EFTA00157548

Page 1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE No.08•CV.80119•CIV•MARRAIJOIINSON 
JANE DOE NO. 2. 
Plaintiff. 
n. 
JEFFREY EPSTEIN. 
Defendant. 
Related cases: 
08.10232. 0840360. 9840381 08.10994. 
0640993. 0840811. 08.80893. 09.80169. 
09.10591.09.80656.09.80802.0941092 
VIDEOTAPED DEPOSITION OF JUAN ALESSI 
VOLUME I 
Tuesday. September 8. 2009 
1012 am.. 3:45 pm. 
2139 Palm Beach Lakes Boulevanl 
West Palm Beach. Banda 31301 
Reported By 
Sandra W Townsend. FPR 
Now), Public. State of Flan& 
PROSE COURT REPORTING AGENCY 
West Palm Beach Office 
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On behalf of the Defendant: 
ROBERTI. CRITTON. ESQUIRE 
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APPEARANCES: 
On behalf of the Plaintiffs: 
RICHARD WII.I.ITS. ESQUIRE 
RICHARD H. WILLITS PA 
STUART hIERAIELS1EIN. ESQUIRE 
KATHERINE W. EZELL. ESQUIRE 
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EXHIBITS 
NUMBER 
DESCRIPTION 
Exhibit number 1 
Exhibit number 2 
Exhibit number 3 
Exhibit number 4 
Exhibit number 5 
Page 4 
PAGE 
Photographs 
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Transcript 
B0 
Incident Report 
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Incorporation Papers 
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Incorporation Papers 
ISO 
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(Pages 
1 to 4) 
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PROIEEDINGS 
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- - - 
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Q. All right, sir. Did you ever work for Jeffrey 
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Deposition taken before Sandra W. Townsend. Court 
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Epstein? 
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Reporter and Notary Public in and for the State of 
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A. Yes, I did. 
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Florida at Large. in the above cause. 
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Q. In what capacity? 
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- - - 
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A. Everything. I started with Jeffrey Epstein 
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VIDEOGRAPHER: Today is September 8. 2009. 
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around 19 -- please bear with the dates because I 
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The time is 12 minutes after 10:00 in the morning. 
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trying --
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This is the videotaped deposition of Juan 
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Q. Sure. 
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Alessi in the matter of Jane Doe number two versus 
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A. -- to remember. 1969 as a part-time 
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Jeffrey Epstein. This deposition is being held at 
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maintenance guy. 
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2139 Palm Beach Lakes Boulevard in West Palm Beach 12 
And then I become a full-time employee. I 
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Florida. 
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think it was January 1.2 -- '91. '92. so '92. Sorry. 
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My name is Stan Sanders. I'm the videographer 
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Q. You said you started in 1969? That would 
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representing Visual Evidence. Incorporated. 
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be —
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Would the attorneys please announce their 
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A. No. No. No. No. No. 
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appearances for the record. 
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Q. Okay. 
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MR. WILLITS: Richard Willits. representing 
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A. '99. 
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Q. 1999? 
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MR. BERGER: WilliamJ. Berger. representing 
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A. Yeah. 
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...mg 
and Jane Doe number two. 
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Q. All right. And how did you happen to get that 
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MR. MERMELSTEIN: Stuart Mermelstein of 
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job? Was it through an employment agency --
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Mermelstein and Horowitz. representing Jane Does 
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A. No. 
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numbers two through eight. 
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Q. -- or an ad in the paper? 
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MR. LANGINO: Adam Langino. on behalf of 
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A. I had a company at that time used to take care 
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Page 8 
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MS. EZELL: Katherine Ezell from Podhurst 
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of a lot of residents in Palm Beach. And I got to know 
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Orseck, on behalf of Jane Does 101 and 102. 
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Jeffrey through Lesley Wexner. And I used to work in 
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MR. CRITTON: Bob Critton. on behalf of 
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about 20 different. 20.25 different homes in Palm Beach 
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Jeffrey Epstein. 
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as a maintenance guy. 
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THEREUPON, 
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Q. Okay. 
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JUAN ALESSI. 
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A. And I have basically my own company and I do 
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having been first duly sworn or affirmed, was examined 
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repairs for them. I did home sit in for them. 
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and testified as follows: 
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Q. And what was — did you work for Jeffrey 
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THE WITNESS: I do. 
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Epstein? What was your position when you started? 
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DIRECT EXAMINATION 
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A. When I started, he hire me to -- he just 
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BY MR. WILLITS: 
11 
bought the house. 
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Q. Good morning. sir. 
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Q. I'm sorry? 
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A. Good morning. 
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A. He just had bought the house --
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Q. I introduced myself through the videographer. 
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Q. Okay. 
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My name is Richard Willits. 
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A. -- where he live on El Brillo. And he hire me 
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A. Okay. 
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through Mr. Wexner's references to do repair works. And 
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Q.
 re resent a young lady by the name of 
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basically what I did the most was taking walls apart. 
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windows and stuff that he didn't want to have it. --
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A. Okay. 
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Q. I see. 
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Q. Is that name familiar to you at all? 
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A. -- fix it. 
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A. Whose name? 
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Q. And when you started working for Mr. Epstein. 
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Q. 
Do you recognize that name 22 
were you still working for other people in Palm Beach? 
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A. No. 
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A. Yes. I did. 
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Q. What is your residence address, sir? 
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Q. Okay. And about how long a period of time did 
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A. My address is 
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you do this type of work for Mr. Epstein. the 
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maintenance and taking out walls? 
A. It was couple months. It was couple months 
before. 
Q. And what was the name of your company? 
A. Alessi Maintenance. 
Q. And how were you paid? 
A. By him? 
Q. Yes. 
A. Usually by check or cash sometimes. 
Q. Do you know what company actually paid your 
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Page 11 
about seven months before -- after I become a full-time 
employee. 
Q. Okay. And how did Ms. Maxwell come into the 
picture? 
A. It was his girlfriend, his main girlfriend. 
Q. Okay. Had you known her before she became --
A. No. 
Q. -- your --
A. Never know her before. 
Q. I'm sorry. I didn't get a chance to finish my 
:1 
company? 
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question. 
:2 
A. It was Jeffrey Epstein and Company. 
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Would you have referred to her as your 
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Q. So you said you had that position for a couple 
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supervisor or your superior or what would you have 
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of months. 
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called Mrs. Maxwell? 
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What happened next? 
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A. I used to call her Ghislaine. 
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A. Then Mr. Epstein asked me to. if I wanted to 
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Q. Okay. And how was it explained to you that 
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be his employee. because I was going from one house to 17 
you were now to deal with Ms. Maxwell. as opposed to 
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another house to another house. one hour here. I was 
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Jeffrey Epstein? 
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just running around Palm Beach all day. 
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A. She would tell me. I am going to take care of 
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So he asked me if I would just work for him. 
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the house. 
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exclusively for him. 
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Q. Okay. That was explained to you by 
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Q. Okay. 
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Ms. Maxwell? 
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A. And we agreed with the terms and I become a 
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A. Uh-huh. 
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full-time employee as a maintenance guy. And I was 
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Q. Is that a yes? 
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taking care of everything. as far as maintenance. 
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A. Yes. 
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Page 12 
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Then my job changed little by little to house 
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Q. And when Ms. Maxwell started assuming 
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man, estate manager. and then to a majordomo. 
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responsibility for the house, did your duties change at 
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Q. Okay. When you first agreed to terms with 
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that time? 
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Mr. Epstein and you first started working for him full 
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A. Not much. 
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time. what were those terms, do you remember? 
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Q. Okay. 
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A. The terms is basically was how much — he 
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A. Not much. 
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asked me how much I was making in all the properties. 
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Q. And at that time when Ms. Maxwell started 
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And I says. well. I make this -- this amount 
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taking responsibility for the house. what were your 
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of money. 
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duties? 
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And he says. fine. 
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A. Basically I was still doing the maintenance 
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Q. And how much was that. did he pay you? 
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work. 
:2 
A. Around 445.000. I think I started with 45. 
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Q. Okay. 
:3 
Q. Okay. And when you started to work for him as 13 
A. Was doing — they were trying to remodel the 
:4 
a full-time employee, did you have anybody that you 
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home and they would told me. okay. tear down this wall. 
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reported to or did you deal directly with Mr. Epstein? 
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We want to see how it's going to look. Or put this 
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A. At the beginning with Mr. Epstein. directly to 
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windows and tear down -- we had a fishing tank. We took 
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him. 
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it out -- I took it out. A kitchen on the second floor. 
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Q. Did that change? 
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I took it out. So it was basically dismantling the 
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A. Later on. yes. 
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house. 
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Q. And how did that change? 
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Q. Okay. And about how long a period of lime did 
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A. When Ms. Maxwell. Ghislaine Maxwell came to 21 
that project last? 
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the picture. 
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A. I would says. six to seven months. 
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Q. Okay. About when was it that she came into 
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Q. Okay. And after the remodeling slacked off or 
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the picture? 
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stopped. did your duties then change? 
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A. Exactly date. I cannot remember. But it was 
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A. Yeah. Increasingly they change. 
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Q. Okay. Who -- 
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living on the property. but outside the house? 
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A. Periodically. It didn't change from one day 
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A. I was living in the property. No. No. No. 
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to another. 
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I was working outside the property. 
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Q. And who would tell you that your duties were 
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Q. Yes. 
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increasing? 
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A. And because it was multiple jobs that I had to 
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A. Either Mr. Epstein or Ms. Maxwell. 
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do. 
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Q. Okay. And how did your duties increase? 
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Q. Okay. 
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A. In — I become more — more involved in the 
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A. Had to do with the pool. the service, the 
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daily running operation of this home. This home was run 
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landscaping. taking care of that. I didn't do it 
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like a hotel basically. 
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myself, but I have people working for me. 
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Q. Okay. Were you given any manuals or rules or 
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Q. Okay. Approximately when was it in 
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procedures that you had to follow? 
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relationship to Ms. Maxwell taking over the 
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A. At the end of my stay. yes. I was. 
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responsibility of the house did you then move inside the 
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Q. Okay. At the end. And I'm going to jump to 
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house? 
