EFTA00157568

Page El 
UNITED STMES DISTRICT COURT 
SOMMRN DISTRICT Or FLOOIDA 
CUE IM.08-CV-80119-GIV4PARA/J01135031 
JAKE DOC NO. 2. 
plat $$$$$ I. 
JEFFREY EPSTEIN. 
Defendant. 
Related mew 
08-80234 0840180, 98.80381, 0840994, 
0840993, 08-8081I, 0840993, 0940469, 
09-50591, 09-80446, 0940102, 0941092 
VIDEOTAPED DEPOSITION Or JUAN ALESSI 
MIME If 
Tuesday, September 8. 2009 
10i12 a.n. - 3:45 p.n. 
2139 Pals beech Letts Boulevard 
West Palm Mech. flor IN 33401 
Reported ny: 
Sandra W. Townsend. flit 
Votary Public. state of Florida 
PROSE COURT REPORTING AGENCY 
Went Fels Mack Or flee 
0608324500 
PROSE COURT REPORTINGAGENCY. INC 
(5611832.7» 
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APPEARANCES: 
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On behalf of the Tliantilfs: 
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RIONARD WILLITS. ESQUIRE 
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STUART MERNELIMIN, ZMUIRE 
mou•elelit 4 ennwsres 
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WILLIAM J. ROOM, ESQUIRE 
RORISTEIN RIMENFELDT ADM* 
YATNERIWZ 
EZELL, 
POI:WORST CREECH. P.A. 
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ADM J. LAM010. ESQ000, 
LEOPOLD MNIN 
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On behalf of the Defendant: 
ROBERT J. GRITION. ESQUIRE 
Wimp. rsirm: 
!Pain" 
1561> 832- i7o.: 
PROM [Quirt REPOM:116 MICKY. D.C. 
1561) 02-7506 
mmenntemagme...—vmmanma 
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PROCEEDINGS 
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Dep0sitiOn taker: before Sandra M. TO.M5Oted. Court 
4 
Reporter end Notary Public. In and for the State et 
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FlOride at large, in the above Cause. 
6 
(Continued tron VOluse 1.1 
VIDCOGRATIMIO 
we'te going beet On the record 
• 
at 12:52. 
10 
CRASS EXAMMTIO11 
11 
BY PR. MMINO: 
12 
O. 
Rolle. 
My maw le Mae Langan., and I 
11 
represent el 1.11 have fewer questions than the rot 
ll 
of everybody. since I's: going next in line. 
nut one of 
15 
the thing. 1 vented to tak you 
16 
lat. GRIMM: before you get .,tart ed. let m 
Just put on fry objection. 
Is 
19 
20 
21 
22 
2) 
24 
25 
Ma, 
your client le
 who allege. that 
she vas at Wr. Met•in's house raset W. 1 think.. 
On One occasion in the ban 
of '03. 
This Mtn's, Is neither relevant, nor 
material, nor Can It  lead to the adnisalhil ay 0 
any relevant infonutIM regardlng ny client. 
So I 
nn rh, ilt•nd 
*0 you certainly can notice Mu, Du: 
.•:. 7ove to •trike 4711 of the question and 
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_000026 15 
EFTA00157568

Pau. 05 
1 
enviers in response to yobs question.. 
2 
le. lANGINO: Thank you. 
3 
BT MR. LANGIMO: 
4 
O. 
One thine I won't sure about was the dote Of 
5 
your enploynent. When did you start with Nr. Cpolein? 
6 
A. 
: as not sure. air. but I think I started lull 
7 
tine ea ay salary. I was on the roll In 1591. 
1551. 
January 1, 1951. 
0. 
In 1551. you started full 
time with 
10 
Nr. Epstein? 
11 
A. 
Yea, wafting for hin alone. 
1 left all ny 
)2 
Clients. I left -- dissolved ny ~Pan?. 
1) 
0. 
And in what year did you start past tine at 
14 
his house? 
IS 
A. 
1590. 
'90. 
16 
Q. 
lea rentlored earlier that sole of the snap. 
1? 
therapist. you pald with check.? 
19 
A. 
Yes. 
19 
0. 
And acne Of the aaaaa pa therapist. you paid 
20 
with cash? 
It 
A. 
Sorry. 
can you repeat the au/ration, 
22 
O. 
Sure. 
You wintiored earlier that you paid 
2) 
.ore of the passel. therapist. with chock. and song with 
21 
cash? 
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Were there any general difference, between 
those message theraplet• that you pall with check. and 
3 
' h. " 
that You paid with canal? 
R. 
Mo. ear. 
It 
seas ... when I vas then savoys 
5 
was a hundred dollar. an hour rat*. root was ler 
6 
everybody. 
O. 
Dad you ever hear Jeffrey Epstein talk about 
S 
hie lea...apes? 
9 
10 
O. 
At one point you wild that you're not -- this 
11 
night be aunNarazing your terettoony -- that you way not 
12 
be the beat guesser or ages. Is that sornhInq that you 
1) 
nay hove said earl er today? 
14 
AIR. CRITIC«, 
Fora. 
15 
INC INTIMSS: 
Yeah. 
Yeah. 
1 think I -- you 
14 
can be thirtieth 
twentleS. 
I don't kn0w. 
It 
BY MR. ?AMINO: 
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0. 
you Penn:Intl a few tines today that you were 
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never told to chock the 1OantifiCatIOn of any of the 
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message therapists that car r0 give Nisse0a.? 
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That's Correct. 
Rao Cabs you paid fault a couple of tines 
4 
today? 
5 
KR. CRITTOM: 
Fern. 
6 
TNN 11:TMESS: 
You caked se. 
They asked no. 
2 
• 
think 1 Just answer question... 
• 
by IS. IAMGINO: 
As you reflect back in your ties 'sorting for 
10 
Nr. Epstein. today de you believe you turned a bland eye 
ll 
to sona Of the apes Of the *Peen Or finales that worked 
12 
for Jeffrey Cpetelri with ma»&OOe1? 
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M. CRITTCW: 
Porn. 
14 
TNN INTOOSS: 
Can you repeat the question? 
IS 
BY is. LANCING: 
16 
Q. 
Sure. 
A. you fat here today and reflect 
back 
On your time waking for Jeffrey Epstein. do you believe 
19 
You turned a bl lad ay* Or ignored. pryO'41Y Ignored the 
It 
epee Of the females that gave hin swages? 
20 
MR. CROFTON: 
4Om. 
Si 
nirret5S: 
I don•t [new. 
I den •t -- I 
22 
cannot -- 
not a judo.. 
I don't know. 
I don't 
21 
knew. 
I don't think so. 
Sincerely. I don't think 
24 
25 
BY MR. LANG1MO: 
15411 TN WOO 
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3504-022 
Page 2 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_000026 16 
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Page $9 
when you were working for Mr. Epstein. did you 
2 
have any doubt that the girls who prOvlded bin masstwes 
3 
were not of the proper age or not older than 18 years 
4 
old? 
M. CRITTON: dorm. 
6 
TUE WOMESS: alb. 
in MR. IPAGINO: 
8 
O. 
Did you keep up with Mr. Epotein's -- keep 
9 
Informed of Mr. Eptiteln'S Criminal COS* while it we in 
10 
the paper? 
11 
A. 
Only whet was On Iv. What it was On tr. 
12 
that's how I found Out. 
13 
O. 
sow Os you feel about Mr. Epstein today? 
14 
A. 
: feel bed, sincerely 1 fool bed, because he 
15 
was -- with me, with my family, with my wife, he was • 
16 
waxy generous guy. extremely -- I don't Now whet the 
It 
used Is in Erml Leh -- but he would press for perfection. 
28 
I smart. and that was • very stmeesful job. but, 
19 
Other else, I have no emblem, with him at all. And 1 
20 
feel had about it. what'. haveened it, his life. 
21 
Q. 
nave you had any contact with Mr. Epetein 
22 
 
 you ended working there? 
23 
A. 
After I work -- after I end working with tint 
24 
Y
. I did. 
25 
when 'him can, when this criminal came 
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Page 90I 
1 
started. I got hone and I had • card, a business card 
• 
teen a collo& derider. 
I think it wepilli 
Iron n.e 
• 
Pain Beach Police Denartnent. 
4 
And -- and : got scared. 
And I was trying to 
• 
find Out what It's 
all about. 
Because It wee an 
oceanic., with Mr. Epstein that we had a disagmmonnt. 
1 
Ye settled that. 
Everything watt well and we went our 
4 
friendly ways and never heard iron his &gain. 
9 
And I received this free the police department 
10 
that we need to talk to you. 
And. 00. I got seared. 
Ii 
And .1 called the office In New York. 
12 
I says. I would like to speak to Mr. Epstein. 
II 
And he come on. end I said, I told him. I 
14 
say. . Jeffrey, what's going one 
What's happening? 
I 
15 
thought it was related to the problem that I had 
16 
petsonaily with him settled. 
17 
And I says -- no, he says. 
And he says to me. 
IS 
nO, John. It's 
nothing to do with that, has nothing 10 
L9 
do with it. 
I've been -- I don't know if he told me I 
20 
been sued or I been -- It's 
• ptoblen with ne. they're 
21 
Investigating sOmething and 1 cannot talk to you. 
That 
22 
wAs the *net 
And tbat'e it. 
2) 
My Other COnvereatiOn, with Kr. Epstein --
24 
ne. 
25 
-- circa that conversation? 
(telt $21.1100 
PROSE COOK REPORT:NC AGENCY, :NC. 
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Page 91 
2 
Q. 
At Bono points you were caught stealing fro. 
Mr. Epstein; is that true? 
A. 
We settled with him as • borrowing money trot 
him. 
Okay? 
M. PIKAORR: 
As whet? 
TtlE WITIiCT: 
Rolrowing. 
M. LANCING: 
Borrowing. 
by M. LANCING: 
10 
11 
12 
13 
14 
15 
0. 
A. 
0. 
money? 
When you took the money (too Mr. Epstein, --
Yes. sir. 
-- did he give yea petwiselon to take that 
At any point Old you take a firearm from 
16 
Kr. Epstein? 
1? 
le 
O. 
At any point Old you enter Kr. Epstein', 
19 
property when you mere mot allowed to he thorn? 
20 
A. 
Yen. 
21 
O. 
And was that the Incident when you took •0/. 
22 
normy from him? 
23 
24 
v. 
Can you explain to on how you and Mi. Epstein 
2n agreement that the cops would not be called: 
wgYe Mein sergrise; NASKY, In:. 
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talk. 
Page 92 
NO Called AO and he nay. John. we need to 
I Pays. Okay. Where? 
4 
And -- and we net At a luncheonette in Palm 
5 
POE% and we have • friendly conversation. 
Me soled 
6 
about my kids, about ny fealty. 
Then -- Is this related to Mr. Epstein', Gee? 
O. 
It Se. 
9 
A. 
Because I prefer to keep this -- this -- I was 
10 
not IncrieMnated. 
1 watt not -- I went to the police 
11 
deportment. 
1 mode ny statement and there was no 
12 
charges filed. 
13 
X don't think I would like to continue with 
14 
this. 
IS 
16 
1$ 
19 
20 
21 
22 
21 
24 
IS. CRITTOW: 
Let no just put on the second as 
think ms conp lllll 
y irrelevant, 
immaterial, 
it's 
not calculated to lead to the --
THE 14111413$: 
And it less often --
MR. ER:210M: 
Let me just finish putting my 
Objection on. 
As I understand it. 
It occurred long before he 
ever got the Card Iron the polite. 
I think you're 
hereptlIng his. 
I think you're trying tO IntiRlditte 
his and 1 think it's 
inapptstos4t.. 
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3504-022 
Page 3 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_000026 17 
EFTA00157570

