1 UNITED STATES DISTRICT COURT

Page 270 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, CASE NO: 08-CV-80119 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant. 8 9 10 Vs. JEFFREY EPSTEIN, Defendant. 13 JANE DOE NO. 3, CASE NO: 08-CV-80232 Plaintiff, 11 12 CONDENSED ,14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. JANE DOE NO. 5, CASE NO: 08-CV-80381 Plaintiff, 19 20 21 22 23 24 25 Vs JEFFREY EPSTEIN, Defendant. Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182344 I JANE DOE NO. 6, CASE NO: 08-CV-80994 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant. 6 7 8 9 10 Mt* DOE NO. 7, Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. 11 12 13 Plaintiff, 14 Vs. 15 JEFFREY EPSTEIN, 16 Defendant. 17 18 19 20 21 22 23 24 25 CASE NO: 08-CV-80993 CASE NO: 08-CV-80811 CASE NO: 08-CW80893 JANE DOE, Plaintiff, Vs. JEFFREY tPSi e N, Defendant. Page 271 1 2 3 4 S 6 7 8 IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319=0d48 AB Plainbff, Vs. JEFFREY EPSTEIN. Defendant 9 10 11 12 1031 Ives Dairy Road Suite 228 13 North Miami, Florida August 7, 2009 14 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 of 20 ALFREDO RODRIGUEZ 21 22 23 24 25 taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Deposition (Duces Tecum) Page 273 Page 272 1 JANE DOE NO. II, 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant. 6 7 8 9 10 CASE NO: 08-CV-80469 JANE DOE NO. 101 CASE NO: 08-CV-80591 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. 11 12 JANE DOE NO. 102, CASE NO: 08-CV-80656 13 Plaintiff, 14 Vs. 15 JEFFREY EPSTEIN, 16 Defendant 17 18 19 20 21 22 23 24 25 1 APPEARANCES: 2 3 MERMOSTEIN & HOROWITZ PA BY: ADAM HOROWITZ- ESQ. 4 18205 Biscayne Boulevard Suite 2218 MINN, FlorIda 33160 Attorney for lane Doe 2, 3, 4, 5, 6, and 7. 5 6 7 8 10 11 12 13 14 PODHURST ORSEOC BY: KATHERINE W. EZELL, ESQ. 15 25 West Hagler Street Suite BOO 16 Miami, Rorida 33130 Attorney for Jane Doe 101 and 102. 17 18 LEOPOLD-KUVIN 19 BY: ADAM 3. LANGIRD, ESQ. 2925 PGA Boulevard 20 Suite 200 Palm Bead, ens, Florida 33410 21 Attorney for 22 23 24 25 ROTHSTEIN ROSPMFELDT ADLER BY: BRAD J. EDWARDS, ESQ., and CAM HOLMES, ESQ. Las Olas Oty Centre Suite 1650 401 East Las Olas Boulevard Fort Lauderdale, Hods 33,EL Zita for Jane Doe and M. Page 274 2 (Pages 271 to 274 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182345 1 2 3 APPEARANCES: RICHARD WILLITS, ESQ. Page 275 1 2 2290 10th AVenue North 3 4 Suite 404 4 5 Lake Worth, Florida 33461 Attorney for 5 Appeared vialaone. 6 6 7 7 BURMAN, CRUTCH, LUTTIER 8 8 COLEMAN, LLP 9 9 BY: ROBERT CARTON, ESQ. 515 North Flagler Drive 10 Suite 400 11 10 West Pakn Beach, Florida 33401 12 11 Attorney for Jeffrey Epstein. 13 12 14 13 ALSO PRESENT: 15 14 JOE LANGSAM, VIDEOGRAPHER 16 15 17 16 18 17 19 18 20 19 21 20 21 22 22 23 23 24 24 25 25 Page 276 1 CONTINUED INDEX OF EXAMINATION 1 2 WITNESS DIRECT CROSS REDIRECT RECROSS 2 3 3 ALFREDO RODRIGUEZ 4 4 5 (8y Ms. Ezell) 278 441, 467 5 6 (By Mr. Willits) 334 453, 469 7 6 (Ely Mr. Critton) 338 464 7 9 (By Mr. Edwards) 419, 454, 468 10 8 11 9 (By Mr. langino) 452 12 10 13 11 14 12 CONTINUED INDEX OF MINTS 13 PLAINTIFFS PAGE 15 14 3 Drawing 315 16 15 4 Photograph 327 17 16 17 5 Photograph 331 6 Photograph 331 18 18 7 Photograph 331 19 19 8 Photograph 331 20 20 21 9 Report 446 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. 21 Ezell.) 22 22 23 23 24 24 25 25 Page 277 Deposition taken before MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is a continuation of the deposition of Alfredo Rodriguez. Today is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in the witness? Thereupon, ALFREDO RODRIGUEZ, having been first duly sworn or affirmed, was examined and testified as follows: MR. CRITTON: Before we get started just with regard to Ms. Ezell represents Jane Doe 101 and 102, the alleged time of her Incidents as of least have been plead in the complaint for 101 is '99 -- I'm sorry, '98 through 2002, with Jane Doe 102 the Spring of -- Spring/Summer of 2003. Mr. Rodriguez never even began employment until '04 and '05. I think her questioning I think -- I can't say she doesn't have standing based on the court order, but I would say it's Page 278 completely irrelevant and immaterial and has no probative value with regard to this particular witness based upon the two clients at least that are in suit at this point in time. MS. EZELL: As Mr. Critton well knows I represent a number of other clients whose cases have not been filed and I believe we do have standing to ask questions, and I do intend to do that today. EXAMINATION BY MS. EZELL: Q. Mr. Rodriguez, you stated last time that there were guests at the house, frequent guests, friends from Harvard. Do you remember that testimony? A. Yes, ma'am. Q. And was there a lawyer from Harvard named Alan Dershowitz? A. Yes, ma'am. Q. And are you familiar with the fact that he's a famous author and famous lawyer? A. Yes, ma'am. Q. How often during the six months or so that you were there was Mr. Dershowitz there? 3 (Pages 275 to 278) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182346 Page 279 1 A. Two or three times. 2 Q. And did you have any knowledge of why he 3 was visiting there? 4 A. No, ma'am. 5 Q. You don't know whether or not he was a 6 lawyer -- acting as a lawyer or whether he was 7 there as a friend? 8 A. I believe as a friend. 9 Q. Were there also young ladies in the house 10 at the time he was there? 11 MR. CRITTON: Form. 12 THE WITNESS: Yes, ma'am. 13 BY MS. EZELL: 14 Q. And would those have included for 15 instance, and 16 A. Yes, ma'am. 17 Q. Were there other young ladies there when 18 Mr. Dershowitz was there? 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 BY MS. EZELL: 22 Q. Do you have any idea who those young 23 women were? 24 A. No, ma'am. 25 Q. Were any of those the young women that Page 281 1 Q. Can you tell me where those were? 2 A. One in the kitchen, and the one in the 3 formal -- the main entrance. And there was one 4 more added later on, but there is two when I was 5 working there. 