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the end now and then come back. 
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A. I will says. after it was done, a big 
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What was it that you were given at the end of 
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renovation. when architects and engineers. And that wu 
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your stay: what kind of papers or manuals? 
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after I did the breaking down of this renovation, they 
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A. It was a manual. I can't remember how many 
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hire architects, they hire decorators and engineers, and 
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pages. but it was quite thick manual that was -- that 
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did the -- they did the work. It was a big renovation. 
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was done by mute manager. that she will manage all — 
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one of the renovations. 
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all the properties. And that was also to be in force in 
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And then they make our quarters. They even 
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Palm Beach. 
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built our -- my quarters in there. 
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Q. I see. Do you still have a copy of that 
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Q. When you said "our." was there someone else 
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manual? 
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who had quarters there. too? 
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A. No. I don't. 
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A. About three years later, after I start 
Page 14 
Page 16 
1 
Q. Do you have any papers whatsoever that were 
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working. my wife came to help me. 
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prepared while you were working -- 
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Q. I see. And are you able to describe for me 
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A. No. 
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where the quarters were. like, what floor? 
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Q. — for Mr. Epstein? 
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A. Yes. It was in the second floor and the --
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A. I left everything in there. 
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let me trying to remember — northeast corner of the 
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Q. Did you make any diary notes yourself or any 
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property. Northeast corner. yes. 
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notes for your own private use while you worked for 
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Q. Did anyone else work for Mr. Epstein while you 
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Mr. Epstein? 
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were working for him there at the house? 
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A. No. sir. The only thing I have is my 
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A. During the whole time? 
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separation agreement. That's it. 
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Q. Yes, sir. 
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Q. Okay. Did you bring that with you today? 
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A. Yes. 
12 
A. No. I didn't. 
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Q. All right. When you first started there. 
:3 
Q. Okay. Did your duties ever include taking 
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there was no one else? 
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telephone messages? 
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A. When I started there. was a — it was a 
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A. Yes. sometimes. 
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Jamaican girl that she was doing the cooking. 
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Q. And when did that start approximately? 
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Q. Okay. Do you happen to remember her name ? 
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A. When I move from the outside to the inside of 
17 
A. No. 
18 
the house. 
18 
Q. All right. 
19 
Q. All right. 
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A. She worked for couple months. 
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A. I -- when I start the position. I never had an 
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Q. I see. All right. When did any other 
21 
apartment in the house. And when I definite they want 
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employees begin to work for Mr. Epstein while you wen 
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me inside to run the house. I had an apartment. I have 
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there? 
23 
a small service quarters in the house, inside the house. 
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A. They hire chefs. There was mostly European 
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Q. Okay. And when you say. outside the house. do 
24 
chefs. It was an English chef. but I cannot -- Rupert. 
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you mean outside the property or were you — or were you 25 
I know his name was Rupert. A french chef that was 
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Didier. A kid from New York who was a chef, also. But 
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Q. Were there any photographs of nude females in 
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they were one after another one. They were hiring chefs 
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the house while you were there? 
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when I doing — sometimes I did most of the cooking. 
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MR. CRITTON: Form. 
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When they wanted to bring their chef, they bring their 
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MR. WILLITS: What's the matter with that 
S 
chef in their plane. And the chef will stay. will work 
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form? 
6 
there and then will travel with them. 
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MR. CRITTON: Overly broad. Nude? You mean 
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Q. Were there any other employees that worked for 
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completely naked? 
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Mr. Epstein while you were worked for him, that you know 
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MR. WILLITS: However you want to interpret 
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of? 
9 
it. 
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A. No. except my wife. 
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THE WITNESS: Excuse me. Can you repeat that 
11 
Q. Did you know a lady by the name of 
11 
again? 
12 
=I 
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MR. CRITTON: Form. 
13 
A. 
• yes. I do. --came 
at the 
13 
BY MR. WILLITS: 
14 
end of my stay there, probably two or three months 
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Q. Yes. Were there any photographs of nude 
15 
before I left. 
15 
females in the house while you worked for Mr. Epstein'? 
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Q. Okay. Did she do any work for Mr. Epstein. 
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A. Yes. Sometimes I saw nude photographs. 
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that you know of? 
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Q. Are you able to describe where you saw those. 
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A. Yes. She was a -- I don't know her deterrent. 
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where in the house? 
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but she was an assistant to him or to her. I don't 
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A. Most of the times those photographs were taken 
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know. 
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by Ms. Maxwell. And they usually are her desk. And sin. 
21 
Q. All right. There is a -- I've seen a 
21 
kept a big album. 
22 
reference in -- and the spelling has changed in my 
22 
Q. Do you remember any pictures of nude or 
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various references -- is there a or.?Do you 
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partially unclothed females on the walls at 
24 
recognize that name? 
24 
Mr. Epstein's house? 
25 
A. 
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MR. CRITTON: Form. 
Page 18 
Page 20 
1 
Q. 
1 
BY MR. WILLITS: 
2 
A. 
Yes. I know 
2 
Q. He's just making objections for the record 
3 
Q. Want to take a chance at spelling that last 
3 
that he can take -- he will take it up with the Judge 
4 
name? 
4 
later on. 
S 
A. I think it was 
But she was not an 
5 
A. Okay. 
6 
employee. She was a guest. 
6 
Q. You don't need to worry about --
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Q. Was she a full-time guest? 
7 
A. Yes, it was. It was pictures of partially 
8 
A. No. 
8 
nude. 
9 
Q. When would she visit? 
9 
Q. And where were they? 
10 
A. Most of the times they were in the pool. 
11 
Q. How about on the stairway? 
Ill 
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A. No. On the stairway there were no pictures 
i 
13 
14 
when I was there. 
re. 
Q. How many stairways were there? 
15 
Q. Okay. Do you — are you familiar with any 
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A. It was the service stairway that is very 
16 
other individuals by the name ME on who worked fo- 16 
narrow coming from the service quarters to the kitchen.
17 
Mr. Epstein? 
17 
And the main stairway. that it was quite wide 
18 
A. No. 
18 
and to the second floor. 
19 
Q. After the renovations were complete. did you 
19 
Just those two. 
20 
have access to the entire house while you worked for 
20 
And also there was a stairway outside through 
21 
Mr. Epstein? 
21 
the pool to the balcony upstairs. 
22 
A. Absolutely. yeah. 
22 
Q. And do you have a recollection of pictures of 
23 
Q. Was there any particular portion of the house 
23 
any females whatsoever on either of the inside 
24 
that was denied access by — to you? 
24 
stairways? 
25 
A. No. 
25 
A. No. I don't. 
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Q. What is your understanding. sir, of the -- a 
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Page 23 
Q. Okay. Do you remember any other females beitq 
2 
reference to a girl. as opposed to a woman? Are you 
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present at the house, other than the females that ou'vc 
3 
familiar with the term. girl? 
3 
mentioned. which were 
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A. Of course. 
4 
Were them any others that you --
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Q. Are you familiar with the term, woman? 
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A. Many. many. many. many. many. 
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A. I interpret most a woman. a married woman. a 
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Q. When did you first --
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married person. 
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MR. CRITTON: Can I just have the last 
8 
Q. Are you -- how would you describe a 14 year 
8 
question read back? 
9 
old, a woman or a girl? 
9 
MR. WILLITS: Of course you can. 
:0 
A. A girl. of course. 
10 
MR. CRITTON: Please. 
:1 
Q. How would you describe a 16 year old. a womar 11 
MR. WILLITS: But only once. 
:2 
or a girl? 
12 
MR. CRITTON: That's all I need. 
:3 
A. Again. I don't know. I am not -- I don't 
13 
MR. WILLITS: You sure. 
:4 
think I can tell you exactly she is 14 or 16. 
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Go ahead. 
:5 
Q. But if you knew -- 
15 
(Previous question was read.) 
:6 
A. Sixteen. I would think is a girl. of course. 
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MR. CRITTON: And can I just ask for a 
17 
Q. Were there ever any visitors to the Epstein 
17 
clarification from you? Arc you going to use -- if 
18 
house that you considered to be girls. as opposed to 
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you use the word woman, am you --
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women? 
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MR. WILLITS: I said. females. 
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A. Yes. Yes. I think I would says. I never 
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MR. CRITTON: No. no. I understand. But in 
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check her i.d. 
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the future if you use woman, does that mean. at 
22 
Q. Right. 
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least to Mr. Alessi. that that's married, and if 
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A. Or I was not told to check i.d.s. -- 
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its a girl she has to be 14 or 16? Because that's 
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Q. Of course. 
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how you asked the question. 
25 
A. — on these girls. But one. I would says. 
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MR. WILLITS: All I'm going to talk about is 
Page 22 
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M. was very young because she was in hi w school. Ant 
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females. 
sometimes either l •ick he 
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MR. CRITTON: Okay. 
I 
3 
MR. WILLITS: And ask --
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I can't 
4 
MR. CRITTON: I'll be alert to the questions 
5 
remember exactly what that place is. the name of the 
5 
then. 
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place. 
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MR. WILLITS: All right. So you don't need it 
7 
Q. Did you give -- provide transportation for any 
7 
sleep through the next few questions. 
8 
other females while you worked for Mr. Epstein? 
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MR. CRITTON: I don't sleep at all. 
9 
A. Occasionally. yes. I did. 
9 
MR. WILLITS: All right. Now I'm totally 
10 
Q. Do you happen to remember the names of any of 
10 
confused. 
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those females? 
11 
BY MR. WILLITS: 
12 
A. I remember one. specifically one. It was. 
12 
Q. When did you first become aware of female:, 
13 
Her name 
I cant remember her last name, but I 
13 
visiting the Epstein house? 
19 
think it w• 
I'm not sure. I can be wrong on that. 
14 
A. Since I know him. 
15 
Q. And how many times did you provide 
15 
Q. During the renovations? 
16 
transportation services for this female? 
16 
A. Yeah. 
17 
A. Whenever I had -- I been told. Whenever I was 
17 
Q. Were there --
18 
told to go get them or brio them back to their house. 
