Case Document Entered on FLSD Docket Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA DOE NO Case No Plaintiff EPSTEIN Defendant JANE DOE NO Case NO Plaintiff EPSTEIN Defendant JANE DOE NO Case No Plaintiff Vs JEFFREY EPSTEIN Defendant DOE NO Case No Plaintiff EPSTEIN Defendant Case Document Entered on FLSD Docket Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page DOE NO Case No Plaintiff EPSTEIN Defendant JANE DOE NO Case No Plaintiff Vs JEFFREY EPSTEIN Defendant Case No Plaintiff EPSTEIN Defendant JANE DOE Case No Plaintiff Vs JEFFREY EPSTEIN Defendant Page DOE NO II Case No Plaintiff EPSTEIN Defendant JANE DOE NO Case No Plaintiff Vs JEFFREY EPSTEIN Defendant DOE NO Case No Plaintiff EPSTEIN Defendant Ives Dairy Road Suite North Miami Florida July a.m to p.m Page I A I I of ALFREDO RODRIGUEZ taken on behalf of the Plaintiffs pursuant a Re-Notice of Taking Deposition Duces Tecum 10-1102.9APPEARANCES MERMELSTEIN HOROWITZ P.A BY STUART MERMELSTEIN ESQ Biscayne Boulevard Suite Miami Florida Attorney for Jane Doe and ROTHSTEIN ROSENFELDT ADLER BY BRAD EDWARDS ESQ and CARA HOLMES ESQ Las Olas City Centre Suite East Las Olas Boulevard Fort Lauderdale Florida Attorney for Jane Doe and E.W And L.M PODHURST ORSECK BY KATHERINE EZELL West Flagler Street Suite Miami Florida Attorney for Jane Doe and Page APPEARANCES LEOPOLD-KUVIN ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B RICHARD WILLITS ESQ 10th Avenue North Suite Lake Worth Florida Attorney for C.M.A BURMAN CRITTON LUTTIER COLEMAN LLP BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER Case Document Entered on FLSD Docket Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page INDEX OF EXAMINATION WITNESS DIRECT CROSS ALFREDO RODRIGUEZ By Mr Mermelstein By Mr Edwards By Mr Langino INDEX OF EXHIBITS 11-18.8EXHIBITS PAGE Message pad Documents Page 1-1235.4Deposition taken before MICHELLE PAYNE Court 2-1235.4Reporter and Notary Public in and for the State of at Large in the above cause THE VIDEOGRAPHER This is the case of Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant And Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant CMA plaintiff versus Jeffrey Epstein defendant And Jane Doe plaintiff versus Jeffrey Epstein et al defendant And Jane Doe is there a shorter thing that we can do here Its also missing this one right here MR MERMELSTEIN Do we have a problem with saying Jane Doe and the Epstein and related cases THE VIDEOGRAPHER Im missing this Jane Page Doe right here on the copy you gave me Im missing which Jane Doe this is Theyre all different case numbers Do you want me to go through each case number MR CRITTON Im going to note my objection Obviously if this deposition gets played not obviously Im going to object to the litany of each one so I dont know how we can separate it out Maybe if and when at the time of trial and depending on how the Court determines what comes in and what doesnt with regard to the consolidated aspects of this I have no great idea other than just saying Jane Doe versus Epstein et al or something like that or Jane Doe et al MS EZELL Couldnt we just say and those cases which have been consolidated with it for Discovery purposes MR EDWARDS Although there is cases here that have cross noticed this from state court that havent been consolidated so that may not work You may have to read them all if it works out your way that will just get edited out at least he will have read Page that caption every caption Right Is there a better suggestion MR CRITTON No There may be a better suggestion if he starts this is such and such day its the deposition of Mr Rodriguez in the case such and such and we can almost fill it in depending on which tape it goes how it fills in at least well have the context of the first and depending on whether the Judge reads it in from a consolidated or they all come related I have no great idea MR EDWARDS I was thinking if he read every one of them and it was the seventh in line then you just would edit it so you would only read that one MR CRITTON Im okay with that too THE VIDEOGRAPHER On page number three there is something missing on the top here Do you want me to read each case number separately MR MERMELSTEIN I dont think its necessary MR EDWARDS I dont think its necessary either Case Document Entered on FLSD Docket Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page THE VIDEOGRAPHER So just go through just the names MR MERMELSTEIN Thats sufficient And there is a cross notice for one of the state cases MR LANGINO That would be our case MR