IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB -• Plaintiff, -vs- JEFFREY EPSTEIN AND Defendants. DEPOSITION OF JANUSZ BANASIAK Tuesday, February 16, 2010 10:09 - 2:30 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1317 (561) 832.7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthla hopkins (601461-976-2934) Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthla hopkins (601-051-976-2934) 205891d-Uaa-42b3-ae22-b5d3c7182d1e 3507-01 I Page I of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006665 EFTA00158250 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff, III 3 BRADLEY J. EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS 4 FISTOS & LEHRMAN, P.L. 7 8 9 10 11 13 14 15 On behalf of the Defendant, Jeffrey Epstein and the Witness: 16 17 JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY GOLDBERGER & WEISS, P.A. 18 and Jane Doe: On behalf of the Plaintiff Jane Does No.'s 1 through 8. STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 205891d-Uaa-42b3t30182dle 3507-011 Pagc 2 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006666 EFTA00158251 Page 3 1 2 3 4 - - - INDEX VOLUME I - - - 5 WITNESS: DIRECT CROSS REDIRECT 6 JANUSZ BANASIAK 7 BY MR. EDWARDS 4 8 9 10 11 EXHIBITS 12 13 14 EXHIBITS DESCRIPTION PAGE 15 PLAINTIFFS' NO. 1 PHOTO 123 16 PLAINTIFFS' NO. 2 PHOTO 123 17 PLAINTIFFS' NO. 3 PHOTO 124 18 PLAINTIFFS' NO. 4 PHOTO 124 19 PLAINTIFFS' NO. 5 PHOTO 124 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2C5aMd4eaa-42b3-ae22-b5d3cflUdle 3507-01I Page 3 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006667 EFTA00158252 Page 4 1 2 3 4 PROCEEDINGS Deposition taken before Cynthia Hopkins, Registered Professional Reporter and Florida 5 Professional Reporter, and Notary Public in and for 6 the State of Florida at Large, in the above cause. 7 8 Thereupon, 9 (JANUSZ BANASIAK) 10 Having been first duly sworn or affirmed, was 11 examined and testified as follows: 12 THE WITNESS: Yes, ma'am. 13 DIRECT EXAMINATION 14 BY MR. EDWARDS: 15 Q. Would you tell us your full name. 16 A. Janusz Banasiak. 17 Q. Could you spell that for us. 18 A. J-a-n-u-s-z, Banasiak, B like boy, 19 B-a-n-a-s-i-a-k. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2W5a9W4eaa42b3-m22-b&IUMIWU 3507-011 Page 4 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006668 EFTA00158253 Page 5 8 Q. And where are you currently employed? 9 A. With Jeffrey Epstein. 10 Q. How long have you been employed with 11 Jeffrey Epstein? 12 A. Since February 2005. 13 Q. What do you do for him? 14 A. My position is called a house manager. So, 15 basically my duties is to make sure that house is in 16 good order when he is around visiting. 17 Q. And have your duties always been the same 18 since February, 2005 through -- 19 A. Yes. 20 Q. -- the present? 21 A. Yes. 22 Q. Okay. Have you ever had your deposition 23 taken before? 24 A. No. This is my first time. 25 Q. All right. The rules are pretty simple. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2c175891c1-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Page 5 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006669 EFTA00158254 Page 6 1 We only have one court Reporter, so it's important 2 that we don't talk over one another. I will wait 3 until you finish your answer. You wait for me to 4 finish my question. 5 A. Okay. 6 Q. Give us an answer similar to what you are 7 doing that we all understand. It's easy when we get 8 into a casual conversation and nod your head or 9 shake your head, but the court reporter can't take 10 it down so just something verbal. 11 A. Okay. 12 Q. If I ask a question you don't understand, 13 tell me you don't understand. 14 A. Okay. 15 Q. So, who hired you to work with Jeffrey 16 Epstein in February of 2005? 17 A. Who hired me? 18 Q. Right. 19 A. I got the phone call from my agency because I 20 signed with agency that Jeffrey Epstein looking for the 21 position in Palm Beach. 22 Q. And what agency was that? 23 A. This was Regal Domestic, Regal Domestic. I .37 24 not sure but something with the Domestic. The office 25 was in Maryland. I signed to the Internet. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthla hopkins (601-051-976-2934) (561) 832-7506 2W5a9W4eaa4211.1-m224,MUMMU 3507-011 Page 6 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006670 EFTA00158255 Page 7 1 2 3 4 5 6 7 8 9 10 • • • • • • • • • • • • • • • Q. Okay. A. I signed a few of them. Then one of them, the one who called me they were the one from Maryland. Q. And what was your A. They told me that they had an opening position in Palm Beach, Florida. Q. And did you know Jeffrey Epstein before working with him? A. No, no. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2C5aMd-Usa-2b3-ae22-bSacflUdle 3507-011 Pagc 7 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006671 EFTA00158256 Page 8 17 Q. And when you started in 2005 when you 18 heard that there was a job position with Jeffrey 19 Epstein, did you interview for that position? 