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ƞ?;IZ ظ??rIxO?n Nd?r c?u?ZtJ b9 m?N?7RJ cģ o?V?ga O?Kk v??ZƍR?jf??xp?d??O??Ńqb Rt?8 ju ݞG ғ?n ķ?G?oh?S??p q?m?n?t?c SqS cZ?g x_ ӫ?F?ۆ e?o?o?R?F?.?TW I??Z I?kk ic?o??NWzL M?g I rڎyr Է?q h?䚒 ʒ?j?ƫ r?Ѐ8?j?K Sħ7 ϯ?z i?o-K e;?K srkigɜ??W?h s??N?qV?e F?N?eqqV S?S v??e i Sq VPNp K?,d?걽 W)??Rt f?;y H?ճ fU?Ӎ:?ۅc u7 Ic?ME?M?I_R Pt??T?nq?0?r i??ĕ?j Q?x bU?n?M?jdc w??K n??S Case Document Filed Page of I II Page Page JANE DOE NO CASE NO CV IN ntE CIRCUIT COURT OF ntE a i ntiff JUDICIAL CIRCUIT IN ANO FOR Vs PALM BEACH COUNTY FLORIDA JEFFREY EPSTEIN CASE NO AB Defendant I B.B JANE DOE NO CASE NO Plaintiff a i nt i ff Vs Vs JEFFREY EPSTElN JEFFREY EPSTEIN Defendant Defendant I A CASE NO CV Plaintiff vs Ives Dairy Road EF FR EY EPSIN Suite Defendant North i ami Florida August JANE DOE CASE NO CV p.m to p.m Plaintiff CONTINUED VIDEOTAPED Vs DEPOSITION of JEFFREY IN ALFREDO RODRlGUEZ Defendant I taken on behalf or th Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Depos i tion Ouces Tecum Page Page JANE DOE NO II CASE NO CV APPEARANCES a i ntiff Vs MERMELSTIIN HOROWITT P.A BY ADAM HOROWITZ ESQ JEFFREY EPSTEIN i scayne Bouleva Defenda Su i te Miami Flo aa Attorney fo Jane Doe JANE DOE NO CASE NO CV and ROTl-lSTclN ROSENFELDT ADI.ER Plaintiff BY BRAD EDWARDS ESQ and CARA HOLMES ESQ Vs Las as Qty Centre Su i te East Las Olas Boulevard JEFFREY EPSTEIN Fort Lauderdale Flonda Attorney lor Jane Doe and Defendant And LM JANE DOE NO CASE NO PODH JRST ORSEO Pla in tiff BY KATHERINE EZELL ESQ West Flag er Street Vs Su i te JEFFREY EPSTEIN i a i Fl orida Defendant Attorney lor Jane Doe and LEOPOLD-KWIN BY ADAM LANGINO ESQ PGA Bo levard Su i te Palm Beach Gardens Flo ri da Attorney for Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR GI UF FR EOO I Case Document Filed Page of Page A I dont remember Maam He came from New Abany Ohio From New A New Albany io New Albany hi i have his own bus i ness A No he worked for Mr Epstein He will maintain all the computers Was he there everyday A No maam Do you know whether at that time Mr Epstein had an office in Palm Beach A Not outside the house no Do you have any know edge whether or not the video equipment was and I do nt know the technical term forgive me but was it the kind of equipment that would record for a certain amount of time and then record over that fi A I dont know MR CRITTON Form BY MS EZELL You dont know A No maam MR CRITTON Just for clar i fication I may have misunderstood but I thought he Page sald he didnt even know the video equipment existed until he read the FBI report MS EZELL He said he didnt know that it was upstairs and downstairs I bel i eve MR CRITTON I thought he said he didnt know that it even existed MS EZELL I may be wrong BY MS EZELL Did you know it existed before you read the FBI report A No maam Im sorry then I was wrong How i you know then that the young technician from Ohio maintained the computers a the video equipment A Because we used to request there were always problems with he computers so he came to the house and he was the programmer It was very sophisticated MR CRITTON Form to the last question move to strike the answer as nonresponsive BY MS EZELL How did you know then that he maintained the video equipment as well A Because he was in charge of computers Page video even phones Would he also repair the televisions if they needed work A No No i you have any kind of intercom system i the house A Yes ma am And what kind of system was that A It was standard office equipment Lucid Technologies maybe but it was an intercom like we using right now MS EZELL Just let the record reflect that the witness pointed to the telephone on the table that has a speaker phone THE WITNESS Yes maam BY MS EZELL And did you use that in your work A Yes ma am And what did you use it for A Mr Epstein used to page me when he needed me i you have one of those phones in the kitchen A Yes maam And was there one out in the staff house Pa ge as well A Yes maam Do you know where others were in the house A Probably have like phones We used to have three in the staff house one In the cabana two In the master bedroom one in each room kitchen dining oom Mrs Maxwe ls office the garage Where was Mrs Maxwells office A Under the stairs next to the kitchen can you give me some idea of what size space that was A It was probably we change the floor Twelve by five something like that And was the computer equipment in that space1 A Yes maam Do you know whether Ms Maxwell kept the names and telephone numbers of the girls who came to do massages A Yes maam MR CRITTON Form BY MS EZELL Do you know that because you saw the Pages to Kres Court Reporti Inc Rue Notre Dame Miami Beach FL NON PARTY VR GfUFFREOO IO L3 Case Document Filed Page of Page names and phone numbers MR CRITTON Form THE WITNESS Yes maam BY MS EZELL Do you know if she kept pictures of the girls on the computer A Yes she i And you know at as well because you happen to see them A Yes maam MR CRITTON Form to the last two questions BY MS EZELL Were they similar to the pictures that Ms Kellen had on her computer MR CRITTON Form THE WITNESS Yes maam BY MS EZE Did the pictures that they kept there look like pictures that were posed A They were more casual Did they look as though the person being photographed knew that they were being photographed MR CRTON Form Page THE WITNESS No ma am BY MS EZELL And what can you tell me about that what lead you to draw that conclusion A They were probably taken in parties i big reception or banquet MR CRITTON Let me offer as a suggestion not that you have to accept or that you would youre us i ng the term young girls generically he has probably seen many many young girls there was no youve used it interchangeably with just young gir versus young girls who may have come to purported to give a massage and therefore that may be a different answer so that part of my form objection I lI CLCLL Ur ay LIICII OU BY MS EZELL When I asked you about Ms Kellen whether she had a list of the i rls and telephone numbers I th i nk I asked about those girls that came to give massages but let me go back and just ask it that way Did you notice that Ms Kellen had a list of the girls that came to give massages on her Page computer MR CRITTON Form THE WITNESS Yes maam BY MS EZELL And did she generally have phone numbers for those girls A Yes maam And were they generally pictures of the girls MR CRITTON Form THE WITNESS No maam BY MS EZELL And did Ms Maxwell have a list of the girls who came to give massages MR CRITTON Form THE WITNESS Yes ma am BY MS EZELL i she have telephone numbers generally A Yes maam MR CRITTON Form BY MS EZELL Were there pictures on her computer of the girls who came to give massages MR CRITTON Form BY MS EZELL Page Ms Maxwell Im talking about A Yes maam And were those pictures the more casual ones that you described when I asked whether or not the subject looked as though she knew she was being photographed MR CRITTON Form THE WITNESS Im sorry can you repeat BY MS EZELL Yeah The pictures of the young girls who came to the house to give massages that were on Ms Maxwells computer did they appear to have been taken when the girls knew they were being photographed MR CRITTON Form THE WITNESS I dont think they knew LI jJloVL":1Yl BY MS EZELL I believe you sa i they were more casual pictures A Yes maam Did you notice any nude photographs in those pictures A Yes maam MR CRITTON Form for the last question Pages to Kress Court Report i ng Inc Rue Notre Dame Miami Beach FL NON PARTY VR IU FR Case Document Filed Page of I I ll Page Page Do you remember whether she came to the A I give him a list of notes that I used to house on more than one occasion take from frequent people I mean people who A I heard her name several times from used to frequent the house and Im sorry its Sarah sir but beyond that I cannot say anything been a few years I dont remember but it was else those years like it was a file with my personal Okay Who have you talked to about your notes because he told me it was very important and knowledge of Mr Epstein in the last year he kind of said can I borrow this from you and he A My wife still has those documents sir Anyone else So even though they pertain to Mr A No sir Epstein you kept those notes at your residence Well you talked to Mr Critton A Yes sir A We have a conversation in West Palm Okay Where in your residence did you Beach keep those notes before you gave them to the Yes So you talked to your wife you Detective talked to Mr Critton A In my bedroom A Yes Did you have a file cabinet or Had you talked to anyone else in the last A No year about Epstein chester drawers or something A No A No they were laying next to some other Did you talk to Mr Goldberger papers that I have A Yeah I called Mr Goldberger first Did the other papers pertain to Mr before I talked to Mr Critton Epstein Okay So we have your wife we have Mr A No no nothing else related to Mr Critton and we have Mr Goldberger Epstein Do we have anyone else that you ta ked to Im just confused as to why you told us Page Page i the last year before that you had a journal at home and today A No sir you say that you gave everything to the Detect i ve How about Mr Epstein of course MR CRITTON Form You also may have A No missed a portion of his earlier testimony if Where did you usually