr. Rodriguez testified at his deposition that he said,
12 Mr. Rodriguez, that you were disgusted with cleaning sex
13 toys. Do you remember that question?
• 14
15
A
Q
Yes. I remember.
And I think your testimony is you never had
16 that conversation with Mr. Rodriguez; is that correct?
17 A No, sir.
18 Q So I think you --
19 : Hold on. I think you said your
20 testimony is, she said no, sir. Can we be clear
21 what the question and answer was?
22 BY MR. CRITTON:
23 Q Did you ever tell Mr. Rodriguez that you were
24 disgusted with cleaning sex toys?
25 A No.
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1
2
Q All right.
MR. :
And if he said that, was he lying?
Form.
•
3 THE WITNESS: He is. He was.
4 BY MR. CRITTON:
5 Q If I asked you to assume Mr. Rodriguez said
6 that you were upset because there were pictures of
7 partially-clothed or naked women near a picture of the
8 Pope, I ask you to assume that he said that, would that
9 be true?
10 A That's a lie.
11 Q All right. Was there a picture of the Pope in
12 Mr. Epstein's house?
13 A Yes.
14
15
Q All right. Was that near any picture of any
individual in some state of undress?
•
16 A No.
17 Q Did Mr. Rodriguez ever lie to you?
18 MR. : Object to the form.
19 MR. : Form.
20 THE WITNESS: Using my name was a lie.
21 BY MR. CRITTON:
22 Q Okay. Did he ever ask you to lie tor him?
23 A One time.
24 Q What happened?
25 A Mr. Epstein was not in his house, he's away,
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• 1
2
and I receive a call from Alfredo, and he told me not to
answer any call from New York.
3 Q Did he tell you why?
4 A He said I'm going to help you and you help me.
5 So I did not know what he means by that. And then I
6 receive a call from one of the secretary, so they said
where are you, and I said the mall.
8 Q Were you in the mall?
9 A Yes.
10 Q All right. was it your day off? Were you
11 working that day, did you have to pick something up?
12 A I was off.
13 Q Okay. So you said the secretary called you
• 14
15
and you told her exactly where you were?
A Yes.
16 Q Did ohe ack you -- and then what happened
17 next? Let me ask you this question, did she ask you
18 where Mr. Rodriguez was?
19 A She did.
20 Q And what did you say?
21 A I don't know, but I chink I mentioned that I
22 receive a call from him.
23 Q Did he want you to cover for him?
24 MR. Object to the form.
25 THE WITNESS: i did not tell Helen that he
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1
2
asked me to cover for him.
BY MR. CRITTON:
•
3 Q Okay. And if I understood your testimony, he,
4 Mr. Rodriguez said if you get a call from New York,
5 simply don't answer it?
6 A Yes.
7 • Because that way what, no one could ask where
8 you were or anybody else was?
9 A Yes.
10 Q That's what you understood?
11 A That's what I understand.
12 MR. CRITTON: That's all I have. Thank you
13 very much, ma'am.
14
15
THE WITNESS:
REDIRECT
You're welcome.
•
16 BY MR.
17 • I have some follow-up questions.
18 Have you ever met with Mr. Critton before?
19 A Yes.
20 Q When was that?
21 A Yesterday.
22 • And where was that?
23 A In his office.
24 • And who called that meeting?
25 : That's privileged.
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1 BY MR.
2 • Q Okay. Was it your idea to meet with
3 Mr. Critton?
4 A No, sir.
5 Q Okay. So when Mr. Critton sat down and said
6 ma'am, I'm Bob Critton and I represent Mr. Epstein,
7 that's something you already knew from yesterday, right?
8 A Yes.
9 Q Okay. SO that was just a show for everybody
10 else in this room to make it seem like you had not met
11 before?
12 MR. CRITTON: It was for the record.
13 THE WITNESS: No, sir.
14 BY MR.
15 Q Okay. What did you talk about with
16 Mr. Critton?
17 MR. CRITTON: That's privileged.
18 MR. : You represent Ms. --
19 MR. CRITTON: She's my employee.
20 BY MR.
21 ✓ vo you understand this to be your aLLorney,
22 Mr. Critton?
23 MR. CRITTON: Well, I am her attorney.
24 is her personal lawyer, I'm her attorney vis-a-vis
25 her employment with Mr. Epstein, and that was a
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1
2
privileged communication.
MR. : This case has got nothing to
•
3 do with employment.
4 MR. CRITTON: I don't care. Take it up with
5 the judge. If I'm wrong, I'm wrong.
6 MR. : i assume you don't have
7 authority with you here?
8 MR. CRITTON: Pardon?
9 MR. : I assume that means you have
10 no authority as we sit here today?
11 MR. CRITTON: What? Am I supposed to give you
12 authority? Take it up with the judge.
13 BY MR.
14
15
Q Okay.
Mr. Critton, was
At this meeting with you and
also there?
•
16 A He is. He was.
17 Q Who else was at the meeting, who else was in
18 the room with you?
19 A Only and Mr. Critton and me.
20 Q How long did the meeting last?
21 A About an hour.
22 • Did you ever cry about a picture of the Pope
23 next to a girl in Mr. Epstein's house?
24 A No.
25 • All right. Now, you testified that
•
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Mr. Rodriguez on one occasion asked you to cover for
2 him?
3 A Not to answer the phone call from New York.
4 Q You don't know why he told you not to answer
5 the phone call from New York?
6 A He mentioned -- he said that one day I'm,
7 like, help you, and the other day...
8 Q You help me?
9 A Yes.
10 Q You don't know what that means, though?
11 A No.
12 Q And the time where there was some
13 confrontation between, or there was some dispute over
• 14
15
Jerome the gardener being at work or not being at work,
that's something that Mr. Rodriguez tried to bring you
16 into?
17 A Yes.
18 Q And was that with Mr. Epstein or with
19 Ms. Maxwell or Ms.
20 A Ms. -- again?
21 Q Okay. My understanding is that it was
22 Mr. Rodriguez who is saying is a witness
23 to whether or not Jerome was at work that day?
24 A Correct.
25 Q And who was he saying that to?
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1
2
A
Q
To Jerome.
Okay. So he's telling Jerome hey, Ms.
•
3 is a witness to you not being here?
4 A Yes.
5 Q Okay. And you said don't use my name any
6 more?
7 A Because Jerome talked to me and he said, he
8 mention to me what Alfredo told him, so I went to
9 Alfredo and talked to Alfredo.
10 Q Okay. And prior to the police coming to the
11 house, there was a massage table inside Mr. Epstein's
12 bedroom, right?
13 A Yes.
14
15
Q was that massage table there after the police
came to the house?
•
16 A No.
17 Q Okay. So before when you told us all they
18 took were photographs, do you know whether or not the
19 police also took a massage table?
20 MR. CRITTON: Form.
21 Strike that, withdraw the form.
22 THE WITNESS: I cannot always remember,
23 like...
24 : Hold on. Do you understand his
25 question?
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BY MR.
2 Q Do you know if the police took the massage
3 table?
4 A No.
5 Q You don't know who took the massage table out
6 of the house?
7 A No.
8 Q Okay. We were talking about a time period
9 where you worked one day and then the following day you
10 came in in the afternoon because you had received a call
11 from Ghislaine Maxwell. Do you remember that scenario?
12 A Yes.
13 Q When you received the call from
14 Ghislaine Maxwell, you didn't know at that time that the
15 police had ever been to the house, right?
16 A No.
17 : Hold on.
18 She didn't answer the question that you asked.
19 MR. I thought she had already said
20 no.
21 : I think the way yuu asked it,
22 it may have been nonresponsive, so why don't you
23 ask it again so it's clear.
24 BY MR.
25 O Okay. At the time when Ghislaine Maxwell
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1
2
called you to tell you you didn't have to come in until
the afternoon, at that point in time you didn't know
•
3 that the police had ever been to the house, right?
4 A No.
5 Q You found out for the first time that the
6 police came to the house when you arrived in the
7 afternoon to show up for work, right?
8 A Correct.
9 Q Okay. That call from Ghislaine Maxwell, your
10 schedule at that time was to show up, at the time when
11 this telephone call is taking place, was to show up at
12 eight in the morning or so, right?
13 A Correct.
14
15
Q So that call from Ghislaine Maxwell was
actually the night before she called you and said don't
•
16 come in until the next afternoon, right?
17 A I think in the same day.
18 Q All right. You told me earlier that she
19 didn't call that early, but she obviously called
20 sometime before you got to work?
21 A Yes.
22 Q All right. what time did she call?
23 A I cannot remember. You know, I have problem
24 with remembering days and what's this.
25 Q I can understand problems with memory. But
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• 2
when you say that you show up at eight o'clock, were you
a punctual employee to where you showed up on time?
3 A I am.
4
6
7
8
9
10
11
12
13
• 14
15
16
17
18
19
20
21 Okay. Do you remember that day if you were
22 scheduled to work eight or nine?
23 A I think nine.
24 Q Okay. I had understood your testimony, and we
25 can go back and look at the record some other time, I
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1
2
understood --
A I get confused, because during that time my
•
3 schedule was like sometimes eight -- I go nine,
4 sometimes I go eight.
5 • How did you find out around that time whether
6 you were supposed to report at eight or nine?
