UNITED STATES DISTRICT COURT

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08•CV.80119•CIV•MARRAIJOIINSON JANE DOE NO. 2. Plaintiff. n. JEFFREY EPSTEIN. Defendant. Related cases: 08.10232. 0840360. 9840381 08.10994. 0640993. 0840811. 08.80893. 09.80169. 09.10591.09.80656.09.80802.0941092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday. September 8. 2009 1012 am.. 3:45 pm. 2139 Palm Beach Lakes Boulevanl West Palm Beach. Banda 31301 Reported By Sandra W Townsend. FPR Now), Public. State of Flan& PROSE COURT REPORTING AGENCY West Palm Beach Office 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of the Defendant: ROBERTI. CRITTON. ESQUIRE R 4 5 67 9 10 11 12 13 14 15 16 IT 19 20 21 22 23 24 25 APPEARANCES: On behalf of the Plaintiffs: RICHARD WII.I.ITS. ESQUIRE RICHARD H. WILLITS PA STUART hIERAIELS1EIN. ESQUIRE KATHERINE W. EZELL. ESQUIRE Page 2 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 EXHIBITS NUMBER DESCRIPTION Exhibit number 1 Exhibit number 2 Exhibit number 3 Exhibit number 4 Exhibit number 5 Page 4 PAGE Photographs 45 Transcript B0 Incident Report 137 Incorporation Papers 149 Incorporation Papers ISO 1 (Pages 1 to 4) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 FOIA Confidential Treatment Requested / Fed. R. Crim. P. 6(e) Material Electronically signed by Sandra Townsend (401-377-676-289S) GJ SUBPOENA RESPONSE 000337 Electronically signed by Sandra Townsend (401-377-676-289S) 76e15648-4alc-Odee-67ac-479898cc7004 3504-021 Pagc I of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002595 EFTA00157548 Page 5 Page 7 1 PROIEEDINGS 1 2 - - - 2 Q. All right, sir. Did you ever work for Jeffrey 3 Deposition taken before Sandra W. Townsend. Court 3 Epstein? 4 Reporter and Notary Public in and for the State of 4 A. Yes, I did. 5 Florida at Large. in the above cause. 5 Q. In what capacity? 6 - - - 6 A. Everything. I started with Jeffrey Epstein 7 VIDEOGRAPHER: Today is September 8. 2009. 7 around 19 -- please bear with the dates because I 8 The time is 12 minutes after 10:00 in the morning. 8 trying -- 9 This is the videotaped deposition of Juan 9 Q. Sure. 10 Alessi in the matter of Jane Doe number two versus 10 A. -- to remember. 1969 as a part-time 11 Jeffrey Epstein. This deposition is being held at 11 maintenance guy. 12 2139 Palm Beach Lakes Boulevard in West Palm Beach 12 And then I become a full-time employee. I 13 Florida. 13 think it was January 1.2 -- '91. '92. so '92. Sorry. 14 My name is Stan Sanders. I'm the videographer 14 Q. You said you started in 1969? That would 15 representing Visual Evidence. Incorporated. 15 be — 16 Would the attorneys please announce their 16 A. No. No. No. No. No. 17 appearances for the record. 17 Q. Okay. 18 MR. WILLITS: Richard Willits. representing 18 A. '99. 19 19 Q. 1999? 20 MR. BERGER: WilliamJ. Berger. representing 20 A. Yeah. 21 ...mg and Jane Doe number two. 21 Q. All right. And how did you happen to get that 22 MR. MERMELSTEIN: Stuart Mermelstein of 22 job? Was it through an employment agency -- 23 Mermelstein and Horowitz. representing Jane Does 23 A. No. 24 numbers two through eight. 24 Q. -- or an ad in the paper? 25 MR. LANGINO: Adam Langino. on behalf of 25 A. I had a company at that time used to take care Page 6 Page 8 1 MS. EZELL: Katherine Ezell from Podhurst 1 of a lot of residents in Palm Beach. And I got to know 2 Orseck, on behalf of Jane Does 101 and 102. 2 Jeffrey through Lesley Wexner. And I used to work in 3 MR. CRITTON: Bob Critton. on behalf of 3 about 20 different. 20.25 different homes in Palm Beach 4 Jeffrey Epstein. 4 as a maintenance guy. 5 THEREUPON, 5 Q. Okay. 6 JUAN ALESSI. 6 A. And I have basically my own company and I do 7 having been first duly sworn or affirmed, was examined 7 repairs for them. I did home sit in for them. 8 and testified as follows: 8 Q. And what was — did you work for Jeffrey 9 THE WITNESS: I do. 9 Epstein? What was your position when you started? 10 DIRECT EXAMINATION 10 A. When I started, he hire me to -- he just 11 BY MR. WILLITS: 11 bought the house. 12 Q. Good morning. sir. 12 Q. I'm sorry? 13 A. Good morning. 13 A. He just had bought the house -- 14 Q. I introduced myself through the videographer. 14 Q. Okay. 15 My name is Richard Willits. 15 A. -- where he live on El Brillo. And he hire me 16 A. Okay. 16 through Mr. Wexner's references to do repair works. And 17 Q. re resent a young lady by the name of 17 basically what I did the most was taking walls apart. 18 18 windows and stuff that he didn't want to have it. -- 19 A. Okay. 19 Q. I see. 20 Q. Is that name familiar to you at all? 20 A. -- fix it. 21 A. Whose name? 21 Q. And when you started working for Mr. Epstein. 22 Q. Do you recognize that name 22 were you still working for other people in Palm Beach? 23 A. No. 23 A. Yes. I did. 24 Q. What is your residence address, sir? 24 Q. Okay. And about how long a period of time did 25 A. My address is 25 you do this type of work for Mr. Epstein. the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FOIA Confidential Treatment Requested /Fed. R. ern. P. 6(e) Material Electronically signed by Sandra Townsend (401-377-676-2895) al SUBPOENA RESPONSE 000338 Electronically signed by Sandra Townsend (401-377-676-2895) 76.1564a-4alc-4dee-87ac-479808cc7004 3504-021 Page 2 of 20 2 (Pages 5 to 8) (561) 832-7506 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00002596 EFTA00157549 _ 2 3 4 5 6 7 S 9 10 Page 9 maintenance and taking out walls? A. It was couple months. It was couple months before. Q. And what was the name of your company? A. Alessi Maintenance. Q. And how were you paid? A. By him? Q. Yes. A. Usually by check or cash sometimes. Q. Do you know what company actually paid your 1 2 3 4 5 6 7 8 9 10 Page 11 about seven months before -- after I become a full-time employee. Q. Okay. And how did Ms. Maxwell come into the picture? A. It was his girlfriend, his main girlfriend. Q. Okay. Had you known her before she became -- A. No. Q. -- your -- A. Never know her before. Q. I'm sorry. I didn't get a chance to finish my :1 company? 11 question. :2 A. It was Jeffrey Epstein and Company. 