MERMELSTEIN So hes got that notice Off the record Thereupon a discussion was held off the record THE VIDEOGRAPHER This is the case of Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant CMA plaintiff versus Jeffrey Epstein defendant Jane Doe plaintiff versus Jeffrey Epstein et al defendant Jane Doe plaintiff versus Jeffrey Epstein et al defendant Jane Doe No Page plaintiff versus Jeffrey Epstein defendant Jane Doe No plaintiff versus Jeffrey Epstein defendant B.B plaintiff versus Jeffrey Epstein defendant This is in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County Florida This is the deposition of Alfredo Rodriguez Today is July the 29th starting time the year starting time approximately a.m Will attorneys please state their appearance MR MERMELSTEIN Stuart Mermelstein for plaintiffs Jane Doe Jane Doe Jane Doe Jane Doe and Jane Doe and Jane Doe MR EDWARDS Brad Edwards for plaintiff Jane Doe MR LANGINO Adam Langino on behalf of plaintiff B.B MS EZELL Cathy Ezell on behalf of Jane Doe and MR CRITTON Bob Critton on behalf of Page Jeffrey Epstein MR WILLITS Richard Willits on behalf of plaintiff C.M.A MR EDWARDS And Brad Edwards on behalf of plaintiffs E.W and L.M 6-1235.4Thereupon ALFREDO RODRIGUEZ been first duly sworn or affirmed was 9-1235.4examined and testified as follows DIRECT EXAMINATION MR MERMELSTEIN Can you state your full name for the please A My name is Alfredo Rodriguez And where do you live A I live in Kendall Southwest Miami Florida Are you currently employed A No Okay When was the last time you were A December of Was there a time you were employed in Beach Florida A Yes I was Page When was that A I began on September of And where were you employed A I work well I have several employers Palm Beach One of them was Jeffrey Epstein By several employers in Palm Beach you A Different employers At the same time A No different times From to I employed by Dana Hammond Donna Hammond A D-A-N-A Hammond Or Aimes is her single Dana Aimes Hammond Dana Aimes Hammond A Yeah That was in Palm Beach A Yes And in September you were employed whom A Jeffrey Epstein Did Mr Epstein employ you as an 23-1134.8individual or through any business or corporate A As an individual Case Document Entered on FLSD Docket Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page Sure go ahead and answer however you MR CRITTON Form THE WITNESS I dont think it was right MR EDWARDS Did you ever voice that opinion that you think that it was right that these young were over behind closed doors upstairs with Epstein in his bedroom MR CRITTON Form THE WITNESS I been asked that question before MR EDWARDS Excuse me A I been asked that question before By whom A Palm Beach Police Department Did you give the same answer that you did think it was right MR CRITTON Form THE WITNESS Yes MR EDWARDS And what about it to you aside from the that you had a daughter roughly the same age besides that told you that it wasnt right Page MR CRITTON Form THE WITNESS Ask me your question again MR EDWARDS My question is why is it your opinion it wasnt right for these young girls to be in Mr Epsteins A It wasnt MR CRITTON Form MR EDWARDS It wasnt right A It wasnt And why not MR CRITTON Form THE WITNESS Because Im a father I have two daughters MR EDWARDS And given Mr Epsteins wealth and power influence is that something that you as a could have seen your daughters doing at age MR CRITTON Form THE WITNESS I dont think that my daughters would be doing that MR EDWARDS You would hope not Page A No exactly MR CRITTON Form MR EDWARDS I think that the next time youre 5-1235.4mentioned in the report I believe its page MS EZELL Off the record briefly Thereupon a discussion was had off the record MR EDWARDS Page It says Alfredo Rodriguez in Miami had eluded meaning you were to evade or avoid service of process previously and was not served the 14-1134.8investigative subpoena This is an investigator saying you just home or something Right A But I never elude anybody You never intentionally tried to avoid police officers A No no never Okay MR CRITTON So much for the police report MR EDWARDS All right The bottom of page says I Page Mr Rodriguez to the interview room Were you taken to an interview room to a in the police department A This was in the District Attorneys Oh it was at the State Attorneys A Yes Okay Was a State Attorney there as A Yes Mrs Weiss Daliah Weiss A Young lady Weiss D-E-I-S-S Okay I have D-A-L-I-A-H Daliah Weiss A Yes Thats her A Yeah Okay Did she ask you any questions A Both of them Okay So it was both if