18 
A. Before the -- before Ms. Maxwell.
19 
Q. Did you conside 
to be a girl or a woman? 
19 
Q. Okay. All right. Let's use that as a 
20 
A. Again. I think it was a woman. from myself. 
20 
milepost. 
21 
her dressing and her — I think it was — again. I don't 
21 
Before Ms. Maxwell --
22 
know if she was 16. 17 or 18 or 19. could have been. 
22 
A. Before it was Ms. Maxwell. it was only one 
23 
But she was not — I never pick her up from a school or 
23 
woman that it was Mr. Epstein's girlfriend. And her 
29 
anything like that. The only girl that I picked up from 
24 
name was Dr. -- she was a doctor of medicine -- Eva 
25 
the school wan 
25 
Anderson. And I really liked this girl. She was veil. 
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nice, nice person. 
1 
A. Because they were local. Sonic people. they 
2 
Q. Did you say Anderson or Underson? 
2 
live in Palm Beach. Sonic of these girls, they live in 
3 
A. Anderson. A-N. 
3 
Palm Beach. 
4 
Q. A-N-D-E-R-S-O-N? 
4 
Q. How did you know that? 
5 
A. Yeah. 
5 
A. They become friends. 
6 
MR. BERGER: What was her first name? 
6 
Q. Okay. Do you happen to remember the names of 
7 
THE WITNESS: Eva. 
7 
any of those friends? 
8 
BY MR. WILLITS 
8 
A. I remember them were some girls that come 
9 
Q. Before Ms. Maxwell assumed responsibilities 
9 
multiple times and they're usually there for dinners or 
10 
for the house, were there any other female visitors to 
10 
lunches. One was M.. 
11 
the house. except for Dr. Eva Anderson? 
11 
Q. Okay. 
12 
A. No. not that I remember. She was one. 
12 
A. I think she was a -- she used to work for 
13 
Q. All right. After Ms. Maxwell assumed 
13 
14 
responsibility for the house, do you recall any female 
15 
visitors? 
15 
Q. Okay. 
16 
A. Many. 
16 
A. Try to remember names but there were a lot of 
17 
Q. When did that start in relationship to when 
17 
visitors in the house, a lot of female visitors. 
18 
Ms. Maxwell assumed responsibilities? 
18 
Q. Are you aware of female visitors to the house 
19 
A. Immediately. 
19 
who were there to perform massage services? 
20 
Q. Were there visitors who came back more than 20
A. Yes. 
21 
once? 
21 
Q. Do you recall the first time that you observed 
22 
A. Yes. 
22 
a female come into the Epstein house for the purposes of 
23 
Q. And when I say. "visitors: I mean, female? 
23 
massage? 
24 
A. And males. 
24 
A. I don't recall that. 
25 
Q. I'm only interested in females. Mr. Critton 
25 
Q. How many different individuals came to the 
Page 26 
Page 28] 
1 
may be interested in the males. I'm not sure. 
1 
Epstein house for the purpose of massage. as far as you 
2 
Did you have any information as to where these 
2 
understood it? 
3 
visitors came from? 
3 
A. In the -- I would says. between 50 and a 
4 
A. They were mostly European girls. 
4 
hundred different persons. 
5 
Q. And when you say. "girls." do you mean 14 to 
5 
Q. Do you happen to know any of those names? 
6 
16. — 
6 
A. I remember couple names. 
7 
A. No. 
7 
Q. Okay. 
8 
Q. — or do you mean females? 
8 
A. And the last name I asked — I going to tell 
9 
A. They all were. I would says. under -- over 20 
9 
you there were girls that come multiple times and there 
10 
years old. 
10 
are girls who come one times and that was it. 
11 
Q. Okay. And it has been explained to us in 
11 
Of the multiple time the girl -- the girls 
12 
another deposition that sometimes females travelled with 12 
come to the house -- "girls: again, mean — I'm going 
13 
Mr. Epstein. 
13 
to refer everybody as girls. 
14 
A. Yes. they did. 
14 
Q. Okay. But you don't necessarily mean under 
15 
Q. Are these females that you are referring to. 
15 
the age of 18 when you say —
16 
did they travel with Mr. Epstein or did they get to the 
16 
A. None of these girls were under the age of 18. 
17 
house in other ways? 
17 
Then again. I don't know. They could have been I8 or 19 
18 
MR. CRITTON: Form. 
18 
or 20 or 25. I don't know. But they were all masseuse' 
19 
THE WITNESS: Both. 
19 
and they came to the house. 
20 
BY MR. WILLITS: 
20 
One of the names that I remember was
21 
Q. Both. Okay. Were you aware of any female 
21 
Q. That' 
22 
visitors to the Epstein house from the local area of 
22 
A. Uh-huh. 
I think it was. 
23 
Palm Beach County? 
23 
So many 
24 
A. Yes. 
24 
'Mere were also massage therapists from 
25 
Q. flow -• and why did you become aware of that? 
25 
Europe. They sometimes travel with him in the plane. 
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And some just namft. that I cannot -- I cannot go on. 
1 
2 
Q. Sure. How did you know than.. were 
2 
She had -- she was livin. wit 
3 
4 
there for purposes of a massage? 
A. Because I was told to either Ms. Maxwell will 
I 
5 
call. I will call or Mr. Epstein will told me. call this 
5 
Q. Okay. Do you happen to remember any other 
6 
girl at that time. Sometimes it was 1:00 in the 
6 
areas of the county where you transported any of the 
7 
morning. Sometimes it was within the afternoon. 
7 
females? 
8 
Sometimes it was after the movies. They usually go ink 
8 
A. I transport her -- one back to a house in 
9 
a movie every night after dinner. And sometimes were 
9 
10 
girls that come at 10:00. 10:30. 
10 
Q. Okay. 
11 
Q. How would you know what number to call? 
11 
A. That's what I can remember now. 
12 
A. I had a list. 
12 
Q. Did you ever speak to any of these females 
13 
Q. Okay. Was this a list that you prepared or 
13 
that you have mentioned -- let's talk specifically about 
14 
was given to you? 
14 
the ones that you have named 
—
15 
A. I had a list that it was in my Roladex. 
15 
about what they did there at the Epstein house? 
16 
Q. Okay. So as part of your job there was a 
16 
A. No. They did massage therapy. 
17 
Roladex? 
17 
Q. And how did you know they were actually 
18 
A. Yes. 
18 
providing massages? 
19 
Q. Who put the information on the Roladex? 
19 
A. Most of them, they had business card and they 
20 
A. I think I did most of the times or I was given 
20 
left me business cards. And some of them asked me to 
21 
a piece of paper. says. call this girl, put a number. 
21 
call them to provide them work. 
22 
And I will call her. And if she was coming back. then 
22 
And I says that was not my job. My job was to 
23 
Ed put her as a regular massage therapist. 
23 
call whoever they wanted. Either when she —
24 
Q. Do you know how these females would be 
24 
Ms. Maxwell want a massage. she will told me. I want d 
25 
transported to the Epstein house? 
25 
massage at this time with this person. 
Page 30 
Page 32] 
1 
A. Ninety-nine percent they -- they would drive 
1 
Q. Uh-huh. 
2 
their own cars. 
2 
A. Or Mr. Epstein will call me and he says. get 
3 
Q. And when they did not drive their own cars. 
3 
this girl at this time. 
4 
how -- 
4 
So it was not my job to pick and choose these 
5 
A. Some, they were transported by the boyfriends 
5 
girls. 
6 
or the husbands and they wait outside. 
6 
Q. Did you have anything to do with paying any of 
7 
Q. How about. are you aware of any of the females 
7 
these females? 
8 
being transported to the house by virtue of a taxi? 
8 
A. Occasionally. yes. I did. 
9 
A. I think it was an occasional time that I have 
9 
Q. Can you describe that? 
10 
to send a girl in a taxi, if I was going to be busy for 
10 
A. The most -- the regular girls that came to the 
11 
transporting them. 
11 
house, sometimes they got paid once every night or even 
12 
Q. Did you ever provide transportation to any of 
12 
day or I knew them and they would just say. just keep a 
13 
the females who were there for purposes of massage? 
13 
tab of the hours and I will pay amount at the end of the 
14 
A. Yes. I did. 
14 
week. 
15 
Q. Okay. Do you remember where you went? 
15 
Q. And how were they paid. by cash or check? 
16 
A. I remember specifically on... -- 
16 
A. Most of the times. I would says. 95 percent of 
17 
Q. Okay. 
17 
the times I was paid by check. 
18 
A. -- that she used to liv 
18 
Q. I mean, the females? 
MI 
19 
A. The females. --
20 
Q. All right. 
20 
Q. The females were paid? 
21 
A. And when she went the first time, she — she 
21 
A. -- I would pay them by check. 
22 
went by herself. I never had to bring her back. But 
22 
Q. Out of what account? 
23 
later I was told by Mr. Epstein to go and pick her up. 
23 
A. I was — I have an account that I was from the 
24 
And she give me the -- or he give me the address and the 24 
bank for Jeffrey Epstein and my name was on it. I woulei
25 
phone. so I call her and I went and pick her up from 
25 
sign the checks. I will make a copy of a check. I will 
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make the girl sign a paper that they receive check for 
1
Q. — the employment of Mr. ng. who were the 
2 
5500 for five massages. 
2 
other employees? You mentioned 
Anybod, 
3 
Q. And do you remember where that -- what ban 
3 
else there? 
4 
that account was with? 
4 
A. The chef, but the chef also work in Europe. so 
5 
A. I think Palm Beach National Bank on Worth 
5 
he was travelling with him. 
6 
Avenue. 
6 
Q. Right. 
7 
Q. Did you ever have any occasions to make 
7 
A. He had a room. 
8 
deposits to that account? 
8 
Thcn it was another renovation of the house in 
9 
A. Yeah. 
9 
the middle -- about a year and a half before my 
10 
Q. Where would the cash or checks come from to 10 
departure. And there was a house built for the -- away 
11 
make deposits? 
11 
from the — from the main house. It was a service 
12 
A. Checks. There was checks, big checks for 
12 
house. There was couple rooms in there with a kitchen 
13 
Mr. Epstein. 