Page 9) 
I 
How di0 you feel about Mr. Epstein being loyal 
2 
t0 you as en employe* (or his by net getting you into 
further trouble with the pollee? 
4 
IN. CRIMP: Pone. 
5 
1NE WITNESS: I feel that it was part of a 
6 
relationship over le veer. that I did a lot ol 
1 
extra work. And I was lore or less says. hey. 
6 
John. you did it for no, I do it for you. Md that 
see It. And w0 end an al ', lends. NO did not 
10 
break It apart. 
11 
BY XR. LANOINO: 
12 
Q. 
As you alt here today. do you have a sense of 
13 
personal loyalty to Mx. Epstein? 
14 
A. 
Mo. 
Natter of fact, that lot has .alt en 
IS 
a lot of se 
1 
avenological pro/game. 
16 
11 
It 
IS 
2C 
21 
nes rhea • • whet i onet you 444444 to end. 
22 
23 
24 
And I went to end it there. 
have 
.. not herd 
think ny stay thene. 
In r•flecting tho 'ob. I was not paid eoll onowah for 
25 
ght we did. And too late new. 
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The overall theme of ay question Is: The feet 
2 
that Hr. Epstein Cho,e not to get you In trouble with 
the pollee further, trouble with the p01100 --
4 
A. 
Uh-huh. 
0. 
-- DO luny years age. has today that Caused 
6 
you or pressed upon you to snybe soften your testimony 
or Change your testlnony at ell? 
A. 
Absolutely net. 
9 
O. 
Neve you ever spoken with any independent 
10 
..... 
tigators regarding the actions, the criminal 
11 
act lone that occurred at Jeffrey Epetein's home? 
12 
Yes. 
13 
than did that occur? 
14 
A. 
Right after I receive e card from the pollee 
15 
depertemot, when I call Jeffrey and : ask him, ehst's 
16 
going on? 
17 
No says. I cannot talk to you. Somebody we.: 
IS 
use en you, 
19 
And titer, I got a call frees this. guy that I 
20 
gannet recall his nee. new. talked to sae arg at set at 
II, 
Grabbed. And we talked -- what? -- about 15 minutes.
22 
Md he asked ma (betetIOne gust Ilk& IOU guy* axe aerie, 
21 
ma and I says a: Melly the ears. answers. 
24 
And he sage. 'will. there's on investigation 
25 
against eel' l tag. You has nothirq to do with it. you 
(5611 $)2.1500 
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Page 95 
here nothing to do, nothing to worry about At• but if 
2 
you went to hire a govern to protect yoares II. 
And I finked -- r. thatIon to hits ••••, I don • t 
eh, to net ..... wing ad see,. ..neetning 
yen en. 
5 
sialsocdv trvino to inert...... se (or -- tor Sr lob. 
And he says, no, no. no. Out If you want to 
get a lawyer, that's fin*. 
And that'. 
where I got Mr. Myrna, 
and he..)at 
9 
cans to um. to akin thin. to -- that Wee the one nf 
10 
Q. 
Mho got Kr. Nuriell for you? 
11 
A. 
Win got it/ Mr. English.. 
)2 
Q. 
Shen you not with this investigator at 
)3 
Carabba•, --
IS 
A. 
Yee. 
IS 
Q. 
-- dld he record your convered.un --
16 
A. 
I? 
0. 
-- In Any way? 
Is 
After %hie needing et Carabbas. 0id you meet 
19 
with any other Investigators? 
20 
21 
 
 -- dories your inspection of the tosser* 
22 
rove alter thew! massages had been completed with 
2) 
Mr. Epstein. --
24 
2$ 
Q. 
-- do you [saber seeing any -- anything that 
0.41i f/2.1501 
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you would describe as blood) 
No. never. 
Cio you renomber seeing anything that you would 
describe as • sexual fluid? 
A. 
No, never. 
6 
0. 
When you worked for Jeffrey Spoleto. the wosan 
that you were married to. what Is her nen. Or -- what le 
6 
her name? 
9 
A. 
The noun that I was neer led tol 
10 
Q. 
I think -- the reason 'a eating la because 
11 
earlier today mean you first spoke, I thought I 
)2 
reseaborod you saying that you -- both you and your 
13 
14 
15 
Q. 
-- Worked (or Ht. Epstein? 
16 
A. 
It's still my wife. It's still icy wife. We 
11 
didn't -- loo got Leeway* away fro.* divorce and the 
IS 
lawyers were toting ny nerdy by pipeline. 
19 
O. 
And what is her nano? 
20 
A. 
And we decide not to diver** gad we 'hill 
2: 
together. 
22 
Sorry. I Missed that. But what is her ramie' 
23 
A. 
wee..  
24 
O. 
bet es bah look through dry notes to see If I 
2$ 
have any other questions. 
(561) f12-4500 
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3504-022 
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_000026 1 8 
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10 
11 
12 
14 
15 
16 
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19 
20 
21 
22 
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24 
25 
2 
A. 
Okay. 
Q 
Thank you very suet,. 
A. 
Velame. 
CROSS EXAMINATION 
Page 97 
5 
BY KW. NEAKELSIKIM: 
• 
0. 
Good afternoon, Kr. Alessi. 
A. 
Yeti. s1r. 
O 
O. 
fly name is Stuart deteelstein. I represent a 
9 
group of the Plaintiffs in thee* Cases and I have posse 
questions for you as well. 
Your wife). Maria. does she live at the ear* 
address a0 you h0e? 
A. 
Yes. she does. 
O. 
New, when you began sorting lull time for 
Mr. Spoleto. I believe you said that was around 1921. Or 
that correct? 
Yea. 
O. 
Was your wife, was she hired at the nee tore 
its you? 
A. 
No. She was hired three years after. 
O. 
And NA did that come about that your wife sr) 
hired? 
A. 
My wife was hired because we had a housekeeper 
that one was doing the cleaning and she left. Then we 
had another housekeeper. Polish girl. and she lett. 
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And then by that tine so kids wont to College 
2 
and nur wife was at hOme. And I suggest my wife to Cede 
3 
to work wIth a. to help a. 
4 
Q. 
so you secessended to Kr. Epstein that he litre 
S 
your wife) 
6 
Yes. 
And he did? 
A. 
Yes. he did. 
0. 
And what were her 100 Outlet' there? 
A. 
Nor only job duties were SlApplog. basically 
the shopping. getting movie tickets, show tickets. bay 
books, blind the food to Kis. EtAteln'S -- Kr. Epstein's 
mother. sometimes drive Mrs. Spaeth to the doctors. 
She was not involved -- and wart 
she did 
sons cleaning for me. 
0. 
did she live with you in the upstairs 
apartment?
there. Out I had to stay these beanie 9y Job starts 
from 5:00 in the sins nn to 10:00 et Binh' 
O. 
Mid did Maria leave her employment the sea 
25 
tins as you? 
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20 
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Page 99 
Yea. ise did at the ars time. 
O. 
you testified that you would come into the 
bedroom and clean up after 
that correct? 
A. 
That's correct. 
O. 
Old you -- were there occasions Were you had 
your wife help you with that? 
0. 
mere there -- did she hove occasion to go into 
the easter bedroom? 
A. 
It was occasions before that she will help to 
set up the tables once in a while, set up the oils and 
the tables. But I will do the clean up 
Q. 
Is there • reason for that? 
A. 
I was non) involved into the final appearance 
Of the house. And It wee my responsibility to mate sure 
that every coo. was perfect after they Nit and before 
they went to bed. 
0. 
was there anyone else who assigned your wire 
work other than you? 
A. 
MO. KS. Maxwell. etOmetliniS She would tell my 
wife. 00 buy >Coe stuff. 00 get this and go get that. 
She was mostly -- my wife was scatty out of the house. 
She was -- this house was Mr. Spetein would pays. go get 
a* this book. go get lie this eaqaxinot 9a get en 
25 
tickets, nevie tiCket• for this Sheet and (hie shoe and 
/561) 012-7500 
rtfOr COOPY NEPATING AM:Y. INC. 
(Sell anti14 
eitersitabtipotts leen Serstarkelell.741•991 
09setatalitheidet Dogs Il.•••••01-1•1•fteils 
199.8-00.1•91.1disielInt 
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1 
this show. And she would have to travel -- and I was on 
2 
the phone with so wife constantly, buy this, get this. 
3 
get this -- and the food, and the food because it was • 
4 
five-star hotel. 
5 
Q. 
Old Its. 'Unwell or Ms. [patio over instruct 
6 
your wife to do housecleaning tasks) 
7 
No. : was blamed for everything. 
O 
Q. 
You were blamed for everything, 
9 
A. 
: was blamed for the gad and the bad. 
10 
O. 
Old you -- during the time your wife wet 
II  
there, did you also have a hired housekeeper? 
12 
A. 
Ma have a crew of house/Cleaners. we have • 
I) 
crew of peOple that would Cone t0 the rouse and do a 
14 
 
 -- 1 Keane 0eep cleaning. you know, to the house. 
If 
Mae that every day? 
16 
A. 
Once • week -- 0m it watt type a *AA. It 
)7 
was ',weedily and friday.. 
16 
It depends on Mr. Epritein't eche/Ade because 
19 
he didn't -- he didn't want nobody at the house while he 
20 
use at the house. So we have to rearrange cloys for the 
21 
clean-tp crew to cone in. And r usually did that. As 
22 
soon as they left 1 bring the cleaning clew, get the 
23 
hOuse reedy and -- end get set for then for the next 
24 
trip. 
25 
O. 
Old you have a hefeekeeper Ntip did 
1,41r M.1531 
AIM COURT IMPOKtle: astsCY, INC. 
mewimeersieueuetwereeenetowsise 
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"ww
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GI ftWOltealtirOnt 010M 
Sell $)2-7506 
3504-022 
Page 5 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_000026 19 
EFTA00157572