6 Q. Could you just give me a rough sketch of 7 the house of where the main entrance was and where 8 the kitchen was? 9 A. I'm not an architect but it's something 10 like this. This is the kitchen, this is the main 11 entrance. 12 Q. Will you mark the kitchen with a K, 13 please, and the main entrance with ME? 14 A. This is the pool. 15 Q. The pool? 16 A. Yes, ma'am. 17 Q. And in the upper left? 18 A. In the terrace, yeah, there was a balcony 19 here. 20 Q. And where were the staircases? 21 A. This Is one, the kitchen, one in the 22 foyer, and the pool. 23 Q. Okay. And would you just put an F where 24 the foyer staircase began? And KS where the 25 kitchen staircase began. Page 280 1 you have said came to give massages? 2 A. Yes, ma'am. 3 Q. And do you have any idea whether or not 4 Mr. Dershowitz was also receiving massages? 5 A. I don't know, Ma'am. 6 Q. I want to ask you to take this piece of 7 paper, please, and a pencil -- 8 MR. WILLITS: Can anybody hear me? 9 MS. EZELL: Yes. Can you hear me? 10 MR. WILLITS: I've heard nothing for 11 about a minute or so. 12 MR. CRITTON: Can you hear me now? 13 MR. WILLITS: Yes. 14 MS. EZELL: I'm asking questions, I'm 15 sorry. 16 MR. CRITTON: Why don't we go off the 17 record for a second. 18 (Thereupon, a discussion was held off the 19 record.) 20 THE VIDEOGRAPHER: We're back on the 21 record. 22 BY MS. EZELL: 23 Q. Mr. Rodriguez, you indicated that there 24 were several staircases in the house? 25 A. Yes, ma'am. Page 282 1 And you said that later another staircase 2 was added? 3 A. Yeah, we rehabilitated this, you know, 4 but you asked me how many stairs there were, to 5 answer your question there were three. 6 Q. Three. So where was the third one? 7 A. The pool, this leads to the pool. 8 Through the outside master bedroom you could go 9 downstairs to the pool. 10 Q. Okay. A stairway then from the outside, 11 from outside the master bedroom? 12 A. Yes, ma'am. 13 Q. Down to the pool? 14 A. Yes, ma'am. 15 Q. One of your duties was to answer the 16 door. Is that correct? 17 A. Yes, ma'am. 18 Q. Which door would you answer? 19 A. Mainly the kitchen. 20 Q. And why was that, why would people mainly 21 come to the kitchen? 22 A. I'll say it was for practicable reasons 23 because not to go to the main -- it was shorter 24 because the entrance was here, so this was the 25 driveway and we used to take into the back door of 4 (Pages 279 to 282) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182347 Page 283 1 the kitchen and they will wait there. 2 Q. All right. Would you just put BD where 3 the back door of the kitchen was, please? 4 Now, these young women that came to give 5 Mr. Epstein massages, would they usually come to 6 the kitchen door? 7 A. Yes, ma'am. 8 MR. CRITTON: Form. 9 BY MS. EZELL: 10 Q. Did any ever come to the front door? 11 A. Very rarely. 12 Q. And you would let them in the kitchen? 13 A. Yes, ma'am. 14 . And then how did you then turn them over 15 to 16 MR. CRITTON: Form. 17 THE WITNESS: I will call her. 18 BY MS. EZELL: 19 Q. How would you call her? 20 A. On her cell phone and she will know they 21 were waiting in the kitchen. 22 Q. And would you bring them In the kitchen 23 and then just leave? 24 A. Yes, ma'am. 25 Q. And where would you go? Page 285 1 A. You're welcome. 2 Q. Could you see the pool from the staff 3 house? 4 A. No, ma'am. 5 Q. How would you know, or would you know 6 when the young women were brought downstairs after 7 giving the massages? 8 MR. CRITTON: Form. 9 THE WITNESS: I will hear the commotion, 10 some voices, but I was not told they were 11 leaving. 12 BY MS. EZELL: 13 Q. And so did you have any duties that had 14 anything to do with their leaving? 15 A. Check the security and see if the gate 16 was closed, that the cars were locked because the 17 garage were here. 18 Q. Would you put a G where the garage was? 19 I believe you testified that you were 20 required to have on your person $2,000 everyday? 21 A. More or less, Ma'am. 22 Q. And if you open the door and a young 23 woman wa there to give a massage you would call 24 and go back to the staff house? 25 A. Yes, ma'am. Page 284 1 A. To my -- to the staff house that was 2 here. 3 Q. Good, I was going to ask you to show me 4 where the staff house is. Just put SH. 5 A. It was just maybe five feet, I used to 6 stay here. 7 Q. Okay. So what you're saying, it's about 8 five feet from the kitchen? 9 A. More or less, yes. 10 Q. Was it connected to the house? 11 A. No, it's detached but it's very close 12 proximity. 13 Q. Okay. So to get to the staff house would 14 you come out the kitchen door? 15 A. Yes, ma'am. And I came through my -- 16 there was two entrances, one through the laundry 17 here and one to the main entrance to the staff 18 house. 19 Q. All right. And what was your usual 20 pathway if you left the kitchen to enter the staff 21 house, how would you generally do it? 22 A. Normally I will came to the laundry, the 23 laundry was here and my office was next to the 24 laundry. 25 Q. Okay. Thank you. Page 286 1 Q. And then you believe would 2 come in and lead the young woman upstairs. 3 Correct? 4 MR. CRITTON: Form. 5 THE WITNESS: I'm sorry, can you repeat 6 your question? 7 BY MS. EZELL: Q. I'll try to, yes. 9 When you would answer the door and there 10 would be a young lady there to give a massage. 11 A. Yes, ma'am. 12 Q. I believe you testified you would let her 13 in the kitchen. 14 A. Yes, ma'am. 15 Q. And you called IMIM? 16 A. Yes, ma'am. 17 Q. And you then left her in the kitchen 18 alone? 19 A. Yes. 20 Q. And went to the staff house? 21 A. Yes, ma'am. 22 Q. And sometimes you heard the commotion 23 when the young woman was leaving -- 24 A. Yes, ma'am. 25 Q. -- but you didn't necessarily see them 5 (Pages 283 to 286) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182348 1 Page 287 1 leave. Is that correct? 