7 A Because we were told that we don't -- don't
8 baby the house. So since Mr. Epstein is not there, so I
9 report between eight or nine.
10 Q Okay. So when you say that you were a
11 punctual employee, that means that if you were supposed
12 to show up at eight you showed up at least by
13 eight o'clock, and if you were supposed to show up at
14
15
nine, you showed up at least by nine o'clock, right?
A Yes.
•
16 Q All right. Did you have a cell phone at the
17 time?
18 A I do.
19 • Did Ghislaine Maxwell call you on the cell
20 phone, or did she call you on your house phone?
21 A Cell phone.
22 • Were you already in the car on the way to
23 Mr. Epstein's house?
24 A
25 Q And were you already ready for work, ready to
0 •
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• 2
go to work?
A Yes.
Q And what did Ms. Maxwell say on the telephone
other than you can show up in the afternoon, anything?
A That's it.
Q All right. And did you ask why?
A No. I just thought that maybe she's giving
8 like half a day off, so I was happy.
9 Q Was Ghislaine Maxwell calling you from
10 New York, or was she in West Palm Beach?
11 A I don't know where she was calling me.
12 Q When you arrived at the house in West Palm
13 Beach, was Ghislaine Maxwell there?
• 14
15
A NO.
: You mean the house in
16 Dalm Beach.
17 BY MR.
18 Q Well, that's the house you went to work to
19 that day, right?
20
21
22
23 MR. . Okay. Understood.
24 BY MR. ;
25 Q
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2
3
4 A
6
7 A Yes.
8 Q Okay. So Ghislaine Maxwell is calling you
that morning then sometime either just before 7:30 or
10 just before 8:30 in the morning to tell you don't have
11 to show up until the afternoon; is that right?
12 A Yes.
13 Q And as we sit here today, you don't remember
14
15
whether it was just before 7:30 or just before 8:30?
A To be honest, sir, I cannot remember.
•
16 O All right. Is it fair to say that it might
17 have been even the night before?
18 MR. CRITTON: Form.
19 THE WITNESS: No.
20 BY MR.
21 Q You're sure that it was that morning?
22 A I think I'm sure it was that morning.
23 Q Okay. You seem to remember specifically
24 getting a telephone call from her and it was early
25 morning before you showed up for work?
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• 1
2 call.
A I cannot remember if it was early, but I got a
I don't know the time.
3 Q All right. Your schedule, just so that we're
4 on the same page here, you were either supposed to show
5 up at eight or at nine o'clock, and you can't tell us
6 which one, right?
7 A Yes, sir. Because I don't how to explain
8 this.
9 Q And you were not in the car at the time when
10 you received the telephone call from Ghislaine Maxwell,
11 right?
12 A Yes.
13 Q So we can all presume, it's a very safe
• 14
15
presumption at this point that the telephone call from
Ghislaine Maxwell was made to you prior to 8:30 in the
16 morning on that. particular morning, right?
17 A Yes.
18 Q Okay. Do you punch a clock so that we could
19 figure out what time you were supposed to be at the
20 house?
21 A No.
22 Q Anybody keep a track of time?
21 A Nn.
24 Q You've been asked a lot of questions about the
25 various females that showed up to the house to give
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2
massages, and the only reason you ever knew that they
were allegedly giving massages is that somebody told you
•
3 that, right?
4 A Correct.
S Q These females that showed up didn't show up
6 MR. CRITTON: Form.
7 BY MR.
8 -- with massage cards or hand you cards or
9 give you any other indication that they were giving a
10 massage other than somebody else told you that?
11 MR. CRITTON: Form.
12 THE WITNESS: Correct.
13 BY MR.
14
15
Okay. And when these females would show up,
they were of very young age; wouldn't you agree with
•
16 that?
17 MR. CRITTON: Form.
18 THE WITNESS: They may look young, but I did
19 not ask their age.
20 BY MR.
21 You know what a thirty year old looks like or
22 a forty year old or a fifty year old, and that's not
23 this classification of females that we're talking about,
24 is it?
25 MR. CRITTON: Form, argumentative,
•
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repetitious.
2 THE WITNESS: Yes.
3 BY MR.
4 Q You think that there were thirty year olds
S that showed up to give massage?
6 A No. Because there are people that look young
7 but, you know, they may be older than what they, how
8 they look.
9 Q And in the period of time from November 2004
10 through the time that Mr. Epstein went to jail, which is
11. 2008, you testified that he received from these females
12 two to three massages or visits from these females per
13 day every day, right?
14 MR. CRITTON: Form.
15 THE WITNESS: I said not every day. I
16 remember that, my answer.
17 BY MR.
18 Q Okay. But almost every day, fair?
19 MR. CRITTON: Form.
20 THE WITNESS: Yes.
21 SI MR.
22 • Okay. we're talking about -- and two of those
23 females that you remember over this four-year period you
24 remember being repeat visitors and that came more than
25 one time, correct?
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A Yes.
2 MR. CRITTON: Form.
3 BY MR.
4 Q The other ones --
S MR. CRITTON: Hold on. I want to put one
6 thing on the record.
7 MR. IIIIIIIIII: I don't break you up like this
8 every time.
9 MR. CRITTON: well, this ie the testimony that
10 you covered for almost three hours earlier today,
11 it's the same, it's not recross, it doesn't cover
12 anything that everybody else touched on in their
13 cross. I'm sorry, 1 mean it's not redirect. It's
14
15
the same material that you covered before.
MR. : Mark this point in the
•
16 deposition, too.
17 MR. CRITTON: Please do.
18 MR. : Thank you.
19 RIC MR.
20 Q The other girls that are coming on nearly an
21 everyday basis as females under the idea that they're
22 going to give Mr. Epstein a massage, besides the two
23 that you've described as repeat masseuses, are different
24 faces every day, right?
25 MR. CRITTON: Form.
•
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• 1
2 BY MR.
THE WITNESS: Yes.
3 Q So if you're only seeing them one time, that
4 could be the reason why you can't think back and
5 remember these particular faces of every single one of
6 these female girls, right?
7 MR. CRITTON: Form, leading.
B THE WITNESS: Yes.
9 BY MR.
10 Q Okay. So did you ever wonder how it was that
11 so many different young-looking female girls arrived at
12 Mr. Epstein's house, how he got in touch with this many
13 girls?
• 14
15 BY MR.
MR. CRITTON: Form.
16 ce Did you ever wonder?
17 MR. CRITTON: Form.
18 THE WITNESS: It was strange, but that's his
19 life, so I was there to work, to do my job.
20 BY MR.
21 • Okay. But while you were dviuy nun jvb, you
22 knew -- look, you didn't witness anything, like
23 Mr. Critton said, what was going on behind closed doors,
24 but you knew that there was sex going on between
25 Mr. Epstein and these young girls?
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2
MR. CRITTON:
THE WITNESS:
Form, argumentative.
I did not see, I did not go
•
3 upstairs and notice.
4 BY MR.
5 • I know you didn't see. You're still employed
6 by Mr. Epstein, right?
A I am.
8 • Mr. Epstein has hired you an attorney,
9 obviously?
10 A Yes.
11 Q You want to keep your employment with
12 Mr. Epstein, right?
13 MR. CRITTON: Form.
14 THE WITNESS: If he'll fire me, I -- you know,
15 they told me to tell, to be honest, to tell the
16 truth, my lawyers.
17 BY MR.
18 • Yeah.
19
20
21 A bunch of these girls are all alleging that
22 ML. Epstein was upstairs having sex with them and/or sex
23 acts with them, and that these were not massages taking
24 place. You're aware of those allegations now, right?
25 A Now I'm aware.
•
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MR. CRITTON: Form.
2 BY MR.
3 Q And had you ever heard that during these sex
4 sessions that Mr. Epstein would then offer these young
5 girls money, cash money to be subjected to sex; had you
6 ever heard that?
7 MR. CRITTON: Form.
8 THE WITNESS: I heard now.
9 BY MR.
10 Q And that if they agree to bring their friends
11 who are also of that same age group, that each friend
12 they brought over to his house he would then pay them
13 for recruiting a new friend. Did you know that?
• 14
15
MR. CRITTON:
THE WITNESS:
Form.
No.
16 BY MR.
17 Q Now it all kind of makes sense how he gets all
18 these young little girls over to his house, right?
19 MR. CRITTON: Form, argumentative.
20 BY MR.
21 • And nobody in the house has ever denied day of
22 what I'm saying, have they?
23 MR. CRITTON: Form. She didn't even answer
24 the last question and you're continuing on with
25 your argument.
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1
2
BY MR.
• Has anybody?
•
3 A I did not hear them talk about it, so I
4 cannot.
5 Q So now that you know what's going on in your
6 boss's house, are you still going to stay employed with
7 him?
8 MR. CRITTON: Form, argumentative, serves no
9 purpose.
10 THE WITNESS: Yes.
11 MR. Okay. Perfect. I don't have
12 anything else.
13 THE WITNESS: But if he fires me, you know.
14
15
MR.
RECROSS
Just a couple of questions.
•
16 BY MR.
17 • Tnis meeting that you had with Mr. Critton and
18 yesterday, where did it take place?