Page 101 
housekeeping tasks en an everyday bests while you were 
2 
employed  
3 
4 
Motore cry vile wont In? 
S 
O. 
Mo. After your wife. 
6 
A. 
Mo. 
Not a full-Ilea housekeeper. 
7 
O. 
Skit you said your wife was hired &&&&& the 
housekeeper left? 
9 
10 
0. 
Out -- so the pencil who left befor• your wit. 
II 
C
. was she doing housekeeping chores? 
12 
A. 
Yee. she was doing the housekeeping chores. 
13 
0. 
Weil. who did it then crier your wife became 
14 
employed there. because and wasn't doing the 
15 
housekeeping? 
14 
A. 
I was. 
I was *Arm it and then we hire people 
17 
for to help us. 
IS 
O. 
SO you were the Main person doing the 
19 
housecleaning? 
20 
A. 
Yeah. 
al 
O. 
And daring -- between that tic* that your elle 
22 
started end when you lett the employment, wee there 
23 
separate housekeeper employed during that tine? 
24 
No. Pull tine? No. 
25 
INII-tine housekeeper? 
i$61i 8)2-7500 
rPOIC COMM lErCoNilic AO 
T. MC. 
Semmerwmantneramemanmaranerme 
...11Mtagana 
a.mermnamsonweammn 
1561) 832-7304 
2 
5 
6 
7 
9 
Page 102 
Moot about a part-tram housekeeper? 
Like I told you, deity baste ea cell this 
company. 
and then they will cow* In with four or five 
girls and clean the whole house. 
This is the crew you were taping about? 
The crew. 
but the crew didn't cone when Mr. Epstein wee 
Q. 
there? 
10 
A. 
Right. 
0. 
So on an everyday bests when Mr. Epetein ea* 
12 
there, yea were the only person who seas cleaning? 
13 
lee -- yeah. or ay wife will help. 
14 
At your instruction? 
15 
That'. right. 
16 
O. 
Out you don't ever rent-bet her cleaning Up 
17 
after maPsagel? 
IS 
If 
Is It possible that you Instructed her to 
20 
clean up? 
21 
A. 
it's poseiblo, but --
22 
lat. MUTTON: 
yowl. Asking Me to speculate. 
23 
BY IS. MEAWELSTCM: 
24 
O. 
Tow tan wooer. 
23 
A. 
It's possible. 
(141I 412.2300 
POOSS COMO REPORNiei ACEACr. INC. 
•••••••••••woWeeeeloweecasinereais 
•••••••••••".•'••••"Taildlligilitanu.......r.n Oaf enema. 
neeninareenearrell 
Mall 8)2-7506 
Page 10) 
0. 
linen olrle would dosa to give a unlade. where 
2 
would they dem In the house? Would they cone to Ins 
(rent door? 
A. 
Mostly Cane to the back kitchen door. 
0. 
The beet kitchen door? 
• 
9 
10 
O. 
Okay. 
And le there a bell them? Would they 
knock or how would they --
A. 
Tnem's a door bell. 
O. 
A door bell? They would ring the door bell', 
I2 
O. 
And who generally would answer the door? 
A. 
Me or ny wire. 
14 
O. 
So you would let then In? 
15 
16 
tat. CINITON: Stuart. con ! Just ask you? 
You 
ll 
use the tern, girls. 
3 ••••••• you lust man. that 
IS 
amine female women. 
It can Man anything? It he, 
19 
no age bracket to It? 
20 
HR. NEIWIELSTEM: 
COrreCt. 
l'n not 
21 
retorting apelltiCally to does right now. 
22 
THE WITNESS: 
KO. 
2) 
BT MR. MESNELSIEINt 
24 
0. 
So es I understand it, 
the girl would cone t. 
If 
the kitchen entrance, which is the service entrance. 
Mel) 022.7,00 
0.10.0c COger PEPOrtile ACONCT, INC. 
(Sell et 
sonendmerawatasnauwonnav 
t•••••••
"'"IINCteAr.21=retrustruido...pdtwea'""'"" 
C.eRetCwatte0OCIOV• 
Page 104 
correct? 
2 
A. 
3 
O. 
You Moe to say yea or no. 
4 
A. 
Yes, sir. 
5 
O. 
If you answer uh-huh, that'. not clear, so you 
6 
have to mower yee or no. 
7 
A. 
Okay. 
And you would typically open the door? 
9 
Yes. sir. 
10 
O. 
And what would happen then? 
Ii  
A. 
Then I will keep her In the kitchen and go to 
12 
Mr. Epstein and find out where they want to have the 
13 
ne)sage. or if it vas for his or for Ma. Maxwell. 
And I 
le 
Iftledlately. if thee were repeat oicl• that are -- they 
IS 
will know inIeCtly where to 90. 
And 1 will go UP with 
14 
thole set the tables, and they will watt for him or her 
I7 
tO go In the /OSA and they lilt there until they CNN up. 
IS 
0. 
So did you generally already know that they 
19 
were coning at the tire that they knocked on the door? 
20 
A. 
Yes, uh-huh. 
21 
O. 
So you had an oppaIntnent schedule? 
22 
A. 
Yeah. 
because rest of the Imes I wee dotal/ 
23 
the calling. you know. 
I called J., ea 
in at 3:00 
24 
this afternoon. 
AM she will told se. no. I cannot. eat 
25 
sosebody else. 
And I knew it the tine they were coning. 
Mali 072.7(1." 
oeME CODA roloaninc ACMCS. MC. 
15612 ill2-7546 
••••••••••••"•""^"ddMilaftati 
OafMatlemetaPPROKele 
3504-022 
Page 6 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002620 
EFTA00157573

Page '05 
1 
so : vas expecting the 
Melt of the tine. 
o. 
So you would expect the.. 
[hey would cone in 
3 
and then you would eeeOrt them upstairs? 
A. 
Oh-huh. 
• 
0. 
6 
A. 
l'n sorry. sir. 
• 
Q. 
Yes> 
e 
Yee. 
Out first 
you would find Mr. Zp nnnnn and check 
10 
to see if he. • ready or find It,. Maximl I to chock to am 
If sheet ready] 
12 
A. 
13 
Q. 
And which nnn a n case would you -- would you 
14 
take then up? 
15 
A. 
Either way. 
16 
Q. 
You would take the» either 
the Min staircase 
17 
or the servant staircase? 
A. 
Ye*. 
19 
O. 
Why would you take the meth staircase, 
since 
20 
you're already in the kitchen? 
71 
A. 
That •e what 1 says, either way. 
We can go 
27 
through the mein staircase 
or we go to the kitchen 
23 
stalscase. So we use both. 
24 
Q. 
Okay. Well, 1.11 talking specifically to 
25 
escort • girl upetaars. 
15611 812-7500 
Melt COLMT RERYAT 
ASIDKY. DC. 
i....mampSeato 
rila
V 
sene~~....~...•~40410.11~ 
0..30.nintom•sest. 
45611 0,37-'104 
Page 104. 
1 
A. 
I escort the girls 
up there either 
way. both 
2 
3 
Q. 
And, to, whet you walked to the upstairs 
bedroom. let's 
take the avenge of when Mr. Epstein is 
• 
netting • .afar/ 
• 
A. 
Yee. 
7 
0. 
W. Epstein wouldn't be up there yet, is the. 
e 
correct? 
9 
A. 
That's correct. 
10 
Q. 
Be would be downstairs Nseterc' 
II 
A. 
oh-huh. 
12 
Would there be a place --
13 
M. CRITTOW: Fore. 
14 
WY M. INOWKELSTZIN: 
15 
0. 
-- where he would normally be while. you too.. 
14 
he'. ttttt 
ng for the omega 
to be set up end ready? 
IT 
A. 
Yea. 
14 
Where Is that? 
Whore would ha be? 
If 
Either et Ms desk or the pool 'Sou.", 
20 
Q. 
Md twee were on the first 
floor? 
21 
A. 
Yee. 
22 
0. 
Md. so. when you arrived .t the top of the 
23 
stelae with the Oirl for thu manage, whet would you do 
24 
then? 
75 
A. 
Go beck to ny duties. 
0411 007-3100 
Pees. COPT INPOIcT:RE Wart INC. 
11••••••••••••••••••••
•••••••••?~ 
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1141• (412.7504 
tape 101 
You weld 'on 
leave? 
Would the roneage table 
2 
already be eet u97 
3 
A. 
No knew already that the girl. 
-- the girl 
4 
went upstairs 
and It was up to hIn to come' up. 
5 
Q. 
Old you have censer:m[1one with any of thatm 
6 
girl., 
7 
A. 
Sometime. 
fs 
Q. 
Moat kind of thing. would you talk about? 
9 
A. 
Regular things. 
Nothing that 
I can renmehr. 
10 
11 
Q. 
Did any of then ever tell 
you their 
mpre7 
12 
13 
Q. 
Did any of then ever assure you that they were 
14 
187 
IS 
M. CAUTION 
Fors. 
16 
BY M. WERKELSIZIN: 
17 
Or over? 
If 
A. 
NO, etc. 
19 
0. 
le one ever lentil:n*4 anything .beet age? 
20 
A. 
Wo, sir. 
21 
Q. 
Mow did the 91[14 appear to you? 
Did the,' 
22 
eerier 
to be very young? 
23 
M. CAM031: 
rota. 
24 
TM: INTICEST: Ag•in, the sari guest ion you ash 
25 
ae. 
Cverytedy ark ne the ism then. 
They could 
'541" 107-"<O' 
4/49,6 Mire INPOIN:ur. ACeirCy. INC. 
ra.«....nielsAnsosittai 
fl aw./ 
4.1.C.X.raPn•tt•OCICOM) 
15611 832.'584 
leer 108 
have been 16 or 20. 
Met of then were. I would 
2 
says. Over 20. 
Md seer mean, It was over 60. 
3 
AM One tine she cane to the door. 
The husband was 
4 
waiting Outside. 
And Ms. Maxwell saw this man. 
• 
that novetedy recorrsona her. 
And knell 
says to 
• 
M. John. you have to find an excuse. We don't 
7 
want her. 
SO I had to pay this man end fleet en excuse 
9 
that they going to have to 00. 
Md she -- they 
10 
never had • woozier with her. 
11 
Rut there was -- »oat of the 
were wens. 
12 
They were not girls. 
13 
BY M. MIANELSTElle 
)4 
O. 
so the some who was over 60 was cent away: 
15 
she was rejected, 
correct] 
16 
M. 001TON: 
IT 
TIM WITIO6=4: 
It was -- 1 was told to send het 
18 
)9 
BY M. MERKELSTE110 
20 
Q. 
Md it woe your understanding when you were 
21 
told t0 send her away. It was teCaaeo Of her age. 
22 
correct? 
23 
M. CEITTZ4N font. 
74 
TWZ WITIEGS: I don't knee. 
1 don't know. 
I 
]5 
was told to tend her away. 
Si- "in: 
ninSc Cerihr rrneln:i.r. Arran, 
INC. 
~toe 
~Pi Noe inane. 
Pintail 
tiesegunn.•••••sle
.
•••••••••• 
beam Ass.. red. 
Con • 
X.)10. 
3504-022 
Page 7 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002621 
EFTA00157574