2 A. Exactly, yes, ma'am. 3 Q. How did tr nsmi the money that you 4 were keeping to to pay those young 5 women? 6 A. would tell me who to pay and how 7 much, [lithe way we work. 8 Q. And when would she tell you that? 9 A. She will call me by phone and say I'll 10 give so much to so on and so forth. 11 Q. Okay. Was that at the conclusion of the 12 massage? 13 MR. CRITTON: Form. 14 THE WITNESS: Yes, ma'am. 15 BY MS. EZELL: 16 Q. Okay. Then I'm a little confused because 17 I thought you said that you didn't see them when 18 they left from giving the massage. 19 A. She will call me and she will say pay X, 20 Y, or Z, and that's the way I knew how much and to 21 whom. But sometimes they would leave and I didn't 22 pay those, I don't know who paid them. 23 Q. Okay. So if she calls you and told you 24 to pay X, Y, and Z $200, would you then go back 25 into the kitchen and give X, Y, and Z $200 each? 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 289 A. Yes. The whole south face of the house, but this was Q. All rig t. so did she usually work with her laptop on the dining room table? A. She will have all over the house but she will sit down here to work on the desk. Q. Do you know whether she kept any lists of names of girls to come and give massages? A. She did, Ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. And do you know in what form she kept those? A. She had notes, you know, she always have papers, but I don't know. Q. Do you recall seeing the papers with telephone numbers on them? A. A couple of times. Q. Do you know whether she also kept records on the computer relating to the girls? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And how do you know that? A. Everything was recorded in -- everything Page 288 1 A. Sometimes in the kitchen, sometimes in 2 the driveway I will pay them in an envelope, you 3 know. 4 Q. Okay. And she would tell you how much to 5 pay them? 6 A. Yes, ma'am. 7 Q. Where was Ms. when you would call 8 her to tell her that there was someone at the 9 kitchen door to give a massage? 10 A. She was inside the house so I call her on 11 her cell and say, Alfredo, leave them in the 12 kitchen, but I don't know where she was. 13 Q. Okay. Did she have an office? 14 A. No, ma'am. 15 Q. Did she have a computer in the house? 16 A. Yes. 17 Q. Where was her computer? 18 A. She had a laptop but she usually work in 19 the dining room. 20 Q. And where was the dining room? 21 A. All this area facing the garde " 22 north -- I'm sorry, facing south, and 23 was at her desk here. 24 Q. So did the dining room have large 25 windows? 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 290 we did as employees we used to record and kept in the internal circuit we used to have among the employees. Q. And so would it be, if I understand you correctly then, was there some sort of a program so that ou could access Information that Ms. was putting into that program and she coul access information you put in? A. Yes, ma'am. Q. And did you also send each other e-mails that way or did you use a different program for e-mails? A. didn't send direct e-mails to me but shellicall me on her cell. But I was supposed to send through Otrix to other employees. Q. E-mail them through Citrix? A. Yes, ma'am. Q. Okay. And who would those other employees be, have been, I mean, while you were there? A. Mrs. Maxwell, Bella in New York, mostly the main people, you know, Bella and -- Q. Lesley was -- A. Lesley, yes, the secretary, and somebody 6 (Pages 287 to 290) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182349 Page 291 1 else, I don't recall. 2 Q. Was there anyone else that you could 3 e-mail? 4 A. We could e-mail anybody in the 5 organization. 6 Q. On that particular program? 7 A. Yes, ma'am. 8 Q. And so who else would be in that 9 organization? 10 A. Other household managers from Paris or 11 the Island, Manhattan. 12 Q. Do you know whether Ms. kept any 13 pictures of the young women who would come to give 14 massages on her laptop? 15 A. Yes, ma'am. 16 Q. You saw those pictures? 17 A. Yes. 18 Q. Were the pictures uniform? And by that I 19 mean, were they all taken, for instance, there at 20 the house so that they would all be fairly 21 standard? 22 MR. CRITTON: Form. 23 THE WITNESS: They will be all over, you 24 know, sometimes out of the country and 25 sometimes in the house. Page 293 IN 1 A. I don't remember ma'am. 2 Q. Did you ever see using that 3 small compact camera to tae a picture of the 4 girls? 5 A. Yes, ma'am. 6 MR. CRITTON: Form. 7 BY MS. EZELL: 8 Q. When you saw her doing that where were 9 they, the girls? 10 A. The dining room, the library, the first 11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 pictures of the girls? 17 A. No, ma'am. 18 Q. Were you ever told by anyone that Mr. 19 Epstein sometimes took pictures of the girls? 20 MR. CRITTON: Form. 21 THE WITNESS: Yes, ma'am. 22 BY MS. EZELL: 23 Q. And do you recall who told you that? 24 A. I think it was IIII. 25 Q. Do you recall what she said about that? Page 292 1 BY MS. EZELL: 2 Q. Were these pictures that were taken by 3 someone for the purpose of keeping them in that 4 program? 5 A. I don't know. 6 MR. CRITTON: Form. 7 BY MS. EZELL: 8 Q. Or opposed to, for instance, one of the 9 you ladies bringing a picture to give to 10 Ms. 11 A. I don't know. 12 Q. You don't know where the pictures came 13 from? 14 A. No, ma'am. 15 Q. Do you know was there anyone staying in 16 the house who often took pictures of young women? 17 MR. CRITTON: Form. 18 THE WITNESS: There was several cameras 19 in the house and they were used often, but I 20 don't know who used them. 21 BY MS. EZELL: 22 Q. Okay. Do you remember what kind of 23 cameras they were? 24 A. The small compact camera. 25 Q. Any other kind? Page 294 1 A. He likes photography and he likes -- like 2 a hobby. 