EFTA00182344

Page 347 
1 
, and I think you told us that you had seen 
2 
r, you recognized her photograph. 
3 
A. Yes, I did. 
4 
Q. On how many occasions did you ever see 
5 
her at the Epstein home? 
6 
A. More than three times. 
7 
Q. More than three? 
8 
A. Yes, sir. 
9 
Q. That's as accurate as you can be? 
10 
A. Yes. 
11 
Q. More than three? 
12 
A. More than three. 
13 
Q. Whether it was four or five you don't 
14 know, but more than three? 
15 
A. More than three, sir. 
16 
Q. In terms of Ws age, did you ever ask 
17 her what her age was? 
18 
A. No, sir. 
19 
Q. Did she appear to you to be someone at 
20 least from seeing her and recalling her that she 
21 appeared at least to you to be while a young woman 
22 appeared to be someone who was 18 or older? 
23 
A. No, sir. 
24 
Q. Okay. Well, did you ever say anything to 
25 the police or did you ever -- were you ever 
Page 349 
1 
Q. I'm sorry? 
2 
A. Yes, I did, I told the police. 
3 
Q. And at the time that you spoke with the 
4 
police and gave them a statement, isn't it true, 
5 
Mr. Rodriguez, that you were no longer employed by 
6 Mr. Epstein? 
7 
A. Yes. 
8 
Q. And you understood that you were required 
9 to tell the police officers the truth at that 
10 time? 
11 
A. Yes. 
12 
Q. And if I understood your testimony I 
13 believe from July 29th through today, you at no 
14 time asked any of these girls how old they were. 
15 True? 
16 
A. No. 
17 
Q. And as to whether the girls were under 18 
18 or 18 or over 18, you really didn't know one way 
19 or the other at the time. Would that be a fair 
20 statement? 
21 
A. Yes. 
22 
MR. WILLITS: Object to the form of the 
23 
question. 
24 
BY MR. CRITTON: 
25 
Q. On Exhibit 6 there is a person who's 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 348 
concerned about that such that you told someone? 
A. No, sir. 
Q. Haven't you told the police, sir -- let 
me strike that, let me ask it this way. 
In your taped statement that you gave to 
the police did you not tell them that all of the 
girls appeared to you to be 18 or above? 
A. Sir, as far as when all these actions 
that were taking place I was under an environment 
that I thought I was going to be -- in other 
words, I was afraid of any reprisal Mr. Epstein 
and Mrs. Maxwell if I say something that is any 
idea of me because I have this confidentiality 
agreement. What I saw that they were very young, 
but I cannot say that they were 18 and old. 
Q. Right. Let me just take you back to my 
question again and see if you can answer my 
question. 
MR. CRITTON: Could you please read it 
back? 
(Thereupon, a portion of the record was 
read by the reporter.) 
THE WITNESS: I think I told the police 
that. 
BY MR. CRITTON: 
Page 350 
1 covered, the lady that Ms. Ezell asked you about I 
2 
believe was on the right-hand side of the 
3 
photograph. There is a young lady on the 
4 
left-hand side with a black hat on. 
5 
Do you recognize her at all? 
6 
A. No, I don't recognize her. 
7 
Q. Okay. Thank you. With regard to the 
8 photograph four tbatiou saw that you think 
9 possibly might be 
I think you told us that 
10 you recall seeing that woman in the sauna at Mr. 
11 Epsteln's house on one occasion and she was naked. 
12 
A. Yes. 
13 
Q. Was that near the end of your employment 
14 or the middle or the front end? 
15 
A. I saw her on January 2005, sir, and I was 
16 terminated in March, so that was two months prior. 
17 
Q. And did you ever tell anyone that you had 
18 seen her naked in the sauna? 
19 
A. I told 
20 
Q. Okay. And what did 
say? 
21 
A. She was surprised. 
22 
Q. Okay. Did you wake the young lady up in 
23 the sauna? 
24 
A. No. 
25 
Q. And do you know how old the young lady 
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Page 353 
1 was at that time? 
2 
A. No, I didn't know. 
3 
Q. If I was to tell you she was born in 
4 
December of '86 which would have made her 18 at 
5 
the time, and you would say, not surprised? 
6 
MS. EZELL: Objection, form. 
7 
MR. WILLITS: Object to the form of the 
8 
question. 
9 
MR. HOROWITZ: Join. 