rage 109 
Of M. KERKELVIEIK: 
2 
Q. 
What was your understanding as to why they 
were sending her Wray? 
MA. CR1DPOM: fors. Asked and answered mire 
5 
UAW, nom. 
MR. MERMELSTEIN: lie Merit -- he hasn't 
1 
annwered ay daeltitin yet. 
MR. CRIMP, He has. 
MR. MERIOLSITIW: Co ahead. 
10 
?RE ollgt3S: Why? 
11 
Sty M. WrAMEYSTEIK: 
12 
0. 
Please ember the question. 
13 
A. 
Can you repeat the question? 
14 
Q. 
What wee your understandlog as to why they 
IS 
tent her away? 
16 
MR. CIUTTOM, Form. 
17 
hit wilt:: Wy understanding was either they 
18 
were busy on they didn't want her. 
19 
BY MR. KERKELAITIK: 
20 
Q. 
What was your uvMutandin0 as to why they 
21 
didn't want her? 
22 
MR. CRITION: Form. Harass ln0. 
23 
THE WITNESS: I don't know. I didn't -- I 
24 
didn't mate to, each et It. 
25 
la MR. taPlabgetilb 
15611 512-7500 
PSOOt Catlin isPOIKInG Ability, INC. 
t5all .11?-7548, 
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.SeaCataanIeseneens eht
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Page 110 
Sot every other wow.n on burgle wad cane over 
2 
to give • message was ouch, much younger, correct? 
3 
4 
Q. 
So this 60 year old woven u s • a gn 
can 
exception, confect? 
M. CR/1160: 
Fero. Paguldritativg. 
7 
ST M. IIKR1481.-9/818: 
0. 
YOu Can answer. 
9 
A. 
I don't know how to answer that question. 
?Oa 
10 
ask me to --
11 
Let se ask you this. 
12 
a. 
CR:170W: 
Why don't you let his answer the 
13 
quest loo beton. you Interrupt Mn. 
11 
SY M. MgRWELSTLIW: 
IS 
0. 
All right. 
Go ahead. 
Please answer. 
It 
didn't look like you were 
A. 
I don't know how to answer that questlon, you 
IS 
asking ne what le your opinlon or that. 
It 
And I told you, ny opinion of that. other 
20 
they saw the girl 
-- I don't think Mr. [potion ever saw 
SI 
the %Van. put its. leallieell bee the viOaari in Cr* 
22 
kitchen. 
And she told ret.. John. pay her and eend Mr 
2) 
24 
0. 
Okay. 
25 
A. 
That wee It. 
1161) 312-7500 
PltoOK WAS NEPOI.W.K. AfbIttv. led. 
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15611 0)2.1506 
Sago 111 
So Mg. Maxwell looked at the women? 
2 
A. 
Right. 
0. 
Did end have a COnvettlatiOn with her? 
4 
A. 
Mo. 
5 
0. 
She lust looked at her end then said to you to 
6 
send her away. correct? 
A. 
Yeah. 
Pay her and seed her away. 
8 
Q. 
Do you recall teeing women who cue to pave 
massages who ere in their 50s7 
10 
Tes. 
11 
There were eaten In the 50e? 
12 
A. 
Toe. 
Il 
0. 
80w Often did that happen? 
14 
A. 
Not too often, Wt it was -- It was wOmen that 
15 
they were in the 50,. 
I says. again, could have been 
16 
49. 45. 
I don't know. 
1 don't know the ages, but it 
17 
Older WOW', 
16 
0. 
80w many middle-age women do you retell 
C.Calln9 
19 
over to glee itiSeageS? 
20 
M. fAITTOIll 
Form. 
2) 
Tit Inewebb 
1 don't renewbor how Sony. hut I 
22 
would says MI 
2) 
was. I would says, in the 400. And she 
24 
Carle very. vety often. 
And I understand she was a 
25 
manage specialist 
and a yoga instructor, 
too, et 
115611 8)2-150: 
MOOSE COW/ ittrOSTIMG/WISKY. INC. 
esawgredene..... 
news. 
0.10WKOLletWaeCiter 
3611 11?-75.04 
Raga 112 
the sale [lee. 
2 
SO that was One Of -- and there was Vieth.? 
3 
ocean he 
she was OUppelle0 to be a teacher at the 
Oche.) of eaesege therepy that I Can't remenber her 
name. 
Rut that's it . 
6 
BY M. 11COMELSTEIL 
So those two you reammber who were older? 
8 
A. 
Two. 
And it 
was • couple gage that ware ol der 
9 
that -- Bose guys that vete elder. too. Ouge. 
10 
0. 
Did Kr • Elietein *Vet have winSaCle• dose be 
men? 
IS 
Ii 
0 
Awl 414 Ho 
ermieln ever lava va•••goe none by 
14 
these Older wane? 
15 
A. 
Yee. 
16 
0. 
When you escorted the fable In this case for 
1? 
the masted* to the upstairs bedroom -- correct? 
-- you 
16 
would the, leave? 
19 
A. 
Yes. 
20 
0. 
You would then walk back dOwnetabs? 
SI 
A. 
22 
0. 
Correct? 
2) 
And would you then -- would you -- you had 
21 
already told Ms. Epstein that she's there. correct? 
25 
A. 
ITAL . . correct. 
15411 1.3.1./:,' 
randt COPT IMPORTIo: WZNCY. INC. 
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15411 Ol2-/504 
3504-022 
Page 8 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002622 
EFTA00157575

Tom 11.3 
And at some point later then Mr. Epstein maid 
2 
cow upstate, 
correct? 
3 
A. 
That's correct. 
4 
O. 
Mad where would you go? 
5 
A. 
to en duties, to the kItchen or to by office. 
6 
O. 
And 1 think you testified 
oozing that the 
• 
doors of the bedroom would be closed during this 
O 
.000090? 
9 
al nut* 
close theater. 
10 
O. 
SO Mr. Epstein. stel, he would arrive palate, 
II  
would clop, the door? 
12 
A. 
Tao, air. 
13 
O. 
And about how long would the passage last 
31 
generally? 
IS 
A. 
Mealy 
an hour. 
le 
And what would happen et the end? 
17 
They would come down. 
Host of the repeat 
le 
girls, 
they would bring the towel. than/rep 
and dap 
19 
it by the kitchen by the laundry room we ad than, In 
20 
order to help us. 
Other girls. 
they just left it up 
21 
there ad they would con awn. 
22 
Kittle, Kr. Epstein will pay or 1 will pey 
23 
24 
Cud they 
25 
or Its. Manna win pay thou. 
45611 412-7500 
nag Con. Ragan. 
AGIMCY, 
reasoneareamennannaninaso 
•••••••••~NriesaussoNasiba• 
10A~••••••••••~11•1111{~00.01ne 
10.•~1.•10.M.P. 
04:t 812-1504 
Page 114 
1 
Q. 
PIA Mr. Epstein walk down with the girl. or 
2 
did he stay unlace? 
3 
A. 
Sammiae, seaman no. Somptimee he teak a 
4 
nap or he look a shower. 
I don't know what they did In 
• 
the roon. 
I don't know. 
I don't know. 
502411.e• he
6 
went down right away. 
Sweet am he grey up there. 
Q. 
So when they nee awn, they would go to the 
• 
kitchen: Is that correct? 
9 
A. 
Yeah, apt of It. 
10 
sea you there waiting for rhea or did you 
Il 
ban --
I2 
A. 
Ny office ase right neat to the kitchen, so I 
1 
was there -- and the kitchen as the foul 
point of the 
14 
house basically. 
So they han to go to the kitchen 
IS 
either to get pay or to go to their are. 
It 
O. 
Dad you Convene with any of the girls 
when 
11 
they Cat darn attar the manage? 
18 
A. 
Very little. 
Very little. 
It 
O. 
Did ya aver observe a girl 
ea appeared 
20 
alai. 
Surprised. Slacked, anything Of that nature when 
21 
they car. down? 
12 
2 
24 
2 
A. 
O. 
A. 
Q. 
Kern. 
Haar. 
kb zonalaa 
you would coy theft Correct? 
/ha'. correct. 
Mow an would you --
(561/ $12-7500 
Can COCIM OMPOICha ACKHCY, IYL. 
15611 
••••••••••••••••• US 
VIMIN•~1 
1~4 
Me (w„Ousw
WOHMMICIMAIO« 
Peg. 115 
1 
A. 
A halal volta. e 0.1.44,4. 
2
 
O. 
A hundred dollars a massage? Were tare over 
eny exCeptiOns? 
4 
A. 
That's the -- t nover pay anY nere
5 
hundred dollarsper 
ma ssage. 
• 
O. 
Here there tires when two girls 
Case? 
▪ 
A. 
/we girls Case at the aeon the? 
O. 
Correct. 
A. 
Yeah. 
There were Clam when two girl* Cale in 
115 
at the Sae tine Surd me will go tO One Pal, the Other 
11 
will go to the other noon. Dr ono -- I would set up two 
12 
tables In his coal or I will ask Inn, where you went to 
13 
at to usages? He will told we, eat in the blue coon 
14 
e14 set them in ny room. Or set thee in Ghislione's 
IS 
tom and to red roan, depends on who people were there. 
16 
but tan 
are tines where two of the gins at the era 
1? 
tine. yea. 
18 
Q. 
sae there ever «canna 
where there w•• • 
19 
girl 
who waited downetain while on. -- while the other 
20 
girl 
went up aaaaaa 
21 
A. 
22 
Q. 
That never happened? 
23 
A. 
I Cannot rentegiar. 
24 
O. 
Ma there over an occasion where you paid a 
25 
girl 
woo waited and didn't actually give It Reeser? 
'Mtn el2-7500 
reaC Oak: AkinTIOK ACEPCY. IOC. 
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1 
2 
O. 
That never happened? 
3 
A. 
Never happened. 
4 
O. 
You mentioned that Mr. Epstein put you in 
5 
contact with Mr. Murrell, 18 that Correct? 
MR. °UPTON: Fag. 
7 
THE 14119690: Hot Hr. Crinkle.. 
• 
BY MR. METMELSICINt 
• 
O. 
Huh? 
10 
A. 
It wasn't Mr. Epstein. 
11 
O. 
Mr. tpatein'a lamplighter Put In. In Contact 
12 
with Mr. Murrell? 
13 
A. 
that's correct. He gave se his at. 
14 
And did you pay Nr. Murrell out of your own 
IS 
pocket? 
le 
A. 
Ma, 1 didn't pay nothing. 
IT 
0. 
Who is -- what wee your undasinnding as to 
18 
who wait paying for Kr. areal? 
19 
A. 
1 don't know. 
I don't Now who was paying for 
20 
21 
0. 
You never asked Mr. Murrell who wag paying hie 
22 
bill? 
23 
A. 
a
t. he never send no a bill. 
24 
0. 
Did you think that Mr. Parer wee doing it 
25 
tor free? 
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Page 9 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002623 
EFTA00157576