13 
and a living room. So he will have a room in there, the 
14 
Matter of fact, one time I was so scared. It 
14 
chefs. 
15 
was a couple million dollar checks that I -- he told me 15
Q. Okay. Does the name ring a bell? 
16 
to go and deposit. 
16 
A. No. Never saw her. 
17 
Q. You said that usually these girls were paid by 
17 
Q. Do you recognize the name Joe Joe as sometxxl. 
18 
check. Were there occasions when the females would 18 
who worked for Mr. Epstein? 
19 
19 
A. Joe Joe? Joe Joe. as far as I knew. it was --
20 
A. There were occasions -- 
20 
I met him. He was the house man in New York. 
21 
Q. -- paid by cash? 
21 
Q. Okay. 
22 
A. -- where the girls says, do you have any cash. 
22 
A. It was him and his wife --
23 
John? They were asking for cash. 
23 
Q. All right. 
24 
I says. let me take a look. So I check my 
24 
A. -- that were the people. they handled the 
25 
petty cash box that we have for the house for the 
25 
house in Ncw York. 
Page 34 
Page 36 
1 
expenses. And if I have it. I pay it. If not. 
1 
Q. Did you ever personally observe a massage 
2 
Mr. Epstein will pay. 
2 
taking place in the Epstein house? 
3 
Q. Did you ever have any concerns that any of the 
3 
A. Never. 
4 
females coming to the Epstein house for the purposes of 
4 
Q. Did you ever have occasion to clean 
5 
massage might be under the age of 18? 
5 
Mr. Epstein's bedroom after a massage? 
6 
A. No. because I never saw younger. young. young 
6 
A. Every time. 
7 
girls. And mostly that I was told they were massage 
7 
Q. Did anyone assist you with that? 
8 
therapists. 
8 
A. Sometimes. 
9 
Q. Told by who? 
9 
Q. Who would be -- who would assist you? 
10 
A. By Ms. Maxwell or Mr. Epstein. 
10 
A. Depends on the day of the hour. Sometimes the 
11 
Q. Did you ever have any dealings with 
11 
cleaning crew that we had. if it was the right date, the 
12 
about the females who came to provide massage 
12 
right time, they will go out and clean up. But most of 
13 
services? 
13 
the time I was involved. I was the one. 
14 
A. No. 
came about. I would says. 
14 
Q. Did you ever observe any vibrators in 
15 
the most two months before my departure. 
15 
Mr. Epstein's bedroom after a massage? 
16 
Q. Okay. Do you think that you would be able to 
16 
A. Yes. I did. 
17 
recognize any of the females if you saw them or their 
17 
Q. How many? 
18 
pictures? 
18 
A. Two. 
19 
A. Pictures? Yeah. I think so. 
19 
Q. How many massage tables were there at the 
20 
Q. Did you ever have any discussions with any 
20 
Epstein residence while you worked there? 
21 
fellow employees about the females who were coming 
21 
A. It was permanent massage tables or we had 
22 
provide massage services? 
22 
tables for every room of the house. So it was about the 
23 
A. No. 
23 
blue room, the red room. It was a massage table for tht 
24 
Q. At the time that you left — 
24 
balcony. It was on Mr. Epstein's bathroom, 
25 
A. Yes. sir. 
25 
Ms. Maxwell's bathroom. There was Ms. Maxwells 
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bathroom was in the same quarters. his quarters. 
1 
Q. The latter? 
2 
So we had quite a bit of expensive tables. 
2 
A. The latter. 
3 
Q. Did you ever get a massage while you were 
3 
Q. What, if anything. can you remember or tell us 
4 
working for Mr. Epstein? 
4 
about your separation agreement? 
5 
A. I wasn't that lucky. 
5 
A. It was basically an agreement between him am 
6 
Q. Okay. I'm sorry. 
6 
myself that we will leave after all those years of 
7 
A. I don't want to lie. Yes, I did. By a guy. 
7 
service. 
8 
It was a -- occasionally it was male massage 
8 
And I regret to agree with the amount, but it 
9 
therapists there. there were called. They did massages 
9 
was 430.000 for me and S20.000 for my wife. 
10 
for Mr. Epstein and Ms. Maxwell. 
10 
And it was -- he give my wife the car that she 
11 
And one time I had some pains in my back and I 
11 
usually drive. It was a minivan. Chrysler minivan. as 
12 
was given as a gift. 
12 
part of the -- as part of the separation. She loved 
13 
Q. Now, there came to be an incident where you 
13 
that car and she did all the shopping. it was done in 
14 
were arrested that caused you to be terminated from 
14 
that car. 
15 
Mr. Epstein? 
15 
So Mr. Epstein was kind enough to give her the 
16 
A. No. 
16 
17 
Q. Were you terminated from Mr. Epstein's 
17 
The rest of the stuff is. was mainly lawyer 
18 
employment? 
18 
stuff that you can't understand. But basically that was 
19 
A. Yes. 
19 
it. And that it was a part that I think I can -- I 
20 
Q. Did you promise to pay him back some money? 20 
would says. it was more or less that I will not sue him 
21 
A. Yes. 
21 
later or he cannot sue me for any reasons or -- and it 
22 
Q. Did you make all the payments? 
22 
was like a confidentiality issue in that separation 
23 
A. Yes. I did. 
23 
agreement. 
24 
Q. When was the last time you made a payment? 
24 
Q. And do you understand that in this instance 
25 
A. I made a payment immediately. the same 
25 
you are subpoenaed under the power of the Court? 
Page 38 
Page 40 
1 
payment. same amount. 
1 
A. Absolutely. 
2 
Q. The full amount? 
2 
Q. And that would include matters that would 
3 
A. Full amount. 
3 
otherwise be confidential? 
4 
Q. Okay. It wasn't a payment plan? 
4 
A. Can you repeat that again? 
S 
A. No. 
5 
Q. Yeah. Do you understand that because you're 
6 
MR. WILLITS: I don't have any other 
6 
under subpoena by the Court to give your testimony. --
7 
questions. You want to take a short break? 
7 
A. Today. 
8 
MR. CRITTON: Would you like to take a short 
8 
Q. -- truthfully — yes. 
9 
break? 
9 
A. Uh-huh. 
10 
THE WITNESS: I'm fine. 
10 
Q. That the confidentiality agreement would not 
11 
VIDEOGRAPIIER: Off the record. 10:56. 
11 
control: the Court's subpoena --
12 
(Brief recess.) 
12 
A. Oh. yeah. 
13 
CROSS EXAMINATION 
13 
Q. -- controls? 
14 
BY MS. EZELL: 
14 
A. I understand that. 
15 
Q. I'm Catherine Ezell. I want to ask you a few 
15 
Q. You mentioned Ghislaine Maxwell did photo 
16 
questions about some things that came up during your 
16 
shoots and kept an album? 
17 
deposition. your earlier questioning in this deposition. 
17 
A. Yes. She was fanatic about photographs --
18 
A. Okay. 
18 
camera. She had a whole bunch of different cameras am 
19 
Q. The book of policies that you mentioned that 
19 
she took all the pictures all over. 
20 
was there by the time you left. I just wanted to 
20 
Q. Did you ever observe her doing a photo shoot 
21 
clarify. was that done by somebody in Palm Beach to be 
21 
of I? 
22 
used by different households in Palm Beach or was it 
22 
A. No. 
23 
done by someone employed by Jeffrey Epstein to apply to 23 
Q. Did you ever observe her doing a photo shoot 
24 
all the homes he -- 
24 
of any of the other young women whose names you 
25 
A. Yes. 
25 
mentioned? 
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1 
A. Young woman? 
1 
M.? Obviously the tape preserves it. We're not 
2 
Q. Yes. 
2 
asking the tape gentleman to edit it. 
3 
A. No. I can't remember. I know that she went 
3 
MS. EZELL: Right. 
4 
out and took pictures in the pool because later on I 
4 
MR. BERGER: So how is it preserved that 
5 
would see them at the desk or at the house. 
5 
means your client's full name? 
6 
And nude -- 99.9 percent of the time they were 
6 
MS. EZELL: Well. we had just agreed in 
7 
topless. They were European girls. They were — 
7 
previous depositions that that's the way it would 
8 
Q. You stated that you believe l.'s name was', 
8 
read. The written transcript would not have the 
9 
but you weren't sure? 
9 
full name. but would just have the initials. 
10 
A. Not sure. 
10 
MR. BERGER: I'm not so sure that constitutes 
11 
Q. Could it have been? 
11 
an identification by Mr. Alessi that's going to be 
12 
A... yeah. Yeah. Could have been. 
12 
clear. But this is the first deposition I've 
13 
Q. I want to show you a picture and have it 
13 
attended, so I'm not sure if I'm -- if what I'm 
14 
marked as an Exhibit to this deposition. 
14 
saying has been dealt with or not. 
15 
MS. EZELL: And did we have the agreement 
15 
MR. MERMELSTEIN: I think we're working on 
16 
beforehand that we've been having all along that 
16 
good faith. Mr. Critton is agreeing that the 
17 
we're just using initials and not names? 
17 
name -- and I don't think anyone's going to come 
18 
MR. WILLITS: My client has waived the 
18 
back later and say, oh. you meant Vince Robinson or 
19 
confidentiality as to herself. But I certainly 
19 
anything like that, so... 
20 
agree as to everybody else. 
20 
MR. BERGER: Well. I'm not — I'm not talking 
21 
MR. LANGINO: As do I. 
21 
about Mr. Critton. Bob Critton I have the full 
22 
MS. EZELL: Is that okay? 
22 
trust in. I'm just talking about a jury watching 
23 
MR. CRITTON: That's what we agreed to on the 23 
this or reading this transcript believing that 
24 
last. 
24 
Mr. Alessi has accurately identified one of these 
25 
MS. EZELL: Right. 
25 
victims. That's all. I don't know if you've all 
Page 42 
Page 44] 
1 
MR. CRITTON: For the court reporter. at 
1 
thought about that. 
2 
least, in terms of the — I guess in terms of the 
2 
MS. EZELL: Well, for one thing. the jury 
3 
transcript she gives to us. if you would just use a 
3 
might, if they're -- if they're hearing or reading 
4 
first initial and a last initial. 