there is a think you said earlier there is a taped 23-1134.8statement there is a tape of this A Yes If we listen to that tape if we ever get Case Document Entered on FLSD Docket Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page tape its going to be Assistant Attorney and Detective Recarey asking questions A Yes It says during the sworn taped statement Rodriguez stated he was employed by Jeffrey for approximately six months I think we already talked about that skipping ahead a little bit If Rodriguez needed to relay a message to he would have to notify Epsteins 11-1134.8secretary Lesley in New York who would then notify personal assistant Sarah who would relay message to Epstein A Yeah MR CRITTON Form MR EDWARDS Thats pretty much the process you 18-1134.8described A Yes it was normal procedure Rodriguez stated Epstein did not want to or hear the staff when he was in the 22-1134.8residence MR CRITTON Form THE WITNESS Thats correct MR EDWARDS Page Thats something you agree with A Yes MR CRITTON Form MR EDWARDS Rodriguez advised Mr Epstein had many In addition to the girls who are roughly and age who had come to the house to have a time who were some of the other guests that know of if you know their name MR CRITTON Form THE WITNESS I mentioned Alan Dershowitz MR EDWARDS Thats a lawyer from Harvard A Yes The magician David Copperfield other lawyers from New York you know There some other guests And how frequently would these other come over A Once a month something like that Okay So if its only once a month and were only there six months youre saying you saw six guests come over in addition to A They have people you know they have Page I will say yeah Then you mentioned that you typed into I guess you Googled Prince Andrew and Bill Why would you pick those names were associated with Mr Epstein A Yes And what is your understanding as to how Andrew is associated with Jeffrey Epstein A Because there were pictures with him In the house A Yes Many pictures or are we talking about A Many pictures Were these pictures that looked that to be at social events at Mr Epsteins or where A Mrs Maxwell took him to England to 20-1134.8introduce him to the royalty Is its your understanding that Ghislaine knew Prince Andrew and introduced A Yes Is it also your understanding that at point in time Ghislaine dated or had a Page 1-1235.4romantic relationship with Prince Andrew MR CRITTON Form THE WITNESS I dont know that MR EDWARDS Do you know around what time period it that Mr Epstein was introduced to Prince A I believe How do you know that A Ive heard dates From people in the Epstein group A Yes Okay MR CRITTON Let me note my objection move to strike its based on his testimony is based on hearsay MR EDWARDS During the six month period of time when worked directly for Mr Epstein how often did Epstein get together with or hangout with Andrew if you know A I didnt see him once You never saw Prince Andrew at the house A No no he called Im sorry how often would he call Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO CASE NO Plaintiff Vs JEFFREY EPSTEIN Defendant I JANE DOE NO CASE NO Plaintiff Vs CONDENSED JEFFREY EPSTEIN Defendant I JANE DOE NO CASE NO Plaintiff Vs JEFFREY EPSTEIN Defendant I JANE DOE NO CASE NO Plaintiff Vs JEFFREY EPSTEIN Defendant I Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Page Case Document Entered on FLSD Docket Page of Page Page JANE DOE NO CASE NO IN THE ORCUIT COURT OF THE 15TH Plaintiff JUDICIAL CIRCUIT IN AND FOR Vs PALM BEACH COUNTY FLORIDA JEFFREY EPSTEIN CASE NO AB Defendant B.B JANE DOE NO CASE NO Plaintiff Plaint i ff Vs Vs JEFFREY EPSTEIN JEFFREY EPSTEIN Defendant Defendant I C.M.A CASE NO Plaintiff Vs Ives Dairy Road JEFFREY EPSTEIN Suite Defendant North Miami Florida I August JANE DOE CASE NO p.m to p.m Plaintiff CONTINUED VIDEOTAPED Vs DEPOSITION of JEFFREY EPSTEIN ALFREDO RODRIGUEZ Defendant I taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Deposition Duces Tecum Page Page JANE DOE NO II CASE NO APPEARANCES Plaintiff Vs MERMELSTEIN HOROWITT P.A JEFFREY EPSTEIN BY ADAM HOROWITT ESQ Biscayne Boulevard Defendant Suite Miami Flor i da Attorney for Jane Doe JANE DOE NO CASE NO and ROTHSTEIN ROSENFELDT ADLER Plaintiff BY BRAD EDWARDS ESQ and CARA HOLMES ESQ Vs Las Olas i ty Centre Suite East Las as Boulevard JEFFREY EPSTEIN Fort Lauderdale Florida Attorney for Jane Doe and E.W Defendant And L.M JANE DOE NO CASE NO PODHURST ORSECK Plaintiff BY KATHERINE EZELL ESQ West Flagler Street Vs Suite JEFFREY EPSTEIN i ami Flor i da Defendant Attorney