UNITED STATES DISTRICT COURT

Page 81 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIV-MARRA/JOHNSQN JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME II Tuesday, September 8, 2009 10:12 a.m. - 3:45 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office PROSE COURT REPORTING AGENCY, INC. E Electronically signed by Sandra Townsend (401 lectronically signed by Sandra Townsend (401300cel-c.860-091-801.banbcaelPde EFTA00181630 Page 82 1 APPEARANCES: 2 On behalf of the Plaintiffs: 3 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 4 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 5 Phone: 6 7 STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 9 Phone: 10 11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 Phone: 14 15 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 16 25 West Flagler Street, Suite 800 Miami, Florida 33130 17 Phone: 18 19 ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 20 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 21 Phone: 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01•ba20bcao87de EFTA00181631 Page 83 1 On behalf of the Defendant: 2 ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER 3 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 4 Phone: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c868-4b91-8d01-ba2Obcaerde EFTA00181632 Page 84 1 PROCEEDINGS 2 - - - 3 Deposition taken before Sandra W. Townsend, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 (Continued from Volume I.) 8 VIDEOGRAPHER: We're going back on the record 9 at 12:52. 10 CROSS EXAMINATION 11 BY MR. LANGINO: 12 Q. Hello. My name is Adam Langino and I 13 represent III. I'll have fewer questions than the rest 14 of everybody, since I'm going next in line. But one of 15 the things I wanted to ask you 16 MR. CRITTON: Before you get started, let me 17 just put on my objection. 18 Adam, your client is ., who alleges that 19 she was at Mr. Epstein's house sometime, I think, 20 on one occasion in the summer of '03. 21 This witness is neither relevant, nor 22 material, nor can it lead to the admissibility of 23 any relevant information regarding my client. So I 24 understand -- so you certainly can notice him, but 25 I'll move to strike all of the questions and PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01•ba2Obcae87de EFTA00181633 Page 85 1 2 3 4 5 answers in response to your questions. MR. LANGINO: Thank you. BY MR. LANGINO: Q. One thing I wasn't sure about was the date of your employment. When did you start with Mr. Epstein? 6 A. I am not sure, sir, but I think I started full 7 time on my salary, I was on the roll in 1991. 1991, 8 January 1, 1991. 9 Q. In 1991, you started full time with 10 Mr. Epstein? 11 A. Yes, working for him alone. I left all my 12 clients, I left -- dissolved my company. 13 Q. And in what year did you start part time at 14 his house? 15 A. 1990. '90. 16 Q. You mentioned earlier that some of the massage 17 therapists you paid with checks? 18 A. Yes. 19 Q. And some of the massage therapists you paid 20 with cash? 21 A. Sorry. Can you repeat the question? 22 Q. Sure. You mentioned earlier that you paid 23 some of the massage therapists with checks and some with 24 cash? 25 A. Yes, sir. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba20bcae87de EFTA00181634 Page 86 1 Q. Were there any general differences between 2 those massage therapists that you paid with checks and 3 those that you paid with cash? 4 A. No, sir. It was -- when I was there always 5 was a hundred dollars an hour rate. That was for 6 everybody. 7 Q. Did you ever hear Jeffrey Epstein talk about 8 his massages? 9 A. No, sir. 10 Q. At one point you said that you're not -- this 11 might be summarizing your testimony -- that you may not 12 be the best guesser of ages. Is that something that you 13 may have said earlier today? 14 MR. CRITTON: Form. 15 THE WITNESS: Yeah. Yeah. I think I -- you 16 can be thirties, twenties. I don't know. 17 BY MR. LANGINO: 18 Q. Do you have any children? 19 A. I have two. One is a doctor in psychology. 20 And one is a financial manager and he starts his own 21 company. 22 Q. Are either of your children female? 23 A. No. 24 Q. Do you have any grandchildren? 25 A. I have one granddaughter. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01•ba20bcao87do EFTA00181635 Page 87 1 Q. How old is she? 2 A. She is five. 3 Q. Do you have any relative that you had spent a 4 significant amount of time with that would be a female 5 teenager? 6 MR. CRITTON: Form. 7 THE WITNESS: No, except my daughter. 8 BY MR. LANGINO: 9 Q. Cousin? 10 A. My daughter, no. 11 Q. Before when we first started speaking with 12 you, you talked a little bit about your business. Are 13 you still working? 14 A. No. I disabled. 15 Q. You owned that business; is that correct? 16 17 only me. 18 Q. You ntioned that one of your children is a 19 doctor? 20 A. My da ghter is a doctor in psychology. 21 Q. 22 members continuing the business that you started? 23 A. No. They have their own business. 24 Q. You mentioned a few times today that you were 25 never told to check the identification of any of the A. Yeah. Yeah. It was my -- my it was me, Are any of your children or any of your family PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86.1-4b91-Etd01-ba2Obcae87do EFTA00181636 Page 88 1 massage therapists that came to give massages? 2 A. That's correct. 3 Q. How come you said that a couple of times 4 today? 5 MR. CRITTON: Form. 6 THE WITNESS: You asked me. They asked me I 7 think I just answer questions. 