20 A. Yes. 21 Q. Who did you interview with? 22 A. First I got interviewed with Ghislaine 23 Maxwell. 24 Q. And that's G-h-i-s-l-a-i-n-e, Maxwell? 25 A. Right, right. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75891d-Uaa-42b3-ae22-bSac7182dle 3507-01I Pagc 8 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006672 EFTA00158257 Page 9 1 Q. Where did that interview take place? 2 A. In New York. 3 Q. And it was for the position as house 4 manager in the Palm Beach house, correct? 5 A. Right. 6 Q. That's at 358 Albrillo way? 7 A. Correct. 8 Q. Why were you interviewed in New York, if 9 you know? 10 A. Because at that time I was living in New York 11 with my friends and so -- 12 Q. Where did the interview take place in New 13 York? 14 A. In her house on 65th Street. 15 Q. Whose house, do you know? 16 A. Ghislaine Maxwell. 17 Q. So, Ghislaine Maxwell interviewed you back 18 in 2005 at her house in New York for a position at 19 Jeffrey Epstein's house in Palm Beach? 20 A. Right. 21 Q. And what did the interview consist of? 22 What did she ask you? 23 A. She asked me basic questions, you know, what's 24 my previous employer, how long I work for them and 25 basically she was checking my resume. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a9td4eaa42b3-m224Mtterifadle 3507-011 Page 9 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006673 EFTA00158258 Page 1C 1 Q. Okay. And did she ask you about a 2 starting salary? 3 A. No, not yet. We just was a preliminary 4 interview, checking. 5 Q. How long was the interview? 6 A. How long? 7 Q. Yes. 8 A. How long did it last? 9 Q. Yeah. How long did the interview last? 10 A. Maybe 20 minutes, half an hour. 11 Q. All right. After that interview, what's 12 your next contact with either Ghislaine Maxwell, 13 Jeffrey Epstein or anybody else associated with that_ 14 job? 15 A. My second interview with Jeffrey Epstein after 16 a few days. 17 Q. And where did that take place? 18 A. In his office on Madison Avenue. 19 Q. What's the address there? 20 A. I don't remember physical address. It was 27, 21 51st Street. Madison and 51st Street, corner. I don't 22 remember physical address. 23 Q. Okay. And what did you speak with 24 Mr. Epstein about during that interview? 25 A. Same thing. He ask me how long I work for III (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 Ninagld-Uaa42b3-m22-b5d3criWWle 3507-011 Page 10 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006674 EFTA00158259 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 11 what was my duty, basically the same thing. Q. Did you talk about salary with him? A. No. Q. All right. So, what happened in that interview to further your position with Jeffrey Epstein? A. After I finish interview with him I, I waiting for a few days. And I got the phone call from secretary that I had been accepted and offered the job. Q. Okay. Who made that phone call to you? A. One of the secretary. I don't remember her name right now. She told me that they agreed to hire me. Q. Is this a secretary that is located in the New York office? A. Yes, yes. It was a call from the New York office. Q. And she told you that you were being offered the job? A. Right. Q. And at that point in time were you offered a salary? A. Yes. Q • Okay. So up to that point, you had made (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2C5aMd4eaa-2b3-ae22-b5d3c7182dle 3507-011 Page 11 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006675 EFTA00158260 Page 12 1 it clear to them that you wanted a job but not 2 necessarily how much you wanted to be paid? 3 A. Yes. 4 Q. All right. And what was your starting 5 salary? 6 A. It was $58,000, I think, yeah. 7 Q. Did Jeffrey Epstein or anybody else during 8 this interview process tell you why the house 9 manager position had become available, meaning 10 somebody quit or why it was vacant? 11 A. No, no, he didn't. Nobody mention it. 12 Q. Okay. Do you know who the house manager 13 was prior to you being the house manager? 14 A. When I get to Palm Beach, one of the people 15 who work over there they told me that this guy working 16 currently for him Alfredo Rodriguez. 17 Q. Alfredo Rodriguez? 18 A. Yes. 19 Q. And who told you that Alfredo Rodriguez 20 was the previous house manager, do you remember who? 21 A. I think it was . She is 22 currently employed with him. 23 Q. is still employed by him, 24 right? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75891d-Uaa-42b3-ae22-bSac7182dle 3507-011 Page 12 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006676 EFTA00158261 Page I-3 1 Q. And she's a housekeeper or something? 2 A. Right. 3 Q. All right. So, when this secretary of New 4 York calls and offers you the job at $58,000, you 5 accept the job? 6 A. Yes. 7 Q. And do you remember about what month that 8 was that January 2005 or so? 9 A. No. I think I start February 2005, but I, I 10 got a phone call I think it was end of December, 2004. 