3 Q. Do you know which camera or what kind of 4 camera he used to take those pictures? 5 A. No, ma'am. 6 Q. And you said I think you never saw him 7 taking them? 8 A. Yes. 9 Q. So -- 10 MR. CRTTTON: Yeah meaning correct? 11 THE WITNESS: Yes. 12 BY MS. EZELL: 13 Q. Was it your understanding that he took 14 those pictures upstairs? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 Q. And when you had occasion to go upstairs 19 do you recall seeing camera equipment? 20 A. No, ma'am. 21 Q. Were you ever told that he took pictures 22 of the girls nude? 23 A. No, ma'am. 24 Q. Were you ever told that he liked to have 25 pictures taken of the girls nude? 7 (Pages 291 to 294 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182350 Page 295 1 MR. CRITTON: Form. 2 THE WITNESS: No, ma'am. 3 BY MS. EZELL: 4 Q. I believe you were asked before in the 5 deposition about the stairway leading from the 6 kitchen upstairs and whether or not there were 7 pictures on that stairway. 8 A. Yes, there were pictures. 9 Q. Were those pictures some of them of nude 10 young women? 11 MR. CRITTON: Form. 12 THE WITNESS: Not on the stairway, they 13 were in the foyer in the second -- on the 14 foyer and the foyer leading to the master 15 bedroom. 16 BY MS. EZELL: 17 Q. I see. Were those -- what size generally 18 were those pictures? 19 A. They were, you know, I'll say three by 20 five. 21 Q. So very large -- 22 A. Yes, ma'am. 23 Q. -- pictures? Were there lots of 24 photographs just around the house on top of 25 furniture in the various rooms? Page 297 1 BY MS. EZELL: 2 Q. And was that already installed when you 3 came there? 4 A. Yes, ma'am. 5 Q. Where is it you -- first of all, did they 6 tell you where the equipment was Installed? 7 A. No. 8 Q. Did you have any understanding of where 9 the equipment was installed? 10 A. No. 11 Q. Do you know whether or not there was 12 surveillance photography equipment upstairs and 13 downstairs? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 17 Q. And how do you know that? 18 A. I read it through the FBI report after 19 the fact that I -- after I left the job. 20 Q. Before reading through the FBI report did 21 you have any knowledge of the fact that there was 22 surveillance equipment both upstairs and 23 downstairs? 24 A. No, ma'am. 25 Q. While you were there was there ever an Page 296 1 A. Yes, ma'am. 2 Q. And were any of those photographs of 3 young women in the nude? 4 A. Yes, ma'am. 5 Q. Did you recognize any of those young 6 women? 7 A. Yes, a couple. 8 Q. And who was it that you recognized? 9 A. Elland some other girl from Brazil 10 that was in t house but I don't remember her 11 name. 12 Q. Was this a girl that would come and stay 13 in the house or one of the girls that would come 14 and give massages? 15 A. They will stay at the house. 16 Q. Stay at the house. Do you recall a 17 picture of the girl, of a young women nude in a 18 hammock? 19 MR. CRITTON: Form. 20 THE WITNESS: No, I don't remember. 21 BY MS. EZELL: 22 Q. Was there surveillance equipment 23 installed in the house? 24 A. Yes, ma'am. 25 MR. CRITTON: Form. Page 298 1 occasion when someone came to do any maintenance 2 or repair on the surveillance equipment? 3 A. Yes, ma'am. 4 MR. CRITTON: Object to the form of the 5 last question. 6 MS. EZELL: Pardon? 7 MR. CitITTON: Form of the last question. 8 BY MS. EZELL: 9 Q. Did that happen more than one time? 10 A. I believe so, yes, ma'am. 11 Q. Do you have any recollection of who came 12 there, either the name of the company or the name 13 of the person who would come to repair or do 14 maintenance on the video equipment? 15 A. We used to have a young technician from 16 Ohio who used to maintain all the computers and he 17 would be the only one dealing with those things. 18 Q. So he maintained the computers and the 19 video equipment. 20 A. Yes. 21 Q. Is that correct? 22 MR. CRITTON: Form. 23 BY MS. EZELL: 24 Q. Do you have any recollection of what his 25 name was? 8 (Pages 295 to 298) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami EFTA00182351 1 A. I don't remember, Ma'am. 2 New Albany, Ohio. 3 Q. From New 4 A. New Albany, Ohio. 5 Q. New Albany, Ohio. 6 business? 7 A. No, he worked for Mr. Epstein. 8 maintain all the computers. 9 Q. Was he there everyday? 10 A. No, ma'am. 11 Q. Do you know whether at that time Mr. 12 Epstein had an office in Palm Beach? 13 A. Not outside the house, no. 14 Q. Do you have any knowledge of whether or 15 not the video equipment was -- and I don't know 16 the technical term, forgive me, but was it the 17 kind of equipment that would record for a certain 18 amount of time and then record over that film? 19 A. I don't know. 20 MR. CRITTON: Form. 21 BY MS. EZELL: 22 Q. You don't know? 23 A. No, ma'am. 24 MR. CRITTON: Just for clarification, I 25 may have misunderstood, but I thought he Page 299 He came from 1 2 3 4 Did he have his own 5 6 He will 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 301 video, even phones. Q. Would he also repair the televisions if they needed work? A. No. Q. No. Did you have any kind of intercom system in the house? A. Yes, ma'am. Q. And what kind of system was that? A. It was standard office equipment, Lucid Technologies maybe, but it was an intercom like we using right now. MS. EZELL: Just let the record reflect that the witness pointed to the telephone on the table that has a speaker phone. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And did you use that in your work? A. Yes, ma'am. Q. And what did you use it for? A. Mr. Epstein used to page me when he needed me. Q. Did you have one of those phones in the kitchen? A. Yes, ma'am. Q. And was there one out in the staff house Page 300 1 said he didn't even know the video equipment 2 existed until he read the FBI report. 3 MS. EZELL: He said he didn't know that 4 it was upstairs and downstairs, I believe. 