12 Would you have referred to her as your :3 Q. So you said you had that position for a couple 13 supervisor or your superior or what would you have :4 of months. 14 called Mrs. Maxwell? :5 What happened next? 15 A. I used to call her Ghislaine. :6 A. Then Mr. Epstein asked me to. if I wanted to 16 Q. Okay. And how was it explained to you that 17 be his employee. because I was going from one house to 17 you were now to deal with Ms. Maxwell. as opposed to 18 another house to another house. one hour here. I was 18 Jeffrey Epstein? 19 just running around Palm Beach all day. 19 A. She would tell me. I am going to take care of 20 So he asked me if I would just work for him. 20 the house. 21 exclusively for him. 21 Q. Okay. That was explained to you by 22 Q. Okay. 22 Ms. Maxwell? 23 A. And we agreed with the terms and I become a 23 A. Uh-huh. 24 full-time employee as a maintenance guy. And I was 24 Q. Is that a yes? 25 taking care of everything. as far as maintenance. 25 A. Yes. Page 10 Page 12 1 Then my job changed little by little to house 1 Q. And when Ms. Maxwell started assuming 2 man, estate manager. and then to a majordomo. 2 responsibility for the house, did your duties change at 3 Q. Okay. When you first agreed to terms with 3 that time? 4 Mr. Epstein and you first started working for him full 4 A. Not much. 5 time. what were those terms, do you remember? 5 Q. Okay. 6 A. The terms is basically was how much — he 6 A. Not much. 7 asked me how much I was making in all the properties. 7 Q. And at that time when Ms. Maxwell started S And I says. well. I make this -- this amount 8 taking responsibility for the house. what were your 9 of money. 9 duties? 10 And he says. fine. 10 A. Basically I was still doing the maintenance :1 Q. And how much was that. did he pay you? 11 work. :2 A. Around 445.000. I think I started with 45. 12 Q. Okay. :3 Q. Okay. And when you started to work for him as 13 A. Was doing — they were trying to remodel the :4 a full-time employee, did you have anybody that you 14 home and they would told me. okay. tear down this wall. 15 reported to or did you deal directly with Mr. Epstein? 15 We want to see how it's going to look. Or put this 16 A. At the beginning with Mr. Epstein. directly to 16 windows and tear down -- we had a fishing tank. We took 17 him. 17 it out -- I took it out. A kitchen on the second floor. 18 Q. Did that change? 18 I took it out. So it was basically dismantling the 19 A. Later on. yes. 19 house. 20 Q. And how did that change? 20 Q. Okay. And about how long a period of lime did 21 A. When Ms. Maxwell. Ghislaine Maxwell came to 21 that project last? 22 the picture. 22 A. I would says. six to seven months. 23 Q. Okay. About when was it that she came into 23 Q. Okay. And after the remodeling slacked off or 24 the picture? 24 stopped. did your duties then change? 25 A. Exactly date. I cannot remember. But it was 25 A. Yeah. Increasingly they change. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FOIA Confidential Treatment Requested /Fed. R. Cren. P. 6(e) Material Electronically signed by Sandra Townsend (401-377-676-2895) al SUBPOENA RESPONSE 000339 Electronically signed by Sandra Townsend (401-377-676-289S) 76ef664a-ealc-edee-87ac-479898ec7004 3504-021 l'a"4e 3 of 20 3 (Pages 9 to 12) (561) 832-7506 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002597 EFTA00157550 Page 13 Page 15 1 Q. Okay. Who -- 1 living on the property. but outside the house? 2 A. Periodically. It didn't change from one day 2 A. I was living in the property. No. No. No. 3 to another. 3 I was working outside the property. 4 Q. And who would tell you that your duties were 4 Q. Yes. 5 increasing? 5 A. And because it was multiple jobs that I had to 6 A. Either Mr. Epstein or Ms. Maxwell. 6 do. 7 Q. Okay. And how did your duties increase? 7 Q. Okay. 8 A. In — I become more — more involved in the 8 A. Had to do with the pool. the service, the 9 daily running operation of this home. This home was run 9 landscaping. taking care of that. I didn't do it 10 like a hotel basically. 10 myself, but I have people working for me. 11 Q. Okay. Were you given any manuals or rules or 11 Q. Okay. Approximately when was it in 12 procedures that you had to follow? 12 relationship to Ms. Maxwell taking over the 13 A. At the end of my stay. yes. I was. 13 responsibility of the house did you then move inside the 14 Q. Okay. At the end. And I'm going to jump to 14 house? 15 the end now and then come back. 15 A. I will says. after it was done, a big 16 What was it that you were given at the end of 16 renovation. when architects and engineers. And that wu 17 your stay: what kind of papers or manuals? 17 after I did the breaking down of this renovation, they 18 A. It was a manual. I can't remember how many 18 hire architects, they hire decorators and engineers, and 19 pages. but it was quite thick manual that was -- that 19 did the -- they did the work. It was a big renovation. 20 was done by mute manager. that she will manage all — 20 one of the renovations. 21 all the properties. And that was also to be in force in 21 And then they make our quarters. They even 22 Palm Beach. 22 built our -- my quarters in there. 23 Q. I see. Do you still have a copy of that 23 Q. When you said "our." was there someone else 24 manual? 24 who had quarters there. too? 25 A. No. I don't. 25 A. About three years later, after I start Page 14 Page 16 1 Q. Do you have any papers whatsoever that were 1 working. my wife came to help me. 2 prepared while you were working -- 2 Q. I see. And are you able to describe for me 3 A. No. 3 where the quarters were. like, what floor? 4 Q. — for Mr. Epstein? 4 A. Yes. It was in the second floor and the -- 5 A. I left everything in there. 5 let me trying to remember — northeast corner of the 6 Q. Did you make any diary notes yourself or any 6 property. Northeast corner. yes. 7 notes for your own private use while you worked for 7 Q. Did anyone else work for Mr. Epstein while you 8 Mr. Epstein? 8 were working for him there at the house? 