11 Q. Okay. So, the previous interview with 12 Ghislaine Maxwell and Jeffrey Epstein happened 13 sometime in late 2004? 14 A. Right. 15 Q. Okay. And when you say you got the job in 16 February 2005, is that when you came down to Palm 17 Beach to start working? 18 A. Yes. 19 Q. So, you had a month or so to gather your 20 stuff and get down? 21 A. Correct. 22 Q. And did you move down with anybody? 23 A. No, just myself. I (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 24:175a91d4eaa-42b3-m224,WW1WWle 3507.011 Page 13 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006677 EFTA00158262 Page 14 8 Q. So, you came down in February 2005 and 9 began working. What did you, what did you first 10 start doing for Jeffrey Epstein? 11 A. First I doing? I don't remember nothing 12 special. 13 Q. Okay. Well, were you working I will 14 rephrase it. Were you working only for Jeffrey 15 Epstein or were you working also for Ghislaine 16 Maxwell, the other person who interviewed you, or 17 anybody else in the house? 18 A. I guess only for him because she was visiting 19 a few times house, but I am employed by him. 20 Q. Okay. What was your understanding at that 21 time as to the relationship between Ghislaine 22 Maxwell and Jeffrey Epstein? 23 A. They were like partners in business. 24 Q. Okay. What business was that, if you 25 know? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2W5a9W4eaa42b3-m22-bUft718:Wle 3507.011 Page 14 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006678 EFTA00158263 Page 15 1 A. I don't know what kind of business but she was 2 the one who organized I would say employment with this 3 organization. So, whatever I need, if I have some kind 4 of problem, I contact her. She was the one who decided 5 what I have to answer my problems with, what I was 6 supposed to do. 7 Q. How many times did you have problems where 8 you had to go through her? 9 A. Well, not big problems. Just a question of 10 what certain, how to do certain things. For example, 11 what kind of flowers I have to buy, what kind of things 12 he likes, what time I supposed to serve him coffee in 13 the mornings, sort of organizing things. 14 Q. Those are things that you wouldn't ask 15 Jeffrey Epstein directly? 16 A. No, no. He doesn't like those things to ask 17 him directly. He would like to prefer either through 18 his assistant or like I say, Ghislaine Maxwell. 19 Q. Is that still the same today? 20 A. Yes, still the same. Unless, something happen 21 that I need to, nobody is around and I need to urgently 22 contact him, I go to him directly. 23 Q. So, for the most part if you have a 24 question or at least -- let's go back to 2005, you 25 had a question about what needed to be done in the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75891d-3eaa-42b3-ae2265d3c7182dle 3507.011 Page 15 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006679 EFTA00158264 Page 16 1 house, day-to-day stuff, you would ask Ghislaine 2 Maxwell? 3 A. Right. 4 Q. And would she normally, back in 2005, be 5 at the house in Palm Beach for you to ask her or 6 would you have to call her in New York? 7 A. To the phone up in New York. She was visiting 8 the house but most of the time I spoke with her on the 9 phone. 10 Q. Okay. Let's talk specifically about that 11 year in 2005. How often would Ghislaine Maxwell be 12 at the Palm Beach house when Jeffrey Epstein was at 13 the Palm Beach house? 14 A. I would say about once a month since I started 15 work. 16 Q. All right. Well, it was a bad question 17 because I understand that Mr. Epstein has several 18 homes, right? 19 A. Right. 20 Q. And he is sometimes in New Mexico or New 21 York or Florida or the Island or somewhere, right? 22 A. Right. 23 Q. So, I guess the first question is in 2005, 24 how often was Jeffrey Epstein at the Palm Beach 25 house on a weekly basis? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Page 16 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006680 EFTA00158265 Page 17 1 A. Probably like two, three times a month. 2 Q. And when he would come to the Palm Beach 3 house two or three times a month, how long would he 4 stay typically? 5 6 A. Three days, sometimes two, sometimes four, depends, you know, but it was no regular -- but no more 7 than four days I would say. 8 Q. Okay. And of those two or three trips to 9 Palm Beach, are you telling me that Ghislaine 10 Maxwell would usually come for one of them per 11 month? 12 A. Not usually, sometimes. Not every time but 13 sometimes they, she comes. 14 Q. Okay. But at that point in time in 2005 15 you understood that Ghislaine Maxwell and Jeffrey 16 Epstein were business partners? 17 A. Right. 18 Q. Did you know at the time what Jeffrey 19 Epstein did for a living? 20 A. Yes. He was one, I overheard invest money 21 with other people. 22 Q. Okay. Who told you that or who did you 23 overhear? 24 A. I think I read in the paper or something. 