19 A In Mr. Critton's office.
20 Q Mr. Critton's office?
21 A Yes, sir.
22 Q And was it Mr. critton's office who called you
23 to advise you of the time and where to go for the
24 meeting?
25 A
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• 1
2 A Yes.
3 O Is that Mr. Critton's assistant?
4 assistant? You don't know.
5 MR.
6 BY MR.
7 I'm sorry. told
8 you where to go for the meeting?
9 A Yes.
10 Q You testified that Mr. Rodriguez was
11 terminated, according to your understanding, for not
12 buying groceries when Mr. Epstein came into the house;
13 is that correct?
• 14
15
A
Q
Yes.
Who told you that that was the reason?
16 A Ms. Maxwell told me that Alfredo should --
17 Ms. Maxwell told me that Alfredo should not -- Alfredo
18 should always like, I don't know.
19 : Answer the question you were
20 asked. Who told you that?
21 THE WITNESS: Ms. Maxwell.
22 I'm sorry.
23 BY MR.
24 Q Why did Ms. Maxwell tell you about the reasons
25 for terminating?
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2
A Because there was one time that I called the
agency that I'm going to quit.
•
3 Q okay. And why was that?
4 A Because Alfredo was not listening to my
5 complaints.
6 Q What were you complaining about?
7 A Like my hand was already -- like I have to
8 help in the kitchen and then, like, iron. So I said my
9 hand is numb already, and Alfredo did not even pay
10 attention. So I called the agency to find another job.
11 Q I'm confused. I thought you were employed
12 so you weren't employed by the agency at this point, you
13 were going to go back to the agency to find another job;
14
15
is that fair to say?
A Yes.
•
:6 Q And this is before you even complained to
17 Ms. Maxwell?
18 A I did not complain to Ms. Maxwell.
19 Q And that was because Mr. Rodriguez was your
20 supervisor, correct?
21 MR. CRITTON: Form.
22 THE WITNESS: At that time, yes.
23 BY MR.
24 Q Did that ever change, before Mr. Rodriguez
25 left the employment?
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• 1
2
A
Q
Yes.
When did it change?
3 A Because I was told that we have to work
4 together, but he was like, you know, like very bossy.
5 Q You didn't like Mr. Rodriguez, did you?
6 A No. I, what's this, I like him first, but
7 then he keeps on talking and talking and talking and
8 criticizing. And then he lied, there was one instance I
9 want to tell you that he also lied.
10 • Other than what you testified to before?
11 A Yes.
12 • Okay. Go ahead.
13 A There was one time I was still new, and
• 14
15
then --
Q I'm sorry. You were what?
16 A Still new. You don't understand my English.
17 Q That's okay. Take your time.
18 A What's this? Before I leave, I always, like,
19 go around tidy. And then that time the master bedroom
20 was closed, so I told Alfredo it's closed, so I went
21 back Co him. He said no, no, no, they went to the
22 movies. And I went back again, but then I feel that
23 it's not proper, so I knock again. No. I did not
24 knock, I went down again to talk to Alfredo. So I went
25 back again and knock, and then Mr. Epstein was in the
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1
2
bedroom.
And the next day Alfredo told me that
•
3 Mr. Epstein will fire me. And Alfredo, I was, what's
4 this. I was disappointed in Alfredo because he should
5 have told Mr. Epstein if he is like a good boss that it
6 was his fault because I'm still new there and I don't,
7 what's this, he was telling me that nobody is there in
8 the bedroom.
9 Q And so Mr. Epstein was going to fire you for
10 knocking on the bedroom door while he was in the
11 bedroom?
12 A That's what Alfredo said, told me.
13 Q Okay. But Mr. Epstein didn't fire you,
14
15
correct?
A No.
•
16 Q What was Mr. Epstein doing in the bedroom when
17 you knocked on the door?
18 A Maybe taking a nap. I don't know.
19 Q Was he in the bedroom with anyone at the time?
20 A I don't know.
21 Q You never heard anything else from anyone
22 about whether you'd be fired, is that basically what
23 happened after this?
24 A No. That was only from Alfredo.
25 Q Okay. So you were waiting to hear something
•
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• 1
2
from Mr. Epstein or Ms. Maxwell but you never heard
anything else; is that it?
3 A No.
4 Q You continued with your job, yuLreuL?
5 A Yes, sir.
6 Q Well, why did you speak to Ms. Maxwell about
7 the reasons that Mr. Rodriguez was terminated?
8 A Why I talk to Ms. Maxwell?
Q Yes.
10 A I think she called me to be in the house when
11 Alfredo comes.
12 Q To be in -- what do you mean?
13 A Because Alfredo at that time was on vacation.
• 14
15
Q Okay.
came back?
And they were terminating him when he
16 MR. CRITTON. Form.
17 BY MR.
18 Q I'm not understanding.
19 A Alfredo told me that he asked for a vacation,
20 so he was on vacation at that time.
21 Q Okay. That's when Ms. Maxwell spoke to you
22 about why she's terminating Alfredo?
23 A She didn't tell me that she's going to
24 terminate Alfredo, but she told me to stay in the house
25 because Alfredo will come and pick up his things.
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1
2
Q Oh. So she wanted you to watch Alfredo when
he came to pick up his things?
•
3 A Yes. And to get something, like a folder from
4 Alfredo.
5 Q Okay. And at that time the reason that she
6 gave you, according to your testimony, for terminating
7 him was that he had failed to buy groceries?
8 A She did not tell me that time that she is
9 going to terminate Alfredo because he did not buy, but
10 she was upset also that Alfredo did not guy groceries.
11 Q But that wasn't the reason she was terminating
12 him?
13 A I don't know.
14
15
Q Did she give any other
unhappy with Alfredo's performance?
reasons that she was
•
16 A No.
17 MR. : Nothing further.
18 MR. : I don't have anything.
19 MR. : Ma'am, can you just put your
20 telephone number on the record just so that we can
21 get in touch with you if we need to find you for
22 trial or something?
23 : You can contact me.
24 MR. : Even if, you know, God forbid,
25 the trial is a year from now and she's not an
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• 1
2
Epstein employee and you don't have it?
: I will be -- I'm her lawyer,
3 you can contact her through me and I'll find her.
4 MR. : Perfect. Good enough for me.
All right. Read or waive?
6 Read.
7 THE COURT REPORTER: Do you need to order?
8 MR. Yes.
9 THE COURT REPORTER: Who needs copies?
10 MR. CRITTON: Are you getting it typed?
IL MR. Yes.
12 MR. CRITTON: I'll take a copy, front page
13 only, mini, with a text.
• 14
15
MR.
MR.
: No.
: Yes.
16 (Witness excused.)
17 (Deposition was concluded.)
18
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1
2
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
•
3
4 I, the undersigned authority, certify that
5 personally appeared before me on the
6 20th of October, 2009, and was duly sworn.
8 Dated this 30th day of October, 2009.
9
10
11
12
13 Teresa Whalen, RPR, FPR
Notary Public - State of Florida
14
15
My Commission Expires: 4/25/11
My Commission No.: DD 644533
Job # 118991
•
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1 CERT:FT C:ATE
2 THE STATE OF FLORIDA)
3 COUNTY OF PALM BEACH)
4
5 I, Teresa Whalen, Registered Professional
Reporter and Notary Public in and for the State of
6 Florida at large, do hereby certify that I was
authorized to and did report said deposition in
7 stenotype; and that the foregoing pages are a true
and correct transcription of my shorthand notes of
8 said deposition.
9 further certify that said deposit Lou Wolk;
taken at the time and place hereinabove set forth
10 and that the taking of said deposition was commenced
and completed as hereinabove set out.
11
I further certify that I am not attorney or
12 counsel of any of the parties, nor am I a relative
or employee of any attorney or counsel of party
13 connected with the action, nor am I financially
interested in the action.
14
The foregoing certification of this transcript
15 does not apply to any reproduction of the same by
any means unless under the direct control and/us
16 direction of the certifying reporter.
17 Dated this 30th day of October, 2009.
16
19
20
J Zdate--.
21 Teresa Whalen, RPR, FPR
22 Job if 118991
23
24
25
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218
DATE:
TO:
October 30, 2009
•
IN RE: III. v. EPSTEIN
5 CASE NO.: 502008CA028052XXXXMB AD
6 Please take notice that on Tuesday, the 20th of
October, 2009, you gave your deposition in the
above-referred matter. At that time, you did not
waive signature. It is now necessary that you sign
your deposition.
As previously agreed to, the transcript will be
9 furnished to you through your counsel. Please read
the following instructions carefully:
10 At the end of the transcript you will find an
errata sheet. As you read your deposition, any
11 changes or corrections that you wish to make should
be noted on the errata sheet, citing page and line
12 number of said change. DO NOT write on the
transcript itself. Once you have read the
13 transcript and noted any changes, be sure to sign
and date the errata sheet and return these pages to
14 me.
If you do not read and sign the deposition
15 within a reasonable time, the original, which has
already been forwarded to the ordering attorney, may
16 be filed with the Clerk of the Court. I£ you wish
to waive your signature, sign your name in the blank
17 at the bottom of this letter and return it to us.