5 MR. CRITTON: I thought he said he didn't 6 know that it even existed. 7 MS. EZELL: I may be wrong. 8 BY MS. EZELL: 9 Q. Did you know it existed before you read 10 the FBI report? 11 A. No, ma'am. 12 Q. I'm sorry, then I was wrong. 13 How did you know then that the young 14 technician from Ohio maintained the computers and 15 the video equipment? 16 A. Because we used to request -- there were 17 always problems with the computers so he came to 18 the house and he was the programmer. It was very 19 sophisticated. 20 MR. CRITTON: Form to the last question, 21 move to strike the answer as nonresponsive. 22 BY MS. EZELL: 23 Q. How did you know then that he maintained 24 the video equipment as well? 25 A. Because he was in charge of computers, Page 302 1 as well? 2 A. Yes, ma'am. 3 Q. Do you know where others were in the 4 house? 5 A. Probably have like 15 phones. We used to 6 have three in the staff house, one in the cabana, 7 two in the master bedroom, one in each room, 8 kitchen, dining room, Mrs. Maxwell's office, the 9 garage. 10 Q. Where was Mrs. Maxwell's office? 11 A. Under the stairs next to the kitchen. 12 Q. Can you give me some idea of what size 13 space that was? 14 A. It was probably -- we change the floor. 15 Twelve by five, something like that. 16 Q. And was the computer equipment in that 17 space? 18 A. Yes, ma'am. 19 Q. Do you know whether Ms. Maxwell kept the 20 names and telephone numbers of the girls who came 21 to do massages? 22 A. Yes, ma'am. 23 MR. CRITTON: Form. 24 BY MS. EZELL: 25 Q. Do you know that because you saw the 9 (Pages 299 to 302) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182352 Page 303 Page 305 1 names and phone numbers? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 6 girls on the computer? 7 A. Yes, she did. 8 Q. And you know that as well because you 9 happen to see them? 10 A. Yes, ma'am. 11 MR. CRITTON: Form to the last two 12 questions. 13 BY MS. EZELL: 14 Q. Were they similar to the pictures that 15 Ms. had on her computer? 16 MR. CRITTON: Form. 17 THE WITNESS: Yes, ma'am. 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 look like pictures that were posed? 21 A. They were more casual. 22 Q. Did they look as though the person being 23 photographed knew that they were being 24 photographed? 25 MR. CRITTON: Form. 1 computer? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. And did she generally have phone numbers 6 for those girls? 7 A. Yes, ma'am. 8 Q. And were they generally pictures of the 9 girls? 10 MR. CRITTON: Form. 11 THE WITNESS: No, ma'am. 12 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 girls who came to give massages? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 A. Yes, ma'am. 20 MR. CRITTON: Form. 21 BY MS. EZELL: 22 Q. Were there pictures on her computer of 23 the girls who came to give massages? 24 MR. CRITTON: Form. 25 BY MS. EZELL: Page 304 1 THE WITNESS: No, ma'am. 2 BY MS. EZELL: 3 Q. And what can you tell me about that, what 4 lead you to draw that conclusion? 5 A. They were probably taken in parties in 6 big reception or banquet. 7 MR. CRITTON: Let me offer as a 8 suggestion, not that you have to accept or 9 that you would, you're using the term young 10 girls generically, he has probably seen 11 many, many young girls, there was no -- 12 you've used it interchangeably with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, 16 so that's part of my form objection. 17 MS. EZELL: Okay, thank you. 18 BY MS. EZELL: 19 Q. When I asked you about Ms. whether 20 she had a list of the girls and telephone numbers, 21 I think I asked about those girls that came to 22 give massages, but let me go back and just ask it 23 that way. 24 Did you notice that Ms. had a list 25 of the girls that came to give massages on her Page 306 1 Q. Ms. Maxwell I'm talking about. 2 A. Yes, ma'am. 3 Q. And were those pictures the more casual 4 ones that you described when I asked whether or 5 not the subject looked as though she knew she was 6 being photographed? 7 MR. CRITTON: Form. 8 THE WITNESS: I'm sorry, can you repeat? 9 BY MS. EZELL: 10 Q. Yeah. The pictures of the young girls 11 who came to the house to give massages that were 12 on Ms. Maxwell's computer, did they appear to have 13 been taken when the girls knew they were being 14 photographed? 15 MR. CRITTON: Form. 16 THE WITNESS: I don't think they knew 17 they were being photographed. 18 BY MS. EZELL: 19 Q. I believe you said they were more casual 20 pictures. 21 A. Yes, ma'am. 22 Q. Did you notice any nude photographs in 23 those pictures? 24 A. Yes, ma'am. 25 MR. CRITTON: Form for the last question. 10 (Pages 303 to 306) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182353 1 BY MS. EZELL: 2 Q. Among those pictures in Ms. Maxwell's 3 computer of the young women who came there to give 4 massages, were the nude photographs in that group 5 taken, did they appear to be taken In the house? 6 MR. CRITTON: Form. 7 THE WITNESS: No, ma'am. 8 BY MS. EZELL: 9 Q. You said before they appeared to be taken 10 at receptions or banquets? 11 A. Yes, ma'am. 12 Q. And I'm a little confused about how they 13 were casual and taken while the girls were nude at 14 receptions and banquets? 15 A. What I saw there were parties in Russia, 16 Eastern Europe, I don't know which country, but 17 there were also pictures of nude girls in a 18 shower, for instance, in a shower stall. 19 Q. You said for instance, so were there 20 other places other than the shower? 21 A. Yes, ma'am. 22 Q. Like what? 23 A. Gatherings, you know, in a party. You 24 could tell everybody is smiling so I believe it 25 was a place where they're having fun. Page 307 1 2 3 4 5 6 Page 309 Q. And was there more than one during the time you were there? A. Yes. Q. Do you remember their names? A. One was David, I don't remember the other one name. 7 Q. Did they appear to be American? 