10 
THE WITNESS: I would say I wouldn't 
11 
know. 
12 
BY MR. CRITTON: 
13 
Q. Other than telling 
did you say 
14 
anything to anyone else when you saw 
the 
15 
lady you believe was 
naked in the sauna? 
16 
A. I believe I mentioned that to my wife. 
17 
Q. All right. Anyone else? 
18 
A. No. 
19 
. And did 
continue -- assuming it was 
20 
, did she continue to sleep in the sauna, that 
21 is, she didn't know you were there? 
22 
A. She never knew that I was there. 
23 
Q. She didn't at least acknowledge that she 
24 
knew. Correct? 
25 
A. Yes, correct. 
1 
correct? 
2 
A. I think so, sir. 
3 
Q. All right. I assume that in over the 
4 
course of your life separate and apart from your 
5 
wife you've seen a naked woman before. 
6 
A. Yes. 
7 
Q. And I assume that in your 50 some odd 
8 years -- how old are you, sir? 
9 
A. 55. 
10 
Q. In your 55 years you've seen pictures of 
11 naked women both photographs, paintings, statutes. 
12 Would that be a fair statement? 
13 
A. Yes. 
14 
Q. And in terms of at least in this 
15 particular case there is all sorts of -- as you 
16 know there is testimony, and you've been asked a 
17 number of questions about sex related issues, that 
18 is whether you saw in photographs or whether you 
19 saw anyone engaged in any type of sexual activity. 
20 Correct? 
21 
A. Correct. 
22 
Q. And I assume that you understand that men 
23 and women -- we'll start there first, that men and 
24 women actually do have sex in this world? 
25 
A. Yes. 
Page 352 
1 
Q. You were asked by Ms. Ezell -- I'm just 
2 
going to cover a couple of things as Ion
 I'm 
3 
staying with Cathy here -- whether 
you 
4 
had told us something about the picture of the 
5 
Pope near a picture of a naked person, naked 
6 
woman. That's what 
told you, you never 
7 
saw those photos. Correct? 
8 
A. I did saw the pictures. 
9 
Q. You did see the pictures? 
10 
A. Yes. 
11 
Q. And the photos that you saw of the naked 
12 woman that was near the Pope's photograph, was 
13 
that someone that you knew or just a picture of a 
14 
naked woman? 
15 
A. It was somebody -- somebody that was a 
16 visitor in the house, but I don't know her name. 
17 
Q. And the visitors, that would have been 
18 
one of the plane women, you described the women 
19 who came in on planes, or that they came with Mr. 
20 Epstein from time to time? 
21 
A. They came with Mr. Epstein from time to 
22 time. 
23 
Q. All right. And those are women that I 
24 
think you testified at your last deposition all 
25 
appeared to be in their 20's or older. Is that 
Page 354 
1 
Q. That comes as no grand surprise to you? 
2 
A. No. 
3 
Q. And you understand that people actually 
4 
enjoy sex from time to time? 
5 
A. Yes. 
6 
Q. Are you familiar with that concept at 
7 
least? 
8 
A. Yes. 
9 
Q. All right. And what may be typical 
10 sexual activity for one man and woman, or whatever 
11 the permutation might be, another couple, or 
12 another man and woman, or another man or woman may 
13 consider to be unusual or overly aggressive. 
14 
MS. EZELL: Objection to form. 
15 
BY MR. CRITTON: 
16 
Q. True? 
17 
A. It depends on your point of view. 
18 
Q. That's what I mean. Everyone has a 
19 different point of view about sex and what may be 
20 considered typical sexual activity for someone, 
21 someone else may consider that's a bit 
22 
adventurous? 
23 
MR. EDWARDS: Object to the form. 
24 
THE WITNESS: Yes. 
25 
BY MR. CRITTON: 
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Page 355 
1 
Q. I'm not trying to make you a sex expert. 
2 
Also, I assume that when you've been in 
3 
CVS or Walgreens, for that matter Publix or Winn 
4 
Dixie I assume that you've -- I don't want to 
5 
assume anything. 
6 
Have you ever been in an aisle where 
7 
you've actually seen condoms being sold? 
8 
A. Yes. 
9 
Q. And where lubricants are being sold? 
10 
A. Yes. 
11 
Q. And as well as massage oils and other 
12 types of oils actually are sold in those kinds of 
13 
stores? 