4 
his testimony, they most likely would be seeing the 
5 
MR. WILLITS: So when you ask about'.. it 
5 
video, which would have the full name. Unless the 
6 
would ben is what the court reporter would 
6 
Judge allows us to block out names and we haven't 
7 
write down? 
7 
come to that point. 
8 
MS. EZELL: Right. 
a 
MR. MERMELSTEIN: I think the idea at trial. 
9 
MR. CRITTON: But make sum everybody uses the 
9 
. if it's read to the ju would become then 
10 
full name, because that way we'll have two 
10 
It would be read as M. But if it flied 
11 
initials. 
11 
with the Court. this transcript, it will be 
. 
12 
MR. WILLITS: When they speak. but she's going 
12 
and that way it doesn't have to be redacted. 
13 
to write it down as initials. Is that what you're 
13 
MR. WILLITS: As I also understood it, if 
14 
saying? I'm confused about everything. 
14 
there would be any question at all. we could simply)
15 
MR. CRITTON: The mason is, is there may be 
15 
ask the court re orter and she would say. according 
16 
25. you know, there may be throe IM. So if you 
16 
to my notes. 
is 
not -- or 
17 
just mention land it just shows up as a ... it 
17 
whatever her notes s 
s e be the fina 
18 
won't make sense. So ergo you need to do that 
18 
authority? 
19 
But 
his client. she gets the 
19 
MS. F7FI I • Well, she would certainly have 
20 
whok megillah. 
20 
that record. 
21 
MR. WILLITS: Right. 
21 
MR. CRITTON: You could listen to the tape. 
22 
MR. BERGER: How is it preserved that we're 
22 
It would be pretty easy. I think we're making it a 
23 
talking about your client? You gave her full name 
23 
lot more complicated than it need be. 
24 
a minute ago. How is it preserved if she's -- the 
24 
MR. WILLITS: For once. I agree. 
25 
court rcponcr is going to change the full name to 
25 
MR. CRITTON: I think it will he all iiolii
, . 
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1 
MS. EZELL: I'm going to ask --I don't know 
1 
THE WITNESS: Could have been. But, you know 
2 
whether you've still been serially designating 
2 
I am not — [don't think I am a very good judge of 
3 
Exhibits or whether we're doing them separately for 
3 
ages. If you ask me how old you are. I really 
4 
deposition. 
4 
couldn't tell you. 
5 
MR. CRITTON: I think we cannot trust that 
5 
MR. CRITTON: Kathy thinks she's 25. 
6 
people will do them serially. I'd do them with 
6 
MS. EZELL: In my dreams. 
7 
each one. 
7 
THE WITNESS: Now, again. I must tell you. I 
8 
MS. EZELL: Then would you mark this, please, 
8 
was never told to check any i.d.s on any of the 
9 
as Exhibit I to this deposition. 
9 
people who work at the house. 
10 
And I'm just going to state on the record that 
10 
BY MS. EZELL: 
11 
I will keep that original. We will not attach it 
11 
Q. I understand that. And. so. I think I'm just 
12 
to the deposition. 
12 
trying to establish that you didn't consider it part et 
13 
(Exhibit number 1 was marked for 
13 
your job description to worry about or consider the 
14 
identification purposes and retained by Counsel for the 
14 
ages --
15 
Plaintiffs.) 
15 
A. No. 
16 
THE WITNESS: Yes. that's — 
16 
Q. — of the young women that came there? 
17 
BY MS. EZELL: 
17 
A. Absolutely not. Absolutely not. 
18 
Q. Can you identify that — the young woman in 
18 
Q. And. so. you never really focused on that or 
19 
those pictures? 
19 
particularly thought about it if they seemed young" 
20 
A. Yes. 
20 
MR. CRITTON: Form. 
21 
Q. Who is it? 
21. 
THE WITNESS: I don't — I didn't see that 
22 
A. That's I. — I. Now that you says., that 
22 
many young girls. you know, young. underage girls 
23 
is M. definite, a hundred percent. 
23 
at the house. I never saw except the two girls 
24 
MR. CRITTON: Let me just note my objection. 
24 
that I mentioned that I think it was undera e was 
25 
as I did in A. Rod's deposition or Mr. Rodriguez's 
25 
for sure because 
Page 46 
Page 48 
1 
deposition. that I know you're going to confiscate 
1 
2 
Exhibit number I. I think it's inappropriate. I 
I 
3 
think I should be allowed to have a copy of 
4 
Exhibits that are being used in deposition. But 
5 
I'll file a motion with the Court so we don't get 
5 
That's the onl girl that I knew she wasyoung 
6 
into a pulling match over your Exhibits. 
6 
becau 
7 
MR. BERGER: I would ask that the court 
I 
But she was not a 
8 
reporter initial that. 
8 
massage therapist. She will go for dinner. And 
9 
MS. EZELL: Sure. 
9 
the • will o for the movies a 
10 
Oh. you did? 
11 
MR. WILLITS: She marked it. 
12 
MR. BERGER: Did she put her initials or did 
12 
That's the only girl that I know that it 
13 
she just put a number or a letter? 
13 
was -- I would says. underage. 
14 
MR. CRITTON: She's nodding that she did 
14 
BY MS. EZELL: 
15 
everything that she usually does, which means. 
15 
Q. Okay. Did — who told you that M. was a 
16 
initials, date and number. 
16 
massage therapist? 
17 
MR. MERMELSTEIN: You can talk. 
17 
A. Nobody. 
18 
MR. WILLITS: But when you talk, use your 
18 
Q. Did you assume that she was a massage 
19 
initials. 
19 
therapist because you were told she was coming to give I 
20 
BY MS. EZELL: 
20 
massage? 
21 
Q. How old did you think ■. was at the time she 21 
A. No. I assumed she was a massage therapy 
22 
began coming to Mr. Epstein's home? 
22 
because I was — I drove Ms. Maxwell to Mar-a-lago. 
23 
A. She could have been 17. IS, 19. 
23 
Donald Trump's residence. And I wait in the car while 
24 
Q. Could she have also been 15? 
24 
Ms. Maxwell got a -- I think it was a facial or massage. 
25 
MR. CRITTON: Form. 
25 
I don't know. But that day I remember this girl... 
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. 
walking down from the main lobby towards the spa of 
1 
there. So I would says. between three months maybe 
2 
Mar-a-lago. And I was driving Ms. Maxwell up. up the 
2 
before I left. And I think I kft at the end of the 
3 
ramp. It's a little ramp there. 
3 
year. so it could have been — I remember it was a very 
4 
And Ms. Maxwell says. stop. And she went and 
4 
hard day because I had to wait in the sun outside in a 
5 
talked to -- she went inside. 
5 
convertible and I was dying. waiting for an hour for 
6 
And that afternoon around 5:00 I saw .. came. 
6 
Ms. Maxwell. I think it was in the summer of 2002. 
7 
She came to the house already. so she was there already. 
7 
Q. And if I remember correctly. you left in 
8 
That was the first day I knew. And then she would come 
8 
November or December of 2002? 
9 
regularly. 
9 
A. Yes. 
10 
Q. Did you ever meet any of l.'s family? 
10 
Q. So that might have been perhaps July or August 
11 
A. No. I think she was -- one time I think her 
11 
of 2002? 
12 
father drove her there. And I net -- I don't know if it 
12 
A. Ult-huh. 
13 
was the boyfriend or husband or -- but he had to wait. 
13 
Q. And, so. as ! understand it. you only saw 
14 
make him wait outside while she was at the house. 
14 
come to that house during the last three months of Nom 
15 
Q. Do •ou know the name or recognize the name 
15 
time at Mr. Epstein's? 
16 
16 
A. Yes. 
17 
A. I think it was him. 
17 
Q. Do you have any -- any sense or can you 
18 
Q. That was her -- 
18 
approximate how many times she came? 
19 
A. I know he had an old beat-up car 
19 
A. I cannot give you a number. but I would says, 
20 
I know it was very old car that I make him 
20 
two. three times a week. 
21 
wait on the street one time. I make him come out of the 
21 
Q. You mentioned that sometimes you would have tc 
22 
driveway because we have to move some cars around. 
22 
call these massage therapists in the middle of the 
23 
Q. Did there ever come a time when 
23 
night. Did you ever have to call.. for Mr. Epstein in 
24 
was welcome in the kitchen? 
24 
the middle of the night? 
25 
A. I think he came once in the kitchen, but 
25 
MR. CRITTON: Form. 
Page 50 
Page 52 
1 
Ms. Maxwell told me to get him out. 
1 
THE WITNESS: No. No. 
2 
Q. Did she tell you why? 
2 
BY MS. EZELL: 
3 
A. No. She didn't —I guess she didn't want to 
3 
Q. Did there come a time while you were there 
4 
become, you know, everybody -- because some of these 
4 
that M. stayed in the house? 
5 
people came with their husbands and they wait outside. 
5 
MR. CRITTON: Form. 
6 
And I guess she didn't want this to become a norm for 
6 
THE WITNESS: I don't think so. I cannot 
7 
everybody to bring their companions while they have -- 
7 
remember. No. 
8 
they will do a massage for her. 
8 
BY MS. EZELL: 
9 
Q. Darin the time you were them. did you ever 
9 
Q. How many bedrooms were there upstairs? 
10 
know of 
bringing any other girls to 
10 
A. One. two. three — one. two. three, four — 
11 
Mr. Epstein? 
11 
four — so that would be five. five bedrooms. 
12 
A. No. I knew that sometimes I saw I. bring 
12 
Q. Five. And. so. would one have been 
13 
other girls with her, not—. 
13 
Mr. Epstein's bedroom? 
14 
Q. Do you remember the names of any of those 
14 
A. Yes. His quarters was big. huge quarters. 
15 
girls — 
15 
Q. Sort of a suite? 
16 
A. No. I don't. 
16 
A. Yeah. And he has -- this is the room. His 
17 
Q. -- that'. brought? 
17 
bathroom was here and her bathroom was here. The main 
18 
A. That was at the end of my stay there. No. 
18 
room was here. And we have -- it was two sets of doors 
19 
That was a very -- at the very end of the last month of 
19 
before — two sets of double doors before you can go 
20 
my stay. 