8 BY MR. LANGINO: 9 Q. As you reflect back in your time working for 10 Mr. Epstein, today do you believe you turned a blind eye 11 to some of the ages of the women or females that worked 12 for Jeffrey Epstein with massages? 13 MR. CRITTON: Form. 14 THE WITNESS: Can you repeat the question? 15 BY MR. LANGINO: 16 Q. Sure. As you sit here today and reflect back 17 on your time working for Jeffrey Epstein, do you believe 18 you turned a blind eye or ignored, purposely ignored the 19 ages of the females that gave him massages? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know. I don't 22 cannot -- I'm not a judge. I don't know. I don't 23 know. I don't think so. Sincerely, I don't think 24 so. 25 BY MR. LANGINO: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b9f-8d0141a2Obcae87de EFTA00181637 Page 89 1 Q. When you were working for Mr. Epstein, did you 2 have any doubt that the girls who provided him massages 3 were not of the proper age or not older than 18 years 4 old? 5 MR. CRITTON: Form. 6 THE WITNESS: No. 7 BY MR. LANGINO: 8 Q. Did you keep up with Mr. Epstein's -- keep 9 informed of Mr. Epstein's criminal case while it was in 10 the paper? 11 A. Only what was on tv. What it was on tv, 12 that's how I found out. 13 Q. How do you feel about Mr. Epstein today? 14 A. I feel bad, sincerely I feel bad, because he 15 was -- with me, with my family, with my wife, he was a 16 very generous guy, extremely -- I don't know what the 17 word is in English -- but he would press for perfection. 18 I mean, and that was a very stressful job. But, 19 otherwise, I have no problems with him at all. _And I 20 feel bad about it, what's happened in his life. 21 Q. Have you had any contact with Mr. Epstein 22 after you ended working there? 23 A. After I work -- after I end working with him? 24 Yes, I did. 25 When this case, when this criminal case PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e.4b91-Bd01-ba20bcae87de EFTA00181638 Page 90 1 started, I got home and I had a card, a business card 2 from a police officer. I think it was Paul from the 3 Palm Beach Department. 4 And -- and I got scared. And I was trying to 5 find out what it's all about. Because it was an 6 occasion with Mr. Epstein that we had a disagreement. 7 We settled that. Everything was well and we went our 8 friendly ways and never heard from him again. 9 And I received this from the police department 10 that we need to talk to you. And, so, I got scared. 11 And I called the office in New York. 12 I says, I would like to speak to Mr. Epstein. 13 And he come on, and I said, I told him, I 14 says, Jeffrey, what's going on? What's happening? I 15 thought it was related to the problem that I had 16 personally with him settled. 17 And I says -- no, he says. And he says to me, 18 no, John, it's nothing to do with that, has nothing to 19 do with it. I've been I don't know if he told me I 20 been sued or I been -- it's a problem with me, they're 21 investigating something and I cannot talk to you. That 22 was the end. And that's it. 23 Q. Any other conversations with Mr. Epstein -- 24 A. No. 25 Q. -- since that conversation? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0c86e-4b91-8d01-ba20bcae87de EFTA00181639 Page 91 1 A. No. 2 Q. At some points you were caught stealing from 3 Mr. Epstein; is that true? 4 A. We settled with him as a borrowing money from 5 him. Okay? 6 MR. BERGER: As what? 7 THE WITNESS: Borrowing. 8 MR. LANGINO: Borrowing. 9 BY MR. LANGINO: 10 Q. When you took the money from Mr. Epstein, -- 11 A. Yes, sir. 12 Q. -- did he give you permission to take that 13 money? 14 A. No. 15 Q. At any point did you take a firearm from 16 Mr. Epstein? 17 A. No. 18 Q. At any point did you enter Mr. Epstein's 19 property when you were not allowed to be there? 20 A. Yes. 21 Q. And was that the incident where you took some 22 money from him? 23 24 25 A. Q. Yes. Can you explain to me how you and Mr. came to an agreement that the cops would not be Epstein called? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0-c868-4b9f4d01-ba2Obcae87de EFTA00181640 Page 92 1 A. He called me and he say, John, we need to 2 talk. 3 I says, okay. Where? 4 And -- and we met at a luncheonette in Palm 5 Beach and we have a friendly conversation. He asked 6 about my kids, about my family. 7 Then -- is this related to Mr. Epstein's case? 8 Q. It is. 9 A. Because I prefer to keep this -- this -- I was 10 not incriminated. I was not -- I went to the police 11 department. I made my statement and there was no 12 charges filed. 13 I don't think I would like to continue with 14 this. 15 MR. CRITTON: Let me just put on the record as 16 I think it's completely irrelevant, immaterial, 17 it's not calculated to lead to the -- 18 THE WITNESS: And it was after -- 19 MR. CRITTON: Let me just finish putting my 20 objection on. 21 As I understand it, it occurred long before he 22 ever got the card from the police. I think you're 23 harassing him. I think you're trying to intimidate 24 him and I think it's inappropriate. 25 BY MR. LANGINO: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b91-Bd01-ba20bcae87de EFTA00181641 Page 93 1 Q. How did you feel about Mr. Epstein being loyal 2 to you as an employee for him by not getting you into 3 further trouble with the police? 4 MR. CRITTON: Form. 5 THE WITNESS: I feel that it was part of a 6 relationship over 422=that I did a lot of 7 extra work. And I was more or less says, hey, 8 John, you did it for me, I do it for you. And that 9 was it. And we end up as _friends. We did not 10 break it apart. 