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1 
Q. 
Did you have any concerns while you were 
2 
working there that criminal acts were occurring with the 
3 
girls who were coming to the door? 
4 
MR. CRITTON: Form. 
5 
THE WITNESS: I had no idea what was going on 
6 
between them. 
7 
BY MR. MERMELSTEIN: 
8 
Q. 
Let me just give you some other names. Tell 
9 
me if you recognize any of these names. 
10 
7 
11 
A. 
(Nods head.) 
12 
Q. 
Name does not ring a bell? 
13 
A. 
(Nods head.) 
14 
MR. CRITTON: You have to answer out loud. 
15 
BY MR. MERMELSTEIN: 
16 
Q. 
You need to say yes or no. 
17 
A. 
No. 
18 
Q. 
M.? 
19 
A. 
Can you repeat that? 
20 
Q. 
II would be the first name. II would be the 
21 
second name? 
22 
A. 
No. 
23 
Q. 
24 
A. 
No. 
25 
Q. 
M.? 
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A. 
No. 
2 
Q. 
M.? 
3 
A. 
No. None of those girls' --
4 
Q. 
None of those girls ring a bell at all? 
5 
A. 
-- name familiar to me. 
6 
Either they came one time, one day and they 
7 
didn't even told me their names or -- or he paid for it 
8 
that I don't have -- but none of those names sound 
9 
familiar to me. 
10 
Q. 
You testified that there were -- about the sex 
11 
toys that you would pick up after 
after there were 
12 
massages, correct? 
13 
MR. CRITTON: Form. 
14 
BY MR. MERMELSTEIN: 
15 
Q. 
The vibrators, correct? 
16 
MR. CRITTON: Form. 
17 
BY MR. MERMELSTEIN: 
18 
Q. 
You can answer. 
19 
A. 
Yes. 
20 
Q. 
And you mentioned there was a basket with 
21 
these vibrators or toys in them, correct? 
22 
A. 
Yes. 
23 
Q. 
Where was the basket kept? 
24 
A. 
In Ms. Maxwell's closet. 
25 
Q. 
And that was in the master bedroom? 
PROSE COURT REPORTING AGENCY, INC. 
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MR. CRITTON: Form. 
2 
BY MR. MERMELSTEIN: 
3 
Q. 
Or off the master bathroom? 
4 
A. 
Her bathroom. 
5 
Q. 
Huh? 
6 
A. 
Her bathroom. 
7 
Q. 
And the closet was -- the entrance to the 
8 
closet was in her bathroom? 
9 
A. 
That's correct. 
10 
Q. 
And it was a portable basket, she could move 
11 
it around, correct? 
12 
A. 
Uh-huh. 
13 
Q. 
You have to say yes or no. 
14 
A. 
Yes, sir. 
15 
Q. 
And -- and that's where the, I think you used 
16 
the word dildo, correct? That's where they were 
17 
located? 
18 
A. 
Yes, sir. 
19 
Q. 
Was there occasions where you would -- the 
20 
dildo, one or more dildos would be out and you would 
21 
clean them up after a massage that only Mr. Epstein had, 
22 
not Ms. Maxwell? 
23 
A. 
It was -- I will says that it was about three 
24 
or four occasions that I had to take this dildos and put 
25 
it back where they supposed to be. And I took it with 
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gloves and towels and stick it in the sink and throw it 
2 
in there. 
3 
Sometimes Ms. Maxwell will have a massage. 
4 
And sometimes I find it after she's supposed to have a 
5 
massage, those things. And also when Mr. Epstein had 
6 
the massage. So I don't know who use it on who. 
7 
Because sometimes they all disappear up there, 
8 
Mr. Epstein, Ms. Maxwell and whoever was up there. 
9 
Q. 
So as I understand it, you couldn't isolate a 
10 
particular instant where --
11 
A. 
I cannot. 
12 
Q. 
-- Ms. Maxwell wasn't there, only Mr. Epstein 
13 
had gotten a massage and then you found the sex toys? 
14 
A. 
I cannot isolate that. 
15 
Q. 
But it's possible that either Mr. Epstein used 
16 
it or Ms. Maxwell used it; is that correct? 
17 
MR. CRITTON: Form. Form. 
18 
THE WITNESS: I have no idea to know. 
19 
MR. MERMELSTEIN: All right. I have nothing 
20 
further. 
21 
MR. BERGER: How about if we take a break? 
22 
Would you like a break for a couple minutes? 
23 
THE WITNESS: No, that's fine. 