18 Very truly yours,
19
Teresa Whalen, RPR, PPR
20 ESQUIRE DEPOSITION SERVICES, INC.
515 North Flagler Drive, Suite 200-P
21 West Palm Beach, Florida 33401
I do hereby waive my signature
22
23
Cc: Via transcript: ESOUIRE
24 ROBERT D. CRITTON, JR., ESQUIRE
Job # 118991 , ESQUIRE
25
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CERTIFICATE
2
3 THE STATE OF FLORIDA)
4 COUNTY OF PALM BEACH)
5 I hereby certify that I have read the foregoing
6 deposition by me given, and that the statements
7 contained herein are true and correct to the best of
8 my knowledge and belief, with the exception of any
9 corrections or notations made on the errata sheet,
10 if one was executed.
11
12 Dated this day of
13 2009.
14
15
16
17
18
19
20
21
22
23
24 Job # 118991
25
Toll Free: 866.709.8777
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1
2
ERRATA
IN RE: III. V. EPSTEIN
SHEET
CR: TERESA WHALEN
•
3 DEPOSITION OF:
4 TAKEN: 10/20/09 JOB NO.: 118991
5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
6 PAGE # LINE # CHANGE REASON
7
8
9
10
11
12
13
14
15
•
16
17 Please forward the original signed errata sheet to
this office so that copies may be distributed to
18 all parties.
19 Under penalty of perjury, / declare that I have road
my deposition and that it is true and correct
20 subject to any changes in form or substance entered
here.
21
22 DATE:
23
24 SIGNATURE OF
DEPONENT:
25
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131:3
a 172:20
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136:2 211:12
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Ah 187:21 216:4 138:19
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204:21
bathing
149:15,18
binder
162:9,17
164:11
bottoms
182:25
Boulevard
calendar
171:17
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•
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•
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133:4 211:2
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belief 165:11 cards
186:6 214:7 177:24
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• citing
218:11
CIVIL
154:24
come
136:17 137:1
210:6
complaints
210:5
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135:19,22
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ENTER
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entered
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211:16
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CONFIDENTIAL Page 134 of 180
EFTA_00070978
EFTA01247701
•
•
•
3501.172-002
CONFIDENTIAL Page 135 of 180
EFTA_00070979
EFTA01247702
•
•
•
3501.172-002
CONFIDENTIAL Page 136 of 180
EFTA_00070980
EFTA01247703
S
•
3501.172-002
CONFIDENTIAL Page 137 of 180
EFTA 00070981
EFTA01247704
•
•
I- x
•
3501.172-002
CONFIDENTIAL Page 138 of 180
EFTA_00070982
EFTA01247705
•
•
•
3501.172-002
CONFIDENTIAL Page 139 of 180
EFTA_00070983
EFTA01247706
•
•
•
3501.172-002
CONFIDENTIAL Page 140 of 180
EFTA_00070984
EFTA01247707
•
3501.172-002
CONFIDENTIAL Page 141 of 180
EFTA_00070985
EFTA01247708
•
•
o
3501.172-002
CONFIDENTIAL Page 142 of 180
EFTA_00070986
EFTA01247709
I IMPOKIANi - MESSAGE I I IMPORTANT MESSAGE I
FOR Mit e 7IT.:i.. FOR
DATE -.5. Z -0 4 TAE DATE
M • -. 1 .e are- La C.:
OF .‘,.. OF
PHONE! PHONE/ •
MOBILE MOBILE •
TELEPHONED' • PLEASE CALL lk TELEPHONED CALL
'4
CAME TO SEd YOU WILL CALL AGAIN• : ..' CAME TO SEE YOU
WANTS TO SEE YOU- RUSH WANTS. TO SEE YOU RUSH
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RETUFINEO YOUR GILL SPECIAL ATTENTION • RETURNED YOUR CALL SPECIAL ATT9ITION
A
MESSAGE messAa—i -
Y.
Veils r Yr
at
SIGNED_
. 1114
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR
DATE MIE a_a(9) "
*
M Pr.
OF MY'
PHONE/
MCNIILE
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAMP IQ SAC YW WILL CALL ACiAIN CAM! 1 o 5P
-e YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WAN Ts TO SEE YOU RUSH
MIMEO YOUR CALL SPECIAL ATIENT1044 RETURNED YOUR CALL SPECIALMTENRON
MESSAGE ACSGAGE
-rincly Irrefro int.
SAae3/4. 6
"Tre.k.-cit, tv,urgo t siak
091 icaut
11" b 44. 310
SIGNED
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4 2_
(0.24 r-a t76..1
3501.172-002
CONFIDENTIAL Page 143 of 180
EFTA_00070987
EFTA01247710
1 1; I IMPOR IA NT MESSAGE
7- 3 •7 -
1 2:5_Lo it .)4. 4_ p.m:
Ta
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Ts
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M=MW! n
new ann./rimy
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tcy
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IMPORTANT MESSAGE IMPORTANT MESSAGE
rill T ol l - ipfi
DATE - TPAEll.t .:4 ) Ta
1
or OP
PHONE/ PHONE/
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TELEPHONED PLEASE CALL. TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN GAGE TO SEE YOU WILL CALL AGAiN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
FirruRNED YOUR CALL
MESS
SPECIAL ATTENTION PETUFMED YOUR CALL
MESSAGE
X SPECIAL. ATTENTION
•
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SIGNED al 01.
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3501.172-002
CONFIDENTIAL Page 144 of 180
EFTA_00070988
EFTA01247711
IMPORTANT MESSA GET OtittatfitStelitS40104
r- 142 t. ...
IA Ti' " 0 ' 64 TIME3_i'V Ar--.erAMb
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OF. ,
FOR
DATE
IA
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OF
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MOSHE . MOBILE
TELEPHONED ' .P1CASE CUL TELEPHONED PLEASE CALL
C.S.Mr TO .P"r Ybif WILL 0411AGAIN CAMC TO SEE YOU WILL CALL AGAIN
WANTS TO ste YOU 'Mita i WANTS TO SEE YOU RUSH
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RFTuRtirn'CX1R CAA. SPF_CIACATTPNRON RETURNED YOUR CALL SPECIAL ATTENTION
M. AUG
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s
3501.172-002
CONFIDENTIAL Page 145 of 180
EFTA_00070989
EFTA01247712
,,p/ANKVIREAril,! , IVIt_SSALIL I
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1.1DR,ft ?
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9#070Pitativ.. " c:#447/4rtabott., *4
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F V rn. (h W.
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SIGNED a
um
IMPORTANT MESSAGE IMPORTANT MESSAGE
FeR_Th —3 • - __
pa -- A M.
DATE _ 141 . TIME. t7 :XL 17.5 P.M
"7.1 (SCItOk,66, rr1r)
OF-- --',.
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pticoior PHONE/
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TE4pi ONED j PLEASE CALL TELEPHONED PLEASE CALL
To geg*il IVO_ CALL AtiALN CAM* Ill Stt You WILL CALL AGAIN
MIOS Tqat YOU 'RUSH WANTS TO SEE YOU RUSH
RETURNED XOLAS CALL 4PEdlAt ATTENTION T RETURNED YOUR CALL SPECIAL ATTENTION
14,5,....r.., meS3Acke
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CONFIDENTIAL 3501.172-002
Page 146 of 180
EFTA_00070990
EFTA01247713
IIVIII— VITFLIflaN a a avtrk.dicinim I / VIC .,Orn-11.-
FOR TOR bt
DATE DATE.443.1.1at nme_14.32._0
IA • CA-ravoik Co t. se lech
OF OF
PHONE/ PHONE/
MOTILE MCGILE.
TELEPHONED PLEASE CALL TI:LEPHOND PLFASF CAI I
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU LL AGAN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTF Pal ION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MEARARS
s Tega 'rt; vhf
Lek., 42 on ?1,4 GA "
a a
SIGNED SIGNED GSA
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR {-4 FOR
{:1O 5T.
-.15 A M.
DATE lot DATE TIME
IA r • LCoi Ay Wo>c_vvt,"
of OF 6 al, c..
PN0NTI PHONE/
MOBILE MOBILE
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL ALAN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPEOAL ATTENTION
MESSAGE FES-SAGE
P
?An. VIOVYN.G 11-6 uAU nit -yr.)
GedIA VAv
SiGNED
a
SIGNED tIN
3501.172-002
CONFIDENTIAL Page 147 of 180
EFTA_00070991
EFTA01247714
I • •• • •• "Imo/ • % •• •• • • • ••=•••bm•• • •—• •—•
" • " '"'•• '• • a “—a•--
FOR FOR /d 1144, ."IL
DATE C:11_ DATE II 0 Zi • yea CO et
cingzfra V ryihee. 14
J0 11
G I ) eTnA. ,kV4 -SOLttley
OF WYC Of
PHONE/ PHONE/
MOBILE MOBILE
PLEASE CALL
CAME TO SEE YOU WILL'CALL AGAIN
WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE
s CeII Ins IA
SIGNED -
IMPORTANT MESSAGE IMPORTANT MESSAGE
ron M ir -It FOR
DATE I II g:1O 1a
P.M. DATE TIME
M P VC* C
,
"aentorttit_
OF
PHONE/ PIIONEt
MOBILE MOBILE
TELEPHONED a Pkela TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL GALL AGAIN ewe To SEE YOU WILL CMS AGAIN
WANTS TO SEE YOU III: RUSH ■ WANES TO SEE YOU i RUSH
BEDEWED YOUR CALL SPEC IN ATTENTON ■ RFRJRNED YOUR CALL I SPECIAL ATTENTION
MESSAGE MCOCACE
!11'13236 c41 k..