9 A. No. sir. The only thing I have is my 9 A. During the whole time? 10 separation agreement. That's it. 10 Q. Yes, sir. 11 Q. Okay. Did you bring that with you today? 11 A. Yes. 12 A. No. I didn't. 12 Q. All right. When you first started there. :3 Q. Okay. Did your duties ever include taking 13 there was no one else? 14 telephone messages? 14 A. When I started there. was a — it was a 15 A. Yes. sometimes. 15 Jamaican girl that she was doing the cooking. 16 Q. And when did that start approximately? 16 Q. Okay. Do you happen to remember her name ? 17 A. When I move from the outside to the inside of 17 A. No. 18 the house. 18 Q. All right. 19 Q. All right. 19 A. She worked for couple months. 20 A. I -- when I start the position. I never had an 20 Q. I see. All right. When did any other 21 apartment in the house. And when I definite they want 21 employees begin to work for Mr. Epstein while you wen 22 me inside to run the house. I had an apartment. I have 22 there? 23 a small service quarters in the house, inside the house. 23 A. They hire chefs. There was mostly European 24 Q. Okay. And when you say. outside the house. do 24 chefs. It was an English chef. but I cannot -- Rupert. 25 you mean outside the property or were you — or were you 25 I know his name was Rupert. A french chef that was (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FM Confidential Treatment Requested I Fed. R. Cren. P. 6(e) Material Electronically signed by Sandra Townsend (401-3n-67B-289S) al SUBPOENA RESPONSE 000340 Electronically signed by Sandra Townsend (401-377-67B-2895) 4 (Pages 13 to 16) (561) 832-7506 760564a4ato-4dee-87ao-479898ce7004 3504-021 Page 4 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00002598 EFTA00157551 Page 17 Page 19 1 Didier. A kid from New York who was a chef, also. But 1 Q. Were there any photographs of nude females in 2 they were one after another one. They were hiring chefs 2 the house while you were there? 3 when I doing — sometimes I did most of the cooking. 3 MR. CRITTON: Form. 4 When they wanted to bring their chef, they bring their 4 MR. WILLITS: What's the matter with that S chef in their plane. And the chef will stay. will work 5 form? 6 there and then will travel with them. 6 MR. CRITTON: Overly broad. Nude? You mean 7 Q. Were there any other employees that worked for 7 completely naked? 8 Mr. Epstein while you were worked for him, that you know 8 MR. WILLITS: However you want to interpret 9 of? 9 it. 10 A. No. except my wife. 10 THE WITNESS: Excuse me. Can you repeat that 11 Q. Did you know a lady by the name of 11 again? 12 =I 12 MR. CRITTON: Form. 13 A. • yes. I do.--came at the 13 BY MR. WILLITS: 14 end of my stay there, probably two or three months 14 Q. Yes. Were there any photographs of nude 15 before I left. 15 females in the house while you worked for Mr. Epstein'? 16 Q. Okay. Did she do any work for Mr. Epstein. 16 A. Yes. Sometimes I saw nude photographs. 17 that you know of? 17 Q. Are you able to describe where you saw those. 18 A. Yes. She was a -- I don't know her deterrent. 18 where in the house? 19 but she was an assistant to him or to her. I don't 19 A. Most of the times those photographs were taken 20 know. 20 by Ms. Maxwell. And they usually are her desk. And sin. 21 Q. All right. There is a -- I've seen a 21 kept a big album. 22 reference in -- and the spelling has changed in my 22 Q. Do you remember any pictures of nude or 23 various references -- is there a or.?Do you 23 partially unclothed females on the walls at 24 recognize that name? 24 Mr. Epstein's house? 25 A. 25 MR. CRITTON: Form. Page 18 Page 20 1 Q. 1 BY MR. WILLITS: 2 A. Yes. I know 2 Q. He's just making objections for the record 3 Q. Want to take a chance at spelling that last 3 that he can take -- he will take it up with the Judge 4 name? 4 later on. S A. I think it was But she was not an 5 A. Okay. 6 employee. She was a guest. 6 Q. You don't need to worry about -- 7 Q. Was she a full-time guest? 7 A. Yes, it was. It was pictures of partially 8 A. No. 8 nude. 9 Q. When would she visit? 9 Q. And where were they? 10 A. Most of the times they were in the pool. 11 Q. How about on the stairway? Ill 12 A. No. On the stairway there were no pictures i 13 14 when I was there. re. Q. How many stairways were there? 15 Q. Okay. Do you — are you familiar with any 15 A. It was the service stairway that is very 16 other individuals by the name ME on who worked fo- 16 narrow coming from the service quarters to the kitchen. 17 Mr. Epstein? 17 And the main stairway. that it was quite wide 18 A. No. 18 and to the second floor. 19 Q. After the renovations were complete. did you 19 Just those two. 20 have access to the entire house while you worked for 20 And also there was a stairway outside through 21 Mr. Epstein? 21 the pool to the balcony upstairs. 22 A. Absolutely. yeah. 22 Q. And do you have a recollection of pictures of 23 Q. Was there any particular portion of the house 23 any females whatsoever on either of the inside 24 that was denied access by — to you? 24 stairways? 25 A. No. 25 A. No. I don't. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FOIA Confidential Treatment Requested /Fed. R. Cren. P. 6(e) Material Electronically signed by Sandra Townsend (401.377478-2895) al SUBPOENA RESPONSE 000341 Electronically signed by Sandra Townsend (401.377476-2895) 5 (Pages 17 to 20) (561) 832-7506 76M5648.4atc-Odee-87ac479898ce7004 3504-021 Page 5 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002599 EFTA00157552 1 Page 21 Q. What is your understanding. sir, of the -- a 1 Page 23 Q. Okay. Do you remember any other females beitq 2 reference to a girl. as opposed to a woman? Are you 2 present at the house, other than the females that ou'vc 3 familiar with the term. girl? 3 mentioned. which were 4 A. Of course. 4 Were them any others that you -- 5 Q. Are you familiar with the term, woman? 5 A. Many. many. many. many. many. 6 A. I interpret most a woman. a married woman. a 6 Q. When did you first -- 7 married person. 7 MR. CRITTON: Can I just have the last 8 Q. Are you -- how would you describe a 14 year 8 question read back? 9 old, a woman or a girl? 9 MR. WILLITS: Of course you can. :0 A. A girl. of course. 