14 
A. Yes. 
15 
Q. And they're available so that someone 
16 walking through Walgreens or Publix or CVS could 
17 actually take it off the shelf, put it In their 
18 cart, go up and pay for it and take it home? 
19 
A. Yes. 
20 
Q. All right. In the photographs that you 
21 talked about, and if I understood you correctly, 
22 at least during the time that you were there, Mr. 
23 
Rodriguez, in '04 and '05 there were -- you said 
24 that there were -- I think you said downstairs --
25 
and I'm talking about really from the kitchen area 
Page 357 
1 
you say her name? 
2 
A. Yes, 
3 
Q. Okay. I s 
there was a 
4 
picture where someone it oo 
like was pulling 
5 
on their swimsuit? 
6 
A. Yes. 
7 
Q. Do you recall ever seeing the old 
8 
Coppertone --
9 
A. Yes. 
10 
Q. Let me ask the question. I know you know 
11 what this is. 
12 
Have you ever seen the old Coppertone 
13 
commercials and billboards that used to be 
14 
plastered all over certainly Florida and other 
15 
places where there is a cute little girl who 
16 appears to be two, three, four years old and 
17 
someone is pulling down at least a portion of her 
18 
swimsuit so she's exposing a small portion of her 
19 
cheek is exposed? 
20 
A. Yes. 
21 
Q. Okay. Is that what the picture of the 
22 
young girl looked like that is Mr. Epstein's God 
23 daughter? 
24 
A. More or less, yes. 
25 
Q. All right. And downstairs in the kitchen 
Page 356 
1 up the back stairway, or what would be the kitchen 
2 
stairway to the upper floor, there was I think you 
3 
said, but correct me if I'm wrong, please, that 
4 
you don't recall seeing there being any pictures 
5 
or photographs of any nude women. Is that 
6 
correct? 
7 
A. They were not nude women in the 
8 
staircase. 
9 
Q. That's all I'm talking about right now. 
10 In that area you never saw any pictures, or 
11 photographs, paintings, any type of depiction of a 
12 
nude woman on that staircase going upstairs. 
13 
Correct? 
14 
A. Correct. 
15 
Q. All right. And I think you said 
16 downstairs you saw a picture of -- the only 
17 
picture that you saw of I'd say of a younger child 
18 
that displayed some form of -- I don't want to say 
19 nudity because it's probably not that, but of some 
20 
portion of their body that was exposed, and I 
21 think you described it as her cheek. 
22 
A. Yes, that's upstairs. 
23 
Q. That's upstairs? 
24 
A. Upstairs. 
25 
Q. And that was -- 
is that how 
Page 358 
1 
were there any pictures of women in any stage of 
2 
undress? 
3 
A. No. 
4 
Q. And then I think you said as you walk 
5 
upstairs, or as you walked up the stairway from 
6 
the kitchen at the top of the landing, I think you 
7 
described -- did you describe it as the foyer? 
8 
A. Yes. 
9 
Q. Okay. But it's really the landing, the 
10 upstairs landing? 
11 
A. Yes. 
12 
Q. I think you said there were -- there was 
13 -- were or was a three by five picture or 
14 
pictures? 
15 
A. Yes. 
16 
Q. Of women in some stage of undress? 
17 
A. Yes. 
18 
Q. Okay. And when you say three by five, I 
19 
assume you meant three feet? 
20 
A. Three feet. 
21 
Q. By five feet? 
22 
A. Yes. 
23 
Q. Were they photographs? 
24 
A. Yes, they were photographs. 
25 
Q. And I think you also told us that you 
23 (Pages 355 to 358) 
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Page 359 
1 didn't recognize who those people were. Is that 
2 
correct? 
3 
MR. EDWARDS: Object to the form. 
4 
THE WITNESS: I knew this articular girl 
5 
because it wa 
6 
BY MR. CRITTON: 
7 
Q. Okay. And is that the picture you're 
8 
talking about? 
9 
A. This is the picture I'm talking about. 
10 
Q. Okay. And that was a three by five? 
11 
A. Yes. 
12 
Q. All right. And the only thing that you 
13 
could see was a portion, that is of her other than 
14 
say her waist or her shoulders or her arms or 
15 
something, that's one where you could see kind of 
16 
like the Coppertone commercial, a picture of her 
17 
cheek? 
18 
A. Yes. Part of her buttocks. 
19 
MR. LANGINO: Object to the form. 