24 
MR. BERGER: Mr. Willits, would it be possible 
25 
if I could sit there, because I've got a couple 
PROSE COURT REPORTING AGENCY, INC. 
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Exhibits I'm going to show him? 
2 
MR. WILLITS: Sure. 
3 
MR. BERGER: Thanks. 
4 
CROSS EXAMINATION 
5 
BY MR. BERGER: 
6 
Q. 
Okay. Good afternoon, sir. 
7 
A. 
Afternoon, sir. 
8 
Q. 
My name is William J. Berger and I represent 
9 
three of the Plaintiffs in this case. 
10 
Did you ever hear of the name I., a young 
11 
woman named I.? 
12 
A. 
No, sir. 
13 
Q. 
How about a young woman named II? 
14 
A. 
No, sir. 
15 
Q. 
Okay. You know, you've referred several times 
16 
to a falling out or a disagreement that you had with 
17 
Mr. Epstein? 
18 
A. 
Yes. 
19 
Q. 
Was that in 
was that the year that you left 
20 
his employment? 
21 
A. 
Right after 
right after I left. 
22 
Q. 
So you had a falling out with him after you 
23 
left his employment? 
24 
A. 
Yes. 
25 
Q. 
Well, why did you leave his employment? 
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A. 
Why? 
2 
Q. 
Yeah. 
3 
A. 
Because I was sick. I was extremely sick. I 
4 
was bleeding, internally bleeding, and I was bleeding 
5 
from my butt and I have fistulas in my colon. And I was 
6 
sick of the job and we had enough. We had good pay, but 
7 
we had enough of the job, especially laersasia-af 
8 
Ms. Maxwell's attitude towards us. 
9 
Q. 
Now, you said you had good pay, but we had 
10 
enough. What was your pay in 2002? 
11 
A. 
2002, right before I left? I think it was 50, 
12 
either 55, something like that. And my wife was 30 or 
13 
35. I could be wrong. 
14 
Q. 
So you think that you were paid $55,000 in 
15 
2002? 
16 
A. 
Uh-huh. 
17 
Q. 
Is that correct? 
18 
A. 
That's correct. 
19 
Q. 
And you believe your wife was paid how much? 
20 
A. 
Thirty, $30,000. 
21 
Q. 
$30,000 in 2002? 
22 
A. 
Uh-huh. 
23 
Q. 
Is that correct? 
24 
A. 
Yes, sir. 
25 
Q. 
How about 2001, what was your salary and your 
PROSE COURT REPORTING AGENCY, INC. 
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wife's? 
2 
A. 
Same thing. 
3 
Q. 
Okay. And in 2000? 
4 
A. 
I was at the same. It never -- we never got 
5 
raises. We never got 
6 
Q. 
I think you said at the very beginning --
7 
A. 
Yes. 
8 
Q. 
-- of the deposition that you were paid 45,000 
9 
when you were first hired full time? 
10 
A. 
Yeah. 
11 
Q. 
In 2002, you were earning 55,000? 
12 
A. 
Uh-huh. 
13 
Q. 
So you did get some raise? 
14 
A. 
Yeah. In the matter of 11 years. Yeah, but 
15 
we didn't get a raise every six months or every year in 
16 
any specific date. And the raises were set by the 
17 
company. Automatically they would come from New York. 
18 
It was not a negotiate point between me and Mr. Epstein. 
19 
Q. 
And then you said earlier with me, you said we 
20 
had enough, you and your wife. You said, we had enough; 
21 
is that correct? 
22 
A. 
That's correct. 
23 
Q. 
What do you mean by that? 
24 
A. 
It was extremely stressful job. It was a lot 
25 
of pressure on us -- on me, on me -- I have to 
PROSE COURT REPORTING AGENCY, INC. 
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correct -- on me. Everything was blamed on me. If a 
2 
chef cook a bad meal, it was my fault. And if the table 
3 
was not proper set royalty style, it was my fault. And 
4 
the hours were terrible, never have a holiday, Saturdays 
5 
and Sundays. We were working between 60 and 70 hours a 
6 
week. And my health was, I think, the most important 
7 
thing. And also the relation with my wife, it was a big 
8 
factor in us leaving the company. 
9 
Q. 
Now, you said that you were blamed for things? 
10 
A. 
Yes, sir. 
11 
Q. 
Who would blame you? Who is it that would say 
12 
that you were blamed? 
13 
A. 
I don't know who did the blaming, but I will 
14 
get my ass chewed out by Ms. Maxwell --
15 
Q. 
She was the one? 
16 
A. 
Most of the times, yes. 
17 
Q. 
Who else did that? 
18 
A. 