11 BY MR. LANGINO: 12 Q. As you sit here today, do you have a sense of 13 personal loyalty to Mr. Epstein? 14 A. No. No. Matter of fact, that job has Laft me 15 a lot of sequels, psychological problems. It was 16 extremely damaging to my mar Right after I left 17 we broke up with my wife. I walk away. I left my 1 house. I left my family. I end up with a woman that 1 she need the money and that's why I went in there and 2 got the money. 21 And that's what I think you wanted to hear. 22 And I want to end it there. 23 I have no -- nothing -- I think my stay there, 24 in reflecting the job, I was not paid well enough for 25 what we did. And too late now. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba20bcae87de EFTA00181642 Page 94 1 Q. The overall theme of my question is: The fact 2 that Mr. Epstein chose not to get you in trouble with 3 the police further, trouble with the police -- 4 A. Uh-huh. 5 Q. -- so many years ago, has today that caused 6 you or pressed upon you to maybe soften your testimony 7 or change your testimony at all? 8 A. Absolutely not. 9 Q. Have you ever spoken with any independent 10 investigators regarding the actions, the criminal 11 actions that occurred at Jeffrey Epstein's home? 12 A. Yes. 13 Q. When did that occur? 14 A. Right after I receive a card from the police 15 department, when I call Jeffrey and I ask him, what's 16 going on? 17 He says, I cannot talk to you. Somebody will 18 talk to you. 19 And then I got a call from this guy that I 20 cannot recall his name now. Talked to me and we met at 21 Carabbas. And we talked -- what? -- about 15 minutes. And he asked me questions just like you guys are asking ,3 3 me and I says exactly the same answers. 24 And he says, well, there's an investigation 25 against Jeffrey. You has nothing to do with it. You PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3alc3ca0-O36e-4b91-6d01-ba20bcadade EFTA00181643 Page 95 1 have nothing to do, nothing to worry about it, but if 2 you want to hire a lawyer to protect yourself. 3 And I asked -- my question to him was, _I don't 4 want to get incriminated into something that, you know, 5 somebody trying to incriminate me for -- for my job. 6 And he says, no, no, no. But if you want to 7 get a lawyer, that's fine. 8 And that's where I got Mr lancl 'ust 9 came to us, to sign this, to -- that was d of it. 10 Q. Who got Mr. Murrell for you? 11 A. Who got it? Mr. Epstein. ✓ 12 Q. When you met with this investigator at 13 Carabbas, 14 A. Yes. 15 Q. -- did he record your conversation 16 A. No. 17 Q. -- in any way? 18 After this meeting at Carabbas, did you meet 19 with any other investigators? 20 A. No. 21 Q. After -- during your inspection of the massage 22 room after these massages had been completed with 23 Mr. Epstein, -- 24 A. Uh-huh. 25 Q. -- do you remember seeing any -- anything that PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba2ObcaeB7de EFTA00181644 Page 96 1 you would describe as blood? 2 A. No, never. 3 Q. Do you remember seeing anything that you would 4 describe as a sexual fluid? 5 A. No, never. 6 Q. When you worked for Jeffrey Epstein, the woman 7 that you were married to, what is her name or -- what is 8 her name? 9 A. The woman that I was married to? 10 Q. I think -- the reason I'm asking is because 11 earlier today when you first spoke, I thought I 12 remembered you saying that you -- both you and your 13 wife -- 14 A. That's my 15 Q. -- worked for Mr. Epstein? 16 A. It's still my wife. It's still my wife. We 17 didn't -- we got two ways away from a divorce and the 18 lawyers were taking my money by pipeline. 19 Q. And what is her name? 20 A. And we decide not to divorce and we still 21 together. 22 Q. Sorry. I missed that. But what is her name? 23 A. Maria Alessi. 24 Q. Let me just look through my notes to see if I 25 have any other questions. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c868-4b9f-Eld01-ba2Obcae87de EFTA00181645 Page 97 1 A. Okay. 2 Q. Thank you very much. 3 A. Welcome. 4 CROSS EXAMINATION 5 BY MR. MERMELSTEIN: 6 Q. Good afternoon, Mr. Alessi. 7 A. Yes, sir. 8 Q. My name is Stuart Mermelstein. I represent a 9 group of the Plaintiffs in these cases and I have some 10 questions for you as well. 11 Your wife, Maria, does she live at the same 12 address as you now? 13 A. Yes, she does. 14 Q. Now, when you began working full time for 15 Mr. Epstein, I believe you said that was around 1991; is 16 that correct? 17 A. Yes. 18 Q. Was your wife, was she hired at the same time 19 as you? 20 A. No. She was hired three years after. 21 Q. And how did that come about that your wife was 22 hired? 23 A. My wife was hired because we had a housekeeper 24 that she was doing the cleaning and she left. Then we 25 had another housekeeper, Polish girl, and she left. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-c860-4b91-8d01-ba2Obcae87de EFTA00181646 Page 98 1 And then by that time my kids went to college 2 and my wife was at home. And I suggest my wife to come 3 to work with me, to help me. 4 Q. So you recommended to Mr. Epstein that he hire 5 your wife? 6 A. Yes. 7 Q. And he did? 8 A. Yes, he did. 9 Q. And what were her job duties there? 10 A. Her only job duties were shopping, basically 11 the shopping, getting movie tickets, show tickets, buy 12 books, bring the food to Mrs. Epstein's -- Mr. Epstein's 13 mother, sometimes drive Mrs. Epstein to the doctors. 14 She was not involved -- and sometimes she did 15 some cleaning for me. 16 Q. Did she live with you in the upstairs 17 apartment? 