20 
BY MR. CRITTON: 
21 
Q. Okay. And was there another picture at 
22 
the top of the foyer, large one, or is that the 
23 only one that you can recall? 
24 
A. There were two of the same girl in 
25 different poses. 
Page 361 
1 
A. Inside his closet, the walk-in closet. 
2 
Q. And those pictures, I think you called it 
3 
a mosaic? 
4 
A. Yes. 
5 
Q. And of the mosaic, approximately how many 
6 
pictures were in the mosaic? 
7 
A. 16 or 20. 
8 
Q. Okay. And of those pictures how many did 
9 
you recognize? 
10 
A. About three or four. 
11 
Q. All right. Were they -- as to who those 
12 
people were, you don't know, you just recognized 
13 
three or four of them? 
14 
A. Mr. Epstein when he was younger, and then 
15 different girlfriends, but I didn't recognize 
16 except the ones --
17 
Q. Okay. You said three or four of those 
18 
were pictures of the girls who came over to give a 
19 
massage? 
20 
A. Yes. 
21 
Q. Okay. But as to who those girls were you 
22 don't know as you sit here today? 
23 
A. No, sir. 
24 
Q. And as to what their ages were you don't 
25 
know? 
Page 360 
1 
Q. But showed the same thing? 
2 
A. Yes. 
3 
Q. Okay. As you walked through into -- then 
4 if I understood it correctly, you go to the pretty 
5 
much to the end of the hallway, then you go 
6 
through another small vestibule, double doors, two 
7 
sets of double doors, and as you go straight ahead 
8 
then you make a left around the bed and then you 
9 
end up in the bathroom. 
10 
A. Yes. 
11 
Q. In the bathroom -- in the bathroom or In 
12 that location were there any pictures of any women 
13 in any stage of undress? 
14 
A. Yes. 
15 
Q. All right. And were any of those 
16 
pictures, did they involve -- or were they of any 
17 of the girls that have been described as women who 
18 came over to give Mr. -- purportedly to give Mr. 
19 Epstein a massage? 
20 
A. Yes. 
21 
Q. And do you remember who any of the names 
22 of any of those people were? 
23 
A. No. 
24 
Q. And the pictures you saw, where were they 
25 
located? 
Page 362 
1 
A. No, sir. 
2 
Q. That's correct? 
3 
A. That's correct. 
4 
Q. And as to what they depicted in the 
5 
photographs of the girls were they in different 
6 
stages of undress? 
7 
A. Yes. 
Q. Was everyone undressed to some degree, 
9 
that is, they were described as nude, or at least 
10 the questions asked were these people nude? Were 
11 they actually nude or someone may have had their 
12 top off? 
13 
A. There were two girls completely naked in 
14 a shower in a sexual act. 
15 
Q. Is that the one when Ms. Ezell asked you 
16 questions, that's one of the photographs that you 
17 
were talking about? 
18 
A. No, sir. 
19 
Q. That was a different --
20 
A. Different one. 
21 
Q. Okay. And the mosaic that you saw where 
22 you saw two girls involved in a sexual act, do you 
2.3 
know where that photograph was taken? 
24 
A. I think it was taken in one of the rooms 
25 in the house because there is an oval bathtub, but 
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Page 363 
1 
I don't know which room, sir. 
2 
Q. Okay. Did you recognize both the girls 
3 
or just one of the girls? 
4 
A. The two girls. 
5 
Q. Then there were -- there was one or two 
6 
other photographs of girls that you recognized? 
7 
A. Yes. 
8 
Q. Okay. And were they fully unclothed or 
9 
did they have some degree of clothes on and/or 
10 off? 
11 
A. They were naked. 
12 
Q. All right. And all of the remaining 
13 
pictures at least within that mosaic were of 
14 
individuals that you did not know? 
15 
A. No, sir. 
16 
Q. And that you did not recognize as having 
17 
been at the house. Is that correct? 
18 
A. Yes, that's correct. 
19 
Q. You were also asked about some -- let me 
20 
switch for just a minute. 
21 
You were asked about a vibrator that you 
22 
saw, and I think you described it as a back 
23 
massager that was approximately 18 inches long 
24 
that had a couple of rotating heads on it. 
25 
A. Yes. 
Page 365 
1 pilots, masseuses, chefs, so she have a copy of 
2 
the black book with herself and as well as the 
3 
computer. 
4 
Q. Did you ever go on Ms. Maxwell's computer 
5 
to see what she had in it? 