for Jane Doe and LEOPOLD-KUVIN BY ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Entered on FLSD Docket Page of APPEARANCES RICHARD WILLITS ESQ 10th AVenue North Suite Lake Worth Florida Attorney for C.M.A Appeared via telephone BURMAN CRITTON LlJlTIER COLEMAN LLP BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ By Ms Ezell By Mr Willits By Mr Critton By Mr Edwards By Mr Langino CONTINUED INDEX OF EXHIBITS PLAINTIFPS PAGE Drawing Photograph Photograph Photograph Photograph Photograph Report Exhibits and were retained by Ms Ezell Page Page Page Deposition taken before MICHELLE PAYNE Court Reporter and Notary Public in and for the State of Florida at Large in the above cause THE VIDEOGRAPHER This is a continuation of the deposition of Alfredo Rodriguez Today is Friday August the 7th the year starting time approximately p.m Will the court reporter please swear in the witness Thereupon ALFREDO RODRIGUEZ having been first duly sworn or affirmed was examined and testified as follows MR CRITTON Before we get started just with regard to Ms Ezell represents Jane Doe and the alleged time of her incidents as of least have been plead in the complaint for is Im sorry through with Jane Doe the Spring of Spring/Summer of Mr Rodriguez never even began employment until and OS I think her questioning I think I cant say she doesnt have standing based on the court order but I would say its Page completely irrelevant and immaterial and has no probative value with regard to this particular witness based upon the two clients at least that are in suit at this point in time MS EZELL As Mr Critton well knows I represent a number of other clients whose cases have not been filed and I believe we do have standing to ask questions and I do intend to do that today EXAMINATION BY MS EZELL Mr Rodriguez you stated last time that there were guests at the house frequent guests friends from Harvard Do you remember that testimony A Yes maam And was there a lawyer from Harvard named Alan Dershowitz A Yes maam And are you familiar with the fact that hes a famous author and famous lawyer A Yes maam How often during the six months or so a::i:m th a a ci a a he rz a sh a a i tz re Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Entered on FLSD Docket Page of Page A Two or three times And did you have any knowledge of why he was visiting there A No maam You dont know whether or not he was a lawyer acting as a lawyer or whether he was there as a friend A I believe as a friend Were there also young ladies in the house at the time he was there MR CRITTON Form THE WITNESS Yes maam BY MS EZELL And would those have included for instance Sarah Kellen and Nadia Marcenacova A Yes maam Were there other young ladies there when Mr Dershowitz was there MR CRITTON Form THE WITNESS Yes maam BY MS EZELL Do you have any idea who those young women were A No maam Were any of those the young women that Page you have said came to give massages A Yes maam And do you have any idea whether or not Mr Dershowitz was also receiving massages A I dont know Maam I want to ask you to take this piece of paper please and a pencil MR WILLITS Can anybody hear me MS EZELL Yes Can you hear me MR WILLITS Ive heard nothing for about a minute or so MR CRITTON Can you hear me now MR WILLITS Yes MS EZELL Im asking questions Im sorry MR CRITTON Why dont we go off the record for a second Thereupon a discussion was held off the record THE VIDEOGRAPHER Were back on the record BY MS EZELL Mr Rodriguez you indicated that there were several staircases in the house A Yes maam Page Can you tell me where those were A One in the kitchen and the one in the formal the main entrance And there was one more added later on but there is two when I was working there Could you just give me a rough sketch of the house of where the main entrance was and where the kitchen was A Im not an architect but its something like this This is the kitchen this is the main entrance Will you mark the kitchen with a please and the main entrance with ME A This is the pool The pool A Yes maam And in the upper left A In the terrace yeah there was a balcony here And where were the staircases A This is one the kitchen one in the foyer and the pool Okay And would you just put an where the foyer staircase began And KS where the kitchen staircase began Page And you said that later another staircase was added A Yeah we rehabilitated this you know but you asked me how many stairs there were to answer your question there were three Three So where was the third one A The pool this leads