18 A. Most of the nights we had an apartment right 19 across the bridge on Flagler that it was my -- my 20 property. And we had an apartment there. 21 So she went home. She didn't like to stay 22 there. But I had to stay there because my job starts 23 from 5:00 in the morning to 10:00 night 24 Q. And did Maria leave her employment the same 25 time as you? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0c860-4b91-8d01-ba20bcae87de EFTA00181647 Page 99 1 A. Yes, we did at the same time. 2 Q. You testified that you would come into the 3 bedroom and clean up after massages; is that correct? 4 A. That's correct. 5 Q. Did you -- were there occasions where you had 6 your wife help you with that? 7 A. No. No. 8 Q. Were there -- did she have occasion to go into 9 the master bedroom? 10 A. It was occasions before that she will help to 11 set up the tables once in a while, set up the oils and 12 the tables. But I will do the clean up after. 13 Q. Is there a reason for that? 14 A. I was more involved into the final appearance 15 of the house. And it was my responsibility to make sure 16 that every room was perfect after they left and before 17 they went to bed. 18 Q. Was there anyone else who assigned your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy some stuff, go get this and go get that. 22 She was mostly -- my wife was mostly out of the house. 23 She was -- this house was Mr. Epstein would says, go get 24 me this book, go get me this magazine, go get me 25 tickets, movie tickets for this show and this show and PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3cae-c86e-4b91-Eld01-ba2Obcae87de EFTA00181648 Page 100 1 this show. And she would have to travel -- and I was on 2 the phone with my wife constantly, buy this, get this, 3 get this -- and the food, and the food because it was a 4 five-star hotel. 5 Q. Did Ms. Maxwell or Mr. Epstein ever instruct 6 your wife to do housecleaning tasks? 7 A. No. I was blamed for everything. 8 Q. You were blamed for everything? 9 A. I was blamed for the good and the bad. 10 Q. Did you -- during the time your wife was 11 there, did you also have a hired housekeeper? 12 A. We have a crew of housecleaners. We have a 13 crew of people that would come to the house and do a 14 serial -- I mean, deep cleaning, you know, to the house. 15 Q. Was that every day? 16 A. Once a week -- no, it was twice a week. It 17 was Tuesday and Fridays. 18 It depends on Mr. Epstein's schedule because 19 he didn't -- he didn't want nobody at the house while he _ •-- 20 was at the house. So we have to rearrange days for the 21 clean-up crew to come in. And I usually did that. As 22 soon as they left I bring the cleaning crew, get the 23 house ready and -- and get set for them for the next 24 trip. 25 Q. Did you have a housekeeper who did PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3alc3ca0-c86o-4b9f-8d01-ba20bcae87de EFTA00181649 Page 101 1 housekeeping tasks on an everyday basis while you were 2 employed there? 3 A. No. 4 Before my wife went in? 5 Q. No. After your wife. 6 A. No. No. Not a full-time housekeeper. 7 Q. But you said your wife was hired after the 6 housekeeper left? 9 A. Yes. 10 Q. But -- so the person who left before your wife 11 came, was she doing housekeeping chores? 12 A. Yes, she was doing the housekeeping chores. 13 Q. Well, who did it then after your wife became 14 employed there, because she wasn't doing the 15 housekeeping? 16 A. I was. I was doing it and then we hire people 17 for to help us. 18 Q. So you were the main person doing the 19 housecleaning? 20 A. Yeah. 21 Q. And during -- between that time that your wife 22 started and when you left the employment, was there a 23 separate housekeeper employed during that time? 24 A. No. Full time? No. 25 Q. Full-time housekeeper? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b9f-4(101-ba2Obcae87de EFTA00181650 Page 102 1 A. No. 2 Q. What about a part-time housekeeper? 3 A. No. Like I told you, daily basis we call this 4 company. And then they will come in with four or five 5 girls and clean the whole house. 6 Q. This is the crew you were talking about? 7 A. The crew. 8 Q. But the crew didn't come when Mr. Epstein was 9 there? 10 A. Right. 11 Q. So on an everyday basis when Mr. Epstein was 12 there, you were the only person who was cleaning? 13 A. Me -- yeah, or my wife will help. 14 Q. At your instruction? 15 A. That's right. 16 Q. But you don't ever remember her cleaning up 17 after massages? 18 A. No. No. 19 Q. Is it possible that you instructed her to 20 clean up? 21 A. It's possible, but -- 22 MR. CRITTON: Form. Asking him to speculate. 23 BY MR. MERMELSTEIN: 24 Q. You can answer. 25 A. It's possible. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0c86e-4b9110101-ba2Obcae87do EFTA00181651 Page 103 1 Q. When girls would come to give a massage, where 2 would they come in the house? Would they come to the 3 front door? 4 A. Mostly came to the back kitchen door. 5 Q. The back kitchen door? 6 A. Uh-huh. 7 Q. Okay. And is there a bell there? Would they 8 knock or how would they -- 9 A. There's a door bell. 10 Q. A door bell? They would ring the door bell? 11 A. Uh-huh. 12 Q. And who generally would answer the door? 13 A. Me or my wife. 14 Q. So you would let them in? 15 A. Uh-huh. 16 MR. CRITTON: Stuart, can I just ask you? You 17 use the term, girls. I assume you just mean, that 16 means female woman. It can mean anything? It has 19 no age bracket to it? 20 MR. MERMELSTEIN: That's correct. I'm not 21 referring specifically to ages right now. 22 THE WITNESS: No. 23 BY MR. MERMELSTEIN: 24 Q. So as I understand it, the girl would come to 25 the kitchen entrance, which is the service entrance, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c96o-4b9f-6d01-ba20bcae67de EFTA00181652 Page 104 1 correct? 