6 
A. Yes. 
7 
Q. And was that something you were allowed 
8 
to do? 
9 
A. No. 
10 
Q. Okay. You actually went in her office? 
11 
A. Yes. 
12 
Q. And was her computer on so that you 
13 
didn't need to access the password? 
14 
A. It was off. 
15 
Q. Okay. So you just turned it on? 
16 
A. Yes, sir. 
17 
Q. And then you were able to access her 
18 
computer? 
19 
A. Exactly. 
20 
Q. And what possessed you to go in and to 
21 access her personal computer? 
22 
A. I needed to send some documents to the 
23 
New York office and it was the only computer 
24 
working in the house. 
25 
Q. Okay. And how many occasions did you use 
Page 364 
1 
Q. And I think you ultimately came up with 
2 
the idea as it was something you had seen at like 
3 
a Sharper Image store. 
4 
A. Yes, sir. 
5 
Q. Have you ever seen one of those types of 
6 
devices, that is a back massager with the rotating 
7 
heads also sold -- well, let me ask you this. 
8 
Strike that last question. 
9 
Have you ever been to Brookstone? 
10 
A. Yes. 
11 
Q. Okay. Have you ever seen a massager like 
12 that at Brookstone? 
13 
A. Yes. 
14 
Q. Okay. You were asked whether Ms. Maxwell 
15 kept the names of any of the girls who came to 
16 give massages on -- let me ask it this way. 
17 
I think you were asked whether 
18 Ms. Maxwell ever kept the names of any of the 
19 girls who came to give massages and I think your 
20 response was yes. 
21 
A. Yes. 
22 
Q. Okay. Did she keep them on a pad of 
23 
paper, did she keep them in a notebook, did she 
24 
keep them in a computer? 
25 
A. We used to have internal books for 
Page 366 
1 
her computer? 
2 
A. Several times. 
3 
Q. Was she ever aware that you used her 
4 
computer? 
5 
MR. LANGINO: Form. 
6 
THE WITNESS: I don't think so. 
7 
BY MR. CRITTON: 
8 
Q. Did you ever ask Ms. Maxwell for 
9 
permission to use her computer? 
10 
A. I was the house manager, I believe I was 
11 supposed to use everything in the house to 
12 accomplish my duties, in that case sending 
13 financial reports or e-mails. 
14 
Q. So would you have been -- did you ever 
15 
use Mr. Epstein's computer? 
16 
A. No. 
17 
Q. Okay. But you used Ms. Maxwell's 
18 computer? 
19 
A. Yes. 
20 
Q. Did you ever use Ms. 
computer? 
21 
A. Yes. 
22 
Q. In looking at Ms. Maxwell still, you went 
23 
into Ms. Maxwell's computer with at least the idea 
24 of sending some documents? 
25 
A. Yes. 
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Page 367 
1 
Q. Up to New York? 
2 
A. Yes. 
3 
Q. Were you going to pdf them? 
4 
A. Yes. 
5 
Q. And did she have a fax machine -- not a 
6 
fax machine, a copy machine in her office as well? 
7 
A. Yes. 
8 
Q. Okay. So how would you generally do 
9 
that? Would you do that through a Microsoft 
10 program? 
11 
A. Through Citrix. 
12 
Q. Through Citrix. All right. With Citrix, 
13 and that is, If you said you saw some names of 
14 individuals on her computer if you were just going 
15 to pdf some documents up to New York why would you 
16 of -- what would of caused you to have seen any 
17 
names on her computer? 
18 
MS. EZELL: Objection to form. 
19 
THE WITNESS: All the calls that came to 
20 
358 El Brillo, they came through the 
21 
telephone, they have a transcript somehow 
22 
that they connect to the computer, so you 
23 
can pull it and you register the time, who 
24 
called, who didn't call, and you can pull 
25 
this at your request. So I used to use that 
Page 369 
1 
record with tape number three. 
2 
BY MR. CRITTON: 
3 
Q. Mr. Rodriguez, I was asking you about 
4 
Ms. Maxwell's computer and you told me how you 
5 
went on the computer. 
6 
If she was out of town would she take her 
7 
computer with her? 
8 
A. No. 
9 
Q. It was something she left there? 
10 
A. Yes. 
11 
Q. All right. And when you went on to pdf, 
12 I think you said it was really one time that you 
13 
saw the names of some of these girls? 
