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living room, which was you made a left turn that brought you 
into the master bedroom, and if you made a right turn, it took 
you to the two guest bedrooms on the right side of the trailer. 
Q. Were the guest bedrooms next to each other or how were they 
set up? 
A. There was a bedroom with a bathroom in between. They 
weren't a Jack and Jill bathroom, but it was still a bedroom, a 
bathroom in between, and then the other bedroom, but they were 
on the right side of the trailer. The left side of the trailer 
was the master bedroom. So it was a split floor plan. 
Q. But you didn't sleep there; right? 
A. On occasion I have slept there. 
Q. Where did you sleep, in one of the guestrooms? 
A. In one of the guestrooms, but this was a vacation where 
Mr. Epstein was on the ranch. It was before I built my home, 
so I was able to spend the time at the lodge. We're going 
really back far. 
Q. But eventually, and I think maybe it was in the 2000s or 
so, Epstein gave you some land; is that right? 
A. That's correct. 
Q. Epstein gave you about 40 acres of land from his ranch so 
that you could build a house; isn't that right? 
A. That's correct. 
Q. And he didn't charge you for that land? 
A. No, he did not. 
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Q. And you built a house there? 
A. I built the house there, yes. 
Q. So from about 2000 onwards when you flew to the ranch, 
you'd stay at your home? 
A. That is correct. 
Q. Let me ask you briefly about the trips to Epstein's island 
in the Virgin Islands. You said that's Little St. James 
Island? 
A. That's correct. 
Q. When you flew to the Virgin Islands, you didn't fly 
directly into little St. James, you said; right? 
A. No. 
Q. It doesn't have an airstrip? 
A. That's correct. 
Q. You flew to St. Thomas, which is the bigger island right 
by? 
A. That's correct. 
Q. You flew Epstein and his guests to Little St. James in a 
helicopter? 
A. Correct. 
Q. Because you're a trained helicopter pilot? 
A. That is correct. 
Q. Where did you stay when you went on the trips to the Virgin 
Islands? 
A. Typical hotel, Marriott Resorts that were there. 
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Q. So you wouldn't stay in the island residence, you'd stay at 
St. Thomas? 
A. I would bring the helicopter back and the crew would stay 
on St. Thomas in a regular hotel. 
Q. Now, we saw a number of photographs of Little St. James 
Island when you were on your direct testimony. 
Do you remember those? 
A. Yes. 
Q. I'm not going to call them up, there were a number of them. 
But you recall that they had structures on the property in 
those photographs; right? 
A. Yes. 
Q. They had the fully built houses on those photographs; 
right? 
A. Yes. 
Q. Well, when Epstein first bought the property, those houses 
weren't there; right? 
A. Some of the buildings were not there. He added buildings, 
yes. 
Q. So there was a fair amount of construction to make the 
island look the way it was in those photographs; right? 
A. That is correct. 
Q. And was it about -- was it roughly '97 when he purchased 
the property? 
A. It was the late '90s, correct. I don't know the exact 
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year, but you're correct that it was late '90s. 
Q. And that construction was going on for several years, 
wasn't it? 
A. Yes. 
Q. Including the helipad that was there? 
A. The helipad moved a couple times, but yeah, it was -- it's 
kind of easy to do a helipad compared to a building, but yes, 
the helipad moved around. 
Q. And Ghislaine supervised all that construction? 
A. She was involved, absolutely. 
Q. Separate question, Mr. 
. You are, I believe, 
somewhat of a car guy; is that right? 
A. That's correct. 
Q. You like cars? 
A. Yes, I do. 
Q. You enjoy looking at the latest models? 
A. I like the classics. 
Q. You like the classics. Okay. Well, Epstein shared that 
interest with you; is that right? 
A. That is correct. 
Q. He also liked cars? 
A. Yes. 
Q. And you and he would discuss cars from time to time; isn't 
that right? 
A. Yes. 
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Q. So he knew about your shared interest, you talked about 
this a lot? 
A. That is correct. 
Q. Now he, I believe, bought some cars that he registered in 
your name; isn't that right? 
A. Yes. 
Q. There was a 2008 Land Rover? 
A. Yes. 
Q. There was a 2005 Mercedes Benz CLK? 
A. Yes. 
Q. There was a 2005 Jaguar X-Type? 
A. Yes. 
Q. These were all kept at his residence in Palm Beach? 
A. That's correct. 
Q. And you could use the cars if you wanted to; right? 
A. If I wanted to, sure. 
Q. But you didn't consider them your cars? 
A. No. 
Q. They were Epstein's cars; right? 
A. I'm sorry? 
Q. They were Epstein's cars; right? 
A. That's correct. 
Q. And other people at the Palm Beach residence could use 
them, as well? 
A. That is correct. 
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Q. I believe Epstein also bought a 34-foot JVC powerboat; 
right? 