keep the journal you couldnt hear something but go ahead with the names of the girls in what part of the MR WILLITS Most likely house THE WITNESS What I said was I thought I A In the staff house had some information and then I look with Sorry my daughter and we couldnt find anything A The staff house the guest house and I remember now that I put everything in Right But you said you had a journal at the file that I give to Detect i ve Recarey your own residence with the names of the girls BY MR WILLITS A I give the whole journal and all the Did anyone help you assemble those papers information regarding this case sir to Detective to give to the Detective Joe Recarey sir A No sir Okay And the materials that you gave to MR WILLITS I dont have any other me ueceCl.lvi i Jl Of yui:,uv1 kept at your own personal residence CROSS EXAMINATION A Yes they were with me sir BY MR CRITTON Okay When you gave the materials to the Mr Rodriguez my name is Bob Critton and Detective did all of the materials you gave to I represent Mr Epstein as youre aware I have a him come from your res i dence few questions for you A Yes What I would like to remind you at the Do you remember exactly what you gave to start of this is if you know something tell us him if you dont know something tell us that Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR GIUFFRE00l022 Case Document Filed Page of Page Page Youre not required to specu ate youre marked up no you cant not requ i red to guess youre not required to MR CRITTON I just want to show him assume because some lawyers ask you a leading Thank you Cathy question or suggested in a report or like the BY MR CRITTON police report like Mr Mermelstein and Mr Edwards This is the first what Ms Ezell was kind did that did you tell the police officers enough to provide is the first part of your or without showing you the statement Youre deposition it was transcribed by the court not required to guess I want personal knowledge reporter and provided by all counsel not speculation Do you understand Do you understand that A Yes I do A Yes understand that All right Now when Mr Edwards and And no one has provided that to you yet Mr Horowitz is here today for Mr Mermelstein today have they but you remember a lawyer asked you some questions A No last time you were here Now think you told us that with the A Yes police officers you gave a taped statement That is he started and he went on for a Did I understand you correctly few hours Do you recall that A Yes A Yes I remember And the only conversation that you had He asked you do you remember telling the with the police officers and it may have been a po ice officer or state attorney it was somebody named Ms Weiss Do you remember that Do you remember who I think was referenced in the questions the that how he phrased his question only time that you talked with at least Officer A Yes yes Recarey and the State Attorneys Office from Palm He never showed you a statement that you Beach County was in a taped statement made to the pol i ce department did he Is that correct Page Page A Im sorry A No He didnt show you a document that sa i Did you talk i th them separate and apart question you know what is your name answer my from that name is Alfredo Rodriguez A Yes I did MR WILLITS Object to the form of the Okay Did they tape that statement question A No MR CRITTON You need to let me finish You told us you also spoke with it first representatives of the FBI MR WILLITS Im sorry I thought you A Yes were Okay And you distinguished between the BY MR CRITTON FBI and between Officer Recarey He never showed you a statement of what A Yes the question was and the answer that you gave So how many times did Officer Recarey or True Detective Recarey I think hes from the Palm MR WILLITS Object to the form of the Beach Police Department speak with you question A Like three or four times HE WITNb I don exau,y unaerstana ut ne oniy WOK one your question A One taped BY MR CRITTON Im sorry one taped statement Do you know what a depos i tion is A Yes A Yes I am All right So as to whether or not if Thats what youre doing here you said something to Officer Recarey or not that MR CRITTON Could I borrow your you would be able to confirm that would only have deposit i on for just a minute been in a taped statement one taped statement out MR HOROWm The transcript Its of the three approximately three times he spoke Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR GIUFFR Case Document Filed Page of Page with you MR EDWARDS Form MR HOROWITT Form BY MR CRITTON Is that correct A Yes correct MR W1LLITS Object to the form MR HOROWITT Join BY MR CRITTON And when we were here I think it was last week or the last ten days anyv-.iay I could tell you On July 29th of this year and Mr Mermelstein started with your deposition and then others asked questions when Mr Mermelstein and I think Mr Edwards asked questions about did you tell Officer Recarey or they didnt show you a statement they didnt give you li ke a transcript like this and say see what the question and see what the answer is A No MR EDWARDS Form MR LITTS Object to the form of the question BY MR CRITTON And you havent had an opportunity to see Page your ta ped statement since you gave it many years ago A No sir Would you agree that your aped statement wou probably be a little more accurate than your testimony today because of the time period that has transpired A Thats correct MR HOROWITZ Object to the form MR WJLLITS Object to he form of the question BY MR CRITTON When you spoke with the FBI ove at Greens I think it was Greens Pharmacy A Yes Did they take a statement from you that is i they have a tape reco de or did they just make notes A hey took notes All right Did you sign anything A No sir That Is like did they take notes of what you said and then you signed it to say yep that accurately reflects what I said A No didnt sign anyth i ng Page When Officer Recarey took spoke with you on those approximately two times when he did not take a taped statement did he ever present anything for you anything in writing that he had written to say Mr Rodriguez I would like you to review this to make certain that I took down correctly what you said A No sir If he ad offered to do that would you have read what he wrote down to determine whether or not he took down that wh i ch you had said or told him MR EDWARDS Object to the form rnE WITNESS Probably I will read it first BY MR CRITTON All right And if In fact he had recorded something incorrectly or recorded in a particular way that he wanted it phrased and it was not accurate would you have told him that MR EDWARDS Object to the form THE WITNESS No I never told him that BY MR CRITTON Listen to my question If he Officer Recarey had taken down Page what you said and it was not accurate that is he put his interpretation of what you said would you have told him thats not accurate Office Recarey MR HOROWm Form MR EDWARDS Object to the form THE WITNESS I will tell him MR CRITTON Go ahead and change Were going to change the tape We do have time Cathy could I borrow back the photographs please While youre giving me those back would it be cor ect that youre going to keep ll you took as you did with photograph number four you took back five six seven and eight and youre going to keep those ano not allow me or anyone eise to nave a copy of them MS EZELL Yes MR CRITTON Youre going to be equally restrictive right MS EZELL Right MR CRITTON All right Thank you BY MR CRITTON You were shown photograph five of a lady Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR GTUFFRE00 I Case Document Filed Page of Page Page F.E and I think you told us that you had seen lm sorry her you recogn i zed her photograph A Yes I did I told the police A Yes I did And at the time that you spoke with the On how many occasions did you ever see police and gave them a statement isnt it true her at he Epstein home Mr Rodriguez that you were no longer employed by A More than three times Mr Epstein More than three A Yes A Yes i And you understood that you were required Thats as accurate as you can be to tell the police officers the truth at that A Yes time More than three A Yes A More than three And i I understood your testimony I Whether it was four or five you dont befleve from July 29th through today you at no know but more than three time asked any of these girls how old they were A More than three i True In terms of F.E.s age d!d you ever ask A No her what her age was And as to whether the girls were under A No sir or or over you really didnt know one way Did she appear to you to be someone at or the other at the time Would that be a fair least from seeing her and recalling her that she statement appeared at least to you to be wh il a young woman A Yes appeared to be someone who was or older MR WILLITS Object to the form of the A No sir 2J question Okay Well did you ever say anything to BY MR CRITTON the pol i ce or did you ever we you ever On Exhibit there is a person whos Page Page concerned about that such that you told someone covered the lady that Ms_ Ezell asked you about I A No sir bel i eve was on the right-hand side of the Havent you told the police sir et photograph There is a young lady on the me strike that let me ask It this Way eft-hand side with a black hat on ln your taped statement that you gave to Do you recognize