SIGNED
ab
N. SIGNED RE4
3501.172-002
CONFIDENTIAL Page 148 of 180
EFTA_00070992
EFTA01247715
I INIYUKIAIN I MESSAGE I
FOS ,
DATE 1116104 Tim R. 4?
Lvt_
OF
PHONES
MOBILE
TELEPHONED PLCASS CALL
CAME TO SEE YOU WIL1. CALL AGAIN
WANTS TO SEE YOU RUSH
RETUMWO YOUR CALL SPECIAL ATTENTION
MESSAGE
\0E -P6 c...A
SIGNED
IMPORTANT MESSAGE impal -ANT mtsvists<
JA rl ignej-3.4v, . ]. .
tar.
DATE _ _ 4
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610 4., TimE imiE .• TIME LS:1S .
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CF ji OP
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cAME 10 t_t YOU WILL CAU1NOAN CAME TO$EE YU).
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_s__. FitiSii
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mcswoc MESSAGE
riA,efltc.:. Cofil Cli t k GS G Cell LI%
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CONFIDENTIAL 3501.172-002
Page 149 of 180
EFTA_00070993
EFTA01247716
Fon
MI". ; FOR rt•
DATE- 770 The V 3 7 1:21)
PM DATE h 7/114 TimE __,TEQ?
M S Ni M !key le_ -* TJAisi
OF
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' PHONE/
MOBILE_ :OGLE--I
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
I-V& -F-LAY MALI yci etkepasG ce-atAkyv,
ca4
SIGNED SIGNED I ad
IMPORTANT MESSAGE
.
FOR
DADE
OF OF
PHONE/ prewar
WOKE MOBIL!
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO sit YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
1-1 MESSAGE AESSAGE
Ca. 63 (LAW Id t; 4. (-9k C.41A Vole'
4-n S Ges>e_gy --orhovrota
ilk
SGNED 1,84 SIGNED RiN
CONFIDENTIAL 3501172-002
Page 150 of 180
EFTA_00070994
EFTA01247717
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR V 1 N. •
Time _t: (5.--.tho
DATE II 11 0 o6
p
M
OF m ...—..—
PHONE/ . 7 . " - . • . •
TELEPHONED PLEASE CALL TELEPHONED I PLEASE CALL
CAME TO SEE YOU WILL CALL AGMN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU _RUSH
RETURNED YOUR CALL SPECIAL ATTENTION I AMMO YOUR CALL SPECIALAT/0MM;
MESSAGE
VID4,0 ? VISTWal.
Ia 4t0Y -i_UN.
La E
SIGNED 114
(
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR .4/CFI.
LL.--
Ali. ±q5
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itA
1-4 DA PIA. DATE A
14 M M
OF OF
14 PHONE/
MOBILE
PRONE)
MOBILE
1-4E TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
14 MTScAGE —— MESSAGE
14
L
sa
a, a
.t.tNED. _ siGYED_ 11
ft
CONFIDENTIAL 3501.172-002
Page 151 of 180
EFTA_00070995
EFTA01247718
OF tq V Of
PHONE! PHONE/
MOBILE MOBILE
TELEPHONED PLEASE CALL TELEPHONED 1 PLEASE CALL
CAME TO SEE YOU 1PALL CALL AGAIN CAME TO SEE YOU VALI GALL AGAM
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
Cc) :1,1 call (nett c—ati 6rel,
SIGNED_ ,8 SIGNED
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR
DATE II 1 '404 TIME 6:K DATE TIME
Pd
P I
M r ch M
OF OF
PHONE/ PHONE/
MOBILE MOBILE
TFI FANCIED Pi FARE GM I TELEPHONED PLEASE Cal
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIALATTENTION
MESSAGE MESSAGE
\Gass Szsa
MeNA- T cukoci
al a
SIGNED SIGNED MA
3501.172-002
CONFIDENTIAL Page 152 of 180
EFTA_00070996
EFTA01247719
I IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR I-OR
II I I 'C.\ AM
DATE 2Z1 Time DATE TFAE Ni P.M.
ta 'v Ve
Ate' • ".
OF OF '
PMONF/
MOBILE MOSAX
TELEPHONED PLEASE CALL I t•LEPHLYIRD 111.M.St UALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOURCALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
I-c
t•-\•& hac AC. 6 4Citrie r
C AI Linn .
y\ne..fc
(Atli IC foryiertad
SIGNED Vf
4 ovni- *tic
SIGNED--
IMPORTANT MESSAGE
FOR
DATE
t
IMPORTANT MESSAGE
WE Sv rout
Pa
__.--
ror. /11. L
DA
• C-K •Ast
• a P.M.
M (t.) In
OF OF
PHONE/
alSa MOBILE
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAA•I CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSACc AESSAGE
al
SIGNED a.84 SIGNED DINI
3501.172-002
CONFIDENTIAL Page 153 of 180
EFTA_00070997
EFTA01247720
rF, imppfernirpmEsMoil
wa .:
4 -nmE z2ieo
FOR
DATE
IMPORTANT MESSAGE
.. 7 -c -
IP&
1.4 r--.C..):::IV‘SACt ..t .Nr Tyr
Of- OF
PHONE? PIEDNET
MORA E. MOBILE
TELEPHONED P=EAS[ CALL TELEPHONED PLEASECALL
to
10 SEE YOU 11:1110A:A AGAIN, CAME TO SEE YOU WILL CALL AGAIN
WANTS tc six roc) WANTS TO SEE YOU RUSH
RETURNED YOUR CALL, t ::1,111. A11t ION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
Ie
e
e k-?_6=tc_
it
ire SYNE° 1184
co IMPORTANT MESSAGE IMPORTANT MESSAGE
IL
FOR FOR J.T.
DATE I1'70/04 DATE IIt i
70/011 TIME 7:00 CPLµi '
Le IA ✓ j C.- 2.v• Li I—
OF OF
PHONE/ PHONE/
MOBILE MOBILE
TELEPHONED Pt EASE CALL TELEPFIONEO IN FARE cm i
Vr CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
Lo WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
Lo MESSAGE MESSAGE
La
Lo kaG 4-VIENVV, V IGt.J6 c-A
Ls
11 ; vv.
l
a
SIGNED 184 SIC flE0 11
3501.172-002
CONFIDENTIAL Page 154 of 180
EFTA_00070998
EFTA01247721
LIMPORTANT MESSAGE I ItORTANT MESSAGE I
NH FOR/14.3
DATE _ai.4.-2 -0 (4 . ___ TIME AA
Pb
m
CF OF_
PHONE! PHONE
MOBILE MOBIL
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALLAGMN CAME TO SEE YOU WA L CALL AGAIN
WANTS TO SEE WU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION REIURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAG
t ee--uv ni tj )(mgt.,
t8
S SIGNED
IMPORTANT MESSAGE I IMPORTANT MESSAGE
FOR FOR ?fit
DATE i C.,1 TAE 10111 Fm DATE
AN
PM
M V. I %., v9 y we. i nJ 6.; n pA. O2)1,11li.2 attandliThe li
OF OF
PHONE/ PHONE!
MOBILE MOBILE
TELEPHONED PLEASE CALL - TELEPHONED PLEASE CAI i
CAME TO SEE YOU WILL CAL.AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
811"‘
MESSAGE SSAGE I I
12 a , 4- v••••-.< vi .5
aL
your vet) ,
SIGNED __ m
1181 ill
ta
3501.172-002
CONFIDENTIAL Page 155 of 180
EFTA_00070999
EFTA01247722
IMPORTANT MESSAGE
OF
PHONE/ PHONE/
MOBILE MOBILE
TELEPHONED PLEASE CAL I lEIEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAR&
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURTED YOUR CALL SPEOAL ATTENTION Ili to!,NE0 YOUR CALL SPECIN.ATTEHTION
IESSAGE
SIGNED
IMPORTANT MESSAGE I IMPORTANT MESSAGE I
FOR FOR rt.
DATE ,‘
,..2i.junils
TIME P.M. DATE TIME I 2S PAL
8A 43C1AMAiS G ta MDUb ch
OF OF
PHONE/
MORE MOBILE C) IC
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL MEAGAN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECLAL ATTENTION RETURNED Yalli CALL' SPECS& ATTENTION
MESSAGE MESSAGE
r
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•
at
SIGHED It SIGNED Ili4
3501.172-002
CONFIDENTIAL Page 156 of 180
EFTA_00071000
EFTA01247723
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR Mc • -0• T • FOR M •
DATE ill 0 104 TIME a)
DATE ofjo4 TIME 4 42C)
',A e Go a 30.4 4-k alevalk
of OF
PHONE/ PIIONE/
MOBILE MOBILE
TELEPHONED PLEASE CALL ■ TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN ■ CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE you RUSH ■ WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION FcrunHED YOUR CALL OPCCIAL ATTCHTICH
MESSAGE MESSAGE
CYkee-SCS CeAlt `7- 143e-s6 oe4A inor.