2 A. Uh-huh. 3 Q. You have to say yes or no. 4 A. Yes, sir. 5 Q. If you answer uh-huh, that's not clear, so you 6 have to answer yes or no. 7 A. Okay. 8 Q. And you would typically open the door? 9 A. Yes, sir. 10 Q. And what would happen then? 11 A. Then I will keep her in the kitchen and go to 12 Mr. Epstein and find out where they want to have the 13 massage, or if it was for him or for Ms. Maxwell. And I 14 immediately, if they were reReat gl.jj.s—that are -- they 15 will know exactly where to go. And I will go up with 16 them, set the tables, and they will wait for him or her 17 to go in the room and they sit there until they come up. 18 Q. So did you generally already know that they 19 were coming at the time that they knocked on the door? 20 A. Yes, uh-huh. 21 Q. So you had an appointment schedule? 22 A. Yeah. Because most of the times I was doing 23 1/ the calling, you know. I called J., come in at 3:00 24 this afternoon. And she will told me, no, I cannot, get 25 somebody else. And I knew it the time they were coming. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c86e-4b91-8d01-ba2Obcae87de EFTA00181653 Page 105 1 So I was expecting them most of the time. 2 Q. So you would expect them, they would come in 3 and then you would escort them upstairs? 4 A. Uh-huh. 5 Q. So -- 6 A. I'm sorry, sir. 7 Q. Yes? 8 A. Yes. 9 Q. But first you would find Mr. Epstein and check 10 to see if he's ready or find Ms. Maxwell to check to see 11 if she's ready? 12 A. Yes. 13 Q. And which staircase would you -- would you 14 take them up? 15 A. Either way. 16 Q. You would take them either the main staircase 17 or the servant staircase? 18 A. Yes. 19 Q. Why would you take the main staircase, since 20 you're already in the kitchen? 21 A. That's what I says, either way. We can go 22 through the main staircase or we go to the kitchen 23 staircase. So we use both. 24 Q. Okay. Well, I'm talking specifically to 25 escort a girl upstairs. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c868<b9f-sd01-ba20bcae87de EFTA00181654 Page 106 1 A. I escort the girls up there either way, both 2 ways. 3 Q. And, so, when you walked to the upstairs 4 bedroom, let's take the example of when Mr. Epstein is 5 getting a massage? 6 A. Yes. 7 Q. Mr. Epstein wouldn't be up there yet; is that 8 correct? 9 A. That's correct. 10 Q. He would be downstairs somewhere? 11 A. Uh-huh. 12 Q. Would there be a place 13 MR. CRITTON: Form. 14 BY MR. MERMELSTEIN: 15 Q. -- where he would normally be while, you know, 16 he's waiting for the massage to be set up and ready? 17 A. 18 Q. 19 A. 20 Q. 21 A. 22 Q. 23 stairs with the girl for the massage, what would you do 24 then? 25 A. Go back to my duties. Yes. Where is that? Where would he be? Either at his desk or the pool house. And those were on the first floor? Yes. And, so, when you arrived at the top of the PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86o4b91-8d01-ba20bcao87de EFTA00181655 Page 107 1 Q. You would just leave? Would the massage table 2 already be set up? 3 A. He knew already that the girls -- the girl 4 went upstairs and it was up to him to come up. 5 Q. Did you have conversations with any of these 6 girls? 7 A. Sometimes. 8 Q. What kind of things would you talk about? 9 A. Regular things. Nothing that I can remember. 10 Nothing. Just. .. 11 Q. Did any of them ever tell you their ages? 12 A. No, sir. 13 Q. Did any of them ever assure you that they were 14 18? 15 MR. CRITTON: Form. 16 BY MR. MERMELSTEIN: 17 Q. Or over? 18 A. No, sir. 19 Q. No one ever mentioned anything about age? 20 A. No, sir. 21 Q. How did the girls appear to you? Did they 22 appear to be very young? 23 MR. CRITTON: Form. 24 THE WITNESS: Again, the same question you ask 25 me. Everybody ask me the same thing. They could PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-6d01-ba20bcae87de EFTA00181656 Page 108 1 have been 16 or 20. Most of them were, I would 2 says, over 20. And some woman, it was over 60. 3 And one time she came to the door. The husband was 4 waiting outside. And Ms. Maxwell saw this woman, 5 that somebody recommend her. And Maxwell says to 6 me, John, you have to find an excuse. We don't 7 want her. 8 So I had to pay this woman and find an excuse 9 that they going to have to go. And she -- they 10 never had a massage with her. 11 But there was -- most of them were womans. 12 They were not girls. 13 BY MR. MERMELSTEIN: 14 Q. So the woman who was over 60 was sent away; 15 she was rejected, correct? 16 MR. CRITTON: Form. 17 THE WITNESS: It was -- I was told to send her 18 away. 19 BY MR. MERMELSTEIN: 20 Q. And it was your understanding when you were 21 told to send her away, it was because of her age, 22 correct? 23 MR. CRITTON: Form. 24 THE WITNESS: I don't know. I don't know. I 25 was told to send her away. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 300ca0-a6o4b9f4a1-baabcaWdo EFTA00181657 Page 109 1 BY MR. MERMELSTEIN: 2 Q. What was your understanding as to why they 3 were sending her away? 4 MR. CRITTON: Form. Asked and answered nine 5 times now. 6 MR. MERMELSTEIN: He hasn't -- he hasn't 7 answered my question yet. 8 MR. CRITTON: He has. 9 MR. MERMELSTEIN: Go ahead. 