er at all the pol i ce did you not ell them that a the A No I don recognize her girls appeared to you to be or above Okay Thank you With regard to the A Sir as far as when all these actions photograph four that you saw that you think that were taldno place was under ar env!ronment possibly might I think you told us that that I though I was going to be yin other you recall seeing that woman in the sauna at Mr words I was afraid of any repr i sal Mr Epstein Epstein house on one occasion and she was oaked and Mrs Maxwell if I say something that is any A Yes i dea of me because have th confldentla ty Was that near the end of your employment agreement What I saw that they we very young or the middle or the front end but I cannot say that they were ard old A I saw her on January sir and I was i ght Let me just take you back to my terminated In March so that was two months prior question again and see it you can answer my ll Ana aia you ever ce11 anyone mat you ou question seen her naked in the sauna MR CRITTON Could you please read it A I told Louel back Okay And what did Louella say Thereupon a port i on of the record was A She was surprised rood by the eporte Okay Did you wake the young lady up In THE WITNESS I think I told tre police the sauna that A No BY MR CRITTON And do you know how old the young lady Pages to Kress Court Reporting Jnc Rue Notre Dame Miami Beach FL NON PARTY VR GI FFREOO I Case Document Filed Page of Page was at that time A No I didnt know If I was to tell you she was born i December of which would have made her at he ime and you would say not surprised MS EZELL Objection form MR WrLLTTS Object to the form of the quest i on MR HOROWITZ Join THE WITNESS I would say I wouldnt know BY MR CRITTON Other than telling Louella i you say anything to anyone else when you saw the 1S la dy you believe was naked in the sauna A I believe I mentioned that to my wife All right Anyone else A No And i continue assuming it was i she continue to sleep the sauna that is,she didnt know you were there A She never knew that I was here She didn at least acknowledge that she knew Correct A Yes correct Page You were asked by Ms Eze Im just going cover a couple of th in gs as long as Im staying with Cathy here whether Louel a you had told us someth i ng about the icture of the Pope near a pict ur a naked person naked woman Thats what Louella told you you never saw those photos Correct A I did saw the ict ures Yo did see the pictures A Yes And the photos that you saw of naked woman that was near the Popes photograph was that someone that you knew or just a picture of a naked woman A was somebody somebody that was a i it or 1n the house but I dont know her name one of plane women you described the women who came In on planes or that they came with Mr Epstein from time to tlme7 A he came with Mr Eps tein from i me to time All right And those are women that I think you testified at your last deposition all appeared to be in their or older Is that Page correct A think so sir All right I assume that in over the course of your ife separate and apart from your wife youve seen a naked woman before A Yes And I assume that in your SO some odd years how old are you si A SS In your years youve seen pictures of naked women both photographs paintings statutes Would that be a fair statement A Yes And In terms of at least ln this particula case there ls all sorts of as you know there is testimony and youve been asked a number of questions about sex related issues that Is whether you saw in photographs or whether you saw anyone engaged in any type of sexual activity Correct A Correct And I assume that you understand tha men and women well start there first that men and women actually do have sex in this world A Yes Page That comes as no grand surprise to you A No And you understand that people actually enjoy se from i me to me A Yes Are you familiar with that concept at least A Yes All right And what may be typical sexual activity for one man and woman or whatever the permutat i on might be anothe couple or another man and woman or another man or woman may consider to be unusual or overly aggressive MS EZELL Obj ection to form BY MR CRITTON True Thats what I mean Everyone has a different point of view about sex and What may be considered typica sexual actMty for someone orm:one else meiy cunsider lhals a i adventurous MR EDWARDS Object to the fo rm THE WITNESS Yes BY MR CRITTON Pages to ess Court Reporting Inc Rue Notre Dame Miami Beach NON PARTY VR GfUFFIU OO I Case Document Filed Page of I I ll Pag Page I not trying to make you a sex expert you say her name Also I assume that when youve been in A Yes her mother or Walgreens for that matter Publix or i nn Okay Its Evas daughter there was a Dix i I assume that youve I dont want to i cture where someone it looked like was pulling assume anything oin their swimsuit Have you ever been in an aisle where A Yes youve actually seen condoms being sold Do you recall ever seeing the old A Yes Coppertone And where ubrica ts are being sold A Yes A Yes Let me ask the question I know you know And as well as massage oils and other what this is types of il actua ly are sold in those kinds of Have you ever seen the old Coppertone stores commercials and billboards that used to be A Yes astered all over certa i nly Florida and other And they re ava ll able so that someone places where there is a cute little i rl who walking through Walgreens or Publix or co ul appears to be two three four years old and actually take it off the shelf put it i their someone i pulling down at least a port i on of her cart go up and pay for it and take it home swimsuit so shes exposing a small portion of her A Yes cheek is exposed All right In the photographs that you A Yes talked about and if I understood you correctly Okay Is that what the picture of the at east dur i ng the time that you were there Mr young girl looked like that is Mr Epsteins God Rodriguez i and OS there were you sa i daughter that there were I think yo said downstairs A More or less yes and Im talking about really from the kitchen area All right And downstairs in the kitchen Page Page up the back sta i rway or what wou be the kitchen were there any pictures of women in any stage of stairway to the upper floor there was I think you undress sa i but correct me i Im wrong please that A No you don recall seeing there being any pictu es And then I th i nk you said as you walk or photographs of any nude women Is that upstairs or as you walked up the sta i rway from correct the kitchen at the top of the landing I think you A They were not nude women in the described did you describe it as the foyer sta ir case A Yes Thats all Im talk in about right now Okay But its really the landing the In that area you never saw any pictures or upsta i rs landing photographs paint i ngs any type of depict i on of a A Yes nude woman on that sta ir case going upstairs I think you sa i there were there was Correct were or was a three by five i cture or A Correct pictures All right And I think you sa i A Yes downstairs you saw a picture of the only Of women in some stage of undress pIccure ma1 you saw or a say or a younger 1u ll A res that displayed some form of I dont want to say Okay And when you say three by five I nudity because its probably not that but of some assume you meant three feet portion of their body that was exposed and I A Three feet th i nk you described it as he cheek By five feet A Yes thats upstairs A Yes Thats upstairs Were they photographs A Upstairs A Yes they were photographs And that was was it Eva Is that how And I think you also told us that you Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR GIUFFRE00 Case Document Filed Page of I Page Page didn recognize who those people were Is that A Inside his closet the walk-in closet correct And those pictures I think you called it MR EDWARDS Object to the form a mosaic THE WITNESS I knew this part i cular i rl A Yes because i was the daughter of Mrs Eva And of the mosaic approximately how many BY MR CRITTON i ctures were i the mosa i Okay And i that the i ctu youre A or talk i ng about Okay And of those i ctures how many did A hi is the i cture Im talking about you recognize Okay And that wa a three by five A About three or four A Yes All right Were they as to who those All i ght And the only thing that you people were you don know you just recognized could see was a portion that is of her other than three or four of them say her waist or her shoulders or her arms or A Mr Epstein when he was yo unger and then something that one where you could see kind of fferent i rlfriends but I didnt recogn i ze like the Coppertone commerc i al a i cture of her except the ones cheek Okay You said three or four of those A Yes Part of her buttocks were i ctures of the irl who came over to give a MR LANGINO Object to the form massage BY MR CRITTON A Yes Okay And was there another picture at Okay But as to who those girls were you the top of the foyer large one or is at the dont know as you sit here today on one that you can re ca ll A No i A There were two of the same irl I And as to what their ages were you dont different poses know Page Page But showed the same thing A No sir A Yes Thats correct Okay As you walked through i nto then A Thats correct if I understood i correctly you go to the pretty And as to what they dep