-Ri re\
at
SIGNED Hu SIGNED '184
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR , ‘- ..r. . FOR H i -"\ 11E •
LM1E /0 TIME A.:I3 ej DATE t7 n A 0 TBE °V4O
M s - Y.- v.re a
FA M
OF OF
PHONE/ PHONE!
MOBILE MOBILE_
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WELL CALL AOAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTON RETURNED YOUR CALL SI/ECU/ATTENTION
MESSAGE MESSAGE
`.1) e.2&& ovii V) dr V k a: Oa C ab\ lelk
•
a
SIGNED. - HU OOHED "III
3501.172-002
CONFIDENTIAL
Page 157 of 180
EFTA_00071001
EFTA01247724
LIMPORTANT MESSAGE I I IMPORTANT MESSAGE I
FOR FOR GL,2
DATE H -4 4 - 40q time -
_.L4 ) d DATE
oF
OF
PHONE, E/
MOBILE MOE
PHONBIL
TELEPHONED ERIEVOA' TELEPHONED PLEASE CAL
TO SEE YOU WILL CALL AGAIN CAME TO SEE You PALL CALL AWN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNEDYOUR CALL SPEMLATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MERSAGF
LooLa-1,0
_o -rt Ca- A.DO
:XS& bit .
is Sr kictci.zieci
AS>r "5 0 0 lt ac i '
SIGNED SIGNED 4 1184
7.3
I IMPORTANT MESSAGE I IMPORTANT MESSAGE I
FOR FOR
DATE TIME j !C c-) DATE I 2-
117(10 7 THE I:304# .
M M 0 I-6rvi -- 61166-
OF_ OF
PHONI PI
MOBIL MOBIL
TELEPHONED INFASFewl [Fl FPHONFO pLI-SSF CM.L
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESkAer VFSSAGE
cPth2s6 i/sc, 2044./ y VIA i'l I
7 a
u1.--
OPA
SIGNED
1 I "A SIGNED
is
am
3501.172-002
CONFIDENTIAL Page 158 of 180
EFTA_00071002
EFTA01247725
IMPORTANT MESSAGE
TOR
DATE
,. J•"E
k1 17/04 fl z5j -
u se
M Cj'z_ re-ck
of
PPM PHONE
MOOLEW MOW
I ELEPWJNEU PLEASE CALL I ELEPHONED PLEASE OPAL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RENEWED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE
(.\) tftasa can
SIGNED_ SIGNED
IMPORTANT MESSAGE
FOR
DATE 12 O 12:4a• Am
45'
OF NY C, OF
PHONE/ PHONE/
MOBILE MOBILE
TELEPHONED PLEASE CALL 1=31111111=7:L .
CAME TO SEE YOU WILL CALL AGAIN =MVO 11/ CiMIT=Ill
WANTS TO SEE YOU RUSH WANTS T. TIMMM'S ■
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED Tr iva ID Ca ATTEN*$
MESSAGEr
raU .asit t57 Altities
if 0 Cosk5 a4-4 40.c
1'84
3501.172-002
CONFIDENTIAL Page 159 of 180
EFTA_00071003
EFTA01247726
I IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
FOR FOR MV. 3 •
DATE DATE I? 17/04 Tag 4'3a
L esiov We% no—
OF EF
PHONE/ PHONE;
MONLE MOBILE
IELtPTIONED
[..... PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CAD-AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSArE
?Laic C4) kw,
SIGNED HIM
IMPORTANT MESSAGE IMPORTANT MESSAGE I
FOR MY. 3ir
I ...,• ,_ _
AM
DATE I .7 /O I tia el Tea_s.._
L ar
M
OF OF
PHONE)
MOBILE vc._ OA t PHONE/
MCBEE
TELEPHONED Pt FLEE CAD_ TELEPHONED PLEASE CALL
CAW TO SFE YOU WILL CALLAGAN CAME TO SEE YOU WALL CALL AGAIN
WANT S TO SEE YOU RUSH WANTS TO SEE YOU ROSH
RETUNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE mg_SSAGE sta/A I I
0/ V.. ant CO rt rt..,1I 7 ..TtOte.A
\.
CD
a
rIGI"Er libi
3501.172-002
CONFIDENTIAL Page 160 of 180
EFTA_00071004
EFTA01247727
IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
FUR A 1? A1-1 FOR IA I.
DATE IV 9 /04 Thic DATE qt .) 0 el TimESSLa
\in i-1 AIL LT lekwq .&
Co7v,14it e, OF_.
PHONE/ PHONE/
MOORE MOBILE
TELEPHONED Pt EASE CCAL
L TPI ;PHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGA*, CAME TO SEE YOU WILL CALL AGAM
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAG/ MESSAGE
S c 116 -.1r.) L.(nIJ
VIOaSs Cal titivt
4 - /TYG, 1?6,,-1,,
0
I-4ov-I o
SIGNED Grim_
IMPORTANT MESSAGE
FOR V
17 pµ GATE TIME
DATE TMIE
1.4 M %-
OF OF
PHONE! PHONE/
MOBILE MOBILE'
TELEPHONED PLEASE CALL TELEPHONED PLEASE CAL/.
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGNN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
sr-MANED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
UtSSAUE
° Tea kr., t)o, T Taw wo
CeAkA ' •
lib
SIGNED P.{ SIGNED "04
3501.172-002
CONFIDENTIAL Page 161 of 180
EFTA_00071005
EFTA01247728
IMPORTANT MESSAGE
FORIC
DATE4iqo THIEL:a P.
OF
PHONE/
MOBILE
TELEPHONED PLEASE CALL
CAME TO SEEYOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE
v rafted
SIGNED
a
nI
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR 1
DATE ____ TIME
AM
PU. DATE it 16 o 4/ r v.21
______ m
Or of Y2 , . t_
PHONE/ PHONE/
mOEFLE MOBILE
TELEPHONED 26, PLEASE CALL TELEPHONED Ft E CALL
CAME TO SEE you WILL CALL AGAIN CAME Tn ACP VOII I LOJU.LACLUN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU
PETURNED YOUR CALL SPECIAL ATTENTION r RETURNED YOUR CALL ATTENTION
MFSSAGP MESSAGE
0 IN c cr -it, -6 okaiaksi,
L0.-.I J MC, • 62 c
Kulp_ irl
(Si -V-1' d 41 (gm ll'otti; _
La11 I( 11 # Y ? )
SIGNED
a
1 SIGNED
a
1114
3501.172-002
CONFIDENTIAL Page 162 of 180
EFTA_00071006
EFTA01247729
filtursw
. .4-
1. 0.4..44714
.....iii h .,e-., ...
time7_10 44;
ky..5 .iox ->c9:
— - v...
: .
r
Ptlilg3/4 4- .-
*. 10;V: • - .
.-.
1\ 22 .-'eN he‘P C. I 'VOA kmkt., aarro4j74
• _
'- --- I —
h:OCIJC4f • ...clonui. you
. _.
•;::
;StGNED 3ae.
I IMPORTANT MESSAGE
• FOR '
DATE 7 IX Oel me R' l‘ S
O
OF /
PHONE/
MOBILE
TELEPHONE-O PLVALSE CALL TELEPHONED PL c CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU a CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL CIM.ATTENTICN
MFSSAGF
5 tyke) tfi
A•WL ma
v • Alcr 1'45 ok
as
1184 SIG ^
am
Dm
3501.172-002
CONFIDENTIAL Page 163 of 180
EFTA_00071007
EFTA01247730
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR M i te
P.
DATE it I1 D4 fME ID: fr I 41) at_ Tim na
DATE
Li v a/YI EA Cori f6• Yield M• e 1)2? Yen
OF OF_
PHONE/ PHONE/
MOBILE MOBILE
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSTS
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YO( CALL SPECIAL ATTENTION
MESSAGE MESSAGE
.f Vleese Amu
S47 \nen° T ced6cE
SEINED_ 1184 SIGNED a
ritM ea Ir M:5 t IMPORTANT MESSAGE
•
FOR
DATE
Mr r.IS
Q4. TiME 10- Z) -' DATJ ThAEZi3dits
LI -
OF' -- OF
A BILE PHONE/
MOBILE
nopir,o 1 PI EssF nu, - TELEPHONCO PLEASE CALL
i EMS TO'BEE COU WEL CAU. AGAIN . CAME TO SEE YOU WU. CALL AGM
WANTS T9 SEE YOU RUSH 4. WANTS TO SEE YOU RUSH
Rcra15913:1121C,41. 4 SpECIALAITSPON RETURNED Sit CALL SPECIAL ATTENTION
....
Mg$SAGE "O.•••I• •
c
\u%
-7.7-47-4,vivtk,s leoktb-e.
L.t,LWL
..._
: vs 1184
CONFIDENTIAL 3501.172-002
Page 164 of 180
EFTA_00071008
EFTA01247731
I IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
Ace gl FOR •
DATE k ICIOC Then P DATE
TIME.
A4 M CAS Le- 14.).e,4 Y161—
OF OF_
PHONE/ PHONE/
MOBILE_ MOBILE.
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME 70 SEE YOU. WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
(-2‘ Ge-1 a CoAk \net-. 716.2se
\
SIGNED a SIGNED a
tiM 11.4
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR V. -3%-f CH
-3. t
DATE 0 TIME-51 l'4. PAe e l -- TIME PP
I I" 0. PM
M P-• ELY ?Chf 6 V /12 V 41 1 Ai se 7 VG
OF OF
PHONE/ PHONE
MOBILE MOCFLE
TELEPHONED PLEA= CALL I I-I FPHONED PLEASE CM!