25 Nobody -- (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a9Idasa-42b3-se2265d3c7182dle 3507-011 Page 17 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006681 EFTA00158266 Page 18 1 Q. So, you don't actually think you overheard 2 it. You think you read it? 3 A. Right. It's hard to say right now. I don't 4 remember but probably most, yeah, I think I read in the 5 paper. 6 Q. Did you understand in 2005 that Ghislaine 7 Maxwell and Jeffrey Epstein had an intimate 8 relationship with one another? 9 A. No. 10 Q. You only believed them to have a business 11 relationship? 12 A. Right. 13 Q. Okay. And when Ghislaine Maxwell would 14 come to Florida, what did you or what did you 15 observe her and Mr. Epstein do back in 2005? 16 MR. GOLDBERGER: Form. 17 THE WITNESS: What would they do? I mean 18 what? 19 BY MR. EDWARDS: 20 Q. What was a typical day for Jeffrey Epstein 21 and Ghislaine Maxwell when she was in town at the 22 same time he was in town. 23 A. I would say that they have breakfast in the 24 morning. They spend time reading, talking on the phone, 25 meeting people, go to the movies sometimes. They did (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Page 18 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006682 EFTA00158267 Page 19 1 entertain a lot. They did go out for dinners I would 2 say. 3 BY MR. EDWARDS: 4 Q. Did you know at that time what Ghislaine 5 Maxwell did for a living? 6 A. No. 7 Q. Do you know today even what she did? 8 A. No. 9 Q. No. Back in 2005 to your knowledge, did 10 Jeffrey Epstein have a girlfriend or female 11 companion that was more than just a business partner 12 to your knowledge? 13 A. No, I didn't know. 14 Q. And for the most part I am going to try to 15 go chronological from 2005 to the present, but for 16 this question for that entire period of time that 17 you have known Jeffrey Epstein, 2005 through today, 18 have you ever known Jeffrey Epstein to have somebody 19 who you would observe to be a female companion or 20 girlfriend? 21 A. Yes. 22 Q. Okay. When is the 23 first time that you believe you recognized 24 as a girlfriend to Jeffrey Epstein? 25 A. At one point, I don't remember exactly what (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507-011 Page 19 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006683 EFTA00158268 Page 20 1 year was it, he told us that will take some part 2 of the organization, organizing, scheduling. And she 3 would decide, you know, which way household supposed to 4 work, and if you have any questions or problems, we 5 could contact her. So, since then I figure out that 6 she's the person who, who is close to him. 7 Q. When did he tell you that? 8 A. I don't remember. Maybe a year ago, two years 9 ago. 10 Q. Okay. Well, if we could put it in -- 11 obviously at this point in time Jeffrey Epstein is 12 on house arrest, right? 13 A. (Witness nods head) . 14 Q. I'm sorry. It has to be verbal so she 15 could take it down. 16 A. Yes. 17 Q. And prior to that, he was serving a jail 18 sentence, right? 19 A. Right. 20 Q. Okay. I am only bringing this up to put 21 it in context as to when this -- when you realized 22 or were told information that led you to believe 23 was Jeffrey Epstein's girlfriend. 24 Was it while he was on house arrest, while he was in 25 jail, before that, after that? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a9Ithleaa-412b3-se22-bSd3c7182dle 3507-011 Page 20 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006684 EFTA00158269 Page 21 1 A. I think before, before house arrest, yes. I 2 mean house arrest, jail sentence. 3 Q. Before the jail sentence? 4 A. Right. 5 Q. So, I can tell you the jail sentence at 6 least the plea was June 30th, 2008. So, you believe 7 it was sometime prior to that date when you learned 8 that was the girlfriend of Jeffrey 9 Epstein? 10 A. Correct. 11 Q. Okay. And when I asked you what gave you 12 that belief, you started to tell me that the 13 conversation was actually Jeffrey Epstein telling 14 you that would be more in charge of 15 what happened around the house, the scheduling, and 16 things like that, right? 17 A. Correct. 18 Q. But that's similar to how Ghislaine 19 Maxwell's role was described before, right? And 20 that's not somebody that you considered a 21 girlfriend. So how do you distinguish and 22 Ghislaine's role? 23 MR. GOLDBERGER: Form. 24 THE WITNESS: I noticed that they, they 25 spent some times together, more time together (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75891d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Page 21 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006685 EFTA00158270 Page 22 1 and they travel together very often. 2 BY MR. EDWARDS: 3 Q. you're talking about? 4 A. Right. And , and she was visiting very 5 often so I assume, you know, that there is some kind of 6 relationship between them. 7 Q. Okay. And when you say they are spending 8 time together, do you mean they are spending time 9 upstairs in the bedroom together, things like that 10 that would give you an idea? 11 A. No. I mean traveling together. They always 12 shop together when he was here. And when they go to 13 other places, she was with him too. 14 Q. Okay. Was already 15 somebody that had a relationship with Jeffrey 16 Epstein in February of 2005 when you first started 17 working? 18 A. No. I don't think so. I don't remember her 19 when I do the job. I don't remember her. 20 Q. So, you think -- I am sorry? 21 A. I don't remember the, 2005 when I started job, 22 I don't remember her being around at least a few months. 23 Q. Okay. 24 A. So, I recognize her and I met her probably 25 after a few months working for him. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2C5aMd4eaa-Ob3-802-bSacflUdle 3507-0 I I Page 22 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006686 EFTA00158271 Page 23 1 Q. So, you think that the first time that you 2 saw , if you started working in 3 February of 2005, may have been April or May 2005? 4 A. Could be. 5 6 Q. I am not going to hold to you to an exact date, but just so I can put it in a timeline. 7 A. Could be. i don't remember exactly the one, 8 but at least a few months. 9 Q. And when you were introduced to her, do 10 you remember where it was? 11 A. Probably -- I don't know. Here I guess she 12 was. 13 Q. At the house? 14 A. At the house I guess. I don't remember. I 15 can't recall. 16 Q. And do you know how Jeffrey Epstein met 17 18 A. No, I don't. 19 Q. The time when you met did 20 it appear to you that Jeffrey Epstein was meeting 21 her at the same time or he already knew her? 22 A. I assume he knew her. She was here in the 23 house in Palm Beach. I assumed he knew her. 24 Q. Okay. It didn't seem like a brand new 25 guest? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 205a9W4eaa4211.1-m224,WWIWWle 3507.011 Page 23 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006687 EFTA00158272 Page 24 1 A. No. 2 Q. Okay. But at that point in time -- well, 3 let me ask you; I don't want to put words in your 4 mouth. The time in April or May or around that area 5 in 2005 when you think is the first time that you 6 saw at the Palm Beach house, what 7 was your understanding of her role in Jeffrey 8 Epstein's life at that time? 9 A. I suppose one of his friends. 10 Q. Just a friend? 11 A. Right. 12 Q. Have you since 2005 through the present 13 seen any interaction between and Mr. Epstein 14 that would give you further reason to believe they 15 are boyfriend and girlfriend or a couple? 16 A. Yeah. I saw him walking with her, you know, 17 holding her hand. I mean her hands, so I assume that 18 there is more than friendship between them. 19 Q. Okay. And when you came in 2005, did you 20 live at the house in Palm Beach? 21 A. Yes. There is a small house attached to the 22 main house. They call it staff house where I live. 23 Q. Okay. And is that the place where you 24 have resided since you began working in February 25 2005 through the present? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 205a9W4eaa42b3-m22-b&WIWWle 3507.011 Page 24 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006688 EFTA00158273 Page 25 1 A. Yes. 2 Q. And that's a staff house that's on the 3 property, same property? 4 A. Right. 5 Q. Okay. All right. In your time living at 6 the staff house -- well, we'll get there. 7 Do you understand -- you understand why 8 you're here today and having your deposition taken, 9 correct? I mean, you know what this case is about? 10 A. Yes. 11 Q. And it revolves around young females going 12 over to Jeffrey Epstein's house on a regular or 13 frequent basis, correct? 14 A. Correct. 15 Q. And that's something that you observed? 16 A. Yes. 17 MR. GOLDBERGER: Form. 18 BY MR. EDWARDS: 19 Q. And when is the first time, you know, if 20 you got here in February 2005 when is the first time 21 that you noticed young females arriving to Jeffrey 22 Epstein's 23 MR. GOLDBERGER: Object to form. 24 MR. EDWARDS: house. 25 MR. GOLDBERGER: You can go ahead and (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2C5a91d4eaa-0113tUflUdle 3507-01I Page 25 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006689 EFTA00158274 Page 26 1 2 3 4 5 6 answer. MR. EDWARDS: There are times during the deposition that your attorney is going to object to the form of the question. And that's a legal objection and so that he is making his record and maybe this attorney will do the 7 same. 8 MR. GOLDBERGER: I will tell you if you 9 can't answer the question. Otherwise answer 10 the question. 11 THE WITNESS: Can you repeat the question? 12 BY MR. EDWARDS: 13 Q. Sure. No problem. If you got here in 14 February of 2005 to begin work -- 15 A. Right. 16 Q. -- when is the first time that you 17 remember observing young females coming to the 18 house? Was it the first day, is it the second day, 19 is it a month, is it -- 20 MR. GOLDBERGER: Form. 21 THE WITNESS: It's -- I don't remember, 22 you know, exactly what was the first, second or 23 third day during my, you know, working hours. 24 Like, I cannot tell you exactly which day was 25 it, but, yes, I notice that those young women (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75891d-Uaa-42b3-m22-b5dUTIMMU 3507-011 Pagc 26 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006690 EFTA00158275 Page 1 were coming for massage. And most of the time 2 I opened the door for them and let them in. 3 BY MR. EDWARDS: 4 Q. All right. Well, the civil aspect of 5 these cases has been going on for almost a year and 6 a half, almost two years. And prior to that you're 7 aware that there was a criminal investigation into 8 the same activity, right? 9 A. Yes. 10 Q. And through this discovery process, 11 information and belief leads us to an understanding 12 that these young females were coming to the house in 13 Palm Beach every day that Jeffrey Epstein was 14 staying at the house; is that fair to say? 15 MR. GOLDBERGER: Form. 16 THE WITNESS: I wouldn't say every day. 17 They come very often but not every day. Maybe 18 like if he was staying four days, probably like 19 two, maybe three days. 20 BY MR. EDWARDS: 21 Q. Okay. So, sometimes you remember there 22 being days where these young females I am describing 23 did not come to the house or at least you didn't see 24 them? 25 A. Right. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Page 27 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006691 EFTA00158276 Page 28 1 MR. GOLDBERGER: Form. 2 BY MR. EDWARDS: 3 Q. And for the most part you were told -- 4 strike that. Your testimony is that you were told 5 these were young females that were coming over for 6 the purposes of giving massages? 7 A. Yes. 8 MR. GOLDBERGER: Form. 9 BY MR. EDWARDS: 10 Q. Who told you that? 11 A. Who told me that? Jeffrey Epstein's 12 assistant. 13 Q. Okay. Were you told prior to you coming 14 down here in February 2005 that there would be these 15 young females coming over to the house very 16 frequently to give massages? 17 A. No. 18 MR. GOLDBERGER: Form. 19 THE WITNESS: No. 20 BY MR. EDWARDS: 21 Q. Okay. So, when you first started working, 22 you were not forewarned that these females would be 23 coming to the house? 24 A. No. 25 Q. All right. When was it -- did tell (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Page 28 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006692 EFTA00158277 Page 29 1 you -- tell me exactly what it was that told 2 you so that I can use your own words to formulate 3 questions. What was it that told you about 4 these girls coming over for massages? 5 MR. GOLDBERGER: Form. 6 THE WITNESS: Either she told me or she 7 called me and let me know that, for example, 8 certain time this woman, she mentioned name, 9 will come over, so I should let her in. That 10 was the procedure I followed. 11 BY MR. EDWARDS: 12 Q. Okay. So, just so that I understand what 13 you are saying, are you saying that the conversation 14 or the words that were spoken to you would be, did 15 she call you Janusz? 16 A. Janusz, right. 17 Q. Janusz, is coming over today at 18 9:00. Let her in. She's coming for a massage? 19 A. Correct. 20 MR. GOLDBERGER: Form. 21 BY MR. EDWARDS: 22 Q. Okay. Please, if that's -- if she said 23 something different to you such as, hey, there is a 24 massage therapist coming over, then tell me. I am 25 just trying to get it accurate. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 zersagid-seaa-42b3-ae22-bsdaerindle 3507-011 Page 29 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006693 EFTA00158278 Page 3C 1 A. Yeah. You were accurate in the first. 2 Q. So, then she may say, at 4:00 III. is 3 coming over to the house to give a massage; let her 4 in? 5 6 A. Correct. Q • Okay. How soon after your first day on 7 the job did you get this call from telling you 8 that some female's name would be coming over for the 9 purpose of providing a massage? 10 A. Maybe on the third or fourth day of my work. 11 I don't remember exactly how much. 12 Q. That was some day when Jeffrey had flown 13 into town and he was there? 14 A. Yes. 15 Q. Do you think that you were told by 16 that one of these young females would be 17 arriving to the house to provide a massage prior to 18 the first time you observed one of these young 19 females coming to the house to provide a massage? 20 Do you understand the question? 21 A. No, not really. 22 Q. Okay. What I'm asking is were you at the 23 house one day and a girl knocks on the door, hey, 24 I'm here to give you a massage and you go I don't 25 even know why, I don't know who you are; or did (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 zeisagie-seaa-42b3-ae22-bsdaerindle 3507-011 Page 30 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006694 EFTA00158279 Page 31 1 call you and say, hi, III. is coming over to 2 provide a massage at X-time and then III. showed up? 3 Do you see what I am saying? Which came first, the 4 girl or the comment? 5 6 A. No. First was either a phone call or conversation with 7 Q. So, there was never any surprise by 8 anybody? 9 A. No, no. 10 Q. And did you ask any questions whatsoever 11 when said, hey, let her in, this person is 12 coming over for a massage? 13 A. No, no question. 14 Q. Do you remember the names of any of these 15 young females that came over to provide massages? 16 MR. GOLDBERGER: Form. 17 THE WITNESS: You just mentioned a few of 18 them. 19 BY MR. EDWARDS: 20 Q. I just picked them out of a hat. 21 A. , and other, I don't know. I 22 don't remember. 23 Q. III. sound familiar? 24 MR. GOLDBERGER: Form. 25 THE WITNESS: No. It's hard to remember (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 Ninagld-3ezta4211.1-m22-bMWIWWle 3507.011 Page 31 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006695 EFTA00158280 Page 32 1 right now but I don't recall right now her 2 name. 3 BY MR. EDWARDS: 4 Q. I don't expect you to remember all of the 5 names. To me that's not important for today's 6 purposes. Is it fair to say that oftentimes there 7 would be a massage in the morning by one of these 8 females and a massage in the afternoon the same day? 9 A. Yes. 10 MR. GOLDBERGER: Form. 11 BY MR. EDWARDS: 12 Q. In fact, you know, you're not the first 13 witness who has testified as to what goes on in the 14 house. So is it, is my understanding correct that 15 there was a specific appointment set and a time set 16 for these girls to come over and that 17 would keep that appointment book? 18 MR. GOLDBERGER: Form. 19 THE WITNESS: I don't know if she kept 20 appointment, but most, I mean, almost -- yeah, 21 all the time I, I knew who is coming so -- 22 BY MR. EDWARDS: 23 Q. And you said you knew the time? 24 A. Yes. Maybe it was like 50 minutes delay or 25 they show up late, but I knew because I have to let them (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a91d-3esa-42b3-se22-b5d3c7182dle 3507-011 Page 32 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006696 EFTA00158281 Page 3-3 1 in. So, it has to be, you know, some kind of 2 announcement that they are here. 3 Q. Was it always telling you the name 4 of the person and the time that that person would be 5 coming over for a massage? 6 A. Yes, most of the time 7 Q. Okay. 8 A. I think there was another name, 9 Q. 10 A. She also contact me when she has been hired. 11 Q. When you say contacted you, that implies 12 that you're not in the same house when she's telling 13 you what time this person is coming over? 14 A. Yeah. I mean, if I have nothing to do in the 15 main house, I have an office in the staff house where I 16 sit over there and I do some paperwork. So, either they 17 call me on the phone or come in and tell me 18 face-to-face. 19 Q. So, when and would call, when 20 you're telling me that or would call 21 you and tell you who was coming over and what time 22 that person was set to come over, you're, you're 23 saying that that call would be made from the main 24 house to the staff house or it would either be made 25 in person depending on whatever it was? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75a9td4eaa42b3-m224MUTIOIMU 3507.011 Page 33 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006697 EFTA00158282 Page 34 1 A. Correct. 2 Q. But everybody is at the property at Palm 3 Beach. That's what we're talking about? 4 A. Yes. 5 Q. And the first time that you noticed one of 6 these young females coming over to provide what 7 told you was a massage, do you remember 8 who it was the first person you saw? 9 A. No, I don't remember. 10 Q. All right. Did you get to know any of 11 these -- 12 A. No. 13 Q. -- females? Did you have much personal 14 interaction with them? 15 A. No. Just good morning, hello and 16 Q. Fair to say that no matter who it was, 17 whether it was III. or or any of the other 18 ones, their routine from the time that they come to 19 the door and knock on the door until the time that 20 they leave was relatively the same? 21 MR. GOLDBERGER: Form. 22 THE WITNESS: Yes. 23 BY MR. EDWARDS: 24 Q. Okay. And so if generically you can just 25 remember the typical scenario of let's say III., for (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75891d-Usa-42b3-ae22-bSd30182dle 3507-011 Page 34 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006698 EFTA00158283 Page 35 1 2 3 4 5 6 instance, somebody that you remember coming to the door, can you tell me in your own words what you observed from the time she arrived at the house until the time that she left. MR. GOLDBERGER: Form. MR. EDWARDS: And just so the record is 7 clear, let's -- you've already been told by 8 , III. is coming this time and then 9 she arrives at the door. So tell me what 10 happens from there. 11 MR. GOLDBERGER: Form. 12 THE WITNESS: Yeah. I hear the doorbell. 13 I went out. She introduce herself. I let her 14 into the kitchen. I offer her something to 15 drink and she sit in the kitchen and I left to 16 do some other stuff. And let her, let 17 know that she's there. 18 BY MR. EDWARDS: 19 Q. Okay. 20 A. And sometimes I don't even, you know, notice 21 when they are leaving because, you know, the girls open 22 the door and just left. 23 Q. So, you were usually the person to greet 24 them but not always the person to walk them out? 25 A. Right. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Page 35 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006699 EFTA00158284 Page 36 1 Q. All right. So, your role was to greet 2 them at the door, offer them something to eat or 3 drink, and then turn them over to for lack of 4 a better -- 5 A. Right. 6 Q. And then, you know, at some point in time, 7 you had a chance to observe what did with one 8 or more of these girls in terms of where she took 9 them for the message and things like that, right? 10 A. Right. 11 Q. So, tell me what would then do? 12 Let's use III. for instance. She comes in. You 13 offer her something to eat or drink. And then you 14 say, all right , III. is here. What happens 15 after that? 16 A. She took her to, to the bedroom upstairs and 17 that's it. 18 Q. Okay. And did you know at the time that 19 Jeffrey Epstein was in the bedroom upstairs? 20 A. I didn't know. I assumed but I never know so 21 it's -- 22 Q. You just knew that he wasn't somewhere 23 downstairs with you? 24 A. Exactly. 25 Q. All right. And the massage was (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 205891d-Uaa-42b3-ae22-bSac7182dle 3507-011 Page 36 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006700 EFTA00158285 Page 37 1 supposedly, the massage table was upstairs? 2 A. Right. 3 Q. Did you know the massage table was 4 upstairs? 5 A. I didn't see that at the time of them, but 6 going a couple of times I folded massage table and put 7 in there in the closet. 8 Q. You have been up to Mr. Epstein's bedroom? 9 A. Yes. 10 Q. I've been in the house recently but I 11 don't know if the house looks today like it looked 12 back in 2005. In fact, I'm led to believe that it's 13 changed somewhat? 14 A. Yes. 15 Q. Before we continue on with the typical 16 massage experience with the young females and 17 Mr. Epstein, I want you to tell me since 2005, since 18 you began working there, how, what changes have been 19 made to the interior of the house? 20 MR. GOLDBERGER: Form. 21 THE WITNESS: There is a new addition to 22 the kitchen. It's like a breakfast table. The 23 living room is different. It's bigger. They 24 knocked down a few walls over there. 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2C5aMd-Usa-02b3-ae22-bSacflUdle 3507-01 I Page 37 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006701 EFTA00158286 Page 38 1 BY MR. EDWARDS: 2 Q. Where did they knock down walls? 3 A. In the living room. 4 Q. In the living room? 5 A. Yes. And the bedroom has been changed. 6 Q. Whose bedroom? 7 A. Master bedroom. Mr. Epstein's room. 8 Q. Mr. Epstein's bedroom was changed? 9 A. Yes. 10 Q. In what way? 11 A. The ceiling was different. 12 Q. How? 13 A. They somehow -- the different shape. There 14 was a flat one and they somehow, the designer figured 15 out how to make different ceiling. You know, it's not a 16 flat. It's sort of like I would say a rectangle. 17 Q. Okay. 18 A. And the room leading to the master bedroom is 19 also ceiling reconstruct. 20 Q. Okay. That's the little -- 21 A. It's not a flat. It's like a -- the one room 22 leading to the master bedroom. 23 Q. Right now it has starfish in it, that one? 24 A. Right, right. 25 Q. It's like a little hallway type room? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2d75a91d4eaa-42b3-m22-b5d3c71WWle 3507.011 Pagc 38 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006702 EFTA00158287 Page 1 A. Yes, yes. 2 Q. How, how is that room changed? 3 A. Before the ceiling was flat. Now it's sort of 4 like a, like a -- 5 Q. So, the change was to the ceiling? 6 A. Yes. 7 Q. Okay. What other changes? 8 A. Swimming pool is bigger. The cabana has been 9 extended. There has been built a wall on the south side 10 of the property. 11 Q. A wall on the south side of the property? 12 A. Right. 13 Q. When was that done? 14 A. During the reconstruction of the house at the 15 same time, and I guess that's it. 16 Q. Okay. When you walk in through -- when 17 these young females would come for the purposes of 18 giving massages, would they -- typically they would 19 go to the back door near the kitchen, right? 20 A. Yes. 21 MR. GOLDBERGER: Form. 22 BY MR. EDWARDS: 23 Q. And then when you walk in the kitchen as I 24 remember, you walk in the door and then you take a 25 left and you're in the kitchen, right? You walk in (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) (561) 832-7506 2d75891d-3eaa-42b3-aen-bsdsaindle 3507-011 Page 39 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006703 EFTA00158288 Page 40 1 that back door and then you take a left and you're 2 in the kitchen? 3 A. Right. 4 Q. And then there on your right-hand side as 5 you walk in the kitchen, ther