i cted in the much to the end of the hallway then you go photographs of the girls were they i different through another small vest i bule double doors two stages of undress sets of double doors and as you go straight ahead A Yes then you make a left around the bed and then you Was everyone undressed to some degree end i the bathroom that is they were described as nude or at least A Yes the questions asked were these people nude Were In bat hr oom in the bathroom or in they actually nude or someone may have had the ir that location were ere any i ctures of any wome top off i any stage of undress A There were two girls complete naked i A Yes a shower in a sexual act All right And were any of those Is that the one when Ms Ezell asked you i ctures i they involve or were they of any questions thats one of the photographs that you or me gi mat nave oeen aescnoea as women wno ll vvcft I dWUl came over to give Mr purported to give Mr A No sir Epste i a massage That was a different A Yes A Different one And do you remember who any of the names Okay And the mosaic that you saw where of any of those peop were you saw two gir involved i a sexual act do you A No know where that photograph was taken And the pictu re yo saw whe were they A I think it was taken in one of the rooms located in the house because there is an oval bathtub but Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR GIUFFRE00l028 Case Document Filed Page of Page I don know wh i ch room ir Okay i you recognize both the gir Page pilots masseuses chefs so she have a copy of the ack book with herse and as well as the or just one of the girls computer A The two gi rl Did you ever go on Ms Maxwells computer Then there were ere was one or two to see what she had i it other photographs of i rls that you recogn i zed A Yes A Yes And was that someth i ng you were allowed Okay And were they fully unclothed or did they have some degree of clothes on and/or off A They were naked All ig And all of the remai ni ng pictures at least i th i that osa i were of ind i viduals that you i not know A No sir And tha you did not recogn i ze as having been at the house Is that cor ect A Yes thats correct You were a so asked about some let me sw i tch for just a minute You were asked about a vib ator that you saw and I think you descr i bed it as a back massager that was approximate inches long that had a couple of rotating heads on it to do A No Okay You actually went in her office A Yes And was her computer on so that you didnt need to access the password A It was off Okay So you just turned it on A Yes sir A the you were ab to access her computer A Exactly And what possessed you to go i and to access her personal computer A I needed to send some documents to the New York office and it was the only computer work i ng in the house A Yes Okay And how many occasions did you use Pag And I think you timately came up i th a her computer the i dea as i was something you had seen at lik a Sharper Image store A Yes sir Have you ever seen one of those types of devices that is a back massager wit the rotating heads a so sold we ll let ask you th i Str i ke that ast quest i on Have you ever been to Brookstone A Yes Okay Have you eve seen a massager like that at Brookstone A Yes Okay You were asked whether Ms Maxwell kept the names of any of the i rls who came to i ve massages on let me ask it th i way A Several i mes Was she ever aware that you used her computer MR LANGINO Form THE WITNESS I dont th i nk so BY MR CRITTON Did you ever ask Ms Maxwell for permission to use her computer A I was the house manager I believe I was supposed to use everything i the house to accomplish my dut i es in that case sending financ i al reports or mails So would you have been i you ever use Mr Epstein computer A No mini you were asKeo wnemer uKay tlut you Ms Maxwell ever kept the names of any of the irl who came to i ve massages a I th i nk your esponse was yes A Yes Okay Did she keep th em a pad of computer A Yes Did you ever use Ms Ke ll ens computer A Yes In look i ng at Ms Maxwell still you went paper i she keep them i a notebook i she keep them in a computer into Ms Maxwells computer with at least the i dea of sending some documents A We used to have i nternal books for A Yes ess Court Report in Inc Rue Notre Dame Miami Beach Pages to NON PARTY VR I UFFRE00 Case Document Filed Page of Page Page Up to New York record with tape number three A Yes BY MR CRITTON We you going to pdf them Mr Rodriguez I was asking you about A Yes Ms Maxwells computer and you told me how you And did she ave a fax machine not a went on the computer fax mach i ne a copy mac hi ne in her office as we ll If she was out of town would she take her A Yes computer i th her Okay So how wou you ge era ll do A No that Would you do that through a Microsoft It was someth i ng she left there ogram A Yes A Through Citr i All right And when you went on to pelf Thro i tr i All ri ht i th Citr I think you sa i it was really one i me that you and hat i i you said you saw some names of saw the names of some of these gir i nd i viduals on her computer i you were just go i ng A Yes to pdf some docume ts up to New York wo ul you And if I understand it correctly it was of what wo ul of caused you to have seen any did it have the name and then a phone number names on her compute A Yes MS EZELL Object i to form And was that something that was THE WITNESS A ll calls that came to automatically downloaded from the system El Br ill ey came hro gh the A Yeah from the phone system to the te ephone they have a transcr i pt somehow computer so we have a transcript that they connect to the computer so you When you say a transcript fact that can pu ll it and you register the i me who Sally Jones phone number whatever it was ca ll ed who didn call and you can pu ca ll ed this at your request So I used to use that A rt was a transcript of the phone calls of Pag Page to go back to some calls that they were the house we can get it from the computer request i ng espec i ally when the hurricane Okay And Im distingu i sh i ng seaso happe ed transcript it would tell you name and phone BY MR CRITTON mber it wouldnt tell you what was sa i Okay So i I understand even the A It was the message also computer you used would have had that same Okay Now I understand And so feature Ms Maxwell when you said she had the names of A No no it was totaily i fferent i ne some of these girls who may have given massages was slower and all the time was breaking down or at least were what you called earlier i rls thats why we have the guy from Ohio came and that gave massages or females that gave massages fixed the computers she would have had it because that was information Okay Were there other computers that that was down oaded from the Citr system into you used that had that feature that is that her computer A ly Sarah Mrs Maxwel and the staff A Yes house MS EZELL Objection form Staff house being yo ur BY MR CR ITT ON A The guest house yes my office uKay unaerstana Now you sata she So you could go out to your guest house also had some pictures Is that that one time you then and look fo the same i nformat i on a so saw i ctu es A No A Yes All right I don unde stand but why And were you go i ng through her computer don we take a break because were almost out of at that time tape A No Thereupon a recess was had The question is if all you were going to THE VIDEOGRAPHER Were back on the do was try to pdf some financial information to Pages to Kress Court Reporting Inc Rue Notre Dame i ami Beach FL NON PARTY VR I UFFRE00 Case Document Filed Page of a Page New York what were you do i ng getting to names and Okay Were any of the photographs that pho numbers and en pict res of girls were i again Im talking abou Ms Maxwells A I was trying to get some i nformation I computer now were those photographs of was working computer and I just happe they I ndiv i dua who were any of the i rls or ladies have the icon of the fi and I open and i was that came over to give massages right there so I was not looking but you know A No hey stay at the house i was already accessible to me Okay So the photographs that you saw on And how many photographs you then Ms Maxwells computer of females in any state of scroll thro gh to look at undress or at parties or at banquets those were A Probably all of i ndividuals who would fly in with Mr Okay And why Epstein at various periods of time that had A Just curiosity sir traveled with him So aga i you never told anyone other A That correct than your i fe Okay Those are the girls that you told A No us I think at yo last deposition and reaffirmed Correct here today those girls all appeared to be in A Yes correct their Of the ict es that you saw if I A Yes i understood it correctly some of those were All right Now you were also asked some pictures of well I th i nk you said some of them questions a lot of quest i ons about surveillance reflected part i es or banquets And if I understood your testimony and th i is A Yes where it goes bad to what do you know what don I think you described some of he you know wha were you speculating on what i pictures gatherings that appeared be i ther in you know at the time what do you know now at Russ i a or astern Europe least I need you to distingu i sh that for me so Pa Page A Yes tha I know what you knew at the time and as A i And then