A. Yes. 
Q. That was registered to you, as well? 
A. Yes, it was. 
Q. And you could use it if you wanted to; right? 
A. That's correct. 
Q. But it wasn't -- you didn't consider it yours? 
A. No. 
Q. Are you also aware of a green Cobra sports car that Epstein 
had? 
A. Yes. 
Q. That one was not registered in your name; right? 
A. No. 
Q. Do you know where Epstein got that from? 
A. Yes. 
Q. Where did he get it from? 
A. That came from Mr. Wexler in Columbus, Ohio. 
Q. Do you know approximately when he got that car? 
A. It had to been -- I know the car was built in '94, 
Mr. Wexner held it for — I'm only guessing now — a year or two. 
So I would think Mr. Epstein got it '96, '97. 
Q. Do you know when he got rid of it? 
A. When he got rid of the Cobra? 
Q. Yeah. 
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A. Yes. 
Q. When was that? 
A. That was probably 
it was in my possession for 20 years. 
Probably around 2000. 
Q. Thank you. Now, Mr. 
, in your testimony a little 
while ago, you said that Epstein gave you 40 acres of land on 
his ranch in New Mexico so you could build a house; right? 
A. Yes. 
Q. I think you would agree that was a pretty generous act on 
his part; yes? 
A. Yes. 
Q. Now, over the years, Epstein also gave you other gifts, as 
well; isn't that right? 
A. He gave other -- yes, he gave gifts to me as well as other 
employees, but yes. 
Q. Isn't it true that he paid for your children's tuition? 
A. Yes. 
Q. You have two daughters; is that right? 
A. Correct. 
Q. And he paid for both of their tuitions? 
A. Correct. 
Q. So were these private school tuitions when they were in 
high school? 
A. Yes. 
Q. Did he also pay for their college tuitions, as well? 
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A. Yes. 
Q. Did you ever mention this to Ghislaine that Epstein was 
paying for your daughters' tuitions? 
A. Yes. 
Q. So she was aware of this fact, too? 
A. Absolutely. 
Q. Did you ask Epstein to pay for your daughters' tuitions? 
A. He offered it when I first got hired. He said that he 
would take care of all employees' children's education. So we 
knew it was pretty much a given. 
Q. So he offered to do this for all of the employees that 
you're aware of? 
A. Yes, correct. 
Q. You didn't have to ask him for it? 
A. No. 
Q. So fair to say that Epstein took an interest in seeing your 
young daughter succeed; isn't that right? 
A. That's correct. He believed in higher education. 
Q. And this was when they were high school aged and college 
aged; isn't that right? 
A. Yes, and even younger, grade school. 
Q. You didn't think there was anything inappropriate about 
that; right? 
A. No. 
Q. It was just a generous act on his part, wasn't it? 
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A. Absolutely. 
Q. And you certainly didn't think that Epstein had any 
ulterior motive for being generous to your daughters, did you? 
A. No. 
Q. And he never asked you for anything in return, did he? 
A. No. 
Q. Mr. 
, are you aware that Epstein had back problems? 
A. He complained about back problems, yes. 
Q. Are you aware he often used a heating pad on his back? 
A. Yes. 
Q. And are you aware that he often got massages on a regular 
basis for the same reason? 
A. Yes, he did. Yes. 
Q. Now, for example, when you flew to the ranch in New Mexico, 
the ranch manager would sometimes arrange massages for Epstein; 
isn't that right? 
A. It's what I heard from the ranch manager, yes. 
Q. When the masseuses showed up, they were from a professional 
saloon in Santa Fe? 
A. To my knowledge, yes. 
Q. That was called the Ten Thousand Waves; is that right? 
A. I know that salon existed and it was famous for massage 
service, yes. 
Q. And he received massages from both male and female 
masseuses; isn't that right? 
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A. I didn't know their sexes, to be honest with you. 
Q. But to your knowledge, these were all adult professional 
masseuses? 
A. Oh, absolutely. 
Q. Now, Mr. 
, I want to ask you some questions about 
where Epstein lived in New York and where Ghislaine lived in 
New York in the 1990s and the 2000s. 
A. Okay. 
Q. Epstein, I think you testified, had two different 
residences in New York from 1991 two 2005? 
A. Correct. 
Q. You visited both of these? 
A. Yes. 
Q. One of the reasons you would have gone to his residence was 
to pick up his luggage or drop it off before or after a flight; 
right? 
A. That was typically the main reason, correct. 
Q. Another reason you said you might have gone there was you 
had a hobby of installing home video and audio equipment and 
home theaters; is that right? 
A. It was home theater. I had been using the word "video 
equipment," but it was in the '90s when home theaters, the 
Dolby came out, so everybody was on installing that. So he 
got -- he was an audio/video person, too, as one on high 
fidelity. So we were doing home theaters in all the 
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residences. 