10 THE WITNESS: Why? 11 BY MR. MERMELSTEIN: 12 Q. Please answer the question. 13 A. Can you repeat the question? 14 Q. What was your understanding as to why they 15 sent her away? 16 MR. CRITTON: Form. 17 THE WITNESS: My understanding was either they 18 were busy or they didn't want her. 19 BY MR. MERMELSTEIN: 20 Q. What was your understanding as to why they 21 didn't want her? 22 MR. CRITTON: Form. Harassing. 23 THE WITNESS: I don't know. I didn't 24 didn't make too much of it. 25 BY MR. MERMELSTEIN: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0-c86e-4b9f-8d01-ba2Obcae87de EFTA00181658 Page 110 1 Q. But every other woman or female who came over 2 to give a massage was much, much younger, correct? 3 A. Yes. 4 Q. So this 60 year old woman was a significant 5 exception, correct? 6 MR. CRITTON: Form. Argumentative. 7 BY MR. MERMELSTEIN: 8 Q. You can answer. 9 A. I don't know how to answer that question. You 10 ask me to 11 Q. Let me ask you this. 12 MR. CRITTON: Why don't you let him answer the 13 question before you interrupt him. 14 BY MR. MERMELSTEIN: 15 Q. All right. Go ahead. Please answer. It 16 didn't look like you were -- 17 A. I don't know how to answer that question, you 18 asking me what is your opinion of that. 19 And I told you, my opinion of that, either 20 they saw the girl -- I don't think Mr. Epstein ever saw 21 the woman. But Ms. Maxwell saw the woman in the 22 kitchen. And she told me, John, pay her and send her 23 away. 24 Q. Okay. 25 A. That was it. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0c868-4b91-8d01-ba20bcae87de EFTA00181659 Page 111 1 Q. So Ms. Maxwell looked at the woman? 2 A. Right. 3 Q. Did she have a conversation with her? 4 A. No. S Q. She just looked at her and then said to you to 6 send her away, correct? 7 A. Yeah. Pay her and send her away. 8 Q. Do you recall seeing women who came to give 9 massages who were in their 50s? 10 A. Yes. 11 Q. There were women in the 50s? 12 A. Yes. 13 Q. How often did that happen? 14 A. Not too often, but it was -- it was woman that 15 they were in the 50s. I says, again, could have been 16 49, 45. I don't know. I don't know the ages, but it 17 older woman. 18 Q. How many middle -age women do you recall coming 19 over to give massages? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't remember how many, but I 22 would says<161:71 23 D.D. was, I would says, in the 40s. And she 24 came very, very often. And I understand she was a 25 massage specialist and a yoga instructor, too, at PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3cae-ce6o-4b9f-8d01-ba2Obcae87de EFTA00181660 Page 112 1 the same time. 2 So that was one of -- and there was another 3 woman that she was supposed to be a teacher at the 4 school of massage therapy that I can't remember her 5 name. But that's it. I mean. .. 6 BY MR. MERMELSTEIN: 7 Q. So those two you remember who were older? 8 A. Two. And it was a couple guys that were older 9 that -- some guys that were older, too, guys. 10 Q. Did Mrit!!!'llYIYLIffflaasage...S__dS.TTLbY 11 men? 12 A.l. 13 Q. And did Mr. Epstein ever have massages done by 14 these older women? 15 A. Yes. 16 Q. When you escorted the female in this case for 17 the massage to the upstairs bedroom correct? you 18 would then leave? 19 A. Yes. 20 Q. You would then walk back downstairs? 21 A. Yes. 22 Q. Correct? 23 And would you then -- would you -- you had 24 already told Mr. Epstein that she's there, correct? 25 A. That's correct. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9f-8d01-ba20bcae87de EFTA00181661 Page 113 1 Q. And at some point later then Mr. Epstein would 2 come upstairs, correct? 3 A. That's correct. 4 Q. And where would you go? 5 A. To my duties, to the kitchen or to my office. 6 Q. And I think you testified earlier that the 7 doors of the bedroom would be closed during this 8 massage? 9 A. He would close the door. 10 Q. So Mr. Epstein, when he would arrive upstairs, 11 would close the door? 12 A. Yes, sir. 13 Q. And about how long would the massage last 14 generally? 15 A. Usually an hour. 16 Q. And what would happen at the end? 17 A. They would come down. Most of the repeat 18 girls, they would bring the towels themselves and dump 19 it by the kitchen by the laundry room we had there, in 20 order to help us. Other girls, they just left it up 21 there and they would come down. 22 Either Mr. Epstein will pay or I will pay 23 them. 24 Q. Did they -- 25 A. Or Ms. Maxwell will pay them. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c136e-4b9f-8d01-ba2Obcae87de EFTA00181662 Page 114 1 Q. Did Mr. Epstein walk down with the girls or 2 did he stay upstairs? 3 A. Sometimes, sometimes no. Sometimes he took a 4 nap or he took a shower. I don't know what they did in 5 the room. I don't know. I don't know. Sometimes he 6 went down right away. Sometimes he stay up there. 7 Q. So when they came down, they would go to the 8 kitchen; is that correct? 9 A. Yeah, most of it. 10 Q. And were you there waiting for them or did you 11 have -- 12 A. My office was right next to the kitchen, so 13 was there -- and the kitchen was the focal point of the 14 house basically. So they have to go to the kitchen 15 either to get pay or to go to their cars. 16 Q. Did you converse with any of the girls when 17 they came down after the massage? 18 A. Very little. Very little. 19 Q. Did you ever observe a girl who appeared 20 upset, surprised, shocked, anything of that nature when 21 they came down? 22 A. Never. Never. 23 Q. And sometimes you would pay them, correct? 24 A. That's correct. 