you talked about a i stinct from what you may have read in the i cture of two i rls i the shower at you i dn newspaper been told by some awyer or someone know the girls Correct else that may not be accu ate Okay A Yes A Yes i Thats cor ect Wi th regard to the with regard to A Thats co rect surve i llance equ i pment if I understood your All i ght A th at in all of he estimony today is you were completely unawa of photographs that you saw the ind i viduals seemed to the existence of anv surveillance equ i pment In the be hav i ng a good time ouse during the ti me per i od that you A Yes worked there Is that correct All rig Would it be a correct A Yes statement that In none of tile photographs i And therefore where i was what may anyone seem to be distressed i sturbed show ave existed whethe i in fact actually did any type of negativ emotion at least from what exist whether anyone a i nta i ned i you hav no you observed personal now edge whatsoever Is that true A nae co reci it ld llU MS EZELL Objection form MR WILLITS Object to the form BY MR CRITTON BY MR CRITTON And in terms of the photographs that you You talked about i ctures of two women did see were a of the photographs that you saw who you saw in he house who were nude one was i they appear i hey a pear to ave bee of Nad i a women that you had seen fly in with Mr Epste in on A Yes his ane And yo knew Nad i a was someone who was in A Yes er Pages to ess Co urt Report i ng I nc Rue Notre Dame Miami Beach FL NON PARTY VR GIUFFRE00 I Case Document Filed Page of Page Page A Yes names and addresses of let me start over All right And then you saw another Strike that picture of a Brazilian woman who had traveled or If I understood your testimony you said flown on the plane before that Sarah had pictures start again A Yes You said that Sarah had the names and All right And she also appeared to be a phone numbers of some of the massage girls woman to you not only i the photograph but from A Yes your having seen her who appeared to be in her Or at least of the people that you thought may have been called to give massages A Yes A Yes Excuse me Thank you You talked about MS EZELL Form Sarah Kellens computer Was she hooked into your MR EDWARDS Form main system BY MR CRITTON A Not to my office in the staff house but And was that in the same format that you she was hooked into the main house saw on Ms Maxwells computer Okay The same Citrix system A No A Yes Okay What occasion wo1,1ld have en And you said that Sarah had pictures of have had to use Sarah Kellens computer women on her computer that you saw Is that A She will instruct me to get some correct information from her desk or telephone numbers so A Yes I will Okay And were those the same types of And thats where you would have seen it i ctures that Ms Maxwell had that is fema es A Yes i ctures of females who had traveled In with Mr I think you testified at your last Epstein from his plane deposition or the start of your deposition that Page Page A his were different pictures the number of women that you remember came over to Okay Were any of hers of any of the give massages was something eight to ten twelve girls who came in on the plane or the ladies or I dont remember whats your best recollection women A Can you repeat that please A No Of the women of different women that you What were her pictures of knew came over to give massages during the time A They were young women modeling you know that you worked for Mr Epstein to I dont remember seeing nudity on Sarahs during that tlme period approximately how many computer women were there All right Hers when I say hers the MR EDWARDS Object to the form photographs that Sarah Kellen had on her computer TiiE WITNESS To i ve massages were all of individuals who appeared or not BY MR CRITTON appeared but were dressed and appeared to be Yes i modeling A Fifteen yeah A Yes So someth ing between one and fifteen of Would it be a correct statement that none the names you would have seen on Ms Kellens me women ma you saw ma 1s me p1aures ll Ult::I llUll!J VVILII IIUII the women that you saw on Sarahs computer were MR EDWARDS Form any of the gi rl women whoever came to give TiiE WITNESS Yes massages Is that correct BY MR CRITfON MR EDWARDS Object to the form Do you remember how many you would have MS EZELL Form seen TiiE WITNESS Thats correct A Fifteen BY MR CRITTON Okay You also told us earl i er today You said that Sarah you thought also had that you saw Sarah Kellen from time to time taking Pages to Kress Court Reporting Inc Rue Notre Dame ia mi Beach FL NON PARTY VR GIUFFRE00 Case Document Filed Page of ll Page Pag pictures in the dining room and the library Regu ar conversat i on A Yes A Yes Photographs And therefore you might in terject A Yes yourself back in because youve been asked to pay Okay Was she taking the pictures she someone or to let thern out took were people who were clothed MR LANGINO Form A Yes THE WITNESS Yes I was called to pay And were any of the pictures hat she then took any of the girls that you ever let me BY MR CRITTON str i ke that All right And when you hear that If I understood your original testimony conve sation that wou be another way that you dont want to say or i ginal If I understood would know that the women were leaving your testlmony from July 29th to what you told us A Yes today as to the women who did come to give And sometimes theyd leave without you massages they knOC or somehow you woura be even being involved I I understood It correctly aware that they were at the back door you would A Thats correct punch the security code and lead them into the So the only places that you ever saw the kitchen women who came to give massages would be of the A Yes some een women dur i ng the time you were there Okay When you brought them into the would be either when you let them into the house kitchen you would say i they would say hi back and escorted them into the kltchen or as they were to you or something to that short greeting leaving youd offer them water there was never any A Yes alcoho in the ole house other than I th i nk you And think you described one I nstance said for one person at one time Is that a fair earlier today is that you may have had In the Page Page statement car in the Suburban A Yes A Yes All right You left the kitchen you And ats the only person that you can understood Sarah Kellen came down and what remember hav i ng driven any place that ls of the happened thereafter you dont h;we any personal women who were described as hav i ng i ven massages knowledge wha ts oever MR EDWARDS Objection A Thats correct MS EZELL Object i on form MR EDWARDS Form THE WITNESS Sir I have to clarify BY MR CRITTON that drove a lot of girls but dont At some point I time Ms Kellen might remember the names associated with the contact you and say pay such and such amount of faces But this particular girl A or dollars she Is now getting ready to leave others whatever I remember driving ln A Yes the Suburban but I cannot say this was TI1at maybe one Another se of BY MR CRITTON cir cumstances might be you use the wo commotion Let me clarify because what I want to be you might hear a commotion I assume you dont dear is i I do remember you testify i ng that mean well let me asK you wnen you say or LU u,u vu commotion do you mean a disturbance something females wou fly in with Mr Epstein they might that was seriously like raised voices or merely want to go shopping they i ght want to go to the you just heard some people talking store they may want to go to the drug store they A Conversat i on of people leav i ng may want to go to tlle beach wherever tt1ey wanted Okay No a comm ti he ror of a to go and you would ri ve them dislwbance but a commotion I the sense that you A Yes heard people ta lki ng All rig And then I remember in A Yes response Ms Ezells questions today she asked Pages to Kress Court Report in Inc Rue Notre Dame Miami Beach FL NON PARTY VR GIUFFREOO I Case Document Filed Page of Page you about having driven and you reuilled having had her In he Suburbon sp ecl flca Uy A Yes Do you remember any of the othe irl women who came to give massages ever hav i ng dr i ven them or is the only one that you remembe MR EDWARDS Form THE WITNESS I only remember right now for the fact at I was driving by the airport and I sh owed her Epsteins plane BY MR CRITTON A ll right Wh i ch really takes me back to really her sta rt ed i th this series of questions You saw the i rls the wome who came in to give the massages when they came in I you were adv i sed i you heard conversation and you saw em you would see them when they left A Yes And you saw because she was i the burba at least one occasion A Yes And therefore ou never saw he,e girls these women who gave the massages In the Page dining room or the library Would that be a fair state ent A ats correct MR EDWARDS orm BY MR CRITTON All right So therefore the pictures that you saw Sarah Kellen tak i ng of girls women either i the i ning room library those were other individuals other than those who may have 1U given or wno came for massages lS ttat correct MS EZELL Form MR EDWARDS Form THE WITNESS Its confusing sir because there were a bunch of girls I don know which one hey were but I saw her rak in pictures of the groups nv Al rr y-r-y i As to whe her they we people who came in on the planes or there may