sags so 
1 
A. 
I don't know. 
2 
Q. 
You don't know. 
As far as you :Wm, 
3 
NC. Murrell Could have been providing you legal IntviCof 
4 
for free? 
5 
A. 
No. I don't [hint it was provided is rot frQQ. 
6 
I don't think he ever -- that question ever cone out of 
Mr. Sorrel/. 
: was In Mr. Murrell's office 
for about 
ten minutes. 
11 
And he says. well, I reset you teMarrOw 
10 
thane -- and that's it -- in older to protect you so 
11 
they don't inCrimlnate you in any way. 
We left It at 
12 
that. 
Me never send ine • bill. 
Me never send ne -- 1 
11 
never talk to Mr. Murrell again. never saw his again. 
It 
Q. 
And you never had any kind of unaerstanclin, 
IS 
with him as to how --
16 
A. 
17 
Q. 
-- how his bill wee going to be Fold: 
IS 
A. 
m. 
19 
Q. 
Did you sign any kind of what we call. 
a 
20 
retainer ogreement. anything whore you hired him? 
ti 
22 
MR. CAISSON: 
Just eo you know. you have en 
23 
ettotney -- nobody's going to tell 
you this 
24 
apparently. 
25 
You hove en attorney/cl lent privilege. 
Any 
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1 
conversation that you had with Mr. Murrell. 
you and 
2 
your wife, is [Cap 00000 y prOt•Cted. as 1009 as you 
• 
want to 00000 t that priestess:. 
4 
You can either assert It or not assert it. 
5 
Thera your right. 
nut nobody's apparently going 
6 
to tell 
you that, at least Mr. Nentolatein Id net 
• 
ring 
to tell 
you that. 
KR. MEAMIUSTSIN: 
Moll. I was trying to 
9 
avoid --
10 
MA. CMITION, Nell, you're nthq 
questions of 
11 
what he said. 
12 
MR. SLANCESTEIM: 
I'm not asking then what 
13 
they said. 
II 
MA. CRITIOW: Sane thing. 
15 
MR. NERMIESTEIN: 
I'm asking him how he get 
IS 
paid. 
I? 
MR. CRIMPS 
Ito, you were -- real back your 
le 
question, where you were. 
19 
Anyhow, that's a right you ?ave. so... 
20 
So much for the law. 
Pi 
NN. PISAMELOrtnis 
I wee net asking min what 
22 
wee said daring any Conversation. 
I asked him if 
23 
he signed • retainer. That's a fair question. 
24 
BY SR. MEASLES'S'S: 
2S 
O. 
DO you renarear a girl wit* Casa to give 
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Page 110 
massages those by the rase QOM_' 
Does that none 
2 
Sound familiar at all? 
3 
4 
De you teamster &nil'? 
Mo. 
O. 
What about allill? 
Do you tonwobor anyone ny 
7 
the name of III'? 
El 
A. 
9 
O. 
Wail it frequent that girls would Coss Nast 
10 
once and not appear again? 
11 
A. 
Frequently. 
12 
Q. 
These girls that would come. would they as 
13 
with their own equipment or supplioa? 
le 
A. 
Mb. 
Some girls, 
they none in with a table, 
15 
the new girl. 
they cone in a. t • 
sillily.. 
And I would 
16 
told them. no, you don't need the table. 
may will 
17 
leave it In the kitellso las:, Me we have tables in ovary 
IS 
room in the. house. 
19 
Q. 
Some of the q oo 1 oo the first 
tine they use 
20 
they didn't have anything. right? 
21 
A. 
May wee. eith that table. urn uf ttp tabsies 
22 
they hang it in the shouldera, portable tables. 
Put we 
23 
didn't have portable tables in the room. 
They were all 
24 
cu•sosenasis. tables. 
23 
O. 
Did ease girls 
cues without -- for the first 
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Page 120 
tied without any *swollen et all. 
whether equipment or 
2 
lotions or anything of that nature? 
3 
A. 
Probably. 
4 
0. 
Did you have a question in your nine as to 
whether they were profesolonal et this business? 
6 
• 
0. 
At massaging? 
• 
A. 
0. 
Why not? 
10 
It was not ny yob. 
11 
MR. CRITICS: 
Fors. 
12 
BY MR. Wen4E4S7EIN: 
13 
Q. 
You lust didn't think about It? 
14 
MR. CRITICS: 
Porn. 
15 
THE WITNESS: 
if 
I was told that a girl 
is 
IA 
Cesiing, ny job was to Open the door, let het In and 
17 
let Sr. Epstein *eclat where he wants his massage. 
II 
And that was the end of it. 
If 
BY SR. MERCIESSIE'N: 
20 
Q. 
Are you aware that sexual conduct between an 
at 
adult mei. end en unesereee isle 
It ccininatu it.. 
22 
against the law? 
23 
KR. CRITTOM: 
Fora. 
24 
THE WITNESS: 
Of course I do. 
25 
BY MR. MCWHIESTEIN: 
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Page I 0 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002624 
EFTA00157577

Pepe 121 
1 
O. 
Old you have any concerns whdle you were 
2 
working them that criminal acts were occurring with the 
3 
girls 
Who were oaring to the door? 
4 
KR. CRITTOM: 
Form. 
Tat WITNESS: 
: had no idea what was groin on 
6 
between then. 
BY MK. MENCLSTEN: 
Q. 
Let in lust glee you sone other naves 
am if 
you recognise any of these nante 
10 
IL 
I? 
13 
14 
1 
l$ 
19 
20 
22 
23 
0. 
=7 
24 
Ho. 
-? 
A. 
(nods heed.? 
Q. 
Mane does not ring a bell? 
A. 
(NOds heed.) 
KR. CAUTION: 
You lave to answer out loud. 
BY MR. MCPect 92601: 
O. 
l'Ou need to say yes Or no. 
A. 
KO. 
O. 
A. 
Can you repeat that? 
O. • would be the first 
nee. 111.0,11 ' 7 T.. 
second nano? 
25 
(5611 111-000 
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1 
2 
Q. IMI7 
3 
A. 
No. None of those girls' --
4 
Q. 
None of these girls sing • ball at ell? 
5 
A.
-- nano familiar to me. 
6 
Either they case ono time. one day and they 
didn't even told me their names or -- or he said for it 
8 
that I don't have -- but none of those napes sound 
9 
fanillar 
to es. 
JO 
Q. 
You tousled 
that there were -- *bout the sax 
11 
toys that you would pick up after -. alto. these were 
12 
?stews**. correct? 
13 
NA. CRITICS: 
Form. 
14 
BY NA. MERKELVIEIM: 
15 
Q. 
The vibrator*, 
correct? 
16 
MR. CRITTON, 
Fen'. 
17 
BY KR. 140MELSIEIN: 
10 
0. 
You can *newer. 
19 
A. 
Yes. 
20 
O. 
And you mentioned there use a basket with 
21 
these vibrators or toys in them, correct? 
22 
A. 
Yee. 
23 
Q. 
Where was the basket kept? 
24 
A. 
In Ms. 14axwoll's closet. 
25 
Q. 
And that was In the master tedroon? 
061/ 932.1500 
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061) 412-7506 
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Page 123 
1 
KR. CRITICS: 
Form. 
2 
BY MR. MIMOMISIKIN: 
1 
Or off the te eter bathroom? 
4 
A. 
Her bathroom. 
O. 
Huh? 
6 
A. 
Her bathtent. 
O. 
And the closet We -- the entrance to the 
8 
closet was in her ',inbreed? 
A. 
that'. 
correct. 
10 
O. 
And It was • portable basket, eh* could now. 
11 
It around, correct? 
12 
A. 
Uh-huh. 
13 
0. 
You have to cay yes or no. 
14 
A. 
Yes, air. 
IS 
O. 
And -- and that's where the, I think you wed 
16 
the ward 01100( correct? lhal'el where they were 
11 
located? 
lE 
A. 
Yes, elr. 
If 
O. 
Mae there OCCOttiOnd where you would -- the 
20 
snide, ono or sore dildos would be out and you would 
22 
clean than up 
aaa.age that only Kr. Epstein had. 
22 
not Ms. Maxwell? 
23 
A. 
It was -- I will says that it was about three 
24 
Or fOur OCC.01Ons that I had to take this dildOs and put 
25 
It back where they supposed to be. And 1 took It with 
(5611 412-)500 
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Page 124 
gloves and towels and stick it In the 'ink and throw it 
2 
in there. 
3 
Soestimes Ms. Maxwell will have a massage. 
4 
MO sonatiass I find it aaaaa she's supposed to have a 
sussuse those things. And also when Mr. Epstein had 
6 
the message. So I don't know who use it on who. 
because sonatinas they all disappear up there. 
8 
Mr. Epstein, Ms. Massiall and steever was up there. 
9 
Q. 
So as 1 understand It, you couldn't isolate a 
10 
partleuler instant uhOre --
II 
A. 
1 Cannot. 
12 
Q. 
-- Ms. Maxwell wasn't there, only Mr. Epstein 
13 
had gotten a 1110Sage and then you found the Sex toys? 
14 
A. 
1 Cannot Isolate that. 
IS 
Q. 
But It's possible that either Mr. Epstein used 
Id 
It or Ms. Maxwell used it; is that correct? 
17 
MA. CRITTOS: Font. Form. 
18 
1HE VIINESS: I have no ides to know. 
19 
KR. MENal-ltrin: All right. 
have nothing 
20 
further. 
21 
MR. arMOSR: How about if we take • break? 
22 
mould you like • break for • couple minutes? 
23 
Thor MANES!: No, that's fine. 
24 
MR. 'MOM: 
Kr. Willits. would it be possible 
25 
If I could Olt there, because I've get a couple 
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3504-022 
Page I I of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002625 
EFTA00157578

Page 12> 
Exhibits a.s maim, to show litn7 
MA. WILLITS: Stirs. 
WA. DEACCA: Thanks. 
CPOSS EXAMINATION 
SY it. SKRGER: 
6 
O. 
Okay. Good afternoon, sir. 
7 
A. 
Afternoon, sir. 
0. 
Wy name is Wil I tan J. Berger and I represent 
three of the Plaintiffs 
in this case. 
10 
Did you aver It... of the mamill, 
a yore{ 
11 
woman named Il? 
12 
A. 
No, air. 
13 
Now about a young wan naiad 
15 
Okay. You know, you"... referred Several [Isms 
16 
tO a falling Out Or a disagreement that you had with 
17 
Mr. Epstein? 
IS 
A. 
Yes. 
19 
0. 
Was that in -- was that the year that you left 
20 
his employment? 
21 
A. 
Right after -- eight after I left. 
22 
0. 
So you had a falling out with Pan atter you 
21 
left hi a employment? 
24 
25 
Q. 
Nell. why did you leave his enploYourrt? 
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Page 126 
A. 
Why? 
2 
Yeah. 
3 
DOCAUBO 1 Wag alCk. 1 was extremely muck. ■ 
4 
And I WS. 
6 
sick of the job and im had enough. We had good pay, but 
we had enough of the 143. especially because of 
8 
Pa. Maxwell's ttttt ode toward. us. 
O. 
Now. you said you had good pay, but we had 
10 
enough. 
What was your pay in 20027 
Ii  
A. 
2002, right before I left7 
I think it WA* 50, 
IS 
either SS, something like that. 
Mid my wife was 30 or 
11 
15. 
I could be wrong. 
14 
Q. 
So you think that you woes paid 455,000 in 
IS 
2002? 
16 
17 
O. 
Is that correct? 
IS 
A. 
fbat'S correct. 
li 
O. 
Md you believe your wife .00 held hew muCh? 
20 
Thirty. 130.000. 
21 
430,000 in 2002? 
22 
A. 
tb-huh. 
23 
O. 
Is that correct? 
24 
25 
Q. 
Nue about 2001, What WaS your salary end your 
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1 
wife's? 
2 
A. 
Oars thing. 
Okay. 
And In 2000? 
4 
A. 
1 was at the sane. 
It never -- we never got 
S 
raise,. 
We never get --
6 
O. 
I think you said at the waxy beginning --
I 
A. 
Yes. 
0. 
-- Of the deposition that you hero paid 45.000 
9 
when you were first 
hired full 
time? 
10 
A. 
Yeah. 
11 
O. 
In 2002. you were earning 55,000? 
22 
A. 
Uh-huh. 
13 
0. 
So you did get note [else? 
14 
A. 
Yeah. 
In the matter of 11 years. 
Yeah. but 
IS 
we didn't get a raise every six menthe of every year in 
16 
any specific date. 
And the  
 were set by the 
17 
company. 
Automatically they would cone from New York. 
IS 
It was not a negotiate point between me and Kr. Epstein.
IS 
0. 
Md then you said earlier with me, you mad we 
20 
had enough, you and your wife. 
You said, we had enough: 
21 
Is that correct? 
22 
A. 
That's correct. 
23 
0. 
What do you mean by that? 
24 
A. 
It warm extremely stressful lob. 
It was a 1._t 
25 
of pressure on us -- on mi. on me -- I hove t0 
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Everything was blaned on se. 
ft a 
2 
chef cook a bad meal. It we fly fault. And II the table 
was not proper set royalty style. It Was fry fault. 
And 
the hours were terrible, 
never have a holiday, Saturdays 
and Sundays. 
Me were working between 60 and 70 hours • 
week. 
And ny health was. I think. the most Important 
thing. 
Md also the relation with my wife, It was a big 
factor in us leaving the 040PsaY• 
Now, you &aid that you were blamed for things? 
10 
A. 
Yea. SI!. 
11 
Q. 
Who would him.* you? 
Who is it that would hey 
12 
that 'wirer* 
blamed? 
13 
A. 
I don't know who did the bleating, but 1 will 
14 
get hey ma dwwM wt by Ms. Maxwell 
IS 
She was the one? 
16 
A. 
Moat of the times. yes. 
17 
0. 
Who else did that? 
IS 
A. 
SOmetimes I had dlu0reenenu with him. 
19 
O. 
'Him,' being, who? 
20 
A. 
Mr. Epstein. 
23 
0. 
About what? 
22 
A. 
Simple thing,. 
Por ne, it's 
stupid things. 
21 
nothing -- if this paper -- If this pencil was not put 
21 
in right there, they will complain. 
25 
0. 
Okay. And is It correct that you left the 
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Page I2 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002626 
EFTA00157579