25 Q. How much would you -- PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0.c86e.4b91-8d01-ba20bcao87de EFTA00181663 Page 115 1 A. A hundred dollars assa-ge-r-- 2 Q. A hundred dollars a massage? Were there ever 3 any exceptions? 4 A. That's the -- I_never pay any more than a 5 hundred dollars per massage. 6 Q. Were there times when two girls came? 7 A. Two girls came at the same time? 8 Q. Correct. 9 A. Yeah. There were times when two girls come in 10 at the same time and one will go to one room, the other 11 will go to the other room. Or one -- I would set up two 12 tables in his room or I will ask him, where you want to 13 set the massages? He will told me, set in the blue room 14 and set them in my room. Or set them in Ghislaine's 15 room and the red room, depends on who people were there. 16 But there were times where two of the girls at the same 17 time, yes. 18 Q. Was there ever occasions where there was a 19 girl who waited downstairs while one while the other 20 girl went upstairs? 21 A. No. 22 Q. That never happened? 23 A. I cannot remember. 24 Q. Was there ever an occasion where you paid a 25 girl who waited and didn't actually give a massage? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0•c86edb948d01-ba20bcaoelde EFTA00181664 Page 116 1 A. No. 2 Q. That never happened? 3 A. Never happened. 4 Q. You mentioned that Mr. Epstein put you in 5 contact with Mr. Murrell; is that correct? 6 MR. CRITTON: Form. 7 THE WITNESS: Not Mr. Epstein. 8 BY MR. MERMELSTEIN: 9 Q. Huh? 10 A. It wasn't Mr. Epstein. 11 Q. Mr. Epstein's investigator put you in contact 12 with Mr. Murrell? 13 A. That's correct. He gave me his name. 14 Q. And did you pay Mr. Murrell out of your own 15 pocket? 16 A. No, I didn't pay nothing. 17 Q. Who is -- what was your understanding as to 18 who was paying for Mr. Murrell? 19 A. I don't know. I don't know who was paying for 20 it. 21 Q. You never asked Mr. Murrell who was paying his 22 bill? 23 A. No, he never send me a bill. 24 Q. Did you think that Mr. Murrell was doing it 25 for free? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b91-8d01-ba2Obtae87de EFTA00181665 Page 117 1 A. I don't know. 2 Q. You don't know. As far as you know, 3 Mr. Murrell could have been providing you legal services 4 for free? 5 A. No, I don't think it was provided me for free. 6 I don't think he ever -- that question ever come out of 7 Mr. Murrell. I was in Mr. Murrell's office for about 8 ten minutes. 9 And he says, well, I meet you tomorrow 10 there -- and that's it -- in order to protect you so 11 they don't incriminate you in any way. We left it at 12 that. He never send me a bill. He never send me -- I 13 never talk to Mr. Murrell again, never saw him again. 14 Q. And you never had any kind of understanding 15 with him as to how -- 16 A. No. 17 Q. -- how his bill was going to be paid? 18 A. No. 19 Q. Did you sign any kind of what we call, a 20 retainer agreement, anything where you hired him? 21 A. No. 22 MR. CRITTON: Just so you know, you have an 23 attorney -- nobody's going to tell you this 24 apparently. 25 You have an attorney/client privilege. Any PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86e-4b9f-8d01•ba20bcao87do EFTA00181666 Page 118 1 conversation that you had with Mr. Murrell, you and 2 your wife, is completely protected, as long as you 3 want to assert that privilege. 4 You can either assert it or not assert it. 5 That's your right. But nobody's apparently going 6 to tell you that, at least Mr. Mermelstein is not 7 going to tell you that. 8 MR. MERMELSTEIN: Well, I was trying to 9 avoid -- 10 MR. CRITTON: Well, you're asking questions of 11 what he said. 12 MR. MERMELSTEIN: I'm not asking them what 13 they said. 14 MR. CRITTON: Same thing. 15 MR. MERMELSTEIN: I'm asking him how he got 16 paid. 17 MR. CRITTON: No, you were -- read back your 18 questions where you were. 19 Anyhow, that's a right you have, 20 So much for the law. 21 MR. MERMELSTEIN: I was not asking him what 22 was said during any conversation. I asked him if 23 he signed a retainer. That's a fair question. 24 BY MR. MERMELSTEIN: 25 Q. Do you remember a girl who came to give PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-4860-4b9h8d01-ba2Obcao87cle EFTA00181667 Page 119 1 massages there by the name of III 7 Does that name 2 sound familiar at all? 3 A. No. 4 Q. Do you remember an II? 5 A. No. 6 Q. What about a Do you remember anyone by 7 the name of III.? 8 A. No. 9 Q. Was it frequent that girls would come just 10 once and not appear again? 11 A. Frequently. 12 Q. These girls that would come, would they come 13 with their own equipment or supplies? 14 A. No. Some girls, they come in with a table, 15 the new girls they comsjILmit-h—a—tA121!ladIT21.2Li_ 16 told them, no, you don't need the tabl he will 17 leave it in the kit se we have tables in every 18 room in the house. 19 Q. Some of the girls, the first time they came 20 they didn't have anything, right? 21 A. They come with that table, one of the tables 22 they hang it in the shoulders, portable tables. But we 23 didn't have portable tables in the room. They were all 24 custom-made tables. 25 Q. Did some girls come without -- for the first PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 ukka-ase-ow4m-bankame EFTA00181668 Page 120 1 time without any supplies at all, whether equipment or 2 lotions or anything of that nature? 3 A. Probably. 4 Q. Did you have a question in your mind as to 5 whether they were professional at this business? 6 A. No. 7 Q. At massaging? 