20 
into the suite. There was one on top of the stairway 
21 
Q. Did you give -- I don't believe I asked you. 
21 
and one in the middle of the hallway. And then you wall, 
22 
but if I did. forgive me. Did you give us an 
22 
into the — into the suite. 
23 
approximate year in which you were taking Ms. Maxwell tc 2 3 
Q. Okay. And you -- you just put a red eight by 
24 
Mar-a-lago and saw ■. for the first time? 
24 
II folder in front of you? 
25 
A. That was at the — at the end of my stay 
25 
A. Yeah. 
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1 
Q. And you said. "this is the room." 
1 
A. Yes. 
2 
Do you mean that is Mr. Epstein's room? 
2 
Q. And who. if anyone. stayed in the blue room? 
3 
A. And Ms. Maxwell. 
3 
A. Yes. many. 
4 
Q. And Ms. Maxwell? 
4 
Q. Guests who would come and go? 
5 
A. Yes. 
5 
A. (Nods head.) 
6 
Q. And his bath was on one side and hers was on 
6 
Q. And in the red room? 
7 
the other? 
7 
A. Same thing. 
8 
A. Yes. Yes. ma'am. 
8 
Q. Again, guests? 
9 
Q. So did she not have a separate bedroom? 
9 
A. Yes. 
10 
A. Ms. Maxwell? No. Sometimes she slept in a 
10 
Q. And did you say that 
did spend nights 
11 
different bedroom. Don't ask me why. 
11 
there? 
12 
Q. Okay. But generally at that point in time she 
12 
A. No. not that I remember. 
13 
was still -- 
13 
Q. She never did? 
14 
A. Yeah. 
14 
A. Not that I remember, no. Because she was not 
15 
Q. -- sleeping in. for most nights. the same 
15 
there until the whole len, th of time that I work for 
16 
bedroom -- 
16 
Mr. • tem. 
17 
A. Yeah. 
17 
18 
Q. -- as Mr. Epstein? 
18 
19 
A. Uh-huh. 
19 
Q. And that's 
20 
Q. And then there was the service quarters. the 
20 
A. 
21 
service department? 
21 
Q. You mentioned Dr. Eva Anderson? 
22 
A. The service quarters before we moved down tc 22 
A. Uh-huh. 
23 
the other house, it was in one corner of the property in 23 
Q. I believe you said she had been a girlfriend 
24 
the second floor. 
24 
of Mr. Epstein's --
25 
Q. And what -- what other bedrooms were there? 
25 
A. Yeah. 
Page 54 
Page 56 
1 
A. In the service quarters? 
1 
Q. — before --
2 
Q. No. 
2 
A. I understand. 
3 
A. In the total amount? 
3 
Q. — Ms. Maxwell? 
4 
Q. On the second floor. 
4 
A. Yeah. 
S 
A. On the second floor. 
S 
Q. And were there times when she would stay in 
6 
Q. Other than -- 
6 
the house? 
7 
A. It was the -- it was a pink room. we called 
7 
A. Yes. 
8 
the pink room. We called the blue room. And the parse( 
8 
Q. Would she stay in the house when Ms. Maxwell 
9 
room. We call a parrot room because there was a crazy 
9 
was there as well? 
10 
designer. all full of parrots. It look like you were in 
10 
A. Yes. 
11 
the jungle. But that was changed. so that became the 
11 
Q. And did she have sort of a regular room there? 
12 
blue room. 
12 
A. Let me repeat. Can you repeat that again, the 
13 
So it was the blue room, the red room and the 
13 
questions before? Because I think I says. yes. when 
14 
pink room. That was the main guest. for the main guest 
14 
Eva — when Maxwell was there. I not think -- I can't 
15 
rooms. 
15 
remember Eva being there. She was there for a little 
16 
Then it was my room and we have like a little 
16 
bit because they become friends after that and they have 
.17 
sitting area for ourselves. for myself. 
17 
dinners and lunches and she would come- because Eva 
18 
And upstairs there were one, two, three. four. 
18 
19 
five. six. six bathrooms. 
19 
2 0 
Q. During the time you were there who, if anyone. 
20 
So they become friends. And -- but I don't 
21 
stayed in the pink room? 
21. 
think she ever slept at the house again because she had 
22 
A. Many people. 
22 
her own house in Palm Beach. 
2 3 
Q. Guests? 
23 
Q. When you first went there to work would she 
24 
A. Yes. 
24 
sometimes sleep at the house? Was that before she was 
25 
Q. Who would come and ...,.‘i? 
25 
married' 
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Page 57 
A. Yes. Before she was married, yeah. They 
split up and she went her own way. 
Q. Did she marry a Glen Dubin (phonetics)? 
A. That's correct. And Mr. Dubin used to come to 
1 
2 
3 
4 
Page 59 
Q. And they called him uncle, you said? 
A. They called him uncle. 
Q. Did you ever leant what 
did for 
a living? 
5 
the house. too. 
5 
A. No. 
6 
Q. Do you know, was 
ever one of the 
6 
Q. Have you had any occasion to see him since the 
7 
massage therapists before she became an assistant? 
7 
time you left Mr. Epstein's employ? 
S 
A. I don't know if she was a massage therapist. 
8 
A. No. 
9 
I don't remember setting up a massage table for her. I 
9 
Q. And you don't — do you have any idea where he 
10 
think she was an assistant. And she would call -- at 
10 
is? 
11 
the end of my stiiwas -- tried to pull aside from my 
11 
A. I have no idea. I remember an incident, one 
12 
obligations and 
was doing all the phone calls and 
12 
time the — I went to pick her up at Royal Paint Beach 
13 
all the arrangement and all the looking out for these 
13 
and she was crying and I went and knock at the door ant 
14 
girls for the -- for massage therapists. They were 
14 
she was crying. And she says. well. -- I think it was 
15 
constantly. 
15 
Tony or — because she used to live with these other 
16 
Q. When did that role get transferred from you to 
16 
guys. too. There were two guys and her or two couples. 
17 
Ms. Maxwell. the role of looking after girls and calling 
17 
I don't know the arrangements there. But I remember 
18 
the girls? 
18 
that she told me the -- Tony or her boyfriend had got 
19 
A. I didn't look after -- out for girls. 
19 
mad and ripped the furniture, he cut the furniture in 
20 
Ms. Maxwell was the one that recruit -- I remember one 20 
pieces and he even broke the screens. Because I was -. 
21 
occasion or two occasions she would says to me. John. 
21 
when I went into to knock the door, the screen was all 
22 
give me a list of all the spas in Palm Beach County. 
22 
ripped up like it was cut. 
23 
And I will drive her from one to the other one to PGA 
23 
And she told me that he got mad at -- I don't 
24 
and Boca. And she will go in. drop credit cards -- not 
24 
know what happened. I never saw him in there. 
25 
credit cards, but business cards, and she come out. And 25 
Q. Did she tell you he had hit her or beaten her 
Page 58 
Page 60] 
1 
then we go to — she will recruit the girls. Was 
1 
at all? 
2 
never -- never done by me or Mr. Epstein or anybody 
2 
MR. CRITTON: Is the she..., 
3 
else, that I know. 
3 
MS. P7I7T T • Yes. Thank you. 
4 
I don't know about 
because 
was 
4 
BY MS. EZELL: 
5 
there at the last. last — probably last weeks 
5 
Q. Did you ever see during the time you were 
6 
stay there. So I cannot say anything about 
. 
, 
6 
there photographs of,. in the house, the Epstein house 'I 
7 
Q. Was there any point in time -- well, let me 
7 
■in 
the Epstein house? 
S 
ask you this way: Did -- you said sometimes you would 
S 
A. I don't think so. I don't think so. 
9 
call the girls to come -- 
9 
Q. Did you ever see photographs of 
in 
:0 
A. Uh-huh. 
10 
Ms. Maxwell's albums? 
:1 
Q. — to give them massage. And sometimes 
11 
A. No. 
:2 
Ms. Maxwell would? 
12 
Q. At the time you were employed by Mr. Epstein. 
:3 
A. Yeah. 
13 
were there any hidden cameras? 
:4 
Q. Did there come a time when she took that over 
14 
A. No. 
:5 
entirely from you -- 
15 
Q. You do know that he installed some after you 
16 
A. No. 
16 
left. correct? 
17 
Q. — or that continued -- 
17 
MR. CRITTON: Correct. 
18 
A. That's continued. 
18 
THE WITNESS: I don't know. 
19 
Q. — until you left? 
19 
BY MS. EZELL: 
20 
A. Yeah. 
20 
Q. Wasn't there a camera involved in the incident 
21 
. Do ou remember, is Jeffrey Epstein godfather 
21 
that -- the incident in which you took money from 
22 
t 
' 
22 
Mr. Epstein? 
23 
A. I don't know if he godfather. I don't 
23 
A. Yeah. Yes. But I don't know if he install it 
24 
remember that. But he was very fond to these children. 
24 
or not. That's what he told me. 
25 
the children. 
25 
Q. Okay. 
_ 
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1 
A. But we settled that completely out of Court. 
1 
the pool. But other than that. they were regular 
2 
It was a. I will pay you back. I'm sorry. I made a 
2 
massages. 
3 
mistake. And that was the end of it. 
3 
Q. Did you know a young lady name who woult 
4 
Q. I understand. And, so. you have no idea then 
4 
come to the home? 
5 
where the cameras were -- 
5 
A. I She was also English? 
6 
A. No idea. 
6 
Q. I don't know? 
7 
Q. — installed? 
7 
A. I think I remember a t 
8 
A. I was never back at the house after that. 
8 
Q. And was she one that came to give massages? 
9 
Q. Okay. I just want to ask you if you recognize 
9 
A. g• g• It 
II 
10 
any other names. 
10 
When you deal with all these girls' names. I 
II 
Do you recognize a namell. who was a friend 
11 
think g was. yes. she was a massage therapist. But I 
12 
of Ms. Maxwell? 