10 MR. CRITTON: Please. :1 Q. How would you describe a 16 year old. a womar 11 MR. WILLITS: But only once. :2 or a girl? 12 MR. CRITTON: That's all I need. :3 A. Again. I don't know. I am not -- I don't 13 MR. WILLITS: You sure. :4 think I can tell you exactly she is 14 or 16. 14 Go ahead. :5 Q. But if you knew -- 15 (Previous question was read.) :6 A. Sixteen. I would think is a girl. of course. 16 MR. CRITTON: And can I just ask for a 17 Q. Were there ever any visitors to the Epstein 17 clarification from you? Arc you going to use -- if 18 house that you considered to be girls. as opposed to 18 you use the word woman, am you -- 19 women? 19 MR. WILLITS: I said. females. 20 A. Yes. Yes. I think I would says. I never 20 MR. CRITTON: No. no. I understand. But in 21 check her i.d. 21 the future if you use woman, does that mean. at 22 Q. Right. 22 least to Mr. Alessi. that that's married, and if 23 A. Or I was not told to check i.d.s. -- 23 its a girl she has to be 14 or 16? Because that's 24 Q. Of course. 24 how you asked the question. 25 A. — on these girls. But one. I would says. 25 MR. WILLITS: All I'm going to talk about is Page 22 Page 24 M. was very young because she was in hi w school. Ant 1 females. sometimes either l •ick he 2 MR. CRITTON: Okay. I 3 MR. WILLITS: And ask -- I I can't 4 MR. CRITTON: I'll be alert to the questions 5 remember exactly what that place is. the name of the 5 then. 6 place. 6 MR. WILLITS: All right. So you don't need it 7 Q. Did you give -- provide transportation for any 7 sleep through the next few questions. 8 other females while you worked for Mr. Epstein? 8 MR. CRITTON: I don't sleep at all. 9 A. Occasionally. yes. I did. 9 MR. WILLITS: All right. Now I'm totally 10 Q. Do you happen to remember the names of any of 10 confused. 11 those females? 11 BY MR. WILLITS: 12 A. I remember one. specifically one. It was. 12 Q. When did you first become aware of female:, 13 Her name I cant remember her last name, but I 13 visiting the Epstein house? 19 think it w• I'm not sure. I can be wrong on that. 14 A. Since I know him. 15 Q. And how many times did you provide 15 Q. During the renovations? 16 transportation services for this female? 16 A. Yeah. 17 A. Whenever I had -- I been told. Whenever I was 17 Q. Were there -- 18 told to go get them or brio them back to their house. 18 A. Before the -- before Ms. Maxwell. 19 Q. Did you conside to be a girl or a woman? 19 Q. Okay. All right. Let's use that as a 20 A. Again. I think it was a woman. from myself. 20 milepost. 21 her dressing and her — I think it was — again. I don't 21 Before Ms. Maxwell -- 22 know if she was 16. 17 or 18 or 19. could have been. 22 A. Before it was Ms. Maxwell. it was only one 23 But she was not — I never pick her up from a school or 23 woman that it was Mr. Epstein's girlfriend. And her 29 anything like that. The only girl that I picked up from 24 name was Dr. -- she was a doctor of medicine -- Eva 25 the school wan 25 Anderson. And I really liked this girl. She was veil. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FOIA Confidential Treatment Requested /Fed. R. ern. P. 6(e) Material Electronically signed by Sandra Townsend (901-377.676-2895) al SUBPOENA RESPONSE 000342 Electronically signed by Sandra Townsend (40f-377-676-2895) 6 (Pages 21 to 24) (561) 832-7506 7601564a-4a Ic-4dee-87ac-479898cc7004 3504-021 Page 6 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002600 EFTA00157553 Page 25 Page 27 1 nice, nice person. 1 A. Because they were local. Sonic people. they 2 Q. Did you say Anderson or Underson? 2 live in Palm Beach. Sonic of these girls, they live in 3 A. Anderson. A-N. 3 Palm Beach. 4 Q. A-N-D-E-R-S-O-N? 4 Q. How did you know that? 5 A. Yeah. 5 A. They become friends. 6 MR. BERGER: What was her first name? 6 Q. Okay. Do you happen to remember the names of 7 THE WITNESS: Eva. 7 any of those friends? 8 BY MR. WILLITS 8 A. I remember them were some girls that come 9 Q. Before Ms. Maxwell assumed responsibilities 9 multiple times and they're usually there for dinners or 10 for the house, were there any other female visitors to 10 lunches. One was M.. 11 the house. except for Dr. Eva Anderson? 11 Q. Okay. 12 A. No. not that I remember. She was one. 12 A. I think she was a -- she used to work for 13 Q. All right. After Ms. Maxwell assumed 13 14 responsibility for the house, do you recall any female 15 visitors? 15 Q. Okay. 16 A. Many. 16 A. Try to remember names but there were a lot of 17 Q. When did that start in relationship to when 17 visitors in the house, a lot of female visitors. 18 Ms. Maxwell assumed responsibilities? 18 Q. Are you aware of female visitors to the house 19 A. Immediately. 19 who were there to perform massage services? 20 Q. Were there visitors who came back more than 20 A. Yes. 21 once? 21 Q. Do you recall the first time that you observed 22 A. Yes. 22 a female come into the Epstein house for the purposes of 23 Q. And when I say. "visitors: I mean, female? 23 massage? 24 A. And males. 24 A. I don't recall that. 25 Q. I'm only interested in females. Mr. Critton 25 Q. How many different individuals came to the Page 26 Page 28] 1 may be interested in the males. I'm not sure. 1 Epstein house for the purpose of massage. as far as you 2 Did you have any information as to where these 2 understood it? 3 visitors came from? 3 A. In the -- I would says. between 50 and a 4 A. They were mostly European girls. 4 hundred different persons. 5 Q. And when you say. "girls." do you mean 14 to 5 Q. Do you happen to know any of those names? 6 16. — 6 A. I remember couple names. 7 A. No. 7 Q. Okay. 8 Q. — or do you mean females? 8 A. And the last name I asked — I going to tell 9 A. They all were. I would says. under -- over 20 9 you there were girls that come multiple times and there 10 years old. 10 are girls who come one times and that was it. 11 Q. Okay. And it has been explained to us in 11 Of the multiple time the girl -- the girls 12 another deposition that sometimes females travelled with 12 come to the house -- "girls: again, mean — I'm going 13 Mr. Epstein. 