to the pool Through the outside master bedroom you could go downstairs to the pool Okay A stairway then from the outside from outside the master bedroom A Yes maam Down to the pool A Yes maam One of your duties was to answer the door Is that correct A Yes maam Which door would you answer A Mainly the kitchen And why was that why would people mainly come to the kitchen A Ill say it was for practicable reasons because not to go to the main it was shorter because the entrance was here so this was the driveway and we used to take into the back door of Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Entered on FLSD Docket Page of Page Page you about having driven A.H and you recalled having had her in the Suburban specifically All right Ms Ezell asked you about Mr A Yes Do you remember any of the other girls Dershowitz being present in Mr Epsteins home and I think she asked and I think that you said Mr Epstein was a and he and Mr Dershowitz women who came to give massages ever having driven them or is A.H the only one that you remember were friends A Yes MR EDWARDS Form She also I think asked was Mr Dershowitz THE WITNESS I only remember A.H right ever there when one of the women who gave a now for the fact that I was driving by the massage was present in the home airport and I showed her Mr Epsteins A I dont remember that plane Thats what I want to clear up Is it BY MR CRITTON All right Which really takes me back to your testimony that Mr Dershowitz was there when any of the women came to Mr Epsteins home to really where I started with this series of give a massage questions A Yes You saw the girls the women who came in MR EDWARDS Form to give the massages when they came in if you BY MR CRITTON were advised or if you heard conversation and you saw them you would see them when they left A Yes And you saw A.H because she was in the As to whether any of those women were ever associated with Mr Dershowitz would it be a correct statement that you have absolutely no knowledge Suburban on at least one occasion A Yes And therefore you never saw these girls these women who gave the massages in the Page dining room or the library Would that be a fair A I dont know sir You dont know A I dont know sir MS EZELL Form BY MR CRITTON Page statement Okay Were you in any way attempting in A Thats correct your response to Ms Ezell to imply that Mr MR EDWARDS Form Dershowitz had a massage by one of these young BY MR CRITTON ladies All right So therefore the pictures A I dont know sir that you saw Sarah Kellen taking of girls women You have no knowledge either in the dining room or library those were A No sir other individuals other than those who may have And you certainly werent implying that given or who came for massages Is that correct that occurred you just have no knowledge MS EZELL Form Correct MR EDWARDS Form MR EDWARDS Form THE WITNESS Its confusing sir THE WITNESS I dont know because there were a bunch of girls I BY MR CRITTON dont know which one they were but I saw her Sorry taking pictures of the groups A I dont know BY MR CRITTON I think in response to one of Ms Ezells As to whether they were people who came questions you responded that let me ask it this in on the planes or there may have been a massage way girl or more than one woman who gave a massage You never saw Mr Epstein ever take you just dont know as you sit here youd just be photographs of anyone Would that be a correct speculating Is that correct statement MR EDWARDS Form A Yes THE WITNESS I dont know Would it be a correct statement you never BY MR CRITTON saw Mr Epstein initiate a phone call to anyone a a ms sdi iis:aa ag IO Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Entered on FLSD Docket Page of Page York house A He will have massages MR CRITTON Form BY MR EDWARDS And are we still talking about a habit of two a day MR CRITTON Form THE WITNESS I dont know that BY MR EDWARDS Okay So for the time period when you have been familiar with Mr Epstein and known his habits is it fair to say that he would have roughly two girls a day in that same age group wherever he was A Yes MR CRITTON Form BY MR EDWARDS All right And have you talked to anybody that has given you similar information from his Island home A No Do you know any of the girls that have been over to his Island A Yes And who are they Page A Nadia the girls who used to stay at the home in El Brillo used to go over there to the Island When he would have these girls I guess weve kind of categorized them as the girls who would come over with him on an airplane