have been a massage girl more than one won,an who gave a massage you just don know as you sit he youd ust be speculating Is that co rect MR EDWARDS Form THE WITNESS I don know BY MR CRITTON Page All righ Ms Ezell asked you about Mr Oershowitz be i ng present in Mr Epsteins home and I th i nk she asked and I think that you said Mr Epstein was a and he and Mr Dershowitz were fr i ends A Yes She also I think asked was Mr Dershowitz ever there when one of the women who gave a massage was present in the home A I dont emember that Thats what I want to clear Up Is it your testimony that Mr Dershowitz was there When any of the women came to Mr Epsteins home to give a massage A Yes MR EDWARDS orm BY MR CRITTON As to whether any of those women we ever associated with Mr Dershowitz would it be a correct statement that you have absolutely no knowledge A I dont know sir You dont know A I dont know sir MS EZELL Form Page386 BY MR CRITTON Okay Were you in any way attempt i ng in your response to Ms Ezell to I mply that Mr Dershowltz had a massage by one of these young ladies A I don now i You have no knowledge A No sir And you certainly werent i mplying that that occurred you Just tiave no knowledge Correct MR EDWARDS fiorm THE WITNESS I dont know BY MR CRITTON Sorry A I don kn ow If questions you esponded that let me ask It this way Yt;iu never saw Mr Epstein ever take photographs of anyone Would that be a correct statement A Yes Would It be a correct statement you never saw Mr Epste in initiate a pho call to anyone Pages to Kress rt Reporting Inc Rue Notre ame Miami Bead1 NON PARTY VR GIUfFR.E00 Case Document Filed Page of age Page A To ace a phone call Of the time that youve done that Yeah i you ever see him place a phone approximately how many years does that include In call your working life A Yes A i ght years ten years If i fact maybe it was this way is All right And have you wo ked for that you never saw him call someone to schedule a have you been In other ci rcumstances where you massage appointment Correct have worked around well let me step back A Thats correct With all of the individual that you I think you said that Ms Kellen to ld you ment i oned estate manager house manager has this that Mr Epste i would take photographs Did I been for individuals who have or at least appear understand you correct to have substantial wealth A Im sorry can you repeat that A Yes Did Ms Kellen ever tell you that Mr And as part of your duties or not duties pstein took a photograp of anyone but as part of being a house manager or genera A No she sa id to me Mr Epstein i lik manager for an estate do you interact with other hes an amateur photographer estate managers Okay I may have misunderstood you then A Yes Let me clar i fy that testimony And do you assist each other from time to Its your testimony that Ms Kellen told time if someone needs help you that Mr Epstein is an amateur photographer A Thats correct A Yes And I assume that youve been In other She never told you that or let me estates in Palm Beach and probably in Fort strike that Lauderdale and other locations ls i correct that she never told you A Yes that Mr Epstein took photograp of any of the As part of dur i ng your working career did Page Page girls women who came over to give him a massage you ever work in restaurant or a personal serv i ces I A Thats correct type business where you would prov i de like All right Mr Rodrigue other than Mr cater i ng or something like that to other wealthy Epstein I thin you told us you had worked for a individuals lady named Ms Hammond A I i A Yes Give us a little of your background if And you had worked for a gentle an you cou then Mr Rodr i guez A i dney Bowman A I work in Long Island Montauk Lake Club ls he the gentleman from ish er Island and Marina a very exclusive country club where A No Arturo Torres Mr Nixon used to spend his summers Richard All right In addition to Ms Hammond up Nixon I worked for Leona Helmsley in New York in Palm Beach you worked for other Indiv i dua as Very demanding lady And then Mr Torres in Texas well in i ranch and as well as Fisher Island And I A I did i part time but I don have her was a general manager of one of his restaurants in name right now sir San Antonio Texas This is the most hi gh profile Dur i ng your career as a let me st ri ke people that I worked for vn..u7 __ IVI l.ll Had you worked other than those places Leona Helms le she used to have the Helmsley Mr Art ro Palace and she with her husband Harry Helmsley I A Arturo Torres yes think they owned a number of real estate in Arturo Tor es Ms Hammond the other add i tion to hote roperties i nd i vid ual you cant remember and Mr Epste i A Thats correct have you worked for other individuals as an estate When you would I th i nk you described manager or general house manager her as a demanding person A No sir A Yes Pages to Kress Court Reporting Inc Rut Nolrt Damt Miami Beach FL NON PARTY VR GfUFFRE00 I Case Document Filed Page of Page All right In terms of these wealthy people that youve worked for he se In iv idua about what they do MR HOROWm Object to the form THE WITNESS Yes Page do they all have that is at least i terms of Mr Epstein the way that his household was managed was it i milar to other set of circ mstances that youve been involved with MR HOROWITT Object to form THE WITNESS They have a common ground BY MR CRITTON All i ght And in terms of you talked about Mr Epstein that here was some sort of a manual or a procedure book with rega to his house A House manual yes A house manua Did other houses have BY MR CRITTON And have you worked at other locations that is in the ot er houses that youve worked where they have massage tables A Yes And in those other locations where they had a massage table were they similar to the massage tab that was in Mr Epsteins home A Yes si All ri ght Almost same make and model A Same type yes And did other indiv i duals in houses that you wo ked a and other places where you helped house manua as well Is that easo ably I mean not common but its something that youve seen before out other estate managers would those individuals I have massages from time to time A Yes i MR EDWARDS Fo rm THE WITNESS I know a lot of ouses do but that was the only estate that we have a ouse manual BY MR CRITTON And othe ind i vidua like ere youve age worked i mi ar to Epste in ow Mr Epstein was i ngle A Yes All ri ght And i having a lot of or bringing a lot of attractive women and other peop to his house I assume at i dnt offend you i any way MR EDWARDS Object to the form THE WITNESS No ir BY MR CRITTON At least based upon your exper:ence in dealing with other individuals ith er of some notoriety li ke Ms He lmsley or when yo said the cl ub that you worked up i in Montauk A Montauk ake ub and Mar ina i ght You ran i nto sepa rat and apart J.I v1 Ul I I corporate people busi ess peop A Yes People of substant i al resources and wealth A Yes Have you found at least in your experience that most of those people are pretty i screet about when I say discreet pr i vate So having a massage or a massage table in someones house that you i ght hat lives i Pa Beach or Montauk or New York or somethi wou you cons i der that unusua MR HOROWm Form THE WITNESS No Page BY MR CRITTON I think you told me at least in Mr Epsteins home other than for one guest he i dnt have any type of alcohol in the house Is that correct A Thats correct Was that basically you understood that that was one of the pol i cies and procedure no a cohol in the house A Yes And did you ever see any type of illegal or inappropriate drugs A No sir And was that another policy or proced ur a solutely no drugs of any kind A No smoking i the house II II l:f IIVU IV fl a cohol A Yes Was that pretty typical for other Pa Beach places that you were familiar with A No All right And other places youd always find alcoho A Yes Pages to Kress Co rt Report in Inc Rue No re Dame Miami Beach FL NON PARTY VR GIUFFR Case Document Filed Page of All right And you i ght find drugs A Yes And some pretty wild parties A Yes Page Now i th regard to the women who came to give massages of those women of those approximately fifteen that you described how many of them came more than one more than one occasion MR HOROWITZ Form THE WITNESS Id say more than ha BY MR CRITfON So maybe seven eight nine ten A Yes Of those people that came on of those seven to ten that came on more than one occasion i those individuals come on many occasions A Yes And as to the women who were who you understood were coming to give the massages MR EDWARDS Form MR CRITTON Im not done yet THE VIDEOGRAPHER I need to go off the record for a ec ond Thereupon an interruption was had Page THE VlDEOGRAPHER Were back on the record BY MR CRITTON Mr Rodr i guez I want to turn to the stay with the women who came to i ve or at least were called to give the massages You were shown a number of message pads I th i nk Mr Mermelstein who represents a number of or at least certainly Jane Doe and some others you were identified or shown a bunch of message pads that had I think in most in stances your initials A.R Do you recall that A Yes I do I think one of the individuals that you ident i fied that called often was C.W A Yes I I This lady ca ll ed on a regular basis or at least from look i ng at your pad she would ca ll on a pretty regular basis