Sage 129 
1 
employsent of Kr. Epstein in Deoesber Of 2002? Does 
2 
that stood correct? 
3 
That's correct. 
4 
Q. 
And the -- no... were you •rrested in 2003? 
5 
A. 
I was never arrested. 
6 
Q. 
You did speak to the pal ice? 
A. 
Yes. 
$ 
0. 
And you did have your 'tetanal token et the 
State Attorney's Office? 
10 
A. 
Yes. 
ii 
0. 
let you -- but that was by On aaaaaaa nt State 
12 
Attorney, Correct? 
I) 
Yes. 
14 
O. 
The CpultIOnIng? 
15 
A. 
(Side 'AKIO 
16 
O. 
Is that correct? 
17 
A. 
That's correct. 
IS 
O. 
You spoke separately with police officers 
19 
though. correct? 
20 
ma. CillITON, 
Morn. 
21 
02 HR. SENDER: 
22 
Q. 
In other words, the date of that Kalamai le 
23 
in October of 2003, is that correct? 
24 
A. 
Yes. 
25 
Q. 
Sod by that statement,. I lean, the 
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1 
tranictipt 
that 1 lava you earlier? 
2 
At what date, sir? 
3 
M. KERMELSITIN. 
2005. 
4 
HS. /Kinn*: 
l'n sorry. 
You're correct. 
5 
Rank you. 
Sorry. 
6 
TAT WITNESS: 
2005. 
M. BERGER' 
In fact, let's 
-- Hs. Reporter. 
'Auld you nark the transcript if anybody needs it? 
9 
MR. CRITTCOh it'. Exhibit 2 row? 
10 
M. BERGER: IS that Pow you're doing it, 
lust 
Il 
COnsedotIvely? 
12 
KR. CRITTON: 
Yeah, let's 
do its otherwise, 
13 
It's 
going to be an awful nese have five Waitron 
14 
Exhibit lumbar Is by everybody. 
I> 
(Exhibit nunber 2 WA netted for 
In 
identification 
purpose..? 
17 
BY KR. BERGER: 
IS 
O. 
You see Exhibit 2' 
It's • transcript; is that 
IR 
correct? 
20 
A. 
That's correct. 
21 
Q. 
Is that the transcript of the *worn statemen 
22 
that you gave to the Assistant State Attorney in 2005? 
23 
A. 
Ms, sir. 
24 
O. 
And during the lunch break, did you ?Ave en 
2> 
opportunity to read it? 
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"ago III 
Yes. sir. 
And do you vanisher that you were placed under 
oath when you gave that statement? 
A. 
Yes. sir. 
5 
O. 
And is everything that you say In hero 
truthful 
and correct' 
A. 
As far es 2 knot., yea. sir. 
O. 
Okay. 
NOw, In ConneCtIOn with the incident in 
9 
October Of 2003 involving Mr. fiastoliVo Nouse and your 
10 
entering his house, that Incident? 
11 
A. 
It was In October 2003? 
12 
Q. 
When do you remember that it was' 
I) 
A. 
: can't remember. 
It 
O. 
Okay. All right. You spoke with police 
u 
office.. In connection with that though, correct? 
16 
I went to the Pain Peach Police Department. 
I? 
Why did you go to the --
It 
I speak to one officer. 
19 
Q. 
and why did you go there? 
20 
A. 
Ilecauae Kr. -- when I spoke to Mr. Epstein end 
23 
we settle the dispute. rte.  
 says, yew 'wet need 
to go to the Milne department end hake O StOttnent. 
23 
gel. WILLITS: 
Could I nave Exhibit molter 2. 
24 
Xt 
Thank you. 
041. ill- 
P5050 COAK REPORTING ACEMCY. INC. 
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Page 132 
BY It. 
BERGER: 
2 
Let sr 00e If I understand this *arterial'. 
I think you testified 
earlier that you found a 
card Or you were given a cerd from a police officer, 
If 
that Correct? 
G 
A. 
That's CorreCt. 
7 
O. 
And a> a reeuit of that, you called 
9 
Mr. Epstein, Correct? 
9 
A. 
That's Correct. 
10 
O. 
betOre you got that Card, did you ?Ave any 
idea that the police were Involved in your lite? 
12 
13 
It. 
MITCH: 
Fern. 
if 
DT It. 
MERGER: 
IS 
0. 
And you celled Mr. Epstein after you got that 
16 
card, correct? 
Yes. 
IS 
0. 
Wow, how did you get 
Was it nailed to 
If 
you? 
20 
A. 
Mo. 
It wo putted In ay door. 
I was not 
21 
home. 
MA they vent to ay house and troy left 
it in the 
door. 
23 
0. 
And did It have a note oe. it, 
OINK call? 
24 
A. 
Yea. 
25 
0. 
Or wee it lust a card? 
041. Ot"-ISK 
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3504-022 
Page 13 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002627 
EFTA00157580

Page 123 
A. 
It was a -- It was a Palm Beach Police 
2 
Departgent. plebe. Call. 
3 
O. 
Okay. And you didn't cell though: you relied 
4 
Mr. Epstein first, right? 
• 
A. 
Yeah. Because I was scared. 
6 
O. 
*hi' were you scared? 
7 
A. 
Because I thought it was of the incident that 
O 
happens previously. 
9 
0. 
Md what woe that Incident/ 
10 
A. 
You knew that Incident. 
11 
O. 
I'd like to hear you thiecrlis• It for no. 
12 
A. 
That incident is. I vent to the house and I 
13 
got ICC* 00,14y. 
14 
O. 
What nee of day did yea go to the house? 
15 
A. 
Night. 
16 
0. 
Was anybody hone? 
17 
A. 
IS 
Where did you get the money? 
IS 
Out of his brig. 
20 
Out of his? 
21 
22 
O. 
Bag. Briefcase? 
beg? 
23 
A. 
Briefcase. 
24 
O. 
Briefcase? 
25 
A. 
Yes. 
(5410 012-7140 
igrOSE Mgt SEPORIM hGbee. INC. 
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Matt did you -- did you know that there was 
• 
noney In the briefcase? 
3 
A. 
Yea. 
O. 
NOW did you know that? 
Because I replenish that cars rimy tines 
6 
bar ore. 
Mow, how many riontha after you :ell 
Nr. Epateirie employment did this occur? 
9 
A. 
I don't hare -- I would says, three to COW 
10 
months. 
I would lust Ask a favor of you. ?he court 
12 
reporter needs to see your face so she can understend 
13 
what you're saying. She's looking -- you put year hand 
14 
in front of your south. that's all. 
15 
Now, when you worked for Mr. Ipatoln, did you 
16 
learn that he kept nohey In that briefcase? 
17 
A. 
Yes. 
25 
0. 
Md, sO, when you went to his house On that 
19 
occasion, did you het arouse that there mould he money 
20 
in the Drtafcase? 
21 
22 
O. 
And -- and did you take noney oat of that 
23 
briefcase? 
24 
A. 
Yes. 
25 
Q. 
Now. is that the only time that you took abbey 
0051 512-7502 
PPG% COVIR 1[14:07N0G. AGENCY. INC. 
(5611 412-7506 
Oneenennie•Intilinafteaninhennelent 
••••••••Inteneettneslemenell-ttleislien 
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Pape 135 
1 
2 
A. 
NO. 
3 
O. 
-- of his DrIefOlsee5
4 
A. 
it was twice. 
5 
O. 
When was the Other time? 
6 
A. 
COuple weeks before. 
7 
O. 
Whet tli•e Of day was that? 
A. 
At night. 
O. 
SAO hew such did you tabs out the first tie. ,
10 
A. 
It wee a total of E6.200. 
tt 
O. 
That'. for both times? 
I? 
A. 
Yeah. 
0. 
CAM you break then debit? 
If 
A. 
: think one tine was 91,500. 
Another time wan 
15 
the rat. 
16 
O. 
Nov, you left in December of 2002 end then 
17 
there rwer• these two Incidents that you Just described: 
te 
19 
O. 
Did you Wan any content with Ni. Epstein In 
20 
between leaving his espleynosa and the first of the** 
21 
two instances? 
22 
A. 
None. 
23 
0. 
And as far 60 you knew. Old anybody See Sou 
24 
take the werey on either occasion? 
25 
(tall II:.7,00 
hancc Chow? AgeArttua AGENCY, :RC. 
15411 012-130t 
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hies 136 
O. 
And, so. when you saw the card firm the 
2 
police, you assumed It had to 00 with Vase two 
instances? 
4 
A. 
Ye.. sir. 
Q. 
Md there was AO Otter rennin why you thought 
6 
it had to do with Nr. Epstein? 
A. 
No. sir. 
6 
O. 
And when you Called MAN 010 you discuss thee* 
9 
two incidents with him? 
10 
A. 
When 1 Cell MI. --
II 
0. 
You said you got the card --
12 
A. 
No. 
13 
O. 
-- and then you Celled hid/ 
14 
A. 
No, we did net discuss that money or nothing 
15 
Involved. 
16 
I ask his, what's going on, Jeffrey? What'. 
1 
it 
it 
NO. he soy*, John, It has nothing to do with 
20 
that money. 
21 
O. 
Did you weer read the incident report by the 
22 
police, the Pain beach Intik* Department? Did you ever 
23 
reed it? 
24 
so. 
25 
vs. CRITION: 
Regarding whet' 
happening? 
I got this and I thought that this was all 
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Page 14 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002628 
EFTA00157581