Q. This is something you know how to do well? 
A. Yeah, I had a knack for that, as well. 
Q. So your mechanics background helps with that? 
A. Yes, it did. 
Q. And he liked having sort of the latest audio/video 
equipment or home theater equipment in his homes? 
A. Absolutely. 
Q. So you would occasionally go to all of his homes and 
install this for him? 
A. Absolutely, yes. 
Q. Did this in all his residences, not just New York? 
A. All of them. 
Q. Palm Beach, Zorro Ranch, the island? 
A. That's correct. 
Q. I want to focus on his residences in New York. Your 
recollection is that when you first began working for him in 
'91, he lived on a residence on 69th Street; isn't that right? 
A. Yes, that was of the first residences I remember. I think 
I only maybe went there one time. It was very early on 
obviously, in '91. 
Q. Was that 34 East 69th Street? 
A. I know it was 69th Street. I don't remember the number. 
But you are correct when you say 69th Street. 
Q. And then sometime after that, maybe in the mid '90s, he 
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moved to a townhouse on 71st Street; right? 
A. That's correct. 
Q. That's the one we saw photographs of? 
A. Correct, that's the 9 East 71st Street. 
Q. That's right off Fifth Avenue and Central Park? 
A. Correct. 
Q. And these are the only two New York residences you recall 
for Epstein; isn't that right? 
A. That's correct. 
Q. That's where you go to pick up his luggage and install 
video equipment? 
A. Yes. 
Q. Now, you also went to Ghislaine's residences during the 
same period, didn't you? 
A. Yes. 
Q. And you went for the same purposes; isn't that right? 
A. Yes, it was exactly -- yes, for luggage and such. 
Q. You'd go pick up her luggage from the residence, drop it 
off there? 
A. Yes. 
Q. I think you also did the home theater work for her 
residences, as well? 
A. Exactly, yes. 
Q. Now, Ghislaine had several different residences in New York 
from 1991 to 2005; isn't that right? 
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A. Yes. 
Q. And I believe you said you think you went to all of them: 
A. Yes. 
Q. So when you first started working for Epstein in '91, she 
lived in an apartment on -- you said a small apartment on the 
east side of Manhattan; is that right? 
A. Yes. 
Q. Do you recall if that was 20 East 66th Street? 
A. I don't remember the -- I definitely don't remember the 
66th Street because I would have remembered that was the 
apartment building where we stayed, but I don't remember the 
address of her very first place. 
Q. And then at some point in the mid '90s, she moved to a 
different apartment on the east side on 84th Street? 
A. I do remember 84th Street, yes. 
Q. I think you described that before in your testimony? 
A. Yes. 
Q. Was that 114 East 84th Street? 
A. Yes, it was. 
Q. Do you recall her living for a few years in the late '90s 
and early 2000s at an apartment on East 81st Street? 
A. I don't remember 81st Street. I just remember 84th Street. 
Q. But you do recall that, at some point, maybe in the early 
2000s, she moved to a townhouse on East 65th Street? 
A. I do remember 65th Street, yes. 
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Q. And that was 301 East 65th Street; right? 
A. No, 301 -- well, 301 was the apartment. 66th Street, that 
address on 65th, which I want to say it was 116 or 114 East 
65th Street --
MR. EVERDELL: One moment, your Honor. 
Q. Sorry. I'm going to correct myself. It was 116 East 65th 
Street? 
A. There you go. That's correct. 
Q. These are all the New York residences that you recall for 
Ghislaine; correct? 
A. Yes, it is. 
Q. These are all different residences than the residences that 
Epstein had as we discussed; isn't that right? 
A. That's correct. 
Q. And that's where you'd pick up Ghislaine's luggage from; 
right? 
A. Yes. 
Q. You wouldn't pick it up from one of Epstein's residences; 
right? 
A. No, not unless I was picking up Jeffrey's luggage, I went 
to Mr. Epstein's residence. 
Q. So at all times from 1991 to the 2000s, Ghislaine 
maintained a separate residence in New York from Mr. Epstein's; 
is that right? 
A. Correct. 
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Q. Mr. 
, I have one related question about the home 
theater equipment you installed. You testified that you 
installed this type of equipment in virtually all of Epstein's 
residences; right? 
A. Yes. 
Q. And you installed it in his residence in Palm Beach, you 
said; right? 
A. Yes. 
Q. So that Palm Beach residence was 358 El Brillo Way in Palm 
Beach? 
A. That's correct. 
Q. Do you recall a time when the El Brillo Way residence was 
being renovated and Epstein had to move to a rental residence 
in Palm Beach? 
A. I do remember that time. 
Q. And did you install the sort of home theater or any audio 
equipment in the rental residence? 