and stay at the house A Yes When they would be staying at the house would he also have the local Palm Beach girls coming over that you were told to call masseuses A Yes So these girls that came on the airplane with him were they also did they also have knowledge that these young girls were coming over to give massages MR CRITTON Form THE WITNESS Yes sir BY MR EDWARDS Okay Who are the girls from the airplane other than Nadia that you remember A Sarah There were so many sir I dont recall right now But Sarah is for sure Nadia was one of the main girlfriends but I dont Page And is your understanding that Mr Epstein was intimate with any of those girls MR CRITTON Form THE WITNESS Yes BY MR EDWARDS With all of them MR CRITTON Form THE WITNESS Yes BY MR EDWARDS With Sarah as well A Yes MR CRITTON Form BY MR EDWARDS With Nadia A Yes MR CRITTON Form BY MR EDWARDS And the girls who would come over on the airplane MR CRITTON Form THE WITNESS Yes BY MR EDWARDS Did you ever have occasion to go into the bedroom and find the vibrators or back massagers out after Mr Epstein was in the room with any of Page the girls that came over on the plane MR CRITTON Form THE WITNESS Yes BY MR EDWARDS So thats something that would be out after the girls that came over on the plane or the girls that came over for the massages A Yes MR CRITTON Form BY MR EDWARDS And at the time when you were house manager you had a 15-year old daughter A Yes Did she live down here A In New Jersey Okay When Alan Dershowitz was at the house I understood you to say that these local Palm Beach girls would come over to the house while he was there but youre not sure if he had a massage from any of those girls A Exactly And what would he do while those girls were at the house MR CRITTON Form remember that THE WITNESS He will read a book with a Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Entered on FLSD Docket Page of Page Page glass of wine by the pool stay inside usually its Yahoo dot com or at Bellsouth dot BY MR EDWARDS net Did he ever talk to any of the girls A It was very uncommon I dont remember A I dont know sir sir Certainly he knew that they were there Did everybody in the I think you MR CRITTON Form called it the organization did everybody have THE WITNESS I dont know sir e-mails BY MR EDWARDS A Yes Do you know how Sarah Kellen knows Mr Okay Would that include Nadia Epstein A Yes A No sir All right And did Mr Epstein have an Or how long shes known him e-mail MR CRITTON Form A Yes THE WITNESS She was on board two years Did you ever correspond with Mr Epstein or a year and a half before I came on board by e-mail BY MR EDWARDS A Yes Okay MR EDWARDS You can go ahead A So its probably or THE WITNESS Thats the only one that I All right You mentioned this Citrix remember system THE VIDEOGRAPHER Okay were off the A Yes record Is that a system that was used to operate Thereupon a recess was had the phones and the computers THE VIDEOGRAPHER Were back on the A The computers mainly record with tape number four All right But you then also described BY MR EDWARDS Page Page some system where someone would call on the Mr Rodriguez what was Mr Epsteins telephone and that would be automatically e-mail downloaded to the computer A Jeep project at something Jeep A Yeah you can retrieve who called in a project I cant remember it right now transcript written who called whats the message Okay In the course of this next or the time so you have it on a piece of paper you minutes can print it out A I can recall Is it your understanding that is also if it comes to you just tell me So part of the Citrix system it was Jeep project A Yes A Like Jeep the brand name Jeep Jeep All right Did you have an e-mail project at I cant remember A Right now yes Okay Was that his only e-mail to your No when you were working at knowledge A Yes I did A No Mr Epstein He had other e-mail addresses And did Sarah Kellen have an e-mail A Yes A Yes Do you know what any of his other e-mail And did all of the e-mails end the same addresses were way such as Epsteins house dot com or something A No I dont remember A Yes Do you know who the carriers were for the Okay What was Sarah Kellens e-mail other e-mail addresses owned by Jeffrey Epstein A I dont remember A No sir What was your e-mail Whether it was Yahoo or hot mail or A Staff house I dont remember sir A No none of those Do you recall how it ended I mean Okay Was this Jeep project e-mail run Pages to Kress Court Reporting Inc Rue Notre Dame Miami Beach FL
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