Sometimes I had disagreements with him. 
19 
Q. 
"Him," being, who? 
20 
A. 
Mr. Epstein. 
21 
Q. 
About what? 
22 
A. 
Simple things. For me, it's stupid things, 
23 
nothing -- if this paper -- if this pencil was not put 
24 
in right there, they will complain. 
25 
Q. 
Okay. And is it correct that you left the 
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employment of Mr. Epstein in December of 2002? Does 
2 
that sound correct? 
3 
A. 
That's correct. 
4 
Q. 
And the -- now, were you arrested in 2003? 
5 
A. 
I was never arrested. 
6 
Q. 
You did speak to the police? 
7 
A. 
Yes. 
8 
Q. 
And you did have your statement taken at the 
9 
State Attorney's Office? 
10 
A. 
Yes. 
11 
Q. 
But you -- but that was by an Assistant State 
12 
Attorney, correct? 
13 
A. 
Yes. 
14 
Q. 
The questioning? 
15 
A. 
(Nods head.) 
16 
Q. 
Is that correct? 
17 
A. 
That's correct. 
18 
Q. 
You spoke separately with police officers 
19 
though, correct? 
20 
MR. CRITTON: Form. 
21 
BY MR. BERGER: 
22 
Q. 
In other words, the date of that statement is 
23 
in October of 2003; is that correct? 
24 
A. 
Yes. 
25 
Q. 
And by "that statement," I mean, the 
PROSE COURT REPORTING AGENCY, INC. 
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transcript that I gave you earlier? 
2 
A. 
At what date, sir? 
3 
MR. MERMELSTEIN: 2005. 
4 
MR. BERGER: I'm sorry. You're correct. 
5 
Thank you. Sorry. 
6 
THE WITNESS: 2005. 
7 
MR. BERGER: In fact, let's -- Ms. Reporter, 
8 
would you mark the transcript if anybody needs it? 
9 
10 
11 
12 
13 
14 
Exhibit number is by everybody. 
15 
(Exhibit number 2 was marked for 
16 
identification purposes.) 
17 
BY MR. BERGER: 
18 
Q. 
You see Exhibit 2? It's a transcript; is that 
19 
correct? 
20 
A. 
That's correct. 
21 
Q. 
Is that the transcript of the sworn statement 
22 
that you gave to the Assistant State Attorney in 2005? 
23 
A. 
Yes, sir. 
24 
Q. 
And during the lunch break, did you have an 
25 
opportunity to read it? 
MR. CRITTON: It's Exhibit 2 now? 
MR. BERGER: Is that how you're doing it, just 
consecutively? 
MR. CRITTON: Yeah, let's do it; otherwise, 
it's going to be an awful mess, have five different 
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A. 
Yes, sir. 
2 
Q. 
And do you remember that you were placed under 
3 
oath when you gave that statement? 
4 
A. 
Yes, sir. 
5 
Q. 
And is everything that you say in here 
6 
truthful and correct? 
7 
A. 
As far as I know, yes, sir. 
8 
Q. 
Okay. Now, in connection with the incident in 
9 
October of 2003 involving Mr. Epstein's house and your 
10 
entering his house, that incident? 
11 
A. 
It was in October 2003? 
12 
Q. 
When do you remember that it was? 
13 
A. 
I can't remember. 
14 
Q. 
Okay. All right. You spoke with police 
15 
officers in connection with that though, correct? 
16 
A. 
I went to the Palm Beach Police Department. 
17 
Q. 
Why did you go to the --
18 
A. 
I speak to one officer. 
19 
Q. 
And why did you go there? 
20 
A. 
Because Mr. -- when I spoke to Mr. Epstein and 
21 
we settle the dispute, Mr. Epstein says, you just need 
22 
to go to the police department and make a statement. 
23 
MR. WILLITS: Could I have Exhibit number 2, 
24 
please? 
25 
Thank you. 
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BY MR. BERGER: 
2 
Q. 
Let me see if I understand this correctly. 
3 
I think you testified earlier that you found a 
4 
card or you were given a card from a police officer; is 
5 
that correct? 
6 
A. 
That's correct. 
7 
Q. 
And as a result of that, you called 
8 
Mr Epstein, correct? 
9 
A. 
That's correct. 
10 
Q. 
Before you got that card, did you have any 
11 
idea that the police were involved in your life? 
12 
A. 
No. 
13 
MR. CRITTON: Form. 
14 
BY MR. BERGER: 
15 
Q. 
And you called Mr. Epstein after you got that 
16 
card, correct? 
17 
A. 
Yes. 
18 
Q. 