14 
A. Yes. 
15 
Q. And if I understand it correctly, it was 
16 -- did It have the name and then a phone number? 
17 
A. Yes. 
18 
Q. And was that something that was 
19 automatically downloaded from the system? 
20 
A. Yeah, from the phone system to the 
21 computer so we have a transcript. 
22 
Q. When you say a transcript, the fact that 
23 
Sally Jones, phone number 561, whatever it was, 
24 
called. 
25 
A. It was a transcript of the phone calls of 
Page 368 
1 
to go back to some calls that they were 
2 
requesting, especially when the hurricane 
3 
season happened. 
4 
BY MR. CRITTON: 
5 
Q. Okay. So if I understand, even the 
6 
computer you used would have had that same 
7 
feature? 
8 
A. No, no, it was totally different. Mine 
9 
was slower and all the time was breaking down 
10 that's why we have the guy from Ohio came and 
11 fixed the computers. 
12 
Q. Okay. Were there other computers that 
13 
you used tiali 
that feature, that is that -- 
14 
A. Onl 
, Mrs. Maxwell, and the staff 
15 house. 
16 
Q. Staff house being yours? 
17 
A. The guest house, yes, my office. 
18 
Q. So you could go out to your guest house 
19 then and look for the same information? 
20 
A. No. 
21 
Q. All right. I don't understand but why 
22 don't we take a break because we're almost out of 
23 
tape. 
24 
(Thereupon, a recess was had.) 
25 
THE VIDEOGRAPHER: We're back on the 
Page 370 
1 the house, we can get it from the computer. 
2 
Q. Okay. And I'm distinguishing, 
3 
transcript, it would tell you the name and phone 
4 
number, it wouldn't tell you what was said? 
5 
A. It was the message also. 
6 
Q. Okay. Now I understand. And so 
7 
Ms. Maxwell when you said she had the names of 
8 
some of these girls who may have given massages, 
9 or at least were what you called earlier girls 
10 that gave massages, or females that gave massages, 
11 she would have had it because that was information 
12 that was downloaded from the atrix system into 
13 her computer? 
14 
A. Yes. 
15 
MS. EZELL: Objection, form. 
16 BY MR. CRITTON: 
17 
Q. Okay, I understand. Now, you said she 
18 also had some pictures. Is that that one time you 
19 also saw pictures? 
20 
A. Yes. 
21 
Q. And were you going through her computer 
22 at that time? 
23 
A. No. 
24 
Q. The question is, if all you were going to 
25 do was try to pdf some financial information to 
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Page 371 
1 New York what were you doing getting to names and 
2 
phone numbers and then pictures of girls? 
3 
A. I was trying to get some information. I 
4 
was working the computer and I just happen -- they 
5 
have the icon of the file and I open and it was 
6 right there, so I was not looking but, you know, 
7 it was already accessible to me. 
8 
Q. And how many photographs did you then 
9 
scroll through to look at? 
10 
A. Probably 30. 
11 
Q. Okay. And why? 
12 
A. Just curiosity, sir. 
13 
Q. So again, you never told anyone other 
14 than your wife? 
15 
A. No. 
16 
Q. Correct? 
17 
A. Yes, correct. 
18 
Q. Of the pictures that you saw, if I 
19 understood it correctly, some of those were 
20 pictures of -- well, I think you said some of them 
21 reflected parties or banquets? 
22 
A. Yes. 
23 
Q. I think you described some of the 
24 pictures gatherings that appeared to be either in 
25 Russia or Eastern Europe? 
Page 373 
1 
Q. Okay. Were any of the photographs that 
2 
were in -- again, I'm talking about Ms. Maxwell's 
3 computer now, were those photographs of 
4 
individuals who were any of the girls or ladies 
5 
that came over to give massages? 
6 
A. No. They stay at the house. 
7 
Q. Okay. So the photographs that you saw on 
8 Ms. Maxwell's computer of females in any state of 
9 undress or at parties or at banquets, those were 
10 all of individuals who would fly in with Mr. 
11 Epstein at various periods of time that had 
12 traveled with him? 
13 
A. That's correct. 
14 
Q. Okay. Those are the girls that you told 
15 us I think at your last deposition and reaffirmed 
16 here today, those girls all appeared to be in 
17 their 20's? 
18 
A. Yes, sir. 
19 
Q. All right. Now, you were also asked some 
20 questions, a lot of questions about surveillance. 