A. I don't recall installing in the rental residence, no. 
Q. Do you recall where the rental residence was located in 
Palm Beach? 
A. I don't know the address. I know approximately where it 
was, but I don't remember the address. 
Q. Do you recall when the renovation took place? 
A. I do not. I'd only be guessing if I said the mid 1990s, 
but I can't give you an accurate date. Nothing sticks out in 
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my head on that. 
Q. Best guess is sometime in the mid '90s? 
A. Mid '90s, yes. 
Q. Do you recall how long the renovation lasted? 
A. It was a pretty serious renovation. I'd only be guessing 
if I said six to eight months. 
Q. Thank you. 
MR. EVERDELL: Your Honor should I continue? 
THE COURT: How much longer do you have? 
MR. EVERDELL: I'm going to have probably about 20 
more minutes. 
THE COURT: Keep going for now. I'll let you know. 
Keep going for now. 
MR. EVERDELL: Understood. 
Q. Mr. 
, I want to ask you some questions about your 
sense of the relationship between Epstein and Ghislaine. Okay? 
A. Okay. 
Q. Now, you said you flew on numerous flights both of them; 
right? 
A. Yes. 
Q. And you interacted with them on a regular basis for several 
years from the 1990s and the 2000s; right? 
A. Yes. 
Q. So I think you got a sense of what Ghislaine did for 
Mr. Epstein; right? 
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A. Yes. 
Q. And you testified that she was one of the assistants he had 
in his office; right? 
A. Yes. 
Q. He had lots of assistants; isn't that right? 
A. That's correct. 
Q. Now, in the mid '90s through the end of the 1990s, 
Ghislaine was the assistant who took care of Epstein's 
properties; isn't that right? 
A. That's correct. 
Q. She would make sure the cleaning people came; right? 
A. Yes. 
Q. Or the -- well, there were -- I should clarify. There were 
staff at each one of these residences; right? 
A. Yes, she took -- yes. 
Q. And there were house managers at each one of these 
residences? 
A. That's correct. 
Q. So they would take care of, sort of, the day-to-day of each 
of these residences? 
A. Exactly. She was in charge of the house managers, making 
sure that --
Q. Right. 
A. -- it got taken care of. 
Q. She supervised the house managers who did the day-to-day? 
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A. Correct. 
Q. If there was something wrong, ultimately it was her 
responsibility if there was a problem? 
A. It probably would have been the first phone call to 
Ms. Maxwell to say we got a problem. 
Q. If there was a problem with a pool guy not coming and the 
house manager wasn't dealing with it, Ghislaine would deal with 
it? 
A. She would jump on it. 
Q. Same thing, cleaning people didn't come on time and it 
wasn't being addressed correctly, Ghislaine had to deal with 
that? 
A. Yes. 
Q. She would manage the household staff as a supervisory over 
the household manager? 
A. Correct. 
Q. She would also oversee repairs and renovations and 
decorating? 
A. Yes. 
Q. Things like that? 
A. Yes. 
Q. She was a shopper for Epstein; right? 
A. She liked to shop. 
Q. She bought furniture and things like that for the 
residences? 
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A. That is correct. 
Q. She bought household items? 
A. Yes. 
Q. She decorated the planes, too; right? 
A. She had a lot put into the airplanes, stocking the airplane 
on what we carry as far as beverages. 
Q. We saw photographs of the plane, right, this isn't a matter 
of hanging a few curtains; right? 
A. No. 
Q. This is a pretty big job to outfit one of these planes 
correctly for their flight? 
A. Sure. 
Q. And we also saw these properties; right? They were --
let's talk about the ranch in particular. That was a large 
piece of property; right? 
A. A lot of square footage, yes. 
Q. You said 10,000 acres, roughly? 
A. Yes. 
Q. It's a pretty big job to manage those properties; right? 
A. Yes. 
Q. In particular, just to call out the ranch for a moment, 
there were animals on that property; right? 
A. Yes. 
Q. There were horses in the stables? 
A. She loved her horses. 
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Q. She took care of the horses; right? 
A. Yes, she did. 
Q. She took care of the other animals on the property? 
A. Yes. 
Q. This took a lot of Ghislaine's time and energy to do this 
job, didn't it? 
A. Yes. 
Q. And she had to travel to the properties from time to time 
to do this work; right? 
A. That's correct. 
Q. Now, I think in your testimony, you called her Epstein's 
number 2; right? 
A. Yes. 
Q. But from your perspective, she was dealing with the 
aircraft and the properties; right? 
A. Yes. 
Q. She wasn't dealing with Epstein's finances; right? 
A. No, not the business side. It was Jeffrey household 
personal. 
Q. The reason why you call her number 2 is because she was 
generally overseeing the running of the households; right? 
A. Correct. 
Q. But as we said, she wasn't on site at each of these 
properties every single day running the day-to-day of these 
households? 
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