Now, how did you get it? Was it mailed to 
19 
you? 
20 
A. 
No. It was putted in my door. I was not 
21 
home. And they went to my house and they left it in the 
22 
door. 
23 
Q. 
And did it have a note on it, please call? 
24 
A. 
Yes. 
25 
Q. 
Or was it just a card? 
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A. 
It was a -- it was a Palm Beach Police 
2 
Department, please call. 
3 
Q. 
Okay. And you didn't call though; you called 
4 
Mr. Epstein first, right? 
5 
A. 
Yeah. Because I was scared. 
6 
Q. 
Why were you scared? 
7 
A. 
Because I thought it was of the incident that 
8 
happens previously. 
9 
Q. 
And what was that incident? 
10 
A. 
You know that incident. 
11 
Q. 
I'd like to hear you describe it for me. 
12 
A. 
That incident is, I went to the house and I 
13 
got some money. 
14 
Q. 
What time of day did you go to the house? 
15 
A. 
Night. 
16 
Q. 
Was anybody home? 
17 
A. 
No. 
18 
Q. 
Where did you get the money? 
19 
A. 
Out of his bag. 
20 
Q. 
Out of his? 
21 
A. 
Bag. 
22 
Q. 
Bag. Briefcase? Bag? 
23 
A. 
Briefcase. 
24 
Q. 
Briefcase? 
25 
A. 
Yes. 
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Q. 
How did you -- did you know that there was 
2 
money in the briefcase? 
3 
A. 
Yes. 
4 
Q. 
How did you know that? 
5 
A. 
Because I replenish that case many times 
6 
before. 
7 
Q. 
Now, how many months after you left 
8 
Mr. Epstein's employment did this occur? 
9 
A. 
I don't have -- I would says, three to four 
10 
months. 
11 
Q. 
I would just ask a favor of you. The court 
12 
reporter needs to see your face so she can understand 
13 
what you're saying. She's looking -- you put your hand 
14 
in front of your mouth. That's all. 
15 
Now, when you worked for Mr. Epstein, did you 
16 
learn that he kept money in that briefcase? 
17 
A. 
Yes. 
18 
Q. 
And, so, when you went to his house on that 
19 
occasion, did you just assume that there would be money 
20 
in the briefcase? 
21 
A. 
Yes. 
22 
Q. 
And -- and did you take money out of that 
23 
briefcase? 
24 
A. 
Yes. 
25 
Q. 
Now, is that the only time that you took money 
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out --
2 
A. 
No. 
3 
Q. 
-- of his briefcase? 
4 
A. 
It was twice. 
5 
Q. 
When was the other time? 
6 
A. 
Couple weeks before. 
7 
Q. 
What time of day was that? 
8 
A. 
At night. 
9 
Q. 
And how much did you take out the first time? 
10 
A. 
It was a total of $6,300. 
11 
Q. 
That's for both times? 
12 
A. 
Yeah. 
13 
Q. 
Can you break them down? 
14 
A. 
I think one time was $1,500. Another time was 
15 
the rest. 
16 
Q. 
Now, you left in December of 2002 and then 
17 
there were these two incidents that you just described? 
18 
A. 
Uh-huh 
19 
Q. 
Did you have any contact with Mr. Epstein in 
20 
between leaving his employment and the first of these 
21 
two instances? 
22 
A. 
None. 
23 
Q. 
And as far as you knew, did anybody see you 
24 
take the money on either occasion? 
25 
A. 
None. 
PROSE COURT REPORTING AGENCY, INC. 
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1 
Q. 
And, so, when you saw the card from the 
2 
police, you assumed it had to do with these two 
3 
instances? 
4 
A. 
Yes, sir. 
5 
Q. 
And there was no other reason why you thought 
6 
it had to do with Mr. Epstein? 
7 
A. 
No, sir. 
8 
Q. 
And when you called him, did you discuss these 
9 
two incidents with him? 
10 
A. 
When I call Mr. --
11 
Q. 
You said you got the card --
12 
A. 
No. 
13 
Q. 
-- and then you called him? 
14 
A. 
No, we did not discuss that money or nothing 
15 
involved. 
16 
I ask him, what's going on, Jeffrey? What's 
17 
happening? I got this and I thought that this was all 
18 
over. 
19 
No, he says, John, it has nothing to do with 
20 
that money. 
21 
Q. 
Did you ever read the incident report by the 
22 
police, the Palm Beach Police Department? Did you ever 
23 
read it? 
24 
A. 
No. 
25 
MR. CRITTON: Regarding what? 
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MR. BERGER: Regarding these incidents. 
