Case Document Filed Page EXHIBIT Case Document Filed Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No 19-CIV-MARRA/.JOHNSON JANE DOE NO Plainti11 vs JEFFREY LPSTEIN Defendant Rdatcd ca:,l i I IL VIDEOTAPED DFPOSITION OF JUAN ALESSI VOLUMFI Tuesday September a.rn pm Palm Beach Lakes loulcvnrd West Palm leach Florida Reported Sandra FPR Pub ic State of Flonda COURT REPORTIN i AGENCY West Palm leach Office AP!l CFS On hdrnlf of the Plaintiffs RICIIARD WILLITS ESQlilRE RICIIARD ll WILLITS 10th venue Suite Lake Voiih Flrnida Phone rcclrhw hot1nail om STl.ART ER El ST ES Lllfr IFR:vlELSTEI IIOROWITi PA Biscayne Bouk 267ard Suite 1imni Florida Phone I ssm i 267scxalrn sea tt ornt:y com IJLFR Last I as U!as Bouh:YanL SH1tc Fo11 Laudcnbk Flond,1 Phone l5 bcd,vardsi rra 1w coin KATIIFR:-;E EZELL ES mr PODIIU ST ORSECK PA Vest Flagkr Street Suite liami Florida JO Phone PGA Boulevard Suite Palm Beach Gankns Florida Phone sku 267infi lcopoldkurin.corn Page a On behalf of the Defendant ROBERT CRITTON ESQUIRE BURMAN CRITTON LUTTIER North Flagler Drive Suite West Palm Beach Florida Phone rcrit bclclaw.com mpike bclclaw.com EXHIBITS NUMBER DESCRIPTION Exhibit number Photographs Exhibit number Transcript Exhibit number Incident Report Exhibit number Incorporation Papers Exhibit number Incorporation Papers Page Page PAGE PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Case Document Filed Page I Page PROCEEDINGS Deposition taken before Sandra Townsend Court Reporter and Notary Public in and for the State of Florida at Large in the abov cause VIDEOCiRAPIIER Today is September The time is minutes atkr in the morning This is the videotaped deposition of.Juan Alessi in the matter of Jane Doc number two versus Jeffrey Epstein This deposition is being held at Palm Beach Lakes Boulevard in West Palm Florida My name is Stan Sanders Im the videographer representing Visual Evidence Incorporated Would the attorneys please announce their appearances for the record MR WILLITS Richard Villits representing Carolyn Andriano MR BERCiFR William Berger representing E.W L.M and Jane Doc number two MR MERMELSTEIN Stuart Mermelstein of Mermelstein and I lorow1tz representing Jane Docs numbers two through eight MR LANCilNO Adam Langino on behalfofB.B Page MS EZELL Katherine Ezell from Podhurst Orscck on behalf of Jane Docs IOI and MR CRITTON Bob Critton on behalf of Jeffrey Epstein Tl EREUPON JlJJ ALESSI having been tirst duly sworn or anirrncd as examined and testified as follows Tl!E WITNESS I do DIRl-:CT EXAMINATION 1G BY MR WILLITS Oood morning sir A Good morning I introduced myself through the vidcographcr My name is Richard Willits A Okay I represent a young lady by the name or Carolyn Andriano A Okay Is that name familiar to you at all A Whose name Carolyn Andriano Do you recognize that A No What is your residence address sirl A My address is Fair ay Lakes Drive Page Boynton Beach Florida All right sir Did you ever work for Jeffrey Epstein A cs I did In what capacity A Everything I started with Jeffrey Epstein around I please bear with the dates because I trying Sure A to remember as a part-time maintenance guy And then I become a full-time employee I think it was January I so Sorry You said you started in That would be A No No No No No Okay A A Yeah All right And how did you happen to get tha job Was it through an employment agency A No or an ad in the paper A I had a company at that time used to take care Page fl of a lot of residents in Palm Beach And I got to know Jeffrey through Lesley Wcxncr And I used to work in about different different homes in Palm Beach as a maintenance guy Okay A And I have basically my own company and I do repairs for them I did home sit in for them And what was did you work for Jeffrey Epstein What was your position when you startcd A When I started he hire me to he just bought the house Im sorry A I just had bought the house Okay A where he live on El Brillo And he hire me through Mr Wexncrs references to do repair works Am basically what I did the most was taking walls apart windows and stuff that he didnt want to have it I sec A fix it And when you started working for Mr Epstein were you still working for other people in Palm Beach A cs I did Okay And about how long a period of time did you do this type of work for Mr Epstein the PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Case Document Filed Page Page maintenance and taking out walls A It was couple months It was couple months fore And what was the name of your company A Alessi Maintenance And how were you paid A By him Yes A Usually by check or cash sometimes Do you know what company actually paid your company A It was Jeffrey Epstein and Company So you said you had that position for a couple of months What happened next A Then Mr Epstein asked me to if I wanted to be his employee because was going from one house another house to another house one hour here I was just running around Palm Beach all day So he asked me if would just work for him exclusively for him Okay A And we agreed with the terms and become a full-time employee as a maintenance guy And was taking care of everything as far as maintenance Page about seven months before alter I become a full-time employee Okay And how did Ms Maxwell come into th picture A It was his girlfriend his main girlfriend Okay lad you known her before she became A lo your A Never know her before Im sorry I didnt get a chance to finish my question Would you have referred to her as your supervisor or your superior or what would you have called Mrs Maxwell A I used to call her Ghislaine Okay And how was it explained to you that you were now to deal with Ms Maxwell as opposed to Jeffrey Epstein A She would tell me I am going to take care of the house Okay That was explained to you Ms Maxwell A Uh-huh ls that a yes