Case Document Filed Page EXHIBIT Case Document Filed Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO Case No Plaintiff Vs JEFFREY EPSTEIN Defendant I JANE DOE NO Case NO Plaintiff Vs JEFFREY EPSTEIN De ndant I JANE DOE NO Case No Plaintiff Vs JEFFREY EPSTEIN Defendant I JANE DOE NO Case No Plaintiff Vs JEFFREY EPSTEIN Defendant I Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Page Case Document Filed Page Page JANE DOE NO Case No VIDEOTAPED Plaintiff DEPOSITION Vs of JEFFREY EPSTEIN ALFREDO RODRIGUEZ Defendant taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Deposition Duces Tecum JANE DOE NO Case No Plaintiff APPEARANCES Vs MERMELSTEIN HOROWITZ P.A JEFFREY EPSTEIN BY STUART MERMELSTEIN ESQ Biscayne Boulevard Defendant Suite Miami Florida C.M.A Case No Attorney for Jane Doe Plaintiff and Vs JEFFREY EPSTEIN ROTHSTEIN ROSENFELDT ADLER Defendant BY BRAD EDWARDS ESQ and CARA HOLMES ESQ Las Olas City Centre JANE DOE Case No Suite East Las Olas Boulevard Plaintiff Fort Lauderdale Florida Attorney for Jane Doe and E.W Vs And L.M JEFFREY EPSTEIN PODHURST ORSECK BY KATHERINE EZELL Defendant West Flagler Street Suite Miami Florida Attorney for Jane Doe and Page JANE DOE NO II Case No Plaintiff APPEARANCES Vs JEFFREY EPSTEIN LEOPOLD-KUVIN Defendant ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida JANE DOE NO Case No Attorney for B.B Plaintiff RICHARD WILLITS ESQ 10th Avenue North Vs Suite Lake Worth Florida JEFFREY EPSTEIN Attorney for C.M.A BURMAN CRITTON LU171ER Defendant COLEMAN LLP BY ROBERT CRITTON ESQ JANE DOE NO Case No North Flagler Drive Plaintiff Suite Vs West Palm Beach Florida JEFFREY EPSTEIN Attorney for Jeffrey Epstein Defendant ALSO PRESENT JOE LANGSAM VJDEOGRAPHER Ives Dairy Road Suite North Miami Florida July a.m to p.m Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Page Page Pages to Case Document Filed Page Page A I dont remember sir The next page is a message in the upper left dated January from C.W Correct A Yes Thats the same that weve been talking about Correct A Yes That was at p.m Correct A Yes And you dont recall what that particular call was about Right A No sir The message dated January from Maria Do you see that on the bottom right A Yes Do you know who that is A I think I have a different page Youre a little ahead of me January MR CRITTON I think thats page THE WITNESS I dont remember who she was sir BY MR MERMELSTEIN You dont recall what that message was about Page A No sir What about the next page there is a message that Eva called A Yes Dated January A Yes Do you know who Eva is A Yes Who is Eva A The assistant comptroller from the New York office Do you remember her last name A Polish last name I guess She was Russian She is Russian actually Did you ever travel to any other residences that Mr Epstein had A No Are you aware he had a residence in the Virgin Islands MR CRITTON Form THE WITNESS Yes BY MR MERMELSTEIN And would he sometimes travel to that residence from Palm Beach A Yes Page Okay Do you recall on any occasion who would travel with him to the Virgin Islands MR CRITTON Form THE WITNESS No sir BY MR MERMELSTEIN I think we were talking about the money before the household account sometimes you gave gifts A Yes I was told to buy some gifts For whom A For the guests Okay And what kind of gifts A Shoes sweaters clothes So were you instructed to buy something in particular at a particular store A They would go to the store if they like something I will go after and pay them and retrieve it Okay So would this be a girl who was staying at the house A Yes Okay This was one of the girls who travelled with Mr Epstein to Palm Beach Correct A Yes Page And so Mr Epstein would instruct you to go shopping with this girl A Yes And instructed you to pay for whatever it is she wanted to buy A Yes Was there a price limit or anything of that nature A No sir So when the girl decided what she wanted you would A I would write them a check In that instance you would pay by check A Yes Any other instances where you gave gifts to girls at the instruction of Mr Epstein A No I was just told you know when they told me I will buy the item Im sorry A You know when I was told to purchase this item for them you know I will do that but not on any other occasions What do you mean not in any locations A Any other occasions Not any other occasions Okay Did you Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page Page Page ever buy flowers for a girl Now