2 
BY MR. BERGER: 
3 
Q. 
You never read it? 
4 
A. 
No. 
5 
Q. 
Let me hand you this. 
6 
MR. CRITTON: Is there an extra copy? 
7 
MR. BERGER: Yeah. 
8 
BY MR. BERGER: 
9 
Q. 
What I'm showing you, have you ever seen this 
10 
before? 
11 
A. 
No. 
12 
MR. BERGER: Let's have this marked as Exhibit 
13 
3, please. 
14 
MR. CRITTON: Can I keep this? 
15 
(Exhibit number 3 was marked for 
16 
identification purposes.) 
17 
BY MR. BERGER: 
18 
Q. 
It appears to be about 20 pages and it has, 
19 
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 
23 
paragraph? Do you see where that starts? 
24 
A. 
Yes, sir. 
25 
Q. 
And it says: "On Sunday, October 5, '03 at 
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approximately 8:24 hours, I was dispatched to a burglary 
2 
at 358 El Brillo Way." 
3 
Do you see that? 
4 
A. 
Yeah. 
5 
Q. 
Now, October 5, 2003, do you recall that that 
6 
was about when the time you took the money from 
7 
Mr. Epstein's briefcase was? 
8 
A. 
Yes. I don't recall. But if they say it, I 
9 
have to agree with it. 
10 
Q. 
Well, you left in December of 
, g202, And 
11 
before I showed you this document, you said that these 
12 
incidents occurred about three or four months later. So 
13 
apparently they occurred more than three or four months 
14 
later; is that correct? 
15 
A. 
Apparently, yes. 
16 
Q. 
Well, now after -- after looking at this, sir, 
17 
do you actually recall that it occurred more than three 
18 
or four months later? 
19 
A. 
After looking at this? 
20 
Q. 
Yeah. 
21 
A. 
It could be. 
22 
Q. 
But do you actually remember it being more 
23 
than three or four months? 
24 
A. 
I don't remember if it was more than three 
25 
months. 
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Q. 
Okay. Okay. Now, if you look further down, 
2 
you'll see it says, quote, Epstein further advised a 
3 
black Glock handgun was taken from the book shelf 
4 
located behind the desk, unquote. 
5 
Do you see that? 
6 
A. 
Yes. 
7 
Q. 
Did you take a black Glock handgun from him? 
8 
A. 
Absolutely not. 
9 
Q. 
Do you know if anybody did? 
10 
A. 
No, sir. 
11 
Q. 
Is this the first time that you ever heard 
12 
that Mr. Epstein may have told the police 
13 
A. 
No. This question I was asked by the police. 
14 
Q. 
Okay. Now, you see the next sentence? It 
15 
says: "Epstein advised he suspected cash had been taken 
16 
from his briefcase on two other occasions while he was 
17 
in town for the weekend. The first was over the Labor 
18 
Day weekend, August 30 to September 1. The second time 
19 
was a weekend in mid-September 2003." 
20 
Do you see --
21 
A. 
Yeah. 
22 
Q. 
-- the mention of those two incidents? 
23 
A. 
Uh-huh. 
24 
Q. 
Yes? 
25 
A. 
Uh-huh. 
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Page 140 
1 
Q. 
You've got to say yes or no. 
2 
A. 
Yes, sir. 
3 
Q. 
Now, look up at the top of that paragraph. 
4 
5 
6 
7 
8 
9 
10 
A. 
Uh-huh 
11 
Q. 
Do you see that? 
12 
A. 
Yes. 
13 
Q. 
And then it goes further on, it says -- after 
14 
a sentence or two, it says: "Epstein stated at 
15 
approximately 7:15 hours on Sunday, October 5, 2003, 
16 
while sitting at his desk, he noticed the briefcase had 
17 
18 
19 
20 
21 
A. 
22 
Q. 
23 
do you agree that Mr. Epstein is -- and assuming that 
24 
25 
is describing three separate instances 
You see where it says: "After" -- it's about the fourth 
sentence -- "Epstein advised that on Saturday evening, 
October 4, 2003, he left his briefcase at his desk and 
went to bed at approximately 12:30 a.m. Epstein said 
when he left his briefcase, it contained approximately 
$5,000 U.S. currency." 
been opened and some of the cash was missing. Epstein 
believed approximately $3,500 was taken from the 
briefcase." 
Do you see that? 
Yes. 
Now, when you read this whole paragraph here, 
the police took this down accurately -- that Mr. Epstein 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Sandra Townsend (401 
3afc3ca0-c86e-4b9f-8d01-ba20bcae87de 
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