A Yes f3 Page Then my job changed little by little to house man estate manager and then to a majordomo Okay When you first agreed to terms with Mr Epstein and you first started working for him full time what were those terms do you remember A The terms is basically was how much he asked me how much was making in all the properties And says well make this this amount of money And he says fine And how much was that did he pay you A Around think I started with Okay And when you started to work for him as a Ii.Ill-time employee did you have anybody that you reported to or did you deal directly with Mr Epstein A At the beginning with Mr Epstein directly to him Did that change A Later on yes And hmv did that change A When Ms Maxwell Ghislaine Maxwell came the picture Okay About when was it that she came into the picture A Exactly date I cannot remember But it was Page And when Ms Maxwell started assuming responsibility for the house did your duties change at that time A Not much Okay A Not much And at that time when Ms Maxwell started taking responsibility for the house what were your duties A Basically I was still doing the maintenance work Okay A Was doing they were trying to remodel the home and they would told me okay tear down this wall We want to see how its going to look Or put this windows and tear down we had a fishing tank We too it out I took it out A kitchen on the second floor I took it out So it was basically dismantling the house Okay And about how long a period of time did that project last A I would says six to seven months Okay And after the remodeling slacked off or stopped did your duties then change A cah Increasingly they change PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Case Document Filed Page _3 rn Page Okay Who A Periodically It didnt change from one day to another And who would tell you that your duties 1vere increasing A Either Mr Epstein or Ms Maxwell Okay And how did your duties increase A In I become more more involved in the daily running operation of this home This home was like a hotel basically Okay Were you given any manuals or rules or procedures that you had to follow A At the end ofmy stay yes I was Okay At the end And Im going to jump to the end now and then come back What was it that you were given at the end of your stay what kind of papers or manuals A It was a manual I cant remember how many pages but it was quite thick manual that was that was done by estate manager that she wil I manage all all the properties And that was also to be in force in Palm Beach I sec Do you still have a copy of that manual A No I dont Page Do you have any papers whatsoever that were prepared while you were working A No for v1r Epstein A I left everything in there Did you make any diary notes yourscl!or an notes for your own private use while you worked for Mr Epstein A No sir The only thing I have is my separation agreement Thats it Okay Did you bring that with you today A No I didnt Okay Did your duties ever include taking telephone messages A cs sometimes And when did that start approximately A When I move from the outside to the inside of the house All right A I when I start the position I never had an apartment in the house And when I definite they want me inside to run the house I had an apartment I have a small service quarters in the house inside the house Okay And 1vhen you say outside the house do you mean outside the property or were you or were Page living on the property but outside the house A I was living in the property No No No I was working outside the property Yes A And because it was multiple jobs that I had to do Okay A lad to do with the pool the service the landscaping taking care of that I didnt do it myself but I have people working for me Okay Approximately when was it in relationship to Ms Maxwell taking over the responsibility of the house did you then move inside the house A I will says after it was done a big renovation when architects and engineers And that wa after I did the breaking down of this renovation they hire architects they hire decorators and engineers and did the they did the work It was a big renovation one of the renovations And then they make our quarters They even built our my quarters in there When you said our was there someone else who had quarters there too A About three years later after I start Page working my wife came to help me see And arc you able to describe for me where the quarters were like what floor A Yes It was in the second floor and the let me trying to remember northeast corner of the property Northeast corner yes Did anyone else work for Mr Epstein while you were working for him there at the house A During the whole time Yes.sir A Yes All right When you first started there there was no one else A When I started there was a it was a Jamaican girl that she was doing the cooking Okay Do you happen to remember her name A No All right A She worked for couple months I sec All right When did any other employees begin to work for Mr Epstein while you wcr there A They hire chefs There was mostly European chefs It was an English chcL but I cannot Rupert I know his name was Rupert A frcnch chef that was PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Case Document Filed Page io Didier kid from New York who was a cheL also But they were one after another one They were hiring chefs when I doing sometimes I did most of the cooking When they wanted to bring their chef they bring their chef in their plane And the chef will stay will work there and then will travel with them Were there any other employees that worked for Mr Epstein while you were worked for him that you No.cxccptmywife Did you know a lady by the name of Sarah Kellen Sarah yes I do Sarah Kellen came at the rnd of my stay there probably or three months before I left Okay