8 A. Yes, ma'am. 9 Q. Do you know the name 10 A. Could be, ma'am, but I'm not sure of his 11 last name. 12 Q. Do you have any idea where those chefs 13 had gotten their training? 14 A. was working in San Francisco when 15 he was . . 16 Q. Was he still there when you left Mr. 17 Epstein's employ? 18 A. Yes, to my knowledge, ma'am. 19 Q. Did the chef interact with the girls who 20 came to give massages? 21 A. In the kitchen, yes. 22 Q. And did he often offer them some food 23 while they were there? 24 A. Yes, ma'am. 25 Q. Were there occasions where a girl came to Page 308 1 Q. Were any of those pictures, if you 2 recall, taken in the cabana? 3 A. I don't remember. 4 Q. Do you recall there being parties and 5 gatherings in the cabana at the house? 6 A. I don't remember. 7 MR. CRITTON: Form. 8 BY MS. EZELL: 9 Q. When Mr. Epstein entertained did you have 10 anything to do with seeing that the bars were 11 stocked and that there was food that was needed 12 and so forth? 13 MR. CRITTON: Form. 14 THE WITNESS: There was no alcohol in the 15 house, only for guests. But, yeah, he will 16 ask sometimes for food. 17 BY MS. EZELL: 18 Q. And do you ever recall him asking for 19 food for parties in the cabana? 20 A. No, ma'am. 21 Q. Was there a chef at the house on El 22 Brillo Way when you were there? 23 A. I'm sorry? 24 Q. A chef. 25 A. Yes, there was. Page 310 1 give a massage accompanied by another girl, or 2 another person, let me say? 3 A. Yes, ma'am. 4 Q. And sometimes was that other person a 5 woman and sometimes a man? 6 A. No, ma'am, always a woman. 7 Q. Always a woman. Usually would it have 8 been a woman about the same age as the young woman 9 coming to give the massage? 10 MR. CRITTON: Form. 11 THE WITNESS: Yes, ma'am. 12 BY MS. EZELL: 13 Q. Were you ever told by Ms. to pay 14 the person who came who didn't give a massage? 15 A. Yes, ma'am. 16 Q. Do you recall how much you paid that 17 person? 18 A. Yes, ma'am. 19 MR. CRITTON: Form. 20 BY MS. EZELL: 21 Q. Flow much? 22 A. 300 to 500 dollars. 23 Q. Were some of those young women who 24 brought other young women for massages regulars, I 25 mean, did they regularly bring other young women? 11 (Pages 307 to 310) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182354 Page 311 1 MR. CRITTON: Form. 2 THE WITNESS: Yes, ma'am. 3 BY MS. EZELL: 4 Q. And were there some who maybe came just 5 once or twice with other young women? 6 A. That's correct, ma'am. 7 Q. Now, where would the young woman who was 8 bringing another young woman go during the time 9 the person that she brought was upstairs giving 10 the massage? 11 MR. CRITTON: Form. 12 THE WITNESS: I will take them to the 13 kitchen and would take them from 14 there. 15 BY MS. EZELL: 16 Q. Do you know where she took them? 17 A. No, ma'am. 18 Q. Were they ever taken to just sit in the 19 living room and wait? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know, ma'am. 22 BY MS. EZELL: 23 Q. These pictures of nude young women taken 24 In gatherings where they were smiling, did they 25 appear to you to be taking part in an orgy? Page 313 1 shower, I don't know whether he ever used 2 plural. 3 BY MS. EZELL: 4 Q. Was there more than one picture of a girl 5 in the shower? 6 A. There were two girls in the shower. 7 Q. Two girls in the shower together? 8 A. Yes, ma'am. 9 Q. And were those two girls engaged in 10 something sexual? 11 A. Yes, ma'am. 12 Q. And I may have asked you this question, 13 forgive me if I did, did you know those two girls? 14 A. No, ma'am. 15 Did Ms. Maxwell have nude pictures of 16 on her computer? 17 MR. CRITTON: Form. 18 THE WITNESS: I don't know, ma'am. 19 BY MS. EZELL: 20 Did you ever meet a young woman named 21 who had an association with Ms. Maxwell? 22 MR. CRITTON: ? 23 MS. EZELL: 24 THE WITNESS: I don't remember, ma'am. 25 BY MS. EZELL: Page 312 1 MR. CRITTON: Form. 2 THE WITNESS: I don't know, ma'am. 3 BY MS. EZELL: 4 Q. Do you know the word cavorting? 5 A. No, ma'am, I don't know. 6 Q. I need my Thesaurus. You said they were 7 smiling, did they appear to be having a good time? 8 A. Yes, ma'am. 9 Q. Did they appear to be doing anything 10 sexual? 11 A. Yes, ma'am. 12 Q. And in these instances were there girls 13 doing sexual things with other girls? 14 A. Yes, ma'am. 15 Q. And I'm still talking about the pictures 16 on Ms. Maxwell's computer. 17 A. Yes, ma'am. 18 MR. CRITTON: You're talking about the 19 group shots that he's mentioned from Russia 20 and Eastern Europe? 21 MS. EZELL: And girls in the shower. 22 MR. CRITTON: Let me object to the form 23 then the way you just now described that. 24 MS. EZELL: He said for instance. 25 MR. CRITTON: He had said a girl in the Page 314 1 Q. Did you ever have any conversations with 2 Ms. Maxwell about any of the women in those 3 pictures? 4 A. No, ma'am. 5 id you ever have a conversation with 6 about any of the pictures of the 7 girls in her computer? 8 A. No, ma'am. 9 Q. You were asked last time about the creams 10 and lotions that Mr. Epstein typically had 11 available to him and you said you thought there 12 was a favorite one but you couldn't remember it. 13 A. Spa. 14 Q. Spa, you did say Spa. 15 A. Yeah. 16 Q. Thank you. 17 Where did the stairway from the kitchen 18 lead -- to where did it lead? 19 A. To the second floor between the first and 20 second bedrooms. 21 Q. Were either of those bedrooms the master 22 bedroom? 23 A. No, ma'am. 24 Q. Could one go up that staircase through -- 25 could one go up that staircase and reach the 12 (Pages 311 to 314) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182355 Page 315 1 master bedroom? 2 A. Yes, ma'am. 3 Q. And how would you do that? If you want 4 to turn the page over for the upstairs you could 5 do that. 6 A. Okay. 7 MR. CRITTON: Are you going to mark this 8 as an exhibit? 9 MS. EZELL: Uh-huh. 10 MR. CRITTON: Would that be Exhibit 3? 11 MR. EDWARDS: I think so. 12 (Exhibit No. 3 was marked for 13 Identification.) 