12 
think she used to --I could be wrong. but I think she 
13 
A. II.? Yes. 
13 
live in New York and she travelled with them once in a 
14 
Q. And was she English? 
14 
while. 
15 
A. English. And she travel all the time with 
15 
Q. Were some of the women that travelled with 
16 
them. Not -- I would says. not a hundred percent of the 16 
Mr. Epstein models, to your understanding? 
17 
time, but she travel maybe 60.70 percent of the time 
17 
A. Very beautiful models. Very nice. Very. 
18 
for a period of years. 
18 
very — most of them were models. models. 
19 
MR. CRITTON: So I'm clear, is it M? 
19 
Q. Did ac r know anyone named 
? 
20 
MS. EZELL: ■ 
20 
A. No. M. no. No. 
21 
THE WITNESS: 
21 
Q. Jean Luc Bruhel? 
22 
MS. EZELL: I 
o 
I'm not sure. 
22 
A. Jean Luc? Jean Luc was a guy. 
23 
MR. CRITTON: Thank you. 
23 
Q. I know that. Did you know him? 
24 
BY MS. EZELL: 
24 
A. Yes. I know him. 
25 
Q. Did she have a regular room in which she 
25 
Q. Who was he? 
Page 62 
Page 64 
1 
stayed — 
1 
A. He was -- he -- matter of fact. I went to his 
2 
A. Yes. 
2 
house a couple of times with Mr. Epstein. And he was a 
3 
Q. — when she was there? Which one was that? 
3 
friend of Mr. Epstein. He was a -- he was French. I 
4 
A. That was the pink room. When she came. she 
4 
think. French. And he was — as far as I know. he had a 
5 
stay in the pink room. 
5 
model agency in Miami. one of the big model agencies ia 
6 
Q. And do you have any idea what her relationship 
6 
Miami. 
7 
to Ghislainc Maxwell was? 
7 
Q. And do you know whether or not Mr. Epstein hat 
8 
A. I understand she was her assistant. And she 
8 
any interest in that model agency? 
9 
will answer the phones. And she will go shopping with 
9 
A. No. No idea. 
10 
her sometimes. And she will -- basically they were 
10 
Q. Do you know whether or not they were business 
11 
friends. I don't think she — I don't think she was a 
11 
partners in any way? 
12 
massage therapist ever. I don't think she ever was a 
12 
A. No. I don't. 
13 
massage therapist. 
13 
Q. Did he ever come over for massages? 
14 
Q. Do you know whether the young women that you 
14 
A. He came to the house couple times. I think 
15 
referred to as massage therapists came there to give 
15 
he — it might have been occasions where he stay 
16 
massages to both Mr. Epstein and Ms. Maxwell? 
16 
overnight. 
17 
A. Yes. 
17 
MR. CRITTON: Move to strike as 
18 
Q. And do you know ialwas ever included in 
18 
non-responsive. to at least your question. 
19 
that activity? 
19 
BY MS. EZELL: 
20 
A. I have no idea because when they went upstairs 
20 
Q. You indicated that you had been to his home. 
21 
they shut all the doors and it was absolutely pitch 
21 
So did he have a home in Palm Beach? 
22 
black in the room. It was no -- we never saw any 
22 
A. No. He has a home in Miami Beach. 
23 
massages done. Occasionally we saw a massage. like. if 
23 
Q. Miami Beach. 
24 
Ms. Maxwell wants a massage by the pool. I would set up 24 
Did you know anyone named. or 
? 
25 
the table by the pool and they will have a massage at 
25 
A. ■? 
- 
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Page 65 
Q. ■ 
A. It sounds familiar. but I cannot tell you for 
sure. 
Q. You mentioned some of the chefs. You didn't 
mention -- 
A. There was — 
Q. — Ryan Dion (phonetics). Was there someone 
there named Ryan Dion? 
A. No. It was a kid from New York. His name was 
Don Perry. Perry? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
Page 67 
Q. And do you know what he did for a living? 
A. He has -- I knew he had a printing company. 
printing the big logos. the big movie projection 
company. 
Matter of fact, my son. when he graduate. he 
went to work for Mark for about couple months in New 
York as a -- as a -- as a trainee. I don't think he 
ever got paid. but he -- he was trying to learn the 
business and Mark gave hint a job. That was for few 
months. 
:1 
Q. And would he travel with Mr. Epstein? 
11 
Q. How often would Mark Epstein come to Miami.
:2 
A. Yeah. 
12 
A. Not too often. Not too often. 
:3 
Q. Now, when -- before the addition out back was 
13 
Q. When he came. do you know, did he participate 
:4 
done. I believe you said the chefs would stay back there 
14 
in having the massages? 
:5 
sometimes? 
15 
A. No. 
:6 
A. Uh-huh. 
16 
MR. CRITFON: Form. 
:7 
Q. Before then, where did the chefs stay? 
17 
THE WITNESS: Never. 
18 
A. In the blue room in the back, the one close to 
18 
BY MS. EZELL: 
19 
mine. 
19 
Q. He did not? 
20 
Q. Did you ever meet any of Mr. Epstein's family: 
20 
A. Neve•. 
21 
his brother, for instance? 
21 
Q. And how do you know that? 
22 
A. Absolutely. yes. 
22 
A. Because it was never --I was never told to 
23 
Q. And what was his brother's name? 
23 
set up a massage in any of the rooms for Mark or his 
24 
A. Mark Epstein. 
24 
mother. They were not too close. 
25 
Q. Would he come and visit regularly? 
25 
Q. Mark and Jeffrey Epstein are not too close? 
Page 66 
Page 68 
1 
A. Regularly. 
1 
A. I would says. they were not. I don't think 
2 
But I was more involved with her mother. I 
2 
so. That was my opinion. 
3 
took care of her mother. Mr. Epstein's mother. She was 
3 
Q. Do you know the name Daniel Estes? 
4 
a very ill lady. I don't know if she's still alive or 
4 
A. No. 
5 
not, but I lost contact. 
5 
Q. Do you know the name Matt Groning (phonetics 
6 
Q. How often would she come to visit? 
6 
— Groning? 
7 
A. She didn't come to visit too often. She had 
7 
A. No. 
8 
an accident, a very bad accident. She lost her trachea, 
8 
Q. I think you mentioned Mr. Wexler? 
9 
so she had a -- how they call the — the thing they put 
9 
A. I believe so. 
10 
them in your neck to talk? 
10 
Q. That you knew him early on? 
11 
Q. Sort of a voice box. I don't know the 
11 
A. Yes. 
12 
technical name. 
12 
Q. And did some work for him? 
13 
A. I don't know the technical name. -- 
13 
A. Also his mother. I work on his mother house 
14 
Q. Right. 
14 
in Palm Beach. 
15 
A. — but they open her throat and she had this 
15 
Q. Did he also have a home in Palm Beach? 
16 
thing to talk and she had to cover her throat to talk. 
16 
A. Before — he had a home in Palm Beach before I 
17 
And I was more involved with her than her own 
17 
went to work for his mother. So I never work on his 
18 
kids. I took her to Miami for the operation. I was 
18 
home. But I work on his mother home. I don't know if 
19 
there for the operation. And she -- we have a lot of 
19 
it was his home or that was used to -- Mrs. Wexler used 
20 
fun with her. I mean. she -- she was a very good lady. 
20 
to live there. 
21 
Q. Now, other than Mark Epstein. were there any 
21 
Q. Did he come over to the Epstein home 
22 
other brothers and sisters? 
22 
frequently? 
23 
A. No. lie only has one brother that I know. 
23 
A. Occasionally. 
24 
Q. And where does he live? 
24 
Q. Did he ever participate in the massages? 
25 
A. Ile lives in New York. 
25 
A. No. 
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Page 71 
1 
MR. CRITTON: Form. 
1 
Diane's secretary. she stay there for a week with her 
2 
THE WITNESS: No. not that I can remember. 
2 
kids and we took care of her. 
3 
BY MS. EZELL: 
3 
Who else? Mr. Trump. That's a celebrity. 
4 
Q. Do you know if he and Mr. Epstein were 
4 
Mr. Robert Kennedy. Junior. Mr. Frederick Fekkai. 
5 
involved in any businesses together? 
5 
Q. Who is that? 
6 
A. Mr. Epstein. I never knew what businesses he 
6 
A. Fekkai. Frederick FeIckai, the famous 
7 
was involved. He will — I was completely shut off of 
7 
hairstylist. Who else? I don't think I can remember 
8 
all of the business. except for the office. transfer of 
8 
anymore. 
9 
communications or faxes. But I have no idea of the 
9 
Q. David Copperfield. the magician? 
10 
relationship with other business partners. 
10 
A. No. I never saw him. 
11 
Q. Did you ever have to deal with his -- the 
11 
Q. You never saw him. 
12 
office in New York with someone named Lesley in Nem 12 
Now, would these — the people that you named 
13 
York? 
13 
were all people that you saw visiting in the home? 
14 
A. The secretary? 
14 
A. Yes. Also was a Noble Prize winners. the -- I 
15 
Q. Yes. 
15 
can't remember his name. It was an old gentleman. I lc 
16 
A. Yeah. I would call -- I would call Lesley 
16 
was a Noble Prize, chemistry. I think, or mathematics. 
17 
almost every day or other secretaries. they live in New 
17 
There was a couple -- a couple of those. very -- also. 
18 
York. Basically it came a point when Mr. Epstein will 
18 
we had at one time at the house. it was a reunion of 
19 
call New York and New York call me to do things for 
19 
very Noble Prize winners. But I don't know. They're 
20 
Mr. Epstein. But he was on the phone or busy or 
20 
not famous. I guess. I can't remember their names. 
21 
something and he would call the office and the office 
21 
Very important people. 
22 
will send me an e-mail or call me or — it was a 
22 
Q. Was that a dinner or a reception? 
23 
constant report with the office in New York. 
23 
A. I think it was a lunch. 
24 
Q. And did you in turn sometimes call New York tc 24 
Q. A lunch. 
25 
get a message to Mr. Epstein? 