Did she do any work for Mr Epstein that you know of cs She was a I dont know her deterrent hut she was an assistant to him or to her I dont know II right There is a Ive seen a reference in and the spelling has changed in my various references is there a or Do you recognize that name Yes I know N.B Want to take a chance at spelling that last name I think it was But she was not an employee She was a guest Was she a full-time guest No When would she visit She was a girl that was very very talented Mr Epstein help her become an actress Now shes a movie actress and shes in a soap opera She came with her mother to the house And she he help her come with her career Okay Do you arc you familiar with any other individuals by the name ofN or who worked Mr Epstein No After the renovations were complete did you have access to the entire house while you worked for Mr Epstein Absolutely yeah Was there any particular portion of the house that Vas denied access by to you No Page Were there any photographs of nude females in the house while you were thcre MR CRITTON Form MR WILLITS Whats the matter with that form MR CRITTON Overly broad Nude You mean completely naked MR WILLITS However you want to interpret it THE WITNESS Excuse me Can you repeat that again MR CRITTON Form BY MR WILLITS cs Were there any photographs of nude females in the house while you worked for Mr Epstein A Yes Sometimes I saw nude photographs Arc you abk to describe where you saw those where in the house Most of the times those photographs were taken by Ms Maxwell And they usually arc her desk And sh kept a big album Do you remember any pictures of nude or partially unclothed females on the walls at Mr Epsteins house MR CRITTON Form Page BY MR WILLITS Hes just making objections for the record that he can take he will take it up with the Judge later on A Okay You dont need to worry about Yes it was It was pictures of partially nude And where were they Most of the times they were in the pool How about on the stairway No On the stairway there were no pictures when I was there How many stairways were there It was the service stairway that is very narrow coming from the service quarters to the kitchen And the main stairway that it was quite wide and to the second floor Just those two And also there was a stairway outside through the pool to the balcony upstairs And do you have a recollection of pictures of any females whatsoever on either of the inside stairways No I dont PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Case Document Filed Page ll Lb l8 Page What is your understanding sir of the a reference to a girl as opposed to a woman re you familiar with the term girl Of course re you familiar with the term woman I intcrct most a woman a married 267oman a married person re you how would you describe a year old a woman or a girl girl of course low would you describe a year old a or a girl gain I dont know I am not I dont think I can tell you exactly she is or Butifyoukncw Sixteen I v,ould think is a girl of course Were there ever any visitors to the Epstein house that you considered to be girls as opposed to women cs cs I think I would says I never check her i.d Right Or I was not told to check i.d.s Of course on these girls But one I would says was very young because she was in high school sometimes tither pick her mother and herself from her house or I pick her from The School of the rts or the ballet place ballet in West Palm Beach cant remember exactly what that place is the name of the place Did you give provide transportation for any other females while you worked for Mr Epstein Occasionally yes I did Do you harpcn to remember the names of any of those females I remember one specifically one It was I er name was I cant remernhcr her last name but I think it was I Im not sure I can he wrong on that nd how many times did you provide transportation services for this femakl Whenever I had I been told Wh never I was told to go gc:t them or bring them back to their house Did you consider to be a girl or a woman A gain I think it was a woman from myself her dressing and her I think it was again I dont know if she was or or could have been But she was not never pick her up from a school or anything like that The only girl that I picked up from the school was _o Page Okay Do you remember any other females bcin present at the house other than the females that youve mentioned which were her mother Sarah Kellen Were there any others that you Many many many many many When did you first MR CRITTON Can I just have the last question read back MR WILLITS Of course you can MR CRITTON Please MR WILLITS But only once MR CRITTON Thats all I need MR WILLITS You sure Go ahead Previous question was read MR CRITTON nd can I just ask for a clarication from you re you going to use if you use the word woman arc you MR WILLITS I said females MR CRITTON No no I understand But in the future if you use woman docs that mean at least to Mr Alessi that thats maiTied and if its a girl she has to be or Because thats how you asked the question MR WILLITS II Im going to talk about is females MR CRITTON Okay MR WILLITS nd ask Page MR CRITTON Ill be alert to the questions then MR WILLITS All right So you dont need sleep through the next few questions MR CRITTON I dont sleep at all MR WILLITS All right Now Im totally confused BY MR WILLITS When did you first become aware of females visiting the Epstein house A Since I know him During the renovations A Yeah Were there A Before the before Ms Maxwell Okay II right Lets use that as a milepost Before Ms Maxwell A Before it was Ms Maxwell it was only one woman that it was Mr Epsteins girlfriend And her name was Dr she was a doctor of medicine Eva Anderson And I really liked this girl She was very PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend