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FBI VOL00009

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1 
warrant being executed, if I understand you 
2 
correctly when Mr. Epstein was in town, there would 
3 
be a set appointment for let's say III and maybe in 
4 
the afternoon there might be one for 
or there 
5 
may only be one that day or on some occasions as you 
6 
have said there may be no young females coming to 
7 
the house that day, right? 
8 
A. 
Right. 
9 
Q. 
All right. After the search warrant was 
10 
executed for the most part, well, after the search 
11 
warrant was executed, Mr. Epstein spent his time 
12 
somewhere else, most likely in New York? 
13 
A. 
Right. 
14 
Q. 
And then he came back down to Florida at 
15 
some point in time. He went over to the courthouse 
16 
and he pled guilty to certain felonies that were 
17 
charged against him. And then he went to jail and 
18 
you didn't see him at the house anymore? 
19 
A. 
Yes. 
20 
Q. 
And then for some period of time now, six 
21 
or seven months or so, he has been on house arrest 
22 
and so you see him in West Palm Beach? 
23 
A. 
Yes. 
24 
Q. 
Or sorry, Palm Beach. I don't know where 
25 
I am. And has there been occasions where you know 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
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of Mr. Epstein, since he's been on house arrest to 
2 
not stay at the house in Palm Beach, to stay 
3 
elsewhere? 
4 
A. 
I think he took a couple trips to New York. 
5 
Q. 
Okay. And that was to meet with lawyers 
6 
on some other case you understand? 
7 
A. 
Yes. 
8 
Q. 
Do you know what that case is about? 
9 
A. 
No. 
10 
Q. 
Something had to do with money and against. 
11 
some other company, do you know that? 
12 
MR. GOLDBERGER: Form. 
13 
THE WITNESS: No. 
14 
BY MR. EDWARDS: 
15 
Q. 
Have you ever heard of a corporation, of 
16 
DB Zwirn or something like that? 
17 
A. 
No. 
18 
Q. 
Doesn't ring a bell? 
19 
A. 
No. 
20 
Q. 
Okay. Other than the couple trips or two 
21 
trips to New York has he stayed at the house to the 
22 
best of your knowledge? 
23 
A. 
Yes. 
24 
Q. 
And were you ever familiar with where 
25 
would get the girls' name and/or would 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
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2 
3 
4 
5 
keep the girls' names and numbers that were coming 
to the house to provide massages? 
A. 
No. 
Q. 
You never saw them on a computer or on an 
appointment book or anything like that? 
6 
A. 
No. 
7 
Q. 
Okay. Do you know how it was that 
8 
would get the girls to arrive at the house at any 
9 
certain time? 
10 
A. 
No. 
11 
Q. 
And what was your understanding then of --
12 
well, strike that. Ghislaine Maxwell was somebody 
13 
that visited Mr. Epstein, I think if he was in town 
14 
three times a month, she would be in town with him 
15 
one time a month, paraphrasing your testimony, but 
16 
that was something that continued from the time you 
17 
first became employed through the search warrant 
18 
being executed on the home, right? 
19 
A. 
Right. 
20 
Q. 
Is that somebody, that being Ghislaine 
21 
Maxwell, somebody that you have seen at the house 
22 
since Mr. Epstein has been back at 358 Albrillo Way 
23 
on house arrest? 
24 
A. 
Can you rephrase? 
25 
Q. 
Sure. Since Mr. Epstein -- it was a bad 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
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question. Since Mr. Epstein has been back at the 
2 
house on house arrest, have you seen Ghislaine 
3 
Maxwell at the house? 
4 
A. 
No. 
5 
Q. 
Do you know if Ghislaine Maxwell and 
6 
Mr. Epstein still talk with one another? 
7 
A. 
Yes. 
8 
Q. 
And do they? 
9 
A. 
Yes. 
10 
Q. 
How frequently, if you know? 
11 
A. 
I don't know. She calls maybe twice asking 
12 
him if he is in the house. 
13 
Q. 
Why? Do you know why she calls? 
14 
A. 
No. 
15 
Q. 
Do you still contact her if you have 
16 
issues with the house or whatever, do you still 
17 
contact Ghislaine Maxwell? 
18 
A. 
No. 
19 
Q. 
You understood her to be a business 
20 
partner of some type back in 2005. What is your 
21 
understanding of Ghislaine Maxwell's relationship 
22 
with Mr. Epstein these days? 
23 
A. 
I don't know what is going on between them. 
24 
Q. 
Do you still think that they have a 
25 
business relationship of some sort? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
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1 
A. 
I don't know. 
2 
Q. 
Okay. And you're here obviously with an 
3 
attorney today, Jack Goldberger, who is also an 
4 
attorney for Mr. Epstein. Safe to assume that 
5 
6 
Mr. Epstein retained Mr. Goldberger for you? 
A. 
Yes. 
7 
Q. 
And whatever fee is being charged by 
8 
Mr. Goldberger, that's something that's being paid 
9 
by Mr. Epstein, not by you? 
10 
A. 
Right. 
11 
Q. 
Okay. And other than 
12 
serving I guess these days as somebody who you would 
13 
consider Mr. Epstein's girlfriend, would you 
14 
consider her to have some sort of business 
15 
relationship with Mr. Epstein as well? 
16 
MR. GOLDBERGER: Form. 
17 
THE WITNESS: I don't know. 
18 
BY MR. EDWARDS: 
19 
Q. 
What do you consider 
role 
20 
to be these days in Mr. Epstein's life? 
21 
A. 
She's his assistant. She may hold a, schedule 
22 
appointments. 
23 
Q. 
Okay. Well, these days Mr. Epstein's on 
24 
house arrest, right? 
25 
A. 
Yes. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
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Q. 
So, what kind of appointment is she 
2 
scheduling for him if you know? 
3 
MR. GOLDBERGER: Form. 
4 
THE WITNESS: I don't know. Some, for 
5 
example, on his trips to New York she organize 
6 
everything, you know, schedule whose flying to 
7 
New York, pick him up from, bring him to the 
8 
airport, pick him up from the airport, bring 
9 
him to the house. I guess she organize all the 
10 
logistic stuff involving his either trips or 
11 
even staying in the house. 
12 
BY MR. EDWARDS: 
13 
Q. 
But these are trips that he's taken I 
14 
think you said two or three times since, in the last. 
15 
seven months or so right? 
16 
A. 
Right. 
17 
Q. 
But what does she do for him on the other 
18 
days when he's not traveling to and from New York? 
19 
A. 
I don't know. 
20 
Q. 
Okay. 
21 
A. 
To tell you the truth, I don't know. 
22 
Q. 
One of the things that she did back in 
23 
2005 was she scheduled his massage appointments with 
24 
these young females who would come to the house, 
25 
right? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
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A. 
Yeah. 
2 
Q. 
That's obviously not something she does 
3 
for him anymore? 
4 
A. 
Correct. 
5 
Q. 
Okay. I mean, to the best of your 
6 
knowledge that doesn't happen anymore? 
7 
A. 
Yes. 
8 
Q. 
And do you know somebody named 
9 
10 
A. 
Yes. 
11 
Q. 
What does -- is he employed by Jeffrey 
12 
Epstein? 
13 
A. 
I assume. 
14 
Q. 
What does he do for Jeffrey Epstein? 
15 
A. 
Some kind of assistant to --
16 
Q. 
Okay. 
17 
A. 
-- to help him to paperwork, whatever. 
18 
Q. 
Since he is 
I am sorry. I didn't mean 
19 
to cut you off. What did you say? 
20 
A. 
I assume that he is one of those person 
21 
involved with organizing his, I would say life. 
22 
Q. 
Okay. And based on what observations do 
23 
you reach that conclusion? 
24 
MR. GOLDBERGER: Form. 
25 
THE WITNESS: I notice he calls a lot of, 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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you know, contractors to do some work around 
2 
the house, irrigation system, lighting, 
3 
landscaping. 
4 
BY MR. EDWARDS: 
5 
Q. 
All right. And does he come to the house 
6 
quite frequently? 
7 
A. 
Yes. 
8 
Q. 
All right. Does he on occasion give 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Mr. Epstein rides places? 
A. 
Yes. 
Q• 
All right. So, you have observed since 
Mr. Epstein has been on house arrest that's also 
somebody who visited Mr. Epstein in jail while he 
was in jail, right? 
A. 
Q. 
A. 
4. 
Yes, right. 
He visited him quite frequently in jail? 
Yes. 
Do you know how Mr. Epstein met 
A. 
No. 
Q. 
Is 
A. 
Yes. 
Q. 
And how did you know that? 
A. 
How did I know that? I notice that they spend 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
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a lot of time together. 
2 
Q • 
You observe them around the house and 
4 
A. 
Yes. 
5 
Q. 
All right. And does 
stay the 
6 
night at Mr. Epstein's house? 
7 
A. 
No. 
8 
Q. 
You have never seen him stay the night 
9 
there? 
10 
A. 
No. 
11 
Q. 
All right. And on any given week, how 
12 
often will 
show up to Jeffrey Epstein's 
13 
house or report to Jeffrey Epstein's house for work? 
14 
A. 
Currently? 
15 
Q. 
Yeah. I mean, I am talking specifically 
16 
about the time period since Mr. Epstein has been on 
17 
house arrest? 
18 
A. 
Very often. 
19 
Q. 
Every day? 
20 
A. 
Three or four times a week. 
21 
Q. 
Okay. And when you became employed with 
22 
Mr. Epstein, did you sign a confidentiality 
23 
agreement? 
24 
A. 
Yes. 
25 
Q. 
And what did that confidentiality 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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agreement say? 
2 
MR. GOLDBERGER: Form. 
3 
THE WITNESS: I don't remember to tell you 
4 
the truth. 
5 
MR. EDWARDS: Okay. 
6 
THE WITNESS: I would say basic 
7 
confidentiality agreement. I don't know 
8 
exactly details but from my own knowledge I not 
9 
supposed to release information what, what is 
10 
going on in the, in Mr. Epstein organization. 
11 
BY MR. EDWARDS: 
12 
Q. 
And when we talk about Mr. Epstein's 
13 
organization, we're talking about those people that 
14 
you told us about earlier, right? 
15 
A. 
Right. 
16 
Q. 
Okay. So, if you know information about 
17 
what those people are doing with one another as an 
18 
organization or what is going on inside the house or 
19 
things of that nature, based on this confidentiality 
20 
agreement you're not supposed to say anything? 
21 
A. 
Yes. 
22 
Q. 
And it's your understanding that 
23 
has also signed a confidentiality agreement 
24 
with Mr. Epstein? 
25 
A. 
No. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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1 
Q. 
You don't know? 
2 
A. 
I don't know. 
3 
Q. 
Do you know if 
signed one? 
4 
A. 
Yes. 
5 
Q. 
How do you know that? 
6 
A. 
She told me. 
7 
Q. 
She did. Okay. Isn't that a violation of 
8 
the confidentiality agreement. Is it you're --
9 
other than 
and yourself, do you know 
10 
of anybody else who signed a confidentiality 
11 
agreement? 
12 
A. 
No. 
13 
Q. 
Do you have a copy of the confidentiality 
14 
agreement? 
15 
A. 
No. 
16 
Q. 
That's something that you supposedly read 
17 
at some point in time, signed it and then you gave 
18 
it back to somebody? 
19 
A. 
Yes. I knew it would happen before I got 
20 
hired, so it's 2005. I know I read it. I sign it, but 
21 
I don't know even know if I, if I have it in my 
22 
possession, a copy of this agreement. 
23 
Q. 
Okay. Do you know people that used to 
24 
work at the house Michael and 
25 
A. 
No. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
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1 
Q. 
Never heard of them? 
2 
A. 
No. 
3 
Q. 
All right. During the year 2005, what 
4 
other visitors do you remember frequenting the house 
5 
when Mr. Epstein was in town aside from 
6 
Ghislaine Maxwell, 
yourself? Who 
7 
else do you remember being there? 
8 
A. 
I don't remember. 
9 
Q. 
All right. Do you know the magician David 
10 
Copperfield? 
11 
A. 
Yes. 
12 
Q. 
Did you see him at the house? 
13 
A. 
No. 
14 
Q. 
Never? 
15 
A. 
No, never. 
16 
Q. 
Okay. Have you seen him at the house? 
17 
Not just in 2005 that we're focusing on the previous 
18 
question, have you ever seen him at the time house? 
19 
A. 
No. 
20 
Q. 
No. Okay. Back in 2005, how about the 
21 
attorney Alan Dershowitz, do you remember seeing him 
22 
at the house? 
23 
A. 
Yes. 
24 
Q. 
And how many occasions do you believe you 
25 
saw him at the house? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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1 
A. 
Maybe twice. 
2 
Q. 
And on the two occasions are we talking 
3 
about he stayed for three days each time, or you 
4 
only saw him on two days if you remember? 
5 
A. 
I think it was either a couple or three days. 
6 
I don't remember exactly. 
7 
Q. 
Okay. So, he may have come in town two 
8 
times and stayed two days each time; is that what 
9 
you are saying? 
10 
A. 
Correct. 
11 
Q. 
Okay. And where would he stay when he was 
12 
at Jeffrey Epstein's house, what room? 
13 
A. 
I don't remember which room. It had like a 
14 
four additional bedrooms. 
15 
Q. 
Okay. And what would, you know, on the 
16 
occasions when Mr. Dershowitz was in the house and a 
17 
young female would come over to give Mr. Epstein a 
18 
massage, if you know, let's say the process I am 
19 
assuming is the same as you told us before, you 
20 
greet them at the door, you're told the person is 
21 
coming, you greet them at the door, you bring them 
22 
in, you let 
know the person is there. And 
23 
what then did you observe or where in the house 
24 
would Mr. Dershowitz stay while Mr. Epstein was 
25 
getting this massage? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
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MR. GOLDBERGER: Form. 
2 
THE WITNESS: I don't remember having him 
3 
and either young girls at the same time at the 
4 
house. I don't recall. I don't remember. 
5 
BY MR. EDWARDS: 
6 
Q. 
Okay. Fair enough. I think I presupposed 
7 
something that may not have been accurate. So, to 
8 
your recollection the two to four days that you 
9 
remember Mr. Dershowitz being at the house, you 
10 
can't say with any degree of certainty that these 
11 
young females were also at the house? 
12 
A. 
Yeah. Right. 
13 
Q. 
Okay. Do you remember there ever being an 
14 
occasion where there was some other person, aside 
15 
from the people that we all know regularly are at 
16 
Mr. Epstein's house that we have named a few times, 
17 
do you ever remember any other people being inside 
18 
the house when these young females or a young female 
19 
would be at the house to give Mr. Epstein a massage? 
20 
A. 
No. 
21 
Q. 
Okay. So, to the best of your 
22 
recollection any time that these young females were 
23 
at the house, it was a time when Mr. Epstein and 
24 
other members of the organization, as you referred 
25 
to it, were in the house only? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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1 
A. 
Right. 
2 
Q. 
Okay. Do you know any of Mr. Epstein's 
3 
neighbors? 
4 
A. 
I know who lives next, I mean, across the 
5 
6 
street, but I never met, I never talk with them. The 
only thing, I talk with the guy who work for them. 
7 
Q. 
Who is the guy who worked for him? 
8 
A. 
His name is Mike. 
9 
Q. 
And when you say --
10 
A. 
Across the street. Sometimes, you know, we 
11 
exchange hello, how are you doing. That's it, but I 
12 
don't keep any, I would say relationship with him. 
13 
Q. 
When you say the guy across the street, 
14 
directly across street from Mr. Epstein? 
15 
A. 
Directly across the street. 
16 
Q. 
Do you know what that person's name is who 
17 
owns that house? 
18 
A. 
Cunningham, last name is Cunningham, I think. 
19 
Q. 
Okay. And have you ever met that person 
20 
before? 
21 
A. 
No. 
22 
Q. 
Do you know of any occasion when that 
23 
person, Mr. Cunningham, has ever come over to 
24 
Mr. Epstein's house? 
25 
A. 
No. 
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Page S6 
1 
Q. 
Any occasion when Mr. Epstein has gone 
2 
over to Mr. Cunningham's house? 
3 
A. 
No. 
4 
Q. 
Is that a neighbor of Mr. Epstein's that 
5 
you are aware that Mr. Epstein knows or talks to? 
6 
7 
8 
9 
10 
11 
12 
13 
A. 
I don't remember but probably before the 
14 
search warrant. 
15 
Q. 
Okay. The time when she took the 
16 
computers out of the house or she came back after 
17 
that? 
18 
A. 
She came back after that. 
19 
Q. 
Okay. So, the time when the search 
20 
warrant was executed, that's the last time you 
21 
remember her being at the house? 
22 
A. 
Yes. 
23 
24 
talked over each other a little bit. 
25 
A. 
No, I have no idea. 
Q. 
Does Mr. Epstein talk with any of his 
neighbors that you know of? 
A. 
I never saw. 
Q. 
Do you ever to talk to 
anymore? 
A. 
No. 
Q. 
When was the last time you saw her? 
MR. EDWARDS: Did you get that? I know we 
(561) 832-7500 
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Page S7 
1 
BY MR. EDWARDS: 
2 
Q. 