8 A. No. 9 Q. Why not? 10 A. It was not my job. 11 MR. CRITTON: Form. 12 BY MR. MERMELSTEIN: 13 Q. You just didn't think about it? 14 MR. CRITTON: Form. 15 THE WITNESS: If I was told that a girl is 16 coming, my job was to open the door, let her in and 17 let Mr. Epstein decide where he wants his massage. 18 And that was the end of it. 19 BY MR. MERMELSTEIN: 20 Q. Are you aware that sexual conduct between an 21 adult male and an underage female is criminal; it's 22 against the law? 23 MR. CRITTON: Form. 24 THE WITNESS: Of course I do. 25 BY MR. MERMELSTEIN: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0c86e-4b9f-t3d01-ba2Obcael37de EFTA00181669 Page 121 1 Q. Did you have any concerns while you were 2 working there that criminal acts were occurring with the 3 girls who were coming to the door? 4 MR. CRITTON: Form. 5 THE WITNESS: I had no idea what was going on 6 between them. 7 BY MR. MERMELSTEIN: 8 Q. Let me just give you some other names. Tell 9 me if you recognize any of these names. 10 7 11 A. (Nods head. ) 12 Q. Name does not ring a bell? 13 A. (Nods head. ) 14 MR. CRITTON: You have to answer out loud. 15 BY MR. MERMELSTEIN: 16 Q. You need to say yes or no. 17 A. No. 18 Q. M.? 19 A. Can you repeat that? 20 Q. II would be the first name. II would be the 21 second name? 22 A. No. 23 Q. 24 A. No. 25 Q. M.? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9f-8d01-ba2Obcae87do EFTA00181670 Page 122 1 A. No. 2 Q. M.? 3 A. No. None of those girls' -- 4 Q. None of those girls ring a bell at all? 5 A. -- name familiar to me. 6 Either they came one time, one day and they 7 didn't even told me their names or -- or he paid for it 8 that I don't have -- but none of those names sound 9 familiar to me. 10 Q. You testified that there were -- about the sex 11 toys that you would pick up after after there were 12 massages, correct? 13 MR. CRITTON: Form. 14 BY MR. MERMELSTEIN: 15 Q. The vibrators, correct? 16 MR. CRITTON: Form. 17 BY MR. MERMELSTEIN: 18 Q. You can answer. 19 A. Yes. 20 Q. And you mentioned there was a basket with 21 these vibrators or toys in them, correct? 22 A. Yes. 23 Q. Where was the basket kept? 24 A. In Ms. Maxwell's closet. 25 Q. And that was in the master bedroom? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181671 Page 123 1 MR. CRITTON: Form. 2 BY MR. MERMELSTEIN: 3 Q. Or off the master bathroom? 4 A. Her bathroom. 5 Q. Huh? 6 A. Her bathroom. 7 Q. And the closet was -- the entrance to the 8 closet was in her bathroom? 9 A. That's correct. 10 Q. And it was a portable basket, she could move 11 it around, correct? 12 A. Uh-huh. 13 Q. You have to say yes or no. 14 A. Yes, sir. 15 Q. And -- and that's where the, I think you used 16 the word dildo, correct? That's where they were 17 located? 18 A. Yes, sir. 19 Q. Was there occasions where you would -- the 20 dildo, one or more dildos would be out and you would 21 clean them up after a massage that only Mr. Epstein had, 22 not Ms. Maxwell? 23 A. It was -- I will says that it was about three 24 or four occasions that I had to take this dildos and put 25 it back where they supposed to be. And I took it with PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c860-4b91-8d01-ba2Obcao87de EFTA00181672 Page 124 1 gloves and towels and stick it in the sink and throw it 2 in there. 3 Sometimes Ms. Maxwell will have a massage. 4 And sometimes I find it after she's supposed to have a 5 massage, those things. And also when Mr. Epstein had 6 the massage. So I don't know who use it on who. 7 Because sometimes they all disappear up there, 8 Mr. Epstein, Ms. Maxwell and whoever was up there. 9 Q. So as I understand it, you couldn't isolate a 10 particular instant where -- 11 A. I cannot. 12 Q. -- Ms. Maxwell wasn't there, only Mr. Epstein 13 had gotten a massage and then you found the sex toys? 14 A. I cannot isolate that. 15 Q. But it's possible that either Mr. Epstein used 16 it or Ms. Maxwell used it; is that correct? 17 MR. CRITTON: Form. Form. 18 THE WITNESS: I have no idea to know. 19 MR. MERMELSTEIN: All right. I have nothing 20 further. 21 MR. BERGER: How about if we take a break? 22 Would you like a break for a couple minutes? 23 THE WITNESS: No, that's fine. 24 MR. BERGER: Mr. Willits, would it be possible 25 if I could sit there, because I've got a couple PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c860-4b9f-8d01-ba2Obcae87de EFTA00181673 Page 125 1 Exhibits I'm going to show him? 2 MR. WILLITS: Sure. 3 MR. BERGER: Thanks. 4 CROSS EXAMINATION 5 BY MR. BERGER: 6 Q. Okay. Good afternoon, sir. 7 A. Afternoon, sir. 8 Q. My name is William J. Berger and I represent 9 three of the Plaintiffs in this case. 10 Did you ever hear of the name I., a young 11 woman named I.? 12 A. No, sir. 13 Q. How about a young woman named II? 14 A. No, sir. 15 Q. Okay. You know, you've referred several times 16 to a falling out or a disagreement that you had with 17 Mr. Epstein? 18 A. Yes. 19 Q. Was that in was that the year that you left 20 his employment? 21 A. Right after right after I left. 22 Q. So you had a falling out with him after you 23 left his employment? 24 A. Yes. 25 Q. Well, why did you leave his employment? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e4b91-8d01-ba2Obcae87de EFTA00181674 Page 126 A. Why? 2 Q. Yeah. 3 A. Because I was sick. I was extremely sick. I 4 was bleeding, internally bleeding, and I was bleeding 5 from my butt and I have fistulas in my colon. And I was 6 sick of the job and we had enough. We had good pay, but 7 we had enough of the