13 to refer everybody as girls. 14 A. Yes. they did. 14 Q. Okay. But you don't necessarily mean under 15 Q. Are these females that you are referring to. 15 the age of 18 when you say — 16 did they travel with Mr. Epstein or did they get to the 16 A. None of these girls were under the age of 18. 17 house in other ways? 17 Then again. I don't know. They could have been I8 or 19 18 MR. CRITTON: Form. 18 or 20 or 25. I don't know. But they were all masseuse' 19 THE WITNESS: Both. 19 and they came to the house. 20 BY MR. WILLITS: 20 One of the names that I remember was 21 Q. Both. Okay. Were you aware of any female 21 Q. That' 22 visitors to the Epstein house from the local area of 22 A. Uh-huh. I think it was. 23 Palm Beach County? 23 So many 24 A. Yes. 24 'Mere were also massage therapists from 25 Q. flow -• and why did you become aware of that? 25 Europe. They sometimes travel with him in the plane. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FOIA Confidential Treatment Requested Fed. it err. P. 6(e) Material Electronically signed by Sandra Townsend (401-377476-2895) al SUBPOENA RESPONSE 000343 Electronically signed by Sandra Townsend (401-377476-2895) 76.1664a-4a Ic-4dee-87ac-479808cc7004 3504-021 Page 7 of 20 7 (Pages 25 to 28) (561) 832-7506 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000260 1 EFTA00157554 Page 29 Page 311 And some just namft. that I cannot -- I cannot go on. 1 2 Q. Sure. How did you know than.. were 2 She had -- she was livin. wit 3 4 there for purposes of a massage? A. Because I was told to either Ms. Maxwell will I 5 call. I will call or Mr. Epstein will told me. call this 5 Q. Okay. Do you happen to remember any other 6 girl at that time. Sometimes it was 1:00 in the 6 areas of the county where you transported any of the 7 morning. Sometimes it was within the afternoon. 7 females? 8 Sometimes it was after the movies. They usually go ink 8 A. I transport her -- one back to a house in 9 a movie every night after dinner. And sometimes were 9 10 girls that come at 10:00. 10:30. 10 Q. Okay. 11 Q. How would you know what number to call? 11 A. That's what I can remember now. 12 A. I had a list. 12 Q. Did you ever speak to any of these females 13 Q. Okay. Was this a list that you prepared or 13 that you have mentioned -- let's talk specifically about 14 was given to you? 14 the ones that you have named — 15 A. I had a list that it was in my Roladex. 15 about what they did there at the Epstein house? 16 Q. Okay. So as part of your job there was a 16 A. No. They did massage therapy. 17 Roladex? 17 Q. And how did you know they were actually 18 A. Yes. 18 providing massages? 19 Q. Who put the information on the Roladex? 19 A. Most of them, they had business card and they 20 A. I think I did most of the times or I was given 20 left me business cards. And some of them asked me to 21 a piece of paper. says. call this girl, put a number. 21 call them to provide them work. 22 And I will call her. And if she was coming back. then 22 And I says that was not my job. My job was to 23 Ed put her as a regular massage therapist. 23 call whoever they wanted. Either when she — 24 Q. Do you know how these females would be 24 Ms. Maxwell want a massage. she will told me. I want d 25 transported to the Epstein house? 25 massage at this time with this person. Page 30 Page 32] 1 A. Ninety-nine percent they -- they would drive 1 Q. Uh-huh. 2 their own cars. 2 A. Or Mr. Epstein will call me and he says. get 3 Q. And when they did not drive their own cars. 3 this girl at this time. 4 how -- 4 So it was not my job to pick and choose these 5 A. Some, they were transported by the boyfriends 5 girls. 6 or the husbands and they wait outside. 6 Q. Did you have anything to do with paying any of 7 Q. How about. are you aware of any of the females 7 these females? 8 being transported to the house by virtue of a taxi? 8 A. Occasionally. yes. I did. 9 A. I think it was an occasional time that I have 9 Q. Can you describe that? 10 to send a girl in a taxi, if I was going to be busy for 10 A. The most -- the regular girls that came to the 11 transporting them. 11 house, sometimes they got paid once every night or even 12 Q. Did you ever provide transportation to any of 12 day or I knew them and they would just say. just keep a 13 the females who were there for purposes of massage? 13 tab of the hours and I will pay amount at the end of the 14 A. Yes. I did. 14 week. 15 Q. Okay. Do you remember where you went? 15 Q. And how were they paid. by cash or check? 16 A. I remember specifically on... -- 16 A. Most of the times. I would says. 95 percent of 17 Q. Okay. 17 the times I was paid by check. 18 A. -- that she used to liv 18 Q. I mean, the females? MI 19 A. The females. -- 20 Q. All right. 20 Q. The females were paid? 21 A. And when she went the first time, she — she 21 A. -- I would pay them by check. 22 went by herself. I never had to bring her back. But 22 Q. Out of what account? 23 later I was told by Mr. Epstein to go and pick her up. 23 A. I was — I have an account that I was from the 24 And she give me the -- or he give me the address and the 24 bank for Jeffrey Epstein and my name was on it. I woulei 25 phone. so I call her and I went and pick her up from 25 sign the checks. I will make a copy of a check. I will (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FOIA Confidential Treatment Requested Fed. It Crin. P. 6(e) Material Electronically signed by Sandra Townsend (401-377478-2895) al SUBPOENA RESPONSE 000344 Electronically signed by Sandra Townsend (401-377-878-2895) 76.1564a-4alc-4clee-87ac-479898ce7004 3504-021 Page 8 of 20 8 (Pages 29 to 32) (561) 832-7506 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002602 EFTA00157555 Page 33 Page 35 1 make the girl sign a paper that they receive check for 1 Q. — the employment of Mr. ng. who were the 2 5500 for five massages. 2 other employees? You mentioned Anybod, 3 Q. And do you remember where that -- what ban 3 else there? 4 that account was with? 4 A. The chef, but the chef also work in Europe. so 5 A. I think Palm Beach National Bank on Worth 5 he was travelling with him. 6 Avenue. 