And the appointment book for Mr. Epstein's 
3 
schedule on any given day, do you know where that 
4 
was kept? 
5 
A. 
No. 
6 
Q. 
Did you ever see it? 
7 
A. 
No. 
8 
MR. GOLDBERGER: Form. 
9 
BY MR. EDWARDS: 
10 
Q. 
You don't even know if it existed? 
11 
A. 
Right. 
12 
Q. 
could have had all this 
13 
information in her head for all you know? 
14 
A. 
Could be. 
15 
Q. 
How about the message pads that, I don't 
16 
know if you're aware of this but there were certain 
17 
messages that were accumulated by the police 
18 
department in part because of the criminal 
19 
investigation and they had been turned over as part 
20 
of the State Attorney's file. I don't really need 
21 
to get into the basics, but I just wanted to 
22 
familiarize yourself with what I am talking about. 
23 
Do you know what I am talking about, message pads? 
24 
A. 
Yes. 
25 
Q. 
And where was that message pad book kept 
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Page SE 
1 
inside the house? 
2 
A. 
There were a few of them, message books. One 
3 
was in the kitchen when most of the time, you know, 
4 
people pick up the phone and get the message for Jeffrey 
5 
Epstein. I had one in my desk in my office. 
6 
Q. 
Okay. So, there is one in the kitchen. 
7 
You had one at your desk, office? 
8 
A. 
Right. 
9 
Q. 
Or your office desk. And where, where --
10 
were there any additional ones? 
11 
A. 
I think the one was in the office next to the 
12 
kitchen. 
13 
Q. 
Okay. And who within the house was able 
14 
to take a message or allowed to take a message for 
15 
Mr. Epstein, answer the phone and take a message and 
16 
write it down? 
17 
A. 
I was the one. 
was the one. 
18 
And anybody who was close to the phone I guess. 
19 
Q. 
Okay. There were no set rules as to --
20 
A. 
No. 
21 
Q. 
Okay. Well, I did learn of some 
22 
information at some point in time that there was a, 
23 
I don't want to say a rule book or a manuscript, but. 
24 
there was some level of organization to various 
25 
roles in the house, yours or somebody else's and 
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Page 
1 
what to do in certain situations. Are you familiar 
2 
with the book I am talking about? 
3 
A. 
Yes, it was like a manual. 
4 
Q. 
Right. 
5 
A. 
How to, I would say, conduct yourself and how 
6 
to make things around the house, like rules or help with 
7 
things to make sure that, you know, everything is the 
8 
right way in the house. 
9 
Q. 
What is your, and when you say everything 
10 
is the right way, by whose standards? 
11 
MR. GOLDBERGER: Form. 
12 
THE WITNESS: Whose standards? Jeffrey 
13 
Epstein. 
14 
BY MR. EDWARDS: 
15 
Q. 
Is he very particular with how things are 
16 
in the house? 
17 
A. 
I mean, he, he is not very strict but he would 
18 
like, you know, to do certain things in his way I would 
19 
say. 
20 
Q. 
Okay. Would you say that he sticks to a 
21 
pretty strict schedule? 
22 
A. 
No. 
23 
Q. 
Okay. Back in 2005 was his schedule more 
24 
strict in terms of when he woke up, when he had 
25 
breakfast, what he had for breakfast? 
(561) 832-7500 
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Page 100 
1 
A. 
Same thing I would say. He didn't change. 
2 
Q. 
So, the only thing that you can tell me 
3 
that has changed about his schedule from 2005, the 
4 
time period before the execution of the search 
5 
warrant to the time now where he is on house arrest, 
6 
is that he no longer has these young females over to 
7 
give him massages? 
8 
MR. GOLDBERGER: Form. 
9 
BY MR. EDWARDS: 
10 
Q. 
That's the only thing that's changed? 
11 
MR. GOLDBERGER: Form. 
12 
THE WITNESS: Yes. 
13 
BY MR. EDWARDS: 
14 
Q. 
This manual on how to conduct yourself, do 
15 
you a have a copy of it? 
16 
A. 
No. 
17 
Q. 
Okay. 
18 
A. 
I used to have but they, it has been changed a 
19 
little bit. So, at one point 
asked me to give it 
20 
to her. She would like to take a look and, you know, 
21 
either update it or change something and she never gave 
22 
me back, so 
23 
Q. 
Okay. So when, when was that, when did 
24 
that occur when 
asked you for the manual so 
25 
that she could update it or read it or whatever? 
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