14 THE WITNESS: This is the master bedroom, 15 master bath, and there were one, two -- the 16 rest of the bedrooms were here and the 17 master bedroom was here. This is master 18 bath one and master bath two. 19 So the staircase came to the second floor 20 like this and it was between the first and 21 second bedroom. And you could go through 22 here and you enter a foyer with double doors 23 here, double doors here, and you enter the 24 master bedroom. 25 BY MS. EZELL: Page 317 1 Q. White. By the way, I have some more 2 water, would you like some? 3 A. Thank you, ma'am. 4 Q. I figure if I'm a little dry you may be 5 too. 6 I believe one of the items that you 7 mentioned that sometimes had to be picked up after 8 girls were there giving massages was a back 9 massager. 10 A. Yes, ma'am. 11 Q. Could you describe that for me, please? 12 A. It was a piece about this big. 13 Q. Would you say that's about 18 inches? 14 A. Yes, ma'am. And two prongs with the 15 rubber tips and a cord. 16 Q. Okay. 17 A. Or it could be detached too. 18 Q. Do you have any recollection of what make 19 that was? 20 A. No, ma'am. 21 Q. Were there any other massagers that you 22 recall seeing there regularly? 23 A. Those are the ones I remember. I think 24 they are from Sharper Image, but I don't -- 25 Q. Okay. Were there often girls around the 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 316 Q. All right. How would you get to the master bathroom on that end? A. You go through these double doors, go around the bed and you gain access to the master bedroom -- master bathroom, sorry. Q. And then there was another master bathroom on the other side of the room? A. Yes, ma'am. Q. Where generally did the massages take place? A. Right here, ma'am. Q. And is that in the master bathroom? A. Master bathroom, yes. Q. Do you recall what color the tile was in that bathroom? A. There was carpet. Q. Was there tile on the walls or marble or -- A. There was a sauna here with marble but outside the sauna everything was carpet, and the walls, they didn't have any tile. Oh yes, I will say four feet off the floor they will have marble. Q. And do you remember what color marble it was? A. White. Page 318 1 pool at the house? 2 A. Yes, ma'am. 3 Q. And were these sometimes the same girls 4 that came to give massages? 5 A. Yes, ma'am. 6 Q. Were there girls in addition to those who 7 came to give massages who hung around the pool? B A. The girls who were staying at the house. 9 Q. Okay. And so they weren't girls who just 10 regularly came to hangout around the pool? 11 A. No, ma'am. 12 MS. EZELL: Excuse me. Can we go off the 13 record for a minute? 14 (Thereupon, a recess was had.) 15 THE VIDEOGRAPHER: We're back on the 16 record with tape number two. 17 BY MS. EZELL: 18 Q. Mr. Rodriguez, did you receive a subpoena 19 that asked you to bring documents with you to the 20 deposition? 21 A. Yes, ma'am. 22 Q. And did you bring any with you? 23 A. I couldn't find anything at my house. 24 Q. Okay. I believe we talked about a 25 journal that you kept, and you looked for that? 13 (Pages 315 to 318) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182356 Page 319 1 A. Yes, ma'am. 2 Q. And you couldn't find it? 3 A. Iati to Detective 4 Q. 5 A. Yes, ma'am. 6 Q. You mentioned that you called Mr. 7 Jean-Luc Bernell about a recommendation when you 8 were looking for a job. 9 A. Yes, ma'am. 10 Q. And did you know him from his visits in 11 the home? 12 A. Yes, ma'am. 13 Q. Did you say that his wife's name was Eva? 14 MR. CRITTON: Form. 15 THE WITNESS: No, ma'am. 16 BY MS. EZELL: 17 Q. Do you know what his wife's name was? 18 A. Eva was a model, a former model from 19 years past who was friend of Mr. Epstein. 20 Q. Do you know if she was married to Glenn 21 Dubin? Do you know Mr. Dubin? 22 MR. CRITTON: Form. 23 THE WITNESS: I believe, yeah, I'm not 24 sure, ma'am. 25 BY MS. EZELL: Page 321 1 BY MS. EZELL: 2 Q. Did they ever visit Mr. Epstein at the 3 home when you were there? 4 A. Yes, ma'am. 5 Q. How old was the little girl at that time? 6 A. Eight years old. 7 Q. Did the girl's father come to visit as 8 well? 9 A. Yes, ma'am. 10 Q. And do you remember his name? 11 A. No, ma'am. 12 Q. Do you remember hearing anything about 13 what he does for a living? 14 A. No, ma'am. 15 Q. Can you describe him? 16 A. Tall, American born, I will say 50 years 17 old. 18 Q. What color hair did he have? 19 A. At that time it was black with a few 20 white hairs. 21 Q. Were there drawings of nude women in the 22 house? 23 A. No, ma'am. 24 Q. Were there paintings of nude women in the 25 house? 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 320 Q. Is she now a doctor? A. No, she was a model, her husband could be a doctor but I don't think she is. Q. Okay. So is Jean-Luc Bemell married; to your knowledge? A. I don't know, ma'am. Q. I think I must have gotten confused because we were talking about the picture in the house of the little girl who is lifting up her skirt or her underpants, I'd forgotten what it was. A. Yes, ma'am. MR. CRITTON: Form. es, ma'am. Q. Do you know where she and her mother live? A. They live in Manhattan. MR. CRITTON: Form. Page 322 1 A. Yes, ma'am. 2 Q. Did any of those appear to be 3 Ms. Maxwell? 4 A. Yes, ma'am. 5 Q. You mentioned that who was still 6 working there when you left -- 7 A. Yes, ma'am. 8 Q. -- was a very religious woman -- 9 A. Yes, ma'am. 10 Q. — and would sometimes be upset about 11 seeing pictures of nude girls or having to pick up 12 sex toys, et cetera. 13 MR. CRITTON: Form. 14 THE WITNESS: Yes, ma'am. 15 BY MS. EZELL: 16 Q. And you said that you remembered her 17 crying because there was a picture of the Pope 18 next to a picture of a naked girl. 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 BY MS. EZELL: 22 Q. Do you know who that naked girl was? 23 A. I don't remember, ma'am. 24 Q. I believe David Copperfield's name came 25 up in the last deposition as someone who would 14 (Pages 319 to 322) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182357 Page 323 1 call or visit. 