6 Q. Right. 7 Q. Did you ever have any occasions to make 7 A. He had a room. 8 deposits to that account? 8 Thcn it was another renovation of the house in 9 A. Yeah. 9 the middle -- about a year and a half before my 10 Q. Where would the cash or checks come from to 10 departure. And there was a house built for the -- away 11 make deposits? 11 from the — from the main house. It was a service 12 A. Checks. There was checks, big checks for 12 house. There was couple rooms in there with a kitchen 13 Mr. Epstein. 13 and a living room. So he will have a room in there, the 14 Matter of fact, one time I was so scared. It 14 chefs. 15 was a couple million dollar checks that I -- he told me 15 Q. Okay. Does the name ring a bell? 16 to go and deposit. 16 A. No. Never saw her. 17 Q. You said that usually these girls were paid by 17 Q. Do you recognize the name Joe Joe as sometxxl. 18 check. Were there occasions when the females would 18 who worked for Mr. Epstein? 19 19 A. Joe Joe? Joe Joe. as far as I knew. it was -- 20 A. There were occasions -- 20 I met him. He was the house man in New York. 21 Q. -- paid by cash? 21 Q. Okay. 22 A. -- where the girls says, do you have any cash. 22 A. It was him and his wife -- 23 John? They were asking for cash. 23 Q. All right. 24 I says. let me take a look. So I check my 24 A. -- that were the people. they handled the 25 petty cash box that we have for the house for the 25 house in Ncw York. Page 34 Page 36 1 expenses. And if I have it. I pay it. If not. 1 Q. Did you ever personally observe a massage 2 Mr. Epstein will pay. 2 taking place in the Epstein house? 3 Q. Did you ever have any concerns that any of the 3 A. Never. 4 females coming to the Epstein house for the purposes of 4 Q. Did you ever have occasion to clean 5 massage might be under the age of 18? 5 Mr. Epstein's bedroom after a massage? 6 A. No. because I never saw younger. young. young 6 A. Every time. 7 girls. And mostly that I was told they were massage 7 Q. Did anyone assist you with that? 8 therapists. 8 A. Sometimes. 9 Q. Told by who? 9 Q. Who would be -- who would assist you? 10 A. By Ms. Maxwell or Mr. Epstein. 10 A. Depends on the day of the hour. Sometimes the 11 Q. Did you ever have any dealings with 11 cleaning crew that we had. if it was the right date, the 12 about the females who came to provide massage 12 right time, they will go out and clean up. But most of 13 services? 13 the time I was involved. I was the one. 14 A. No. came about. I would says. 14 Q. Did you ever observe any vibrators in 15 the most two months before my departure. 15 Mr. Epstein's bedroom after a massage? 16 Q. Okay. Do you think that you would be able to 16 A. Yes. I did. 17 recognize any of the females if you saw them or their 17 Q. How many? 18 pictures? 18 A. Two. 19 A. Pictures? Yeah. I think so. 19 Q. How many massage tables were there at the 20 Q. Did you ever have any discussions with any 20 Epstein residence while you worked there? 21 fellow employees about the females who were coming 21 A. It was permanent massage tables or we had 22 provide massage services? 22 tables for every room of the house. So it was about the 23 A. No. 23 blue room, the red room. It was a massage table for tht 24 Q. At the time that you left — 24 balcony. It was on Mr. Epstein's bathroom, 25 A. Yes. sir. 25 Ms. Maxwell's bathroom. There was Ms. Maxwells (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. FOIA Confidential Treatment Requested /Fed. R. err. P. 6(e) Material Electronically signed by Sandra Townsend (401-377-678-2895) al SUBPOENA RESPONSE 000345 Electronically signed by Sandra Townsend (40f-377-678-2895) 9 (Pages 33 to 36) (561) 832-7506 760564a-4a ic-4dee-87ac-479898ce7004 3504-021 Page 9 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002603 EFTA00157556 Page 37 Page 39 1 bathroom was in the same quarters. his quarters. 1 Q. The latter? 2 So we had quite a bit of expensive tables. 2 A. The latter. 3 Q. Did you ever get a massage while you were 3 Q. What, if anything. can you remember or tell us 4 working for Mr. Epstein? 4 about your separation agreement? 5 A. I wasn't that lucky. 5 A. It was basically an agreement between him am 6 Q. Okay. I'm sorry. 6 myself that we will leave after all those years of 7 A. I don't want to lie. Yes, I did. By a guy. 7 service. 8 It was a -- occasionally it was male massage 8 And I regret to agree with the amount, but it 9 therapists there. there were called. They did massages 9 was 430.000 for me and S20.000 for my wife. 10 for Mr. Epstein and Ms. Maxwell. 10 And it was -- he give my wife the car that she 11 And one time I had some pains in my back and I 11 usually drive. It was a minivan. Chrysler minivan. as 12 was given as a gift. 12 part of the -- as part of the separation. She loved 13 Q. Now, there came to be an incident where you 13 that car and she did all the shopping. it was done in 14 were arrested that caused you to be terminated from 14 that car. 15 Mr. Epstein? 15 So Mr. Epstein was kind enough to give her the 16 A. No. 16 17 Q. Were you terminated from Mr. Epstein's 17 The rest of the stuff is. was mainly lawyer 18 employment? 18 stuff that you can't understand. But basically that was 19 A. Yes. 19 it. And that it was a part that I think I can -- I 20 Q. Did you promise to pay him back some money? 20 would says. it was more or less that I will not sue him 21 A. Yes. 21 later or he cannot sue me for any reasons or -- and it 22 Q. Did you make all the payments? 22 was like a confidentiality issue in that separation 23 A. Yes. I did. 23 agreement. 24 Q. When was the last time you made a payment? 24 Q. And do you understand that in this instance 25 A. I made a payment immediately. the same 25 you are subpoenaed under the power of the Court? Page 38 Page 40 1 payment. same amount. 1 A. Absolutely. 2 Q. The full amount? 2 Q. And that would include matters that would 3 A. Full amount. 3 otherwise be confidential? 