25 
President Clinton. did you ever--
Page 70 
Page 72] 
1 
A. Yes. 
1 
A. I met President Clinton on Mr. Epstein's plane 
2 
Q. Did you ever overbear Mr. Epstein talking to 
2 
in the last. I think it was the last month or just 
3 
any people that you would consider celebrities? 
3 
before I left — I left. I met President Clinton in 
4 
A. Yes. I knew some — many celebrities. 
4 
Miami at his plane. We drove him to Miami. 
5 
Q. Who -- what celebrities did you understand 
5 
Q. And do you know. was that a trip -- were they 
6 
that he spoke with? 
6 
going on a trip to Africa? 
7 
A. He spoke to it? 
7 
A. I hear about it. but it was not when I was 
8 
Q. Yes. 
8 
there. 
9 
A. I don't know who he spoke to because I never 
9 
Q. So that was not the time that you drove --
10 
listen to his conversations. But I saw guests at the 
10 
A. No. I was already out. 
11 
house that were celebrities. 
11 
Q. And Kevin Spacey. did you ever meet him? 
12 
Q. Who did you see at house? 
12 
A. No. I hear about it on the news. but I never 
13 
A. Many. It was senators. It was Senator 
13 
met him. 
14 
Mitchell. George Mitchell. It was Prince Andrew. It 
14 
Q. Were Prince Andrew and Princess Sarah friends 
15 
was Princess Sarah. 
15 
of Ms. Maxwell? 
16 
Q. Princess? 
16 
A. Both of them. 
17 
A. Sarah. the wife of Andrew. 
17 
Q. Both Ms. Maxwell and Mr. Epstein? 
18 
Q. Sarah Ferguson? 
18 
A. Yeah. 
19 
A. Ferguson. 
19 
Q. Did -- did they ever have massages when they 
20 
And it was a couple Misses. Misses Yugoslavia. 
20 
were there? 
21 
Miss Germany that I don't even know the names. But they 21 
A. Prince Andrew did. I think Sarah was there 
22 
were a lot of queens and other famous people that I 
22 
only once and for a short time. I don't think she slept 
23 
can't remember. It was a very famous lawyers that I'm 
23 
in there. I cannot remember. I think she was visiting 
24 
sure you know. Alan Dershowitz. who spend at the house 
24 
Wellington and she came to the house and we met her. 
25 
couple times. And he slept there. Ile — Princess 
25 
But Prince Andrew. yes. Prince Andrew spent weeks with 
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Page 73 
Page 75 
1 
us. 
1 
MR. LANGINO: Go ahead. Sure. 
2 
Q. Where would he sleep? 
2 
BY MS. EZELL: 
3 
A. In the main mom, the main guest bedroom. 
3 
Q. You said that you set up the massage tables. 
4 
That was the blue mom. 
4 
And would you also set up the oils and the towels? 
5 
Q. And, so. when he would come and stay. during 
5 
A. Yes. ma'am. 
6 
that time would he frequently have massages? 
6 
Q. And I think I read one time you said they used 
7 
MR. CRITTON: Form. 
7 
40 or 50 towels a day? 
8 
THE WITNESS: I would says. daily massages. 
8 
MR. CRITTON: Form. 
9 
They have a daily massage. 
9 
THE WITNESS: That's correct. There was a 
10 
BY MS. EZELL: 
10 
tremendous amount of work in the house, especially 
I
Q. Was it sometimes more than one a day? 
11 
laundry towels, because they were -- we have 
12 
A. I can't remember if he had more than one, but 
12 
towels, piles of towels. And they use in the pool. 
13 
I think it was just a massage for him. We set up the 
13 
There was a lot of people in the pool and there 
14 
tables and -- 
14 
were a towel that went in the floor, we have to go 
15 
Q. Do you have any recollection of M. coming to 15 
and pick it up. wash it. So it was -- it was a lot 
16 
the house when Prince Andrew was there? 
16 
of towels. yes. 
17 
A. It could have been, but I'm not sure. 
17 
BY MS. F7FI I • 
18 
Q. Not sure. When Mr. Dershowitz was 
18 
Q. And did you ever have occasion to go upstairs 
19 
visiting. -- 
19 
and clean up after the massages? 
20 
A. Uh-huh. 
20 
A. Yeah. uh-huh. 
21 
Q. — how often did he come? 
21 
Q. Did you ever find any vibrators in that area? 
22 
A. He came pretty — pretty often. I would says. 
22 
A. Yes. I told him, yes. 
23 
at least four or five times a year. 
23 
MS. F7FI I • And did you ask that? I'm sorry. 
24 
Q. And how long would he stay typically? 
24 
MR. CRITTON: Yes. 
25 
A. Two. three days. 
25 
MS. F7FI I • I don't know how I missed that. 
Page 74 
Page 76 
1 
Q. Did he have massages sometimes when he was 
1 
BY MS. EZELL: 
2 
there? 
2 
Q. Since I did miss it. if you don't mind, let me 
3 
A. Yes. A massage was like a treat for 
3 
just ask you again. 
4 
everybody. If they want it. we call the massage and 
4 
Would you describe for me what kinds of 
5 
they have a massage. 
5 
vibrators you found? 
6 
Q. Now. Mr. Trump had a home in Palm Beach. 
6 
A. I'm not familiar — not too familiar with the 
7 
correct? 
7 
names. but they were big dildos, what they call the big 
8 
A. Uh-huh. 
8 
rubber things like that (indicating). And I used to go 
9 
Q. So he didn't come and stay there, did he? 
9 
and put my gloves on and pick them up. put them in the 
A 
A. No. never. 
10 
sink, rinse it off and put it in Ms. Maxwell — 
:1 
Q. He would come for a meal? 
11 
Ms. Maxwell had in her closet, she had, like. a laundry 
:2 
A. He would come, have dinner. He never sat at 
12 
basket. one of those laundry basket that you put laundr
13 
the table. He eat with me in the kitchen. 
13 
in. She have full of those toys. And that was -- and 
14 
Q. Did he ever have massages while he was there? 
14 
that was me being professional. leaving the room ready 
15 
A. No. Because he's got his own spa. 
15 
for bed when he would conic back to the room again. 
16 
Q. Sure. 
16 
Q. Okay. 
17 
MS. EZELL: I don't have any other questions 
17 
A. That happened a few times. few times. 
18 
right now. I'd just like to reserve if something 
18 
Q. Were there other sex toys that you found in 
19 
comes up to ask. But. otherwise. you may go ahead. 
19 
the area --
20 
MR. LANGINO: It is noon. so I don't know what 20 
A. No. 
21 
everybody else's schedule is. I don't know how 
21 
Q. -- sometimes? You mentioned she kept them in 
22 
you're feeling. 
22 
a basket in her closet? 
23 
THE WITNESS: I am fine. 
23 
A. She kept them in her basket. She had some 
24 
MS. EZELL: I do have another question. May I 
24 
videos there and she have a costume there. I know that 
25 
ask it? 
25 
she bought it. tint she hrought it with her. 
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Page 77 
Q. What kind of costume? 
A. I don't know. It was a black. shiny costume. 
I never saw it on her. 
1 
2 
3 
Page 79 
CERTIFICATE OF OATH 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
4 
Q. Was it leather? 
4
5 
5 
A. No. I think it was like a vinyl. But we were 
6 
I, the undersigned authority. certify that 
6 
very fussy about touching any of that stuff. We just... 
7 
JUAN ALESSI personally appeared before me and was dui; 
7 
MS. F7PI  L: No other questions. Thank you. 
8 
sworn on the 8th day of September. 2009. 
8 
sir. 
9 
9 
THE WITNESS: You're welcome. 
10 
Dated this 19th day of September. 2009. 
10 
MR. LANGINO: I shouldn't have more than a 
11 
11 
half hour's worth of questions, if everybody is 
12 
12 
okay to power through. 
13 
3 
MR. BERGER: I probably have a half hour to an 
14 
a...Ar
yl-a(
14 
hour. 
15 
• 
.15 
MR. LANGINO: Okay. 
Sandra W. Townsend. Court Reporter 
1 6 
MR. BERGER: Unless you cover what I cover. 
16 
Notary Public - State of Florida 
17 
MR. MERMELSTEIN: I could say the same thing, 
My Commission Expires: 6/26/12 
18 
so probably less than that. 
17 
My Commission No.: DD 793913 
19 
MR. LANGINO: So I guess my question is -- 
18 
20 
MR. BERGER: I think we ought to take a break. 
19
21 
MR. LANGINO: That was my 
20
question. 
21 
22 
MR. BERGER: We're going to take a break. 
22 
23 
Do you have any problem with that? 
23 
24 
THE WITNESS: No. Whatever you guys want to 
24 
25 
do. 
25 
Page 78 
Page 80 
1 
(Lunch recess.) 
1 
IERTIFIIATE 
2 
STATE OF FLORIDA 
2 
(Continued to Volume II.) 
3 
COUNTY OF PALM BEACH 
3 
a 
5 
L Sandra W. Townsend. Court Reporter and 
4 
Notary Public in and for the 914e of Florida at Large. 
5 
6 
do hereby certify that the aforementioned witness was h) 
me last duly non to testify the whole truth. that I 
6 
7 
was authorized to and did report said deposition in 
7 
stenotype: and that the foregoing pages numbered I to 
8 
78. iDC18.88. ate a true and cotton =ascription of 
8 
my shorthand notes of said deposition. 
9 
9 
I rootlet certify that said deposition was 
1O 
to 
taken at the time and place hercinahove set forth and 
11 
11 
that the taking of said deposition was commenced and 
completed as hereinabove set out 
12 
12 
I rootlet certify that I am DPI attorney or 
counsel Many of the parties. not am I a relative or 
13 
13 
employee of any attorney or counsel of party connected 
14 
with the action. nor am I financially interested in the 
14 
action. 
15 
15 
The foregoing certification of this transcript 
16 
dots not apply to any wpm:Ionian of the same by any 
16 
means unless under the direct control andlor direction
17 
et the certifying reporter 
18 
17 
10 
19 
Dated this 19th day of September. 2009. 
20 
19 
21 
20 
2t4stroaa—_ 
22 
21 
23 
22 
Sandra W. Townsend. Conn Reporter 
24 
23 
24 
25 
— 
25 
--
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