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIALATTENTION REIVFNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
V\ ,...\(.- yov .-01-AVG:. k I G 21es cla41 14.0 ,4
dieci,..,,....s k>.s-i- p,,,s1,‘ ni WV Lr
z,...-a yb., C aiv t at{ Inds 'Ns a6..4. t s" 4 4,43---4rtair4
4- •\ nna. v...a vt.ohGv ‘,
SIGNED am
SIGNED NH Nw
3501.172-002
CONFIDENTIAL Page 165 of 180
EFTA_00071009
EFTA01247732
I IMPORTANT MESSAGE I I IMPORTANT MESSAGE I
FOR 1 01 Th
i FOR v. .t
DATE
nor TDAE DATE
-I O <
TRAE
v orgt
Oao M
.1v OF
PHONE: PHONE/
MOOR NOBLE
TELEPHONE() PLEASE CALA TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEC YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
fleas. 4J 14,-3
"2* T celc,d "
SIGNED 1414 SIGNED 1034
IMPORTANT MESSAGE
H/
FOR
-7/O
DATE 'WE
M
OF OF
PHONE! PHONE/
MOBILE MOBILE 1
WI FPHooro PLEASE CALL TELEPHONED PLEASE CALL
DALE TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS To SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL /MENTION RETURNED YOUR CALL SPEOAL ATTENTION
MESSAGE MESSAGE
Vie-7s4, ‘11 -11- S1, s2; cA
-37 c,c..0 Gil CIFIth Co..10 Y: yvEie j ./frO
\i / y MCSSED 4.5
a a
SIGNED_ It04 SIGNED nN
3501.172-002
CONFIDENTIAL Page 166 of 180
EFTA_00071010
EFTA01247733
I IMPORTANT MESSAGE I IMPORTANT MESSAGE I
FOR FOR
DATE O PM.
LI M
OF
PHONE/ I PI .0',1:7
MOMLEJ MOBILE
1
TELEPHONED
._ PLEASE CALL TELEPHONED PLEASE GALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALI. SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE
m707,/aCt" coil
1GzS G cal The, r 'Lige
SIGNED—
a, SIGNED
a
I IMPORTANT MESSAGE
FOR 1 :r
DATE ED
Mi a
OF Ot
PHONE/ PHONE/
PAORI F MOBILE
TELEPHONED PLEASE CALL ■ TELEPHONED • PLEASE CALL
CAME TO SEE YOU ■ WILL CALL AGAIN ■ CAME TO SEE YOU WILL CAU.AGAIN
WANTS TO SEE YOU RUSH ■ WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION ■ RETURNED YOUR CALL SPECIAL ATTENTION
mr.P.Ang ME
OU
II
c /Uri
71e. ?1 G eih, n. 1 ho-a
ciesrargiw yon-q,
• „messiiie Aniet-
a.
SIGNED 1:EA
tm SIGNED 11.4
it
3501.172-002
CONFIDENTIAL Page 167 of 180
EFTA_00071011
EFTA01247734
I IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR NY. -11:C FOR
$
DATE TIME 5° DATE TIME ••
M
OF OF
PHONE/ _ .
MOBILE MOBILE
TELEPHONED PLEASE CALL TELEPHONED X PLEASE CALL
CAME TOWE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN.
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
ROAM YOUR CALL SPECIAL/ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
\ e?sc cel kvA -
a•
SASHED — 11 SIGNED
IMPORTANT MESSAGE
FOR FOR
DATE DATE TIME
M M
OF
PHONE/
MOBILE
TELEPHONED - PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU • RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE
A
I;GIVO Ili
3501.172-002
CONFIDENTIAL Page 168 of 180
EFTA_00071012
EFTA01247735
,.IMPORTANT MESSAGE I I IMPORTANT MESSAGE
rCili_
, .__- DIAS._
AM
' PM TIME Imo 4
-. --
• —— Cf
Phti,:ii PHONE/
Na[slitg---- MOBILE
04:WOCIE0 Pti-l*thiti./c.: : ItULPHUNkU PLEASECALL
11s - ...11*er Y;;LI:
"vrameLiteAN CAME TOSEE YOU WILL CALL AGAIN
,TO SEE YOU . . , -' I . .: I WANTS TO SEE YOU RUSH
$14INEGYCIMP(1-1. SPFCIALPTTEN fICA ,. RETURNED YOUR CAU. SPECIAL ATTENT/ON
t
" Zy..s4 Lath Ilk,
fr k_ ),... ' ,>,;'.
• . .
..... . _. • Is
I IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR
DATE 14.2 0-5" TrMEIZ egf DATE
IA 1.r-ok.n A1:), - 7-•ert-Aen
Of OF
PHONE/ PRONE,
MOBILE
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WIU. CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGF Mt b.AGE
•
Vitb2s6 ceti met 1 6 _S? /k''
px kohne,
AIL I
SIGNED sIGNED moo
3501.172-002
CONFIDENTIAL Page 169 of 180
EFTA_00071013
EFTA01247736
IMPORTANT MESSAGE
FOR FOR (µY
DATE TIMEa t DATE kill I D ec TIME
IA CSCI\ k .-
a OF OF t9 C-
a PHONE/
MOBILE PHONE/
MOBILE
0 TELEPHONED PLEASECALL TELEPHONED PLEASECALL
0 CAMETOSECYOU WILLCAU.AGAIN CAMETOSEEYOU WILLCALLAGM
WANTSTOSEEYOU RUSH WANTSTOSEEYOU RUSH
RETURNED
YOURCALL,C SPECALATTENTION RETURNED
YOURCALL SPECIALMENTION
MESSAGE
r e MESSAGE
rde ecii/e/
9 Sc sis4 .) ?LS?Sc c..11 her
Fr- zetaisk
0
SIGNED la SIGNED
a
(
a
IMPORTANT MESSAGE IMPORTANT MESSAGE
a FOR ---J;T • FOR l el* cy
DATE i 1 11/n Ir uma DATE YU/Cir- ma 0,31OA4 ;
a
m ve - len SI/try M
OF OF
MOBIL MOBILE • • -
PHONE/
IELEPH P-EASECALL TELEPHONED PLEASECALL r)C
CAMETOSEEYOU WILLCALLAGAIN CAMETOSEEYOU WILLCALLAGAIN
WANTSTOSEEYOU RUSH WANTSTOSEEYOU RUSH
RETURNEDYOURCALL SPECIALATTENTION RETURNEDYOURCALL SPECIALATTENTION
AMan;
t
er‘..>e c croa
l i 16 ZS 6 coil T%%4 h' eka(--fr
13Z a
SIGNED It SIGNED-r-Aer—A:
CONFIDENTIAL
3501.172-002
Page 170 of 180
EFTA_00071014
EFTA01247737
I IMPORTANT MESSAGE I IMPORTANT MESSAGE
FOR FOR
A
DATE TIME DATE TIME -_ P
M M
OF OF
PHONE/ PHONE/
MOBILE MOBILE
TELEPHONED PLEASE GALL TeLermoNcO name CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL MINN
mural .° SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED VIM CALL SPECIAL ATTENTION
MESSAGE MESSAGE
Tkrial G e •-•
a.
SIGNED 1164 SIGNED
IM ANT MESSAGE
FOR
DATE TIME 2... t1
:1::g
al
i
MOST
TEL EPIO4D 1._ PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL i SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL AV Emnom
MESSAGE
Elk
SION TM
CONFIDENTIAL 3501.172-002
Page 171 of 180
EFTA_00071015
EFTA01247738
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR —3 •• ._
DATE .„„, 5. ioj
M Meft, i.e. I. 7
OF
PHONE,
MOBILE
eV PLEASE CALL TELEPHONED PLEASE CALL
-----
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALI. AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
IESSAGE MESSAGE
°Aar), -1-Lvice
\>>6n6 c.,11 ‘nro-inza-
1OO14.1..3 •
SIGNED
a
11 SIGNED
I
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR r FOR '3 .W
,---
OATS TIME
CI)
DATE I 4 1. 6 / 0 S TIME I •r et
M M v• lei vreal Get( Hank
OF ___ OF
PHONE/ PHONE/
MOBILE WORE -
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR GALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
me SSAGE MESSAGE
RAS LA/1j i G. c l •13.
----26‘" %nk
_/ 2- Lit 2..J.4 CA AFfkakk 6a
Cal .
40 rAIV .
SIGNED
a
,. 64 SIGNED IN
3501.172-002
CONFIDENTIAL Page 172 of 180
EFTA_000710I6
EFTA01247739
IMPORTANT MESSAGE
FOR AM
DATE
Le ma.ucia.
of OF—
PHONE/
MOBILE, PHONE/
MOBILE
TELEPHONED
D PLEASECALL TELEPHONED PLEASE CALL
CAMETO YOU WILLCALLAGAIN
SEE CAMETOSEEYOU WILLCALLAGAIN
WANTSTOSEEYOU RUSH WANTSTOSEEYOU RUSH
RETURNED
YOURCALL SPECIAL
ATTENTION RETURNED
YOURCALL SPECIAL
AUDITION
MESSAGE MESSAGE
1-7-01A In\ 1 .26•41,/ ti ;„
‘1% . › ct)la
(04 ki AG 4L a s irk W.F.
c i 4> •
S'ONED a
11
I IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR lAv - 3VE • FOR
DAE Ib TIME Z 5e: DATE 7O Oi
MI. GI]; t; LLJG'S v- M friavq/
OF OF
PHONE/ j %in IC."(71.•to
MOCKS to
I
i‘V‘V:ir .