4 Q. Okay. It wasn't a payment plan? 4 A. Can you repeat that again? S A. No. 5 Q. Yeah. Do you understand that because you're 6 MR. WILLITS: I don't have any other 6 under subpoena by the Court to give your testimony. -- 7 questions. You want to take a short break? 7 A. Today. 8 MR. CRITTON: Would you like to take a short 8 Q. -- truthfully — yes. 9 break? 9 A. Uh-huh. 10 THE WITNESS: I'm fine. 10 Q. That the confidentiality agreement would not 11 VIDEOGRAPIIER: Off the record. 10:56. 11 control: the Court's subpoena -- 12 (Brief recess.) 12 A. Oh. yeah. 13 CROSS EXAMINATION 13 Q. -- controls? 14 BY MS. EZELL: 14 A. I understand that. 15 Q. I'm Catherine Ezell. I want to ask you a few 15 Q. You mentioned Ghislaine Maxwell did photo 16 questions about some things that came up during your 16 shoots and kept an album? 17 deposition. your earlier questioning in this deposition. 17 A. Yes. She was fanatic about photographs -- 18 A. Okay. 18 camera. She had a whole bunch of different cameras am 19 Q. The book of policies that you mentioned that 19 she took all the pictures all over. 20 was there by the time you left. I just wanted to 20 Q. Did you ever observe her doing a photo shoot 21 clarify. was that done by somebody in Palm Beach to be 21 of I? 22 used by different households in Palm Beach or was it 22 A. No. 23 done by someone employed by Jeffrey Epstein to apply to 23 Q. Did you ever observe her doing a photo shoot 24 all the homes he -- 24 of any of the other young women whose names you 25 A. Yes. 25 mentioned? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 10 (Pages 37 to 40) (561) 832-7506 FOIA Confidential Treatment RequestedlFed. R.Crirn. P. 6(e) Matedal Electronically signed by Sandra Townsend (401-377476-2895) al SUBPOENA RESPONSE 000346 Electronically signed by Sandra Townsend (401-377476-2895) 76effsta-taloldee-nae479808“7004 3504-021 Page 10 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002604 EFTA00157557 Page 41 Page 43 1 A. Young woman? 1 M.? Obviously the tape preserves it. We're not 2 Q. Yes. 2 asking the tape gentleman to edit it. 3 A. No. I can't remember. I know that she went 3 MS. EZELL: Right. 4 out and took pictures in the pool because later on I 4 MR. BERGER: So how is it preserved that 5 would see them at the desk or at the house. 5 means your client's full name? 6 And nude -- 99.9 percent of the time they were 6 MS. EZELL: Well. we had just agreed in 7 topless. They were European girls. They were — 7 previous depositions that that's the way it would 8 Q. You stated that you believe l.'s name was', 8 read. The written transcript would not have the 9 but you weren't sure? 9 full name. but would just have the initials. 10 A. Not sure. 10 MR. BERGER: I'm not so sure that constitutes 11 Q. Could it have been? 11 an identification by Mr. Alessi that's going to be 12 A... yeah. Yeah. Could have been. 12 clear. But this is the first deposition I've 13 Q. I want to show you a picture and have it 13 attended, so I'm not sure if I'm -- if what I'm 14 marked as an Exhibit to this deposition. 14 saying has been dealt with or not. 15 MS. EZELL: And did we have the agreement 15 MR. MERMELSTEIN: I think we're working on 16 beforehand that we've been having all along that 16 good faith. Mr. Critton is agreeing that the 17 we're just using initials and not names? 17 name -- and I don't think anyone's going to come 18 MR. WILLITS: My client has waived the 18 back later and say, oh. you meant Vince Robinson or 19 confidentiality as to herself. But I certainly 19 anything like that, so... 20 agree as to everybody else. 20 MR. BERGER: Well. I'm not — I'm not talking 21 MR. LANGINO: As do I. 21 about Mr. Critton. Bob Critton I have the full 22 MS. EZELL: Is that okay? 22 trust in. I'm just talking about a jury watching 23 MR. CRITTON: That's what we agreed to on the 23 this or reading this transcript believing that 24 last. 24 Mr. Alessi has accurately identified one of these 25 MS. EZELL: Right. 25 victims. That's all. I don't know if you've all Page 42 Page 44] 1 MR. CRITTON: For the court reporter. at 1 thought about that. 2 least, in terms of the — I guess in terms of the 2 MS. EZELL: Well, for one thing. the jury 3 transcript she gives to us. if you would just use a 3 might, if they're -- if they're hearing or reading 4 first initial and a last initial. 4 his testimony, they most likely would be seeing the 5 MR. WILLITS: So when you ask about'.. it 5 video, which would have the full name. Unless the 6 would ben is what the court reporter would 6 Judge allows us to block out names and we haven't 7 write down? 7 come to that point. 8 MS. EZELL: Right. a MR. MERMELSTEIN: I think the idea at trial. 9 MR. CRITTON: But make sum everybody uses the 9 . if it's read to the ju would become then 10 full name, because that way we'll have two 10 It would be read as M. But if it flied 11 initials. 11 with the Court. this transcript, it will be . 12 MR. WILLITS: When they speak. but she's going 12 and that way it doesn't have to be redacted. 13 to write it down as initials. Is that what you're 13 MR. WILLITS: As I also understood it, if 14 saying? I'm confused about everything. 14 there would be any question at all. we could simply)15 MR. CRITTON: The mason is, is there may be 15 ask the court re orter and she would say. according 16 25. you know, there may be throe IM. So if you 16 to my notes. is not -- or 17 just mention land it just shows up as a ... it 17 whatever her notes s s e be the fina 18 won't make sense. So ergo you need to do that 18 authority? 19 But his client. she gets the 19 MS. F7FI I • Well, she would certainly have 20 whok megillah. 20 that record. 21 MR. WILLITS: Right. 21 MR. CRITTON: You could listen to the tape. 22 MR. BERGER: How is it preserved that we're 22 It would be pretty easy. I think we're making it a 23 talking about your client? You gave her full name 23 lot more complicated than it need be. 24 a minute ago. How is it preserved if she's -- the 24 MR. WILLITS: For once. I agree. 