Is that true A Yes And she and others who are reflected on those message pads they were calling to come to give massages Correct A Yes Page MR EDWARDS Object to the form BY MR CRITTON And I dont know whether he asked do you remember a person named T.M A Yes And would she call from time to i me asking if she could come to give a massage just like C.W MR EDWARDS Object to the form THE WITNESS Yes BY MR CRITTON So at least those two individuals they were overtly that is they were asking whether they could come to give Mr Epste i a massage Correct A They will call and they will say I need to talk to Sarah and Sarah fifteen minutes later will tell Alfredo were going to have a massage with so and so So either C.W or T.M would call to ask if they could come and then a massage would be set then they would show up A Thats correct sir Okay And from time to time they would bring other people as well Page A Thats correct Both C.W and T.M A Yes Of the females that the women that came to the house did you ever see anyone force any of these women onto the property A No sir Did you ever see anyone force them into the house A No Did you ever see anyone force them into the kitchen A No sir Did you ever use any force any type of intimidation or coercion to bring them into the house and get them into the kitchen Did you ever observe Ms Kellen using any force or intimidation or coercion A No I i not with any of these individuals A I did not MR EDWARDS Object to the form BY MR EDWARDS Did Ms et me use the init i als Pages to Kress Court Reporting Inc Rue Notre Dc1rm i ami Beach FL NON PARTY VR GfUFFRE00I037 Case Document Filed Page of Page that way it will show up correctly Did ever use from what you saw did she ever use any force or coercion or intimidation i th any of the women that she brought to the house MR HOROWm Form MR EDWARDS Object to the form THE WITNESS No sir BY MR CRITTON Okay Im just talklng about what you observed dur i ng the time And you know what I mean by force A Yes You know what I mean by intimidation A Yes Could to be verbal intimidation or coercion either verbally or using some form of her body or their bodies A Yeah I understand that MR EDWARDS Fo rm MR HOROWITT Form MS EZELL Objection form BY MR CRITTON When C.W brought individuals to the house did you ever see her use any force or Page i ntimidation or coercion from what you could observe with those women who had come to give a massage A No MR EDWARDS Form MR HOROWITT Form MS EZELL Form BY MR CRITTON With any of the fifteen women that you observed who came to the home to give massages during the time period through I think you said February of OS the time period I think was it August Mr Rodriguez A August August of through February of A March of I A Yes Okay Thats the time per i od Im focussing on Of the approximately fifteen women that you came to see to i ve massages that you let i the back door after punching the security code i any of them ever appear to be scared A No Page Did any of them ever appear to be frightened MR HOROWITT Form THE WITNESS No BY MR CRITTON Did any of the women appear to be fearful A No Did any of them appear to be uncomfortable in coming Into the house MR EDWARDS Form THE WITNESS No BY MR CRITTON At any time did any of them express to you verbally that they were in fear when they came into the house A No sir id any one of the fifteen girls that came to the back door then into the kitchen and prior to your leaving them in the kitchen say Mr Rodriguez or Alfredo or sir could you get me out of here A No sir Did any of them tell you verbally that they were uncomfortable A No Page Did anyone say help me or Im scared A No Did all of them appear to be at least when they came to the back door in a reasonably good mood A Yes They all appeared to be happy A Yes Smile Id say interact with you verbally in your greetings A Thats correct Did any one of the fifteen girls that you observed during the August through March time period from your personal observation appear to be there appear to be at the Epstein home MR EDWARDS Object to the form MR HOROWITT Object to the form THE WITNESS No BY MR CRITTON Did any one of the fifteen women who came to give the massage ever tell you that they had been forced to come to the house or coerced into coming to the house Pages to Kress Court Reporting Inc Rue Notre Dame i ami Beach Fl NON PARTY VR GfUF I Case Document Filed Page of Pag Page A No them stop and have anything to eat or did you I MR EDWARDS Form always see them at the end that is theyre ready BY MR CRITTON to go For those women I think I need let A I didnt know they came from downstairs me strike that they went to the kitchen but I didnt know they On some occasions youd see the women were there because I was in the guest house come down from upsta i rs because you wou either Okay thats my question You only let them out of the house or you might give them observed them either if you heard conversation or an envelope that had money in it Is that Sarah had called you and said would you pay such correct and such A Yes A Yes Did any of those Mr Edwards asked you At which time you would give them the some questions I think I was Mr Edwards envelope with money whether they had sat down and had anyt hin to eat A Yes whether they had ce eal or anything ik that In that set of circumstances they were on A Yes the i way bas i cally to leave Did you ever observe any of those women A Yes before they wen upstairs eat i ng anything at the When you saw them leave did any of them house at any time any of the ones that you saw dur in A Somet im es August of through March of OS appear to you And I think he used he meaning Mr to be scared Edwards used cereal and I ce cream A No sir A Yes Did any girls women ever appear to have And he said if I recall from the ast been Injured in any way deposition kids li ke ice cream MR EDWARDS Form Page Page A Yes THE WITNESS No sir Do you remember him asking you that BY MR CRITTON A Yes i anyone appear to be in shock Are you familiar that teenagers like ice A No sir cream Was anyone ever crying A Yes A No sir Are you familiar that peop who are Was anyone disheveled or appeared to be and years old ik ice cream unhappy A Yes A No i Are you familiar that older people even Did all of them appear that is the ones our age Mr Rodr i guez like ice cream too that you saw leave the house that you had an A Yes opportunity to observe during that time period Okay And when the in i viduals would sit did they appear to be approximately the same there and that i these women who would come over personality same demeanor that they had had when to give a massage and they wou ld you would they came into the house observe them eat i ng did they appear to be MR HOROWITT Form I VU A Yes BY MR CRITTON MR HOROWITZ Form Did anyone ever tell you when they came BY MR CRITTON down the sta i rs that they had been injured i they appear to be Interacting i th A No either you or the chef Im talking about the young lady the A Yes women who had given the massages that you saw When any of those women wou come over actually eave the house that is you had some to i ve massage came downstairs i you ever see interaction i th i ther some Interaction as they Pages to Kress Court Report in Inc Rue Notre Dame Miami Beach FL NON PARTY VR GIUFFRE00 I Case Document Filed Page of Page were leaving the house did anyone ever tel you at they had been Inj red A No sir Did they ever tell you that they had been forced do something against their will A No Did they ever tell you that they had been forced do something inappropria A No Did they ever tell you that they had been assaulted in any way A No Did they ever tell you that they had been i nappropriately touched A No MR HOROWITZ Form This Is a cumulative He already to you the lim i ted contact he had This is totally inappropriate line of questions MR CRITTON ls that a form objection MR HOROWITZ Youre exceeding the scope of the direct because nobody asked i MR CRITTON Form you get form in federa court ats what you get Give me your form Page MR HOROWITZ Form cumulat i ve MR CRITTON Great Why dont you let me finish the question and then you can object to i Could you give me back at my last question was ease Thereupon a portion of the record was read by the reporter THE WITNESS No BY MR CRITTON i they ever tell you hat ey had been sexually assa ult ed in a way MR EDWARDS Fo MR HOROWITZ Form THE WITNESS No BY MR CRITTO I A No At any i me i you hear anyone strike that As to the women who came to give a massage did you ever ear anyone scream A No sir Did you ever hear anyone cry out what sounded like to you help Page MR EDWARDS Form THE WITNESS No BY MR CRITTON Did you ever hear anyone yell rape or assault or battery MR HOROWITZ Form THE WITNESS No BY MR CRITTON I Did you ever hear anyone yell out In anger A No Youve gone online Mr Rodriguez and looked at various articles or post i ngs that have been made regarding these cases Is that a fair statement A Im sorry If I understood your testimony from July 29th and a little bit today is that youve gone onl i ne and read some artides and/or what the pol i ce report may have said that is youve read i nformation that youve about these lawsuits after the time that you left Mr Epstein emp oyment A Yes Cor ect Pag A Yes And therefore you have at least seen certain allegations and what people say