you said you never went inside the A Yes sir theatre Tell me about that A No sir A I was told to buy flowers and roses for a Okay How did you get to the flower girl performing in high school store Which girl was that A I called the girl to her cell and she A I dont remember the name sir will come to the back door and I give her the What was Mr Epsteins relationship to flowers this girl Was anyone else around at the time MR CRITTON Form A No sir THE WITNESS I think she was an And you mentioned this was a girl you had acquaintance friend seen before BY MR MERMELSTEIN A Yes She was a friend Was this girl who had come to give A Yes sir massages to Mr Epstein Now she was performing at the high MR CRITTON Form school in what capacity THE WITNESS I dont know if she was A There was like a like a play in the doing massages but she was at the house graduation for high school BY MR MERMELSTEIN A play for graduation What would she have been there for A Yes in the high school theatre there was A To visit him some kind of performance This was a high school girl who was Was it like a theatre production coming to visit Mr Epstein at the house A Yeah something like that I didnt go A She came to the house I open the door inside so I didnt know what was going on inside and I left you know Page Page Why do you say it was for graduation Did you take her to the kitchen like you A Because everybody was the graduation did outside there were parents there were a lot of A Yes people at the school So you brought her to the kitchen just Okay A lot of high schools have theatre like you did for the girls who gave him massages production companies and they put on plays Correct Correct A Yes sir MR CRITTON Form Did you ever pay her THE WITNESS It was towards the end of A I dont remember sir but probably I the year Well I think I overheard that did there was a graduation performance of some MR CRITTON Form move to strike kind speculation BY MR MERMELSTEIN BY MR MERMELSTEIN But you didnt go in so you dont know Why do you say you probably did A No sir A Because I was the only one paying But this was a high school student you well not the only one but you know but chances were bringing the flowers to Is that correct are I paid her but I dont remember that A Yes particular instance that I gave her money Had you seen this girl before at the El Is it fair to say that the girls who came Brillo Way property to the Palm Beach residence these are not the A Yes sir girls who are staying there the girls who came You had seen her a number of times were there to give massages Correct A Yes sir MR CRITTON Form Do you recall her name THE WITNESS Yes A I dont remember her name sir BY MR MERMELSTEIN Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page Page written down anywhere A No Its my understanding that and either came to his house alone to visit with Mr Epstein or brought other girls in their age group to Mr Epstein Were you familiar with that type of recruitment process of girls bringing other girls MR CRITTON Form THE WITNESS Yes BY MR EDWARDS Can you tell me more about what you know about girls bringing other girls that are relatively the same age to come to Jeffrey Epsteins house and to use your words have a good time MR CRITTON Form THE WITNESS Its hard to know who they knew But I think that was they feel better themselves when theyre in a group than going by themselves but I dont know somebody recruiting BY MR EDWARDS Okay And youve talked about at least referred to yourself I believe to the police and Page as well today as a human ATM machine Right MR CRITTON Form THE WITNESS Something like that I was supposed to carry cash at all times BY MR EDWARDS One of the primary reasons why you carried cash was to pay the girls in this age group of and for whatever happened at the house Right MR CRITTON Form THE WITNESS Yes BY MR EDWARDS Thats a fair statement Right MR CRITTON Form THE WITNESS Yes BY MR EDWARDS Okay And when lets use her for example would bring somebody else to the house did you pay as well as whomever she brought to the house pay them both A No I pay only one person Okay My understanding and tell me if this is wrong or you can corroborate this is that Mr Epstein would pay the girl that was actually performing whatever was happening in the room Page for now well call it a massage as well as anybody who brought that person over to the house they would both get paid cash Are you familiar with that MR CRITTON Form THE WITNESS No BY MR EDWARDS If brought another girl over to the house and stayed downstairs but this other girl went upstairs with Mr Epstein which one would you pay A I dont know because I was told who to pay And Sarah Kellen always told you A Sarah told me pay so and so So if we were going to ask anybody else about the exact method in terms of who would get paid and for what who would the people be I mean other than Mr Epstein who else could we ask these questions A Sarah Sarah Kellen A Yes She would know this A Yes What about Ghislaine Maxwell MR CRITTON Form Page THE WITNESS Youre talking about the boss I dont know BY MR EDWARDS To your knowledge was Ghislaine Maxwell aware of these girls that are in the age group of and coming to Jeffrey Epsteins house to have a good time MR CRITTON Form THE WITNESS I have to say something Mrs Maxwell called me and told me not to ever discuss or contact her again in a threaten way BY MR EDWARDS When was this A Right after I left because I call one of the friends for a job and she told me this but you know I feel intimidated and so I want to keep her out What exactly did she say First of all was this a telephone call A Yes she was in New York She called you on your cell phone A Yes Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page Page Page Is this the cell phone that was issued to precisely did she say you by Mr Epstein A She said I forbid you that youre going A No it was my personal phone I was to be that I will be sorry if I contact any of already her friends again Gone Okay other than you will be sorry if A Yeah this is three four months down the you contact any of my friends again did she say road anything else about what you know about Mr So if you left in Epstein and/or what goes on at his house A February March it was May or June A She said something like dont open your Of mouth or something like that But you have to A Yes understand Im a civil humble I came as an And you got a call from Ghislaine Maxwell immigrant to service people and right now you out of the blue feel a little Im and Im afraid First of A Yes all I dont have a job but Im glad this is on And do you know what prompted that tape because I dont want nothing to happen to me telephone call This is the way they treat you better do this and A Because I contact somebody in New York to you shut up and dont talk to nobody and get a job When you say this is the way they treat Who was that person who specifically are you talking about when you A I contact Jean-Luc and I contact Eva the say the word they Swedish girl she used to be very good friends A Maxwell with Mr Epstein because she asked me she need And usually when you say the word they somebody in New York youre not only talking about one person What does Eva do A Wealthy people A Eva was a model many years ago and he Are you also putting Jeffrey Epstein in Page Page married Eva is the mother of the girl who was that category on the wall MR CRITTON Form Who is on the wall of Mr Epsteins THE WITNESS I didnt talk to him house directly most of the time A Yeah BY MR EDWARDS All right There is a younger girl model Whats the reason why if you were his thats on the wall of Mr Epsteins house and this head of security that you wouldnt have more lady Eva is her mother direct contact with him Why is that A Yes MR CRITTON Form And at some point in time you called her THE WITNESS He wanted that way you in New York to get a job know so yeah I have to talk to Sarah A Thats right Sarah is not available talk to Lesley in New And you also called Jean-Luc Bernell York He didnt want to be disturbed Thats his name Right BY MR EDWARDS A Jean-Luc yeah I dont remember his last Even while you were in the same house name with him he still had other people you could talk Does that sound familiar to you Jean-Luc to directly but he was not one of them Bernell A Yeah A Yeah When you were fired you were not fired What did Eva and/or Jean-Luc say about directly by him employing you A No A No they said theyre going to find out It was through somebody else and obviously the first thing they did was talk to A Ms Maxwell Mrs Maxwell Okay But it was for upsetting him for She made a telephone call to you and what taking the wrong car Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page Page A Yes Okay Ever since this communication that Ms Maxwell made to you where she called you sometime in May or June of and have you felt threatened A Yes