Page 137 
Y.R. BERGER: 
Regar0ing them. Incidents. 
2 
BY I
. BERGER: 
3 
You never reed It? 
4 
O. 
Let me head you this. 
MR. COMPS: 
Is there an aaaaa copy? 
1 
I
. BERGER: 
Yeah. 
BY MR. BERGER: 
%hat I'm showing you. have you ever peen this 
10 
before? 
Il 
KR. BERGER: Let's have this narked ea Kahlbit 
1) 
3. 
14 
MM. COITION: Gen I keep this? 
IS 
'Exhibit member 3 was masted for 
16 
Identification porno...) 
Il 
BY ME. BMA: 
14 
Q. 
It appears to be about 20 pages and It 10s. 
LP 
Palm Beach Police Department Incident Report. on the top 
20 
page. 
21 
Turn to the third page. 
22 
And you see where It starts the narrative, the 
2) 
paragraph? 
00 you see where that starts? 
24 
2t 
end It says: 
?On Sunday, October 5. .01 at 
041. 532.11,0 
flf3fn 00.1k, sr:PORI:a: ArlEACy. INC. 
ilea 
012-750S 
-Tare
lease 
aenailie 
elerseeteesreilmeelommtntrar ........„..
c..„. 0.....prsarersiees 
oniarceeteranestamo 
Page 1)0 
approxlmtely 1.24 hour., / was dlepatched to a burglary 
2 
at 354 El Orilla Way. -
9 
Do you see that? 
4 
A. 
Yeah. 
• 
Q. 
Now, October 5, 2003, do you recall that that 
• 
was about when the tine yea took the money tr0n 
• 
14r. EpOtein'S briefcase was? 
• 
A. 
Yee. 
I don't retell. 
Bat It they say It. 
9 
have to agree with It. 
10 
Q. 
Kell. you left In OeCeeber of 2002. 
And 
11 
before 1 shoved you this daciarent, you said that those 
12 
Incidents occurred about three or four months later. 
So 
13 
apparently they occurred more than three or four Meth* 
14 
later: 
10 that Correct? 
If 
A. 
Apparently. Yap. 
16 
0. 
Keil. 
now otter -- after looking at this. sir, 
17 
do you actually recall that It occurred move than three 
10 
or four months later? 
le 
After looking at this? 
20 
Yeah. 
21 
It could be. 
22 
But de you actually remember It being more 
23 
than three or tour menthe? 
24 
A. 
I don't remeriber It It 
wars mere than three 
25 
+oaths. 
O61i 4)2-2500 
MOSE 000.0 ACKI0X1145 MGM,. Inc. 
amaisompanrieesemanomemsseare 
reeleeereeNaleetr 
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Page 139 
Okay. 
Okay. 
NOW. If you look further down. 
you'll 
see It says. quote. Epstein further edslawd • 
black Clock handgun was taken Iron the boot shelf 
located behind the desk. unqUote. 
00 yw see that? 
A. 
Yen. 
Q. 
Did you take a black Glatt handgun iron him? 
Absolutely not. 
9 
Q. 
De you know if anybody did? 
10 
No, sir. 
11 
is this the first 
tine that yew aver heard 
12 
that Kr. Epstein nay here told the police .-
19 
A. 
No. ibis question I was asked by the police. 
)4 
O. 
Okay. 
Nem. you ace the neat sentence? 
ft 
35 
says: 'Epstein advised he evapeCfed cash had been tab, 
16 
frOmitIe. briefcase on OW other OCC0020mts Mlle 
he 05' 
27 
in teem for the weekend. The first 
was over the Labor 
14 
Day weekend, August 30 t0 September 1. The second tine 
IS 
wee a weekend in mid-September 200).' 
20 
Oa you see --
Zi 
22 
0. 
-- the mention or those two Incidents? 
2) 
A. 
24 
0. 
Yee? 
25 
A. 
(56.0 002-2500 
bunt Cooks aLIVerlyie. nowici. Inc. 
061) 112-1506 
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. " ... "'' " "Tlatrereasarese.ege 
sobera pear "'"" 
O.e.erternateter.rease. 
Page 140 
You've got to soy Yes or to . 
Yes. sir. 
New, loot up at the top of that paragraph. 
You see where it says: 
'After' 
-- It's 
about the fourth 
sentence --'Epstein 
advised that on Saturday evening, 
October 4. 200), he left his briefcase at his desk and 
vent t0 bed at approximately 12:30 a.a. 
Epstein said 
• 
when he left hie briefcase, It contained approximately 
9 
35.000 O.S. currency.' 
10 
11 
Pa you see that? 
12 
A. 
Yes. 
I) 
Q. 
And then it goes further on, it says -- after 
14 
a sentence or two. It says. 
'Epstein stated at 
15 
appromimately ?:IS hours on Sunday. October 5, 2003, 
16 
while sitting at his desk. he noticed the briefcase her 
I? 
been Opened and SO.a of the Cash was nigelng. 
Epoteln 
18 
believed approxinately $2,500 was taken free the 
19 
briefcase.' 
20 
Do you see that? 
21 
A. 
Yes. 
22 
0. 
NOW. wises you reed this whole Paragraph bare. 
23 
do you agree that Kr. rp aaaaa is 
and •••taling that 
24 
the police took this down accurately -- that N . Epstein 
25 
Is describing three separate Instances --
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Page I5 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002629 
EFTA00157582

Palo 141 
A. 
2 
0. 
where he believes money was token? 
3 
KR. ERIVTOW: foe. 
4 
IRE WITNESS: I don't agree with this. 
5 
BY M. BERGER: 
4 
O. 
No? 
O. 
Well, he Oily!: 'the titer -- at the cotton, 
9 
it says/ 
The first was over Labor Day weekend, August 
10 
)0 to September I, 200)." 
11 
You sea It says that et the bottom? The very 
12 
betted. 
1) 
'The first was over tabor Day weekend, 
14 
August 30 to Septewtem I, 2003.' 
15 
Co you sae that? 
16 
1/ 
Yea or no) 
IS 
A. 
Yes. 
It 
0. 
MA then It says: 'The second ties was a 
20 
weekend in mid-septbaber 2003.' 
21 
00 you see that? 
22 
A. 
Yea. 
2) 
O. 
And then above, do you see "here he tatted 
24 
about October 4, 2003? You eme mention of that? Or 
25 
October 5, 2003) 
ettli 
MCA ater 
achiteciot Adnat
. nC. 
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3 
Page 142 
A. 
Right Mn. 
O. 
Right in the middle, it sayer -Epstein stated 
4 
A. 
No. I don't agree with this. 
1 never :my 
5 
this. 
6 
I's not asking -- that's not whet On **king. 
What 
saying, sir, do you mm though thee 
the police report refers to three instance.; to that 
9 
correct) 
10 
A. 
11 
O. 
Obey. But it's correct that the police report 
12 
refers to three instances. correct? 
13 
M. ERITTON: Porn. 
14 
BY M. BEADICR: 
IS 
TIM polite talk about three instinges, right? 
16 
A. 
That's Correct. 
M. CRITTON: Porn. 
19 
BY M. BERGER: 
If 
0. 
Now, how many times did yow tate Ca:sh fres 
20 
Kr. Epstein? 
21 
A. 
Twice. 
22 
0. 
So do you have any idea whet he's talking 
23 
about here? 
24 
A. 
No. 
25 
Q. 
Wow, the first 
time that you took cash. way it 
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Page 113 
on August ID to 1:op:Amber 1, NMI? 
7 
I can't renesber. 
3 
Or September -- std-September 2003? 
can't remember. 
Okay. 
la the third incident accurate whom it 
6 
tel
 about October 5 or October 4, 20037 
A. 
I don't thew if it's 
accurate or not, but I 
know that 1 went to the house twice. 
Not three times? 
10 
Not three limos. 
11 
Any Idea why Kr. Lp 
 would talk about 
12 
three times? 
13 
A. 
Ito idea, sir. 
14 
Q. 
And any Idea why be would talk about a Clock 
15 
handgun? 
16 
A. 
NO, sir. 
17 
M. h. ITT 
Pons. 
BY M. BERGER: 
19 
0. 
New, you bold that -- that you had a -- Okay. 
20 
I've put this aside. ratan. to ask you another 
21 
quest ion, so why don't 
I don't want to distract 
22 
2) 
Xu, you meld that yew duagvasnt 
or Yaw 
24 
failing 
out wish No. Epstein was af ter you le ft  his 
ap:oyeent. 
Co you remember saying that? 
(S4 
,,<0 
roots car Procelnit AGENCY. INC. 
_es lwanaesm 
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.5611 0)2-7106 
Pogo 144 
Yea. 
After -- after this incident. 
0. 
NM what did that disagreement have to do 
3 
with? Did it have to do with these Incidents? 
Of course. 
I screw it up. 
Otay. 
And do you know who Nr. Aden I:ottoman 
6 
10 
Il 
12 
13 
lt 
15 
16 
17 
le 
19 
20 
21 
22 
2) 
24 
25 
A. 
Yea. 
Who is he? 
ms's en, Immet. 
0. 
And did dr. Epstein pay for Nr. I:ottoman:e 
legal services for you 
A. 
No. I pay on sty own pocket. 
O. 
Now, let ire ask you sone question, about son* 
property in Palm Beach County. Mx. /Cent. 
(5411 Ott-7500 
ex?rt «edi AZPOP7INC AGENCY. MC. 
....
`•••"'"*""'"'""m
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3504-022 
Page 16 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002630 
EFTA00157583

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0[1i 038-00) 
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25 
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4 
6 
0. 
Okay. 
And now. did Mt. Epstein contribute any 
emery to the purchase of any of these properties? 
A. 
NO contribute the -- he contribute the $20.000 
towers., the purchase of the fl rat property. 
10 
11 
I> 
0. 
01d he contribute Any other noney towards any 
11 
of the other prop 
IS 
16 
11 
Is 
IR 
20 
21 
22 
23 
24 
2. 
11411 012-1.00 
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061) 172-7506 
3504-022 
Page 17 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002631 
EFTA00157584

Page 149 
1 
Okay. 
2 
M. DIMCilt: Hark this ae Exhiblt 4. pleas.. 
3 
(Exhibit nutter 4 waa marked for 
4 
identification purposes.) 
5 
BY is. BERGER: 
6 
Q. 
Leek at Exhiblt I, sir. It's two pages. And 
1 
it's from Stolid. Department or State, DIvialon of 
e 
Corporations? 
9 
A. 
Yeah. 
10 
Q. 
And would you twin to the next page, the 
11 
second page? 
12 
On the anion.] page, do you see your signature 
13 
and your wife's? 
14 
A. 
Yes. 
IS 
Q. 
And 00 you recognize this as an application 
16 
for registration of a fictitious name? 
17 
A. 
Yeti. 
14 
O. 
Md is that --did you and your wife apply for 
19 
registration of a fictitious nine,
20 
A. 
Right. This w00 done by Our lawyer. 
21 
retternan. 
22 
O. 
MO was that done in 
Loot In 
23 
the upper right. 
24 
25 
O. 
Is that correct? 
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IWOUE COMM eiri(lniw) wait. MC. 
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Page 150 
A. 
2 
0. 
yes? 
A. 
Yes. 
4 
And the fictitious name was 
5 
Correct? 
6 
A. 
Mat's COrreCt. 
1 
O. 
Md did Jeffrey Epstein have anything 
whatsoever to do with the registration of this 
9 
fictitious flake? 
10 
A. 
Absolutely nothing. 
11 
MR. BERGER: Hark this es the next Enhiblt. 
12 
(Exhibit weber 3 wee marked for 
i) 
identification purp0008.) 
14 
M. NIL-.2T9: 
Spell the are of that la,' 
15 
M. PIERStR: 
It's 
16 
11 
M. NELLIIS: 
Thank you. 
1$ 
BY M. DERCER: 
19 
Q. 
Rs newt Exhibit, sir, has pipers grow 
20 
Departsent of State. Division of Corporations. Co ye, 
21 
see It makes reference to 
' 
lip at 
22 
the top. 
23 
It says: •Olt.111 by OffSCOr/regiSt•red agent 
24 
mow.' Md then erne( that It says. • 
23 
($41, 1)2-7,00 
thett pots? reenerne AWENC7. 
()tit al]-2526 
reswwwwernmenweennawares 
nw•w*••••••••••••••••`113iMernlwrewner inns ce.i• 
unr
•••••••••••••••
nesturisinnmamta 
rage 151 
1 
A. 
Were is that. sir? just point it. 
2 
O. 
Then it says, 
is that 
right? 
4 
A. 
Yes, sir. 
5 
Q. 
Then do you nee the next couple pages Includes 
6 
a letter free Man Fetterman Co the Departeent of State? 
• 
00 you see that? 
e 
A. 
Yes, sir. 
9 
O. 
And then the next -- the next page is an 
10 
articles -- articles of organization for-
11
Co you see that? 
12 
A. 
Yes, sir. 
13 
0. 
Md then on the very last page. Is that your 
14 
eIgnstere? 
15 
A. 
Yee, sir. 
1G 
O. 
Okay. le that your application to organise 
17 
le 
19 
A. 
Tes. i lest sign It. This vas dome by the 
20 
21 
O. 
Did Jaffrey Ep 
 have anything to do with 
22 
tee creation of this comiatiy? 
23 
A. 
Absolutely nothing. 
24 
O. 
Did Jeffrey Epstein pay for Mr. 
ttermages 
25 
services Of 40 this? 
1561' et2-1500 
MOE COURT 121CNTIMO ACFNCM NC. 
(5611 522-7106 
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Page 152 
A. 
Absolutely no. 
2 
O. 
Now, this 
Illmmears to have been incorporated in August et 200). 
4 
Co you recall that? Does that sound correct) 
A. 
Yeah. 
Q. 
Md between DeConbar Of 2002, when you loft 
7 
Mr. Epotelei's enplOynant. and August of 2003. 
e 
did you speak to 
9 
Jett." 
Epstein? 
10 
A. 
Never spoke again. 
1m 
O. 
Or with anybody on his behalf, such as his 
12 
staff or an investigator for hie? Anylardy/ 
13 
A. 
Nothing. 
le 
O. 
Okay. Old you go to his her* between January 
15 
and Aueve[ of 2003? 
16 
A. 
No. Except Hite, the two incidents that it 
17 
ha0Perle0. 
18 
Q. 
But those -- and these happened later, after 
19 
August of 2003. Correct? These happened nP 
20 
A. 
Yeah. t navet went to the home for any reason 
21 
to talk to hie or to anybody. 
22 
O. 
Okay. So in Se0teroer and October when you 
23 
went to Nt. Epstein's house --
24 
A. 
Yeah. 
25 
0. 
-- uninvited. --
'5611 9)2-)550 
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3504-022 
Page I 8 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002632 
EFTA00157585