occurred or at east their recitat i on of what may have occurred at Epstein home A Yes You have no personal know edge one way or the other MR HOROWITZ Object to the form MR EDWARDS Form BY MR CRITTON Correct A Thats correct Are yo also aware that the i ndividuals who have filed lawsuits want i some instance millions of dollars A Okay Are you aware that some of them a now claim i ng that they were sexually assaulted A Yes And batte ed A Yes And you have no information no personal knowledge In that regard Is that true Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR GfUFFREOO I Case Document Filed Page of Page A Yes MR EDWARDS Form MR HOROWITT Form BY MR CRITTON All right Were you aware of the backgrounds of any of these women who came over to i ve massages MR HOROWITT Form THE WITNESS No sir BY MR CRITTON Well have you did any one of the females who ever came to give massages did they ever tell you that they were prostitutes A No sir Did they ever tell you that they had been lead into a life of prostitution MR HOROWITT Form lB THE WITNESS No BY MR CRITTON Did they ever tel you abou their family life whether it involved pr stitution abuse prior posttraumatic stress synd ome drugs alcohol abuse by I nd i viduals physica abuse as well as verbal abuse A No hey didnt lei me PaQe And obvfously you have no personal knowledge one way or the other A No sir with regard to what their backgrounds were before they ever met or came in contact with Mr Epstein A No sir Did any person female who tame to give a massage at the Epstein home did aryone ever come downstairs and say Mr Rodriguez or sir call the po li ce MR EDWARDS form MR HOROWITZ Form THE WITNESS No sir BY MR CRITTON think you said on one occasion you saw LL J,J II I I you didnt recognt:z.e A Exactly You called the police A Yes I did Did you go to the police or you called the police and they came A went to the police department So how did you did you actually leave the property in our car Page A was pulling over from blix so I turned ar und and I went to the po ice and say Okay You were coming back to the home when you saw that car there A EXactly And they sent they the police sent a police car with you to come there A Yes Did you and the po li ce office walk up to the car A The police went first All right And if I understand that that was in January of A Yes And when you did that then did you follow behind the lice officer to see who was in the car A Yes And then you recognized that as Yes A And said she had come back or was there to get some money A Yes And did you i fact give her money A Yes I i And I think you said you told the police officer you recognized her A Yes Did you have to get permission to pay her or did you just pay her7 A No because Sarah told me already bu I forgot she was going to be that fate so that was my concern in ca ling the police Okay And that person who came do you have any idea what her age was at that time A That night Right January of A No no Im sorry January of A No had had with Louella who was I think she was one of the house the main housekeeper A Yes And Louella told you a number of thoughts that she had Is that correct A Yes And as to Louella what she told you about lei me strike that Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NO PA TY VR G!VFFR I Case Document Filed Page of I think you told us you were asked questions about sex toys I think you certainly described the back mass.igers Correct A Yes I think you sa i the only sex toys that Page you ever saw were in the armo re at the end of Mr Epsteins bed A Yes Okay And whatever other sex toys that to which there was a reference thats somet ing that Louella to you ls that cor ect A Th ats correct Page A To br i ng pictures from my computer Let me rephrase the quest i on I thought what you said ast time was that as to the pictures that you did see of naked women of a naked woman or naked women on the computer that youve looked at ose pho ographs hrough your computer A No Okay Then I may have misunderstood you Was your refe ence to Ms Maxwells computer that you made at the last deposition A Yes Yo were asked at he last depos i tion I dont remembe who asked the question but whet er Okay Your comput that you ad eith in the staff se or tha you A i dn access you had ever seen pornograp on any computer I think one of your responses was you saw some You couldnt access those files A Thats correct photos of a naked woman who appeared you to be a model All ri ht now Im with you So the photographs youve talked of the nude individua or the naked women were the photographs that weve already talked about i th both i.e In A Yes Okay Do you conside every photograph picture painting of a naked nude woman to be pornography Ms Maxwel compu er MR HOROWITZ Form A Yes MS EZELL Objection form Tha you for clear in hat up TI-IE WITN SS I consider we if its Im going to ask you to assume that a frontal picture it pornography I will look at my way BY MR CRITTON In your view A Yes a ge So if you looked at don remember whether Playboy stil has say a Playboy that has a frontal nud i ty shot of a woman you would in esse ce say that Playboy is selling pornography A Yes The efore every rson who buys a Playboy that has over the last umpteen tens of years that has a frontal picture of a woman in th de woul be purchas i ng pornography eth er i from CVS or Walgreens or ckerd as they existed VI CIIY I I t::I lUIC lOl ll A Yes MS EZELL Objection fo MR EDWARDS Form MR HOROW ITZ Form BY MR CRITTON The photographs Im sorry th pictures thot you saw in the computer I think you were able to draw those up or bring those up from your own computer Page who youve descr i bed as hav i ng come to Mr Epste i ns house on three or four ti mes a wee for a period of ime one of her cla i ms in th i case i hat she has been emotiona ll traumat i zed by her contact with Mr Epstein Just assume that to be true for purposes of th i quest i on Did you ever observe any what you would have seen as emot i ona tra ma any type of i sturbance with c.w on the many ti mes she came to your house MR EDWARDS Fo rm TI--lE WITNESS I i see any BY MR CRITTON Doe it make sense yo that a perso who cla i ms emotiona trauma would continue come i MR EDWARDS Form MR HOROWITT Form MR WILUTS Object to the form the question TI--lE WITNESS Im ot a psycholog i st MR EDWARDS Qin you stcte your swer I did hear it TI--lE WITNESS Yeah Im not a Pages to Kress Court Report i ng Inc otre Dame i ami Beach FL NON PARTY VR GIUFFREOO I Case Document Filed Page of psycho og i st I don know MR CRITTON I have no further questions REDIRECT EXAMINATION BY MR EDWARDS Page Mr Rodriguez I dont know if we covered this last time I think that we did not but can you tell us during the period of time when you worked at that house at Brillo Mr Epsteins what cars did he own or were in the driveway A We have two Suburbans two Mercedes and a Cobra and a motorcycle And which if any did he dr i ve A He preferred the Mercedes or any of the Suburba All i ght Do you know whe he owns homes A Yes Where MR CRITTON Form THE WITNESS Paris New York City El Brillo Saint James Island Im sorry an Island in the Caribbean and a ranch in Nevv Mex i co BY MR EDWARDS Page Page Whats the address A Foch Avenue Paris Okay Do you know a telephone number for Balsone A No I dont remember sir All right How did it come up that you ta ked to him about whether or not Mr Epstein had massages at that house A He came on two occasions and stay with me fo a week because Mr Epstein wanted me to get into his style of running the house and he was good enough to give me some inside information what he likes and doesnt like so he told me the same th i ng was in Paris And I think that you described Mr Epstein usually had about two massages a day or at least we were calling them massages A Yes sir MR CRITTON Form BY MR EDWARDS And did Mr Balsone describe it in a similar fash i on A Yes in Paris And did he also tell you that the girls Page Have you been to any of the other were very young in age that he was receiving these properties massages from A No MR CRITTON Form Do you know the house managers at any of THE WITNESS Yes the other properties BY MR EDWARDS A Yes Did he indicate whether or not or how And who are they old these girls were A Balsone in Paris good friend of mine A No he didnt told me from Brazil And the peop In New York give me Just that the age group was similar to the briefing when I came aboard There is a the age group that he was interested in in Palm couple from the Philippines And I talked to the Beach couple that used to own the Island I mean who MR EDWARDS Form used to manage the Island a couple from South THE WITNESS Yes African Ba sone was closer to me BY MR EDWARDS Have you talked to Ba sone about whether And did you talk to any of the ouse UI place A No A Yes I did Who was the house manager in New York at And what did he say about that A That he had a lot or massages over there too MR CRITTON Mr Balsone was which one THE WITNESS Baslone was the house manager of Paris Foch Avenue BY MR EDWARDS the time when you were the house manager at El zo Brillo A His nickname was Jo-Jo but I dont remember Jo-Jo and his wife but I don remember his name sir Do you know whether Mr Epstein would have massages when he was in New York at his New Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL NON PARTY VR IUTFR