25 court rcponcr is going to change the full name to 25 MR. CRITTON: I think it will he all iiolii, . (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 11 (Pages 41 to 44) (561) 832-7506 FOIA Confidential Treatment RequestedlFed. R. Cren. P. 6(e) Material Electronically signed by Sandra Townsend (40147747B -289S) al SUBPOENA RESPONSE 000347 Electronically signed by Sandra Townsend (401.37743711-28415) 76et564a-aalc4dee-El7ac-479888cc7000 3504-021 Page 11 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002605 EFTA00157558 Page 45 Page 47 1 MS. EZELL: I'm going to ask --I don't know 1 THE WITNESS: Could have been. But, you know 2 whether you've still been serially designating 2 I am not — [don't think I am a very good judge of 3 Exhibits or whether we're doing them separately for 3 ages. If you ask me how old you are. I really 4 deposition. 4 couldn't tell you. 5 MR. CRITTON: I think we cannot trust that 5 MR. CRITTON: Kathy thinks she's 25. 6 people will do them serially. I'd do them with 6 MS. EZELL: In my dreams. 7 each one. 7 THE WITNESS: Now, again. I must tell you. I 8 MS. EZELL: Then would you mark this, please, 8 was never told to check any i.d.s on any of the 9 as Exhibit I to this deposition. 9 people who work at the house. 10 And I'm just going to state on the record that 10 BY MS. EZELL: 11 I will keep that original. We will not attach it 11 Q. I understand that. And. so. I think I'm just 12 to the deposition. 12 trying to establish that you didn't consider it part et 13 (Exhibit number 1 was marked for 13 your job description to worry about or consider the 14 identification purposes and retained by Counsel for the 14 ages -- 15 Plaintiffs.) 15 A. No. 16 THE WITNESS: Yes. that's — 16 Q. — of the young women that came there? 17 BY MS. EZELL: 17 A. Absolutely not. Absolutely not. 18 Q. Can you identify that — the young woman in 18 Q. And. so. you never really focused on that or 19 those pictures? 19 particularly thought about it if they seemed young" 20 A. Yes. 20 MR. CRITTON: Form. 21 Q. Who is it? 21. THE WITNESS: I don't — I didn't see that 22 A. That's I. — I. Now that you says., that 22 many young girls. you know, young. underage girls 23 is M. definite, a hundred percent. 23 at the house. I never saw except the two girls 24 MR. CRITTON: Let me just note my objection. 24 that I mentioned that I think it was undera e was 25 as I did in A. Rod's deposition or Mr. Rodriguez's 25 for sure because Page 46 Page 48 1 deposition. that I know you're going to confiscate 1 2 Exhibit number I. I think it's inappropriate. I I 3 think I should be allowed to have a copy of 4 Exhibits that are being used in deposition. But 5 I'll file a motion with the Court so we don't get 5 That's the onl girl that I knew she wasyoung 6 into a pulling match over your Exhibits. 6 becau 7 MR. BERGER: I would ask that the court I But she was not a 8 reporter initial that. 8 massage therapist. She will go for dinner. And 9 MS. EZELL: Sure. 9 the • will o for the movies a 10 Oh. you did? 11 MR. WILLITS: She marked it. 12 MR. BERGER: Did she put her initials or did 12 That's the only girl that I know that it 13 she just put a number or a letter? 13 was -- I would says. underage. 14 MR. CRITTON: She's nodding that she did 14 BY MS. EZELL: 15 everything that she usually does, which means. 15 Q. Okay. Did — who told you that M. was a 16 initials, date and number. 16 massage therapist? 17 MR. MERMELSTEIN: You can talk. 17 A. Nobody. 18 MR. WILLITS: But when you talk, use your 18 Q. Did you assume that she was a massage 19 initials. 19 therapist because you were told she was coming to give I 20 BY MS. EZELL: 20 massage? 21 Q. How old did you think ■. was at the time she 21 A. No. I assumed she was a massage therapy 22 began coming to Mr. Epstein's home? 22 because I was — I drove Ms. Maxwell to Mar-a-lago. 23 A. She could have been 17. IS, 19. 23 Donald Trump's residence. And I wait in the car while 24 Q. Could she have also been 15? 24 Ms. Maxwell got a -- I think it was a facial or massage. 25 MR. CRITTON: Form. 25 I don't know. But that day I remember this girl... (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 12 (Pages 45 to 48) (561) 832-7506 FOIA Confidential Treatment Requested /Fed. R. Cris. P. 6(e) Material Electronically signed by Sandra Townsend (401.377476.2895) al SUBPOENA RESPONSE 000348 Electronically signed by Sandra Townsend (401.377476.2895) 703e(564a-eatc-idee-87ae479898cc7004 3504-021 Page 12 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002606 EFTA00157559 Page 49 Page 51 . walking down from the main lobby towards the spa of 1 there. So I would says. between three months maybe 2 Mar-a-lago. And I was driving Ms. Maxwell up. up the 2 before I left. And I think I kft at the end of the 3 ramp. It's a little ramp there. 3 year. so it could have been — I remember it was a very 4 And Ms. Maxwell says. stop. And she went and 4 hard day because I had to wait in the sun outside in a 5 talked to -- she went inside. 5 convertible and I was dying. waiting for an hour for 6 And that afternoon around 5:00 I saw .. came. 6 Ms. Maxwell. I think it was in the summer of 2002. 7 She came to the house already. so she was there already. 7 Q. And if I remember correctly. you left in 8 That was the first day I knew. And then she would come 8 November or December of 2002? 9 regularly. 9 A. Yes. 10 Q. Did you ever meet any of l.'s family? 10 Q. So that might have been perhaps July or August 11 A. No. I think she was -- one time I think her 11 of 2002? 12 father drove her there. And I net -- I don't know if it 12 A. Ult-huh. 13 was the boyfriend or husband or -- but he had to wait. 13 Q. And, so. as ! understand it. you only saw 14 make him wait outside while she was at the house. 14 come to that house during the last three months of Nom 15 Q. Do •ou know the name or recognize the name 15 time at Mr. Epstein's? 16 16 A. Yes. 17 A. I think it was him. 17 Q. Do you have any -- any sense or can you 18 Q. That was her -- 18 approximate how many times she came? 19 A. I know he had an old beat-up car 19 A. I cannot give you a number. but I would says, 20 I know it was very old car that I make him 20 two. three times a week. 21 wait on the street one time. I make him come out of the 21 Q. Yo