1 
A. 
On-huh. 
2 
Page 1 
O. 
-- you Just assume that he would have money 
in hie briefcase? 
4 
A. 
1 assume. 
O. 
You hadn't talked to him in Alm/ nOnthsi la 
• 
that your testimony? 
that's ny testier:Cy. 
8 
0. 
And you said that you needed that seney 
because of 4 vegan ha 
you were fused up with? 
O 
A. 
That's CetreCt. 
11 
12 
11 
14 
IS 
1. 
17 
IR 
19 
20 
21 
22 
O. 
And then you said during the Questioning Of 
One or two of the attorneys that you entered into it 
24 
separation agreement with Mt. Epstein that included a 
25 
contident lllll 
y agreement and a release. 
Do you 
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renaaaer saying that ,
A. 
Yeah. 
MR. CRITICS: rota. 
DY BR. BERGER: 
And those were Signed by you? 
And We. Epstein. 
And was that signed after the October 
incident? 
We. 
This was signed in January 2003. 
10 
When you left? 
11 
Right after 1 heft. 
12 
13 
Right alit, 
: left, 
it 
was done through the 
14 
office in MOW York. 
Mr. Epottein never spoke to on 
IS 
again. St was done through the lawyers in Mew Toil. 
16 
they mends the paper vi. red Km. 
they send us a 
11 
check. 
That was the end of it. 
That happened in 
it 
January. January 1003. 
19 
Co you have a copy of those doCuments? 
20 
A. 
Hot In here. 
21 
0. 
Do you have then at Mee? 
22 
A. 
Yes, t do. 
21 
0. 
And let ne lust make cure I know whet the 
24 
documents are. 
29 
Threte. n a Separate on agreement: 
(541: 532-3/20 
VPD:E. COI*: am/CAI:in: ACCACY. 14C. 
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IftemeeelleVele ........Pr erdr eee Truet nee,. Its. fa • sitor.... 
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Chi) 132.7506 
Page ISS 
1 
A. 
Just a separation agreement. 
2 
0. 
And that includes a confidentiality 
prevision/ 
A. 
It was a -- there's a provision inside. 
4 
0. 
And It also inCludes in it a ******* Or IS the 
5 
relabel. separate? 
6 
A. 
1 don't knew. 
Lawyer terse. 
l'n not tannin 
• 
with that. 
• 
0. 
Did you nave a lawyer represent Neu in 
9 
COnnection with that? 
10 
A. 
No. 
1 never need It. 
11 
0. 
And you said Mr. Epstein pall you 150,000 to 
12 
you and 520.000 to your wife? 
1) 
A. 
Thet'S correct. 
14 
O. 
And haw was that paid to you? 
15 
A. 
Cash -- I Mean. check. 
It was • check but it 
16 
wOo take, -- tames were taken out. 
So at woe nines 
Id 
tare.. 
It 
Was It one check for each of you? 
It 
Yea. 
20 
MA. CRITTOM: 
Can we take a five-n1nute break? 
21 
5*. RACER: 
Side. 
22 
MA. cairnaoh 
Do you want to finish one line 
23 
of ciumationIno? 
24 
ie . BERGER. 
Os, go ahead. 
Co ahead. 
25 
VIDTOGRAPRTA . 
Off the record At 2:15. 
15411 8)2-15x1 
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Page 156 
1 
It rial 
recosal 
2 
VIDECCAAPAIR: 
We're back on the record at 
2:21. 
4 
BY KR. BEAGLE: 
Q. 
Mow say Lives Klee you talked with 
6 
Investigators of Mr. Rpstein/ 
1 
On. tine. 
And that's the one tins that you've month/fled 
9 
already? 
10 
A. 
Yes. 
11 
O. 
Aral have you net -- talked to Mc. Critton 
13 
helots today? 
13 
A. 
Oh, wait • Minute. 
Sorry. 
I haw 
to Ori beck 
14 
on that. 
Twice. 
One tine when the Criminal Case 
If 
started when they, like, 
find the card and Jeffrey say., 
14 
1 cannot talk to you. sonebody will 
call you. 
I talked 
I/ 
the eeeeeee gator that I told you. 
18 
And the second time was. I guess,. 
If 
don't know who was it, 
but they send -- they and in 
20 
the -- !don't. 
know If lawn 
fan invest %gator or they 
21 
Just Pie* a 
your notice that L was Pelee to be 
22 
subpoena. 
23 
ER. TRITION: 
I think that case from 
34 
Mr. Vliiite' 
Office. 
25 
NA 
WILLITS: 
Jack Rill's 
office. 
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3504-022 
Page 19 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002633 
EFTA00157586

Page 151 
MA. CRIBION: That wasn't an investigator. It 
2 
we, a subpoena served) 
3 
BIM WITNESS: Yeah. 
BY M. BERVIZR: 
5 
Q. 
Proems seven. Process server. 
6 
New, this Is Mr. Robert Celtton. Nave you 
7 
talked to has before today? 
A. 
Yes, sir. 
9 
0. 
Mow many tines have you tailed to Mr. Ctlttord 
10 
A. 
WICO In my house. MI w• talk about ten 
ll 
minutes yesterday? Monday? Monday? 
12 
0. 
Yesterday? 
1) 
A. 
Yesterday. 
14 
O. 
Okay. 
And whet did you discuss? 
15 
A. 
Discuss the Mae questions that you telling 
16 
me. Md he told ne basically. say the truth. Tell the 
I? 
troth, nothing but the truth. Md be fin, and be --
IS 
spook your RIM and don't be  
19 
thought that this incident about way life 
20 
never would have come out. 
1 wish It would have never 
21 
come at. nut 1 quesa it cone out and id'. 
too lore. 
22 
0. 
Wall, you tom what this case Is about. don't 
2) 
you? 
24 
A. 
Of course. 
I think It's 
a Case egalisM 
25 
Mr. Epatoln. 
But it's 
net a case against me. is it? 
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MOSE COURT REPIRTION MERCY. MC. 
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(5611 $12-1506 
Page 156 
1 
2 
A. 
• 
O. 
AM you lode it's 
--
4 
(Brief interruption.) 
5 
BY MA. litRCOR: 
6 
O. 
MO you know It's 
• serious Case for the 
• 
people that ere bringing It? 
TWA COAT: 
Pore. 
9 
h6 INTS[3:: 
Absolutely. 
10 
BY DIR. URGER: 
11 
O. 
So you had this Conversation with Mr. Crltton 
12 
yesterday? 
1) 
A. 
Mot about the seriousness, no. 
14 
Q. 
NO. 
No. 
But the conversation that you had 
11 
with Mr. Crittit 
MS yesterday, Correct? 
16 
A. 
Yes. 
Told his he -- he told we basically he
17 
was going to be here, that a bunch ci lawyers were going 
le 
to ask no 000sti006 end that 1 should be truthful 
and 
If 
nothing else. basically. 
20 
0. 
Nell, what etas did he say? 
21 
A. 
What else did Mr. Britten 
says? 
Nothing. Ii. 
22 
eked n• about Sly health. 
2) 
Me 'mkt, — how 1 felt. 
24 
And 1 says, well. 1 vast tO get this dome. 
1 
25 
went to get it over, done, and go on with sy Ille 
for 
1161s 0)2-7100 
MOM COURT REICOTING AGDO7. INC. 
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112'1104 
Page 159 
the rest of my life. 
I want to finish with this. 
2 
don't went nothing to de with Jet fray Bp/dein or this 
Case, once and for all. 
4 
0. 
Old you talk to him about the confidentiality 
5 
MretiOnt that you Mat toned? 
6 
A. 
7 
O. 
Or the separation agreements 
A. 
Mo. 
9 
O. 
Or the arrest? 
10 
A. 
NO. 
11 
O. 
Or the :30,000 that you. were paid? 
12 
1) 
O. 
Did he tell 
you that this case that kms.. here 
14 
about -
15 
A. 
330,000 where/ 
that 3)0,0007 
16 
0. 
TOY said you ware paid 330,000 and yowl ware 
17 
was Intel :20,00O. 
IS 
Yea. 
Yoe. 
The separation ogreenent. 
NO. 
19 
20 
0. 
You didn't talk about that? 
21 
22 
O. 
Old he tell 
you there wets stung women suing 
2) 
Mr. Epstein? Old he tell 
you that yesterday? 
24 
A. 
Ne. 
He mentioned to ma :het it was • lot of 
21 
lawsuit. against Mr. Epstein, crIninal drA civil sults. 
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Page 160 
1 
And -- not yesterday, but whet he was In my home with 
2 
his secretary. 
O. 
NO% yesterday? 
A. 
Not yesterday. 
0. 
when ass he was et your house with the 
6 
secretary? 
A. 
About two Maths age, a month and a half ago. 
• 
0. 
TM can't look to hi. to &Muer. 
You've Mt 
9 
t0 
10 
A. 
1 cannot remember MeCtly the date. but 
11 
would say it 
was about a month age. 
12 
O. 
Maybe f aisunderstood. 
Mas Mr. CrItton at 
IJ 
your house yesterday? 
14 
No. 
No called se yesterday. 
is 
No celled you yesterday? 
Id 
A. 
Yea, Mr. 
17 
Q. 
And you tal tad for about tan minutes yesterday 
IS 
on the phone? 
19 
A. 
No more. 
20 
0. 
01d you tell 
me everything that you and 
21 
Mr. CrIttOn talked about yesterday? 
22 
A. 
Yes. 
2) 
O. 
Now. he wished your house --
24 
A. 
Yea. 
25 
O. 
-- • month and a half or two months ago 
061( $12.7100 
PRO= COURT INPORTIM ACKACY, 
car 
maemamireesseammatemrimmi 
•••••••••••••ase. 
tc:, es:-nor. 
3504-022 
Page 20 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002634 
EFTA00157587