MR CRITTON Form BY MR EDWARDS Have you felt reluctant to come forward and give truthful honest and full disclosure of all information that you know about this case MR CRITTON Form THE WITNESS I said this off the record but I will say it on the record being in the Epstein case for me resulted in two years I have I wont bring the names but I was in the third interview to get hired as a household manager in Palm Beach and they told me you are the Jeffrey Epstein guy Not in the sense I did something wrong because of the scandal so they shun the job away from me And so I was afraid that this is very powerful people and one phone call and you finish so Im the little guy Even Im wearing a tie Im a Im talking from my heart This is the way it is BY MR EDWARDS I feel for you Im sorry that you have to be in this position MR CRITTON Move to strike this BY MR EDWARDS Page Well when you applied for these jobs and they turned you down and gave you the reason that youre the person involved in the Jeffrey Epstein scandal was it that they are associated or friends with Jeffrey Epstein or is it that you have information and you have this confidentiality but youre revealing some certain information that Mr Epstein would not like MR CRITTON Form THE WITNESS Both BY MR EDWARDS Both A Both And since then given what you just told us about these people being very powerful are you afraid for your life given the fact that youre involved to some extent in this case MR CRITTON Form THE WITNESS I just start thinking about Page this Because I went through the first time I went to the deposition I was in Palm Beach and I did my duty I mean I tell what I know but now I know there is more digging all I want is this to be to get on with my normal life and stuff BY MR EDWARDS So when you come here today to testify your main objective is to get back to your normal life and get out of the spotlight of this case Yes A Yes And in doing so have you held back some of the details that you know about that happened in this case to remove yourself from the spotlight MR CRITTON Form THE WITNESS No sir BY MR EDWARDS Okay Have you ever talked to Ghislaine Maxwell after that telephone call where she called you and you felt threatened A No Okay So going back to where we started here was does Ghislaine Maxwell have knowledge of Page the girls that would come over to Jeffrey Epsteins house that are in roughly the same age group as and and to have a good time as you put it MR CRITTON Form THE WITNESS Yes BY MR EDWARDS And what was her involvement and/or knowledge about that MR CRITTON Form THE WITNESS She knew what was going on BY MR EDWARDS You referred to her at one point in time as Jeffrey Epsteins companion But then later on you said that if she flew she flew on a different airplane and oftentimes or sometimes she slept in a different bed from Mr Epstein Did that seem unusual to you MR CRITTON Form THE WITNESS It was odd but I mean and again everything is odd in Palm Beach BY MR EDWARDS Okay I dont mean to laugh A Mr Epstein fly to Jet Aviation she fly to Galaxy Aviation but they never flew the same Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page Page that tape its going to be Assistant Attorney Weiss and Detective Recarey asking questions A Yes It says during the sworn taped statement Mr Rodriguez stated he was employed by Jeffrey Epstein for approximately six months I think we already talked about that Im skipping ahead a little bit If Rodriguez needed to relay a message to Epstein he would have to notify Epsteins secretary Lesley in New York who would then notify Epsteins personal assistant Sarah who would relay the message to Epstein A Yeah MR CRITTON Form BY MR EDWARDS Thats pretty much the process you described A Yes it was normal procedure Rodriguez stated Epstein did not want to see or hear the staff when he was in the residence MR CRITTON Form THE WITNESS Thats correct BY MR EDWARDS Page Thats something you agree with A Yes MR CRITTON Form BY MR EDWARDS Rodriguez advised Mr Epstein had many guests In addition to the girls who are roughly and age who had come to the house to have a good time who were some of the other guests that you know of if you know their name MR CRITTON Form THE WITNESS I mentioned Alan Dershowitz BY MR EDWARDS Thats a lawyer from Harvard A Yes The magician David Copperfield some other lawyers from New York you know There were some other guests And how frequently would these other guests come over A Once a month something like that Okay So if its only once a month and you were only there six months youre saying you only saw six guests come over in addition to A They have people you know they have Page friends I will say yeah Then you mentioned that you typed into Google I guess you Googled Prince Andrew and Bill Clinton Why would you pick those names were they associated with Mr Epstein A Yes And what is your understanding as to how Prince Andrew is associated with Jeffrey Epstein A Because there were pictures with him together In the house A Yes Many pictures or are we talking about one A Many pictures Were these pictures that looked that appeared to be at social events at Mr Epsteins house or where A Mrs Maxwell took him to England to introduce him to the royalty Is its your understanding that Ghislaine Maxwell knew Prince Andrew and introduced A Yes Is it also your understanding that at some point in time Ghislaine dated or had a romantic relationship with Prince Andrew MR CRITTON Form THE WITNESS I dont know that BY MR EDWARDS Page Do you know around what time period it was that Mr Epstein was introduced to Prince Andrew A I believe How do you know that A Ive heard dates From people in the Epstein group A Yes Okay MR CRITTON Let me note my objection move to strike its based on his testimony is based on hearsay BY MR EDWARDS During the six month period of time when you worked directly for Mr Epstein how often did Mr Epstein get together with or hangout with Prince Andrew if you know A I didnt see him once You never saw Prince Andrew at the house A No no he called Im sorry how often would he call Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page of Page A I will say once a week we used to get a call from him Did you ever hear or did you ever know of Prince Andrew being involved with any of the same girls that Jeffrey Epstein was involved A No All right Same question with Bill Clinton were you ever aware of him being involved with any girls A No And David Copperfield A No What would he do when he was in town A He came to the house played tricks and he leave Did you watch A Yeah Cards and Thats nice you get an up close and personal show from David Copperfield How often would David Copperfield and Jeffrey Epstein talk A When I was there he was maybe two or three times in the house Besides those guests have you pretty much listed the guests that you were aware of Page Page A Probably is MR CRITTON Form move to strike its a guess speculation BY MR EDWARDS When you say he probably is what are you basing that on A Because he belongs to all the clubs in Palm Beach Okay But you dont have a list of all of the clubs that he belongs to A I used to And on that list A I dont remember you know Okay Do you know where that list is A Probably its in the house Skipping down on page of the report to the third paragraph Rodriguez stated once the masseuses would arrive he would allow them entry into the kitchen area and offer them something to eat or drink Do you agree with that A Yes MR CRITTON Form BY MR EDWARDS They would then be encountered by Sarah or Epstein A Mr Dershowitz was there I took him two Page MR CRITTON Form or three times to the airport And like I say lawyers from New York business matters Okay And Donald Trump did you ever see him at the house A No he used to call Is it your understanding that or through your knowledge do you know if Donald Trump owned or runs the Mara Lago Club A Yes Did Mr Epstein go to the Mara Lago Club A No Why not MR CRITTON Form THE WITNESS Hes a very private person BY MR EDWARDS So its your understanding that Mr Epstein didnt go to the Mara Lago Club just because hes private MR CRITTON Form THE WITNESS Yes BY MR EDWARDS Are you aware has he ever been there A That I dont know Do you know if hes a member THE WITNESS Shakes head BY MR EDWARDS Yes A Shakes head They would then be taken upstairs to provide a massage Right MR CRITTON Form THE WITNESS Yes BY MR EDWARDS Again you dont know what happened behind closed doors A No But you were told to refer to these girls as masseuses A Yes Aside from being told that you have absolutely no idea what went on up there A No All right I asked Rodriguez any of the masseuses appeared to be young in age he advised he didnt ask their ages but felt they were very young A Early you know Theyre all very young but I mean its hard to say whos underage Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO I CASE NO Plaintiff Vs JEFFREY EPSTEIN Defendant I JANE DOE NO CASE NO Plaintiff Vs CONDENSED JEFFREY EPSTEIN Defendant I JANE DOE NO CASE NO Plaintiff Vs JEFFREY EPSTEIN Defendant I JANE DOE NO CASE NO Plaintiff Vs JEFFREY EPSTEIN Defendant I Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Page Case Document Filed Page of Page Page JANE DOE NO CASE NO IN THE CIRCUIT COURT OF THE 15TH Plaintiff JUDICIAL CIRCUIT IN AND FOR Vs PALM BEACH COUNTY FLORIDA JEFFREY EPSTEIN CASE NO AB Defendant I B.B JANE DOE NO CASE NO Plaintiff Plaintiff Vs Vs JEFFREY EPSTEIN JEFFREY EPSTEIN Defendant Defendant C.M.A CASE NO Plaintiff Vs Ives Dairy Road JEFFREY EPSTEIN Suite Defendant North Miami Florida August JANE DOE CASE NO p.m to p.m Plaintiff CONTINUED VIDEOTAPED Vs DEPOSITION of JEFfRf:-Y EPSTEIN ALFREDO RODRIGUEZ Defendant taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Deposition Duces Tecum Page Page JANE DOE NO II CASE NO APPEARANCES Plaintiff MERMELSTEIN HOROWITT P.A Vs BY ADAM HOROWITT ESQ JEFFREY EPSTEIN Biscayne Boulevard Defendant Suite Miami Florida i Attorney for Jane Doe JANE DOE NO CASE NO and ROTHSTEIN ROSENFELDT ADLER Plaintiff BY BRAD EDWARDS ESQ and CARA HOLMES ESQ Vs Las Olas Oty Centre Suite East Las Olas Boulevard JEFFREY EPSTEIN Fort Lauderdale Florida Attorney for Jane Doe and E.W Defendant And L.M JANE DOE NO CASE NO PODHURST ORSECK BY KATHERINE EZELL ESQ Plaintiff West Flagler Street Vs Suite JEFFREY EPSTEIN Miami Florida Defendant Attorney for Jane Doe and LEOPOLD-KUVIN BY ADAM LANG!NO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Filed Page of Page Page MR CRITTON Form shower I dont know whether he ever used THE WITNESS Yes maam plural BY MS EZELL BY MS EZELL And were there some who maybe came just Was there more than one picture of a girl once or twice with other young women in the shower A Thats correct maam A There were two girls in the shower Now where would the young woman who was Two girls in the shower together bringing another young woman go during the time A Yes maam the person that she brought was upstairs giving And were those two girls engaged in the massage something sexual MR CRITTON Form A Yes maam THE WITNESS I will take them to the And I may have asked you this question kitchen and Sarah would take them from forgive me if I did did you know those two girls there A No maam BY MS EZELL Did Ms Maxwell have nude pictures of Do you know where she took them Nadia on her computer A No maam MR CRITTON Form Were they ever taken to just sit in the THE WITNESS I dont know maam living room and wait BY MS EZELL MR CRITTON Form Did you ever meet a young woman named THE WITNESS I dont know maam Emmy who had an association with Ms Maxwell BY MS EZELL MR CRITTON Emmy These pictures of nude young women taken MS EZELL Emmy in gatherings where they were smiling did they THE WITNESS I dont remember maam appear to you to be taking part in an orgy BY MS EZELL Page Page MR CRITTON Form Did you ever have any conversations with THE WITNESS I dont know maam Ms Maxwell about any of the women in those BY MS EZELL pictures Do you know the word cavorting A No maam A No maam I dont know And did you ever have a conversation with I need my Thesaurus You said they were Sarah Kellen about any of the pictures of the smiling did they appear to be having a good time girls in her computer A Yes maam A No maam Did they appear to be doing anything You were asked last time about the creams sexual and lotions that Mr Epstein typically had A Yes maam available to him and you said you thought there And in these instances were there girls was a favorite one but you couldnt remember it doing sexual things with other girls A Spa A Yes maam Spa you did say Spa And Im still talking about the pictures A Yeah on Ms Maxwells computer Thank you A Yes maam Where did the stairway from the kitchen MR CRITTON Youre talking about the lead to where did it lead group shots that hes mentioned from Russia A To the second floor between the first and and Eastern Europe second bedrooms MS EZELL And girls in the shower Were either of those bedrooms the master MR CRITTON Let me object to the form bedroom then the way you just now described that A No maam MS EZELL He said for instance Could one go up that staircase through MR CRITTON He had said a girl in the could one go up that staircase and reach the Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL
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