2 A. Yes, ma'am. 3 Q. Were you ever there when he visited? 4 A. Yes, ma'am. 5 Q. And do you remember did he spend the 6 night? 7 A. No, ma'am. 8 Q. Did he come for dinner? 9 A. Yes, ma'am. 10 Q. Did that happen more than one time when 11 you were there? 12 A. Yes, ma'am. 13 Q. Do you remember whether or not any of the 14 young ladies who came to perform massages also 15 stayed for dinner? 16 A. No, ma'am. 17 MR. CRITTON: Just so Ifs clear, no, you 18 don't remember? 19 THE WITNESS: No, they were not there. 20 BY MS. EZELL: 21 Q. Did any of them ever stay for dinner? 22 Just any dinner, not the dinner with David 23 Copperfield. 24 A. You said they, the girls? 25 Q. The girls who came to give massages. Page 325 1 we are start with it and then you can use 2 the initials after that for all I care. 3 BY MS. EZELL: 4 Q. Do you remember a girl named. 5 A. I heard that name. 6 Q. So I will refer to her as from now 7 on. 8 I'm going to show you a document, we can 9 mark it but I'm not going to leave it. I'm going 10 to take the exhibit. 11 MR. CRITTON: Wait a minute. Are you 12 going to make a copy of it? 13 MS. EZELL: No, I'm not going to leave a 14 copy. 15 MR. CRITTON:. All right. Then I object 16 to you showing him a document that is not 17 part of this record. 18 MS. EZELL: Then object and the Judge can 19 rule, but I'm going to ask him to look at 20 this document. We can mark it as Exhibit 4. 21 THE WITNESS: Oh yeah. 22 BY MS. EZELL: 23 Q. Do you remember this young woman? 24 A. Yes. 25 MR. CRITTON: Let's see. Page 324 1 A. No, ma'am. 2 Q. In the earlier part of the deposition you 3 stated that you didn't drive the girls but then 4 later you remembered that you did sometimes have 5 to drive them. 6 A. Yes, ma'am. 7 Q. Do you remember a young woman named 8 who came there? 9 A. Yes, I do remember. 10 MS. EZELL: And again, we're going to 11 have the same agreement, if we use a girl's 12 name it will be shown on the transcript as 13 the initials only. 14 MR. EDWARDS: Agreed. 15 MR. CRITTON: Why don't you give him the 16 initials? Because in reading the transcript 17 we could end up with 25 l's ores ores, 18 in looking at it by just using the first, I 19 am just offering a suggestion because none 20 of us will remember who in the heck these 21 people are. 22 MS. EZELL: So you're asking me to give 23 both names so we would have two initials? 24 MR. CRITTON: He may not recognize either 25 the first or the second name but as long as Page 326 1 BY MS. EZELL: 2 Q. And was she one of the ones who came to 3 the house to give massages? 4 A. Yes, ma'am. 5 Q. Do you remember her name? 6 A. No, ma'am. 7 Q. Is it possible she was le? MR. CRITTON: Form. 9 THE WITNESS: I hear that name but I 10 cannot say for sure. 11 BY MS. EZELL: 12 Q. Okay. Did she come often to the house? 13 A. Yes, ma'am. 14 Q. Were you ever aware of her being 15 photographed? 16 A. No, ma'am. 17 Q. I asked you about David Copperfield 18 before and let me ask you again. In thinking 19 about it is it possible that you remember that she 20 was there for dinner with David Copperfield? 21 MR. CRITTON: Form, asked and answered. 22 THE WITNESS: Possible, yes, ma'am. 23 BY MS. EZELL: 24 Q. Did you ever meet her parents? 25 A. No, ma'am. 15 (Pages 323 to 326) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182358 Page 327 1 Q. I'll take the pictures back. 2 MR. CRITTON: Just put on the record that 3 my dient obviously could be here at the 4 deposition, or anyone's clients could be 5 here at the deposition and have full arrest 6 to the information that's being provided, by 7 taking the photograph back I'm not going to 8 be able to provide to that client, nor will 9 I have possession of it so I could discuss 10 that photograph, it's now been explored with 11 this witness. 12 (Exhibit No. 4 was marked for 13 Identification.) 14 BY MS. EZELL: 15 Q. Do you recall that on occasion you drove 16 this young woman to or from Mr. Epstein's house? 17 MR. CRITTON: Form. 18 THE WITNESS: I don't remember, ma'am. 19 BY MS. EZELL: 20 Q. Do you ever recall driving her by the 21 airport and showing her Jeffrey Epstein's plane? 22 MR. CRITTON: Form. 23 THE WITNESS: Yes, ma'am. 24 BY MS. EZELL: 25 Q. Do you ever recall one time perhaps by Page 329 1 BY MS. EZELL: 2 Q. You mentioned last time that Mr. Epstein 3 asked you to go and rent a car for one of the 4 girls who gave him massages. 5 A. Right. 6 Q. Do you know if that was IMI.? 7 A. I'm not hundred percent sure, ma'am. 8 Q. Do you know how long that girl kept the 9 car? 10 A. A couple of months. 11 Q. Did she bring it back to you or did she 12 turn it in at the agency? 13 A. She brought it back to me. 14 Q. Did you ever have any knowledge of Mr. 15 Epstein helping this girl with her college 16 applications? 17 MR. CRITTON: Form. 18 THE WITNESS: I believe Mr. Epstein was 19 giving her money for good grades, that's 20 what I -- she told me, I understood that. 21 BY MS. EZELL: 22 Q. Was this the girl that you were 23 instructed by Mr. Epstein to take roses to at the 24 completion of her graduation? 25 A. I don't remember exactly, ma'am, but Page 328 1 accident seeing her naked? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. How did that happen? 6 A. I told to go upstairs because I 7 saw Mr. Epstein leave, so we rushed upstairs to 8 clean and this girl was sleeping naked in the 9 sauna, she fall asleep there, there was nobody 10 else there. 11 MR. CRITTON: Can I ask just for 12 clarification, is he talkie now about the 13 person he thought was. but he wasn't sure 14 or the person that's in photo four? 15 MS. EZELL: The person that's in 16 photo four. 17 THE WITNESS: Yes. 18 MR. CRITTON: Okay, thank you. 19 BY MS. EZELL: 20 Q. And just so we're clear, do you t