PHONE/
MOBILE.
TELEPHONED PLEASE CALL TELEPHONED CALL PLEASE
CAMETOSEEYOU WILLCAM.AGAIN CAMETOSEEYOU WILLCALLAGAIN
WANTSTOSEEYOU RUSH WANTS
TOSEEYOU RUSH
RETURNED
YOURCALL SPECIAL ATTENTION RETURNED ATTENTION
YOURCALL SPECIAL
MESSAGE MESSAGE
Pt G ?SG x411 AAN te,sc —cc" tiiven
e S nv..) it) z4- T et/
SIGNED 1114
a SIGNE a
1114
7
3501.172-002
CONFIDENTIAL Page 173 of 180
EFTA_00071017
EFTA01247740
PMPORTANT MESSAGE IMPORTANT MESSAGE
FOR
A
DATE hi)
1.
it M
OF
PHONE/
MOBILE..
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
► CAME TO SEE YOU Will CALL AGAIN CAME TO SEE YOU I WILL CALL AGAIN
► WANTS TO SEE YOU RUSH 'HANTS To See You RUSH
RETURNED YOUR CALL SPECIAL ATTENTION' RE-TURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
T2a•V‘-•••""A`.. \to.. "OkAai -•••
QAA
0
► SIGNED SIGNED
0.
IMPORTANT MESSAGE IMPORTANT MESSAGE
r011
.••••
DATE T 'ME P.M DATE 13za
M
D OF OF
D. PHONE! PHONE/
Ds MOINLE MOBILE
TEICH IONCD PLCAOC CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGNN
0 WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
0 MESSAGE MESSAGE
9 ( - )2 cc .
P1e 11 1,E
0
. c atirri
SIGNED
all a
tIIM 1114
3501.172-002
CONFIDENTIAL Page 174 of 180
EFTA_00071018
EFTA01247741
IMPORTANT MESSAGE IMPORTANT MESSAGE I
FOR
DATE I 1 7.7 TYNE ZnfLt st
1 At. C:v I 14..:kok OF
PHONE/
MOBILE
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AEL01 CAME TO SEE YOU vas CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOURCALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MEC-SACS
kr^e)e reit. Veit-
at
SATED 118.
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR —IT • FOR
AM.
DATE 1 \ 2 z (c,-) TIME DATE TIME' PM
OF._ OF
pHONE/ PHONE/
MOBILE MOBILE
TOLE PHONED PLF.ASt CALI. TELEPHONED i•LLA0 CALL
CAME TO SEE YOU WILL CALL AGMN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL An EN TION RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
I S
1 ti
—3eci< ro-1
az 0
11
3501.172-002
CONFIDENTIAL Page 175 of 180
EFTA_00071019
EFTA01247742
rIMPORTANT MESSAGE I I IMPORTANT MESSAGE]
FOR FOR
DATE TIME 1'f 2 fl Or
• DATE TIFAE 5 ". PM
ir On
• OF Cs 2 ,02.1,‘ a
a PHONE/
MOBILE _
PHONE/
MOBILE
a TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
0 WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
a RETURNED YOUR CALL SPECIAL ATTENTION RETUFINED YOUR CALL SPECIAL ATTENRON
MESSAGE MESSAGE
II
R She
a
0 ceAt " 'rye c 211
4
4
a
a SIGNED
IMPORTANT MESSAGE IMPORTANT MESSAGE
a
FCR FOR
DAIS Inter TIME 1'2 O kitt.t./ DA-F TIME (9:43 P.M.
a . PA
Or OF
a_ PHONE/
VOBILE
PHONE/
MOBILE
k
I EL LPHONbD PLEASE CALL T EtEniONEO PLEASE CALL
as CALIE TO SEE YOU WILL CAU.ACIAN CAME TO SEE YOU WILL CALL AGAIN
a WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
a REIURNED YOUR CALL. SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION I
MEccrir MESSAGE
a
a SInc- st: \1Aelt -PAC ?Sr" 3tc,0 L\ Y^
a
4 E"; sks1 L 2:1c 2.ocl pin A-11'11 stl
S
SIGNED IN
AA SIGNED
3501.172-002
CONFIDENTIAL Page 176 of 180
EFTA_00071020
EFTA01247743
IMPORTANT MESSAGE IMPORTANT MESSAGE
Pori- FOR
DATE Pi_ TIME r DATE I 2/ f O7 Tin #!!
M
CYCO
OF CIF
PHONE/.
MOBILE \Chou./ 44 , MOBILE_
LCAM
TELEPHONED PLEASE CA TELEPHONED PLEASE CALL
TO SEE YOU WILL CALL AGAIN CAME 70 SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR GALL SPECIAL A
II PSNANP MESSAGE
SIne 1S Cern*: y vnIkvz5 ?\CPso cpAk
v 5.30 todk
SIGNED— SIGNED
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR FOR
DATE µ7 0 nmE4teto DATE
nmE Z:40 cit-4.
Of OF
', NONE/ PHONE/
MOBILE
TELEPHONED
CANE TO SEE YOU
PLEASE CALL
TOLL CALL AGAIN
MOBILE
TELEPHONED
CAME TO SEE YOU
PLEASE CALL
WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RENEGED YOUR CALL SPECIAL ATTENTION
MESSAGE MESSAGE
ck16,1 • \.‘f, cavil
S
steNrn - 1184 SIGNE NIM
3501.172-002
CONFIDENTIAL Page 177 of 180
EFTA_00071021
EFTA01247744
[ IMPORTANT MESSAGE I I IMPORTANT MESSAGE
FOR M • T
RILE 70:00 pa DATE I 127or TILE in' tn. c'
M 3 C C.1-17_.
OF 0 0.7.4 I:\
PONE/
MOBILE
TELEPHONED PLEASE CAI/ TELEPHONED PLEASE GALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION RETURNS) YOUR CALL SPECIAL ATTENTION
MESSAGE
'
Th4,s i S ‘AG ••• 1, GM/
Cc il . yt vsnn.126b.:- 'Pk 67,1A
C.41 tne)^
a
SIGNED_ - l'f
IMPORTANT MESSAGE IMPORTANT MESSAGE
FOR -3 . ' • FOR .3 1 'T
M. 2ta 041.--- f asi aA
DATE i 1 R Tr TIE . t) DATE i TIME •
IA li C ke t. -a. LI 1 I
OF OF
- --)
PHON
n
Wen ?..
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL I
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
ROUSED YOUR CALL SPECIAL ATTENTION PERMED YOUR CALL SPECIAL ATTENTION
MESSAGE AESSAGE
'`PI( -n Coil lAril, Ito 2 T it
I 1 .-- l
JANA. 2
-- -— - - . -
v 1n, ye'
i
Gi ) NA
„pA SIGNED _ TIM
3501.172-002
CONFIDENTIAL Page 178 of 180
EFTA_00071022
EFTA01247745
rIMPORTANT MESSAGE IMPORTANT MESSAGE
FOR J e--- FOR J.
DATE i laapi— . 1.35 DATE 2/2 / P S TimE atg
tr. M Ljewless a Mod
, 61.t/ , M Corson. moo.
OF IA E v v4 ..) puowa MIS: hi. OF
PRONE/ PHONE/
MOM NOME
TELEPHONED PLEASE CALL TELEPHONED PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TO SEE YOU WILL CALL AGAIN
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURKD YOUR CALL SPECIALMI*01110N RETUNEDYOUR CALL SPECUL ATTENTION
MESSAGE MESSAGE
. 7/rose cod 0 ,,eal
aujik- 4o 16 -le ynul eabnµl 79;)e or o si
2O 3 31O8
KNOW Nn7 HOW P1w Glnv40).
SIGNED
IMPORTANT MESSAGE I IMPORTANT MESSAGE
FOR 3 7 P .
FOR j -
10 ;
DATE 2131/0 C TIME /0.12 llie•LI-4
,......- DATE 7 /5/IS Time 0 CP •,c
IA r m 6Ven Ay, LeAl
OF /.5 67 OF
PHONE/
MOBILE MOBILE
TELEPHONED PLEASE CALL I I TELEPHONED X PLEASE CALL
CAME TO SEE YOU WILL CALL AGAIN CAME TOSEE YOU WILL CALL AGAIN
4
WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH
RETURNED YOUR CALL SPECIAL ATTENTION i RETURNED YOUR CALL SPECIAL ATTENTION
MESSAGE '7,4-air i r alei .Aer MESSAGE
2)&4
SIGNED_____ .
3501.172-002
CONFIDENTIAL Page 179 of 180
EFTA_00071023
EFTA01247746
3501.172-002
CONFIDENTIAL Page 180 of 180
EFTA_00071024
EFTA01247747