21 And if I understood your testimony, and this is 
22 where it goes back to what do you know, what don't 
23 you know, what were you speculating on, what did 
24 you know at the time, what do you know now, at 
25 least I need you to distinguish that for me so 
Page 372 
1 
A. Yes. 
2 
Q. All right. And then you talked about a 
3 
picture of two girls in the shower that you didn't 
4 
know the girls. Correct? 
5 
A. Yes. 
6 
Q. That's correct? 
7 
A. That's correct. 
8 
Q. All right. And that in all of the 
9 
photographs that you saw the individuals seemed to 
10 
be having a good time? 
11 
A. Yes. 
12 
Q. All right. Would it be a correct 
13 statement that in none of the photographs did 
14 
anyone seem to be distressed or disturbed or show 
15 any type of negative emotion, at least from what 
16 you observed? 
17 
A. That's correct. 
18 
MS. EZELL: Objection, form. 
19 
BY MR. CRITTON: 
20 
Q. And in terms of the photographs that you 
21 did see, were any of the photographs that you saw, 
22 did they appear -- did they appear to have been of 
23 
women that you had seen fly in with Mr. Epstein on 
24 his plane? 
25 
A. Yes. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 374 
that I know what you knew at the time, and as 
distinct from what you may have read in the 
newspaper or been told by some lawyer or someone 
else that may not be accurate. Okay? 
A. Yes, sir. 
Q. With regard to the -- with regard to 
surveillance equipment, if I understood your 
testimony today is you were completely unaware of 
the existence of any surveillance equipment in the 
house during the 2004/2005 time period that you 
worked there. Is that correct? 
A. Yes. 
Q. And therefore, where it was, what may 
have existed, whether it in fact actually did 
exist, whether anyone maintained it, you have no 
personal knowledge whatsoever. Is that true? 
A. That's true. 
MR. WILLITS: Object to the form. 
BY MR. CRITTON: 
Q. You talked about pictures of two women 
ar
u saw in the house who were nude, one was 
A. Yes. 
Q. And you knew 
was someone who was in 
her 20's? 
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Page 375 
1 
A. Yes. 
2 
Q. All right. And then you saw another 
3 
picture of a Brazilian woman who had traveled or 
4 
flown on the plane before? 
5 
A. Yes. 
6 
Q. All right. And she also appeared to be a 
7 
woman to you not only in the photograph but from 
8 
your having seen her who appeared to be in her 
9 
20's? 
10 
A. Yes. 
11 
me. Thank you. You talked about 
12 
computer. Was she hooked into your 
13 
main system? 
14 
A. Not to my office in the staff house but 
15. she was hooked Into the main house. 
16 
Q. Okay. The same Citrix system? 
17 
A. Yes. 
18 
Q. And you said that= 
had pictures of 
19 
women on her computer that you saw. Is that 
20 correct? 
21 
A. Yes. 
22 
Q. Okay. And were those the same types of 
23 pictures that Ms. Maxwell had, that is, females, 
24 
pictures of females who had traveled in with Mr. 
25 
Epstein from his plane? 
Page 377 
1 names and addresses of -- let me start over. 
2 
Strike that. 
3 
.11 understood your testimony, you said 
4 thaehad pi 
start again. 
5 
You said tha 
had the names and 
6 
phone numbers of some of the massage girls. 
7 
A. Yes. 
8 
Q. Or at least of the people that you 
9 
thought may have been called to give massages. 
10 
A. Yes. 
11 
MS. EZELL: Form. 
12 
MR. EDWARDS: Form. 
13 
BY MR. CRITTON: 
14 
Q. And was that in the same format that you 
15 
saw on Ms. Maxwell's computer? 
16 
A. No. 
17 
Q. Okay. Wh 
' 
uld you have been 
18 -- have had to use 
computer? 
19 
A. She will instruct me to get some 
20 
information from her desk or telephone numbers, so 
21 I will. 
22 
Q. And that's where you would have seen it? 
23 
A. Yes. 
24 
Q. I think you testified at your last 
25 
deposition, or the start of your deposition that 
Page 376 
1 
A. This were different pictures. 
2 
Q. Okay. Were any of hers of any of the 
3 
girls who came in on the plane, or the ladies or 
4 
women? 
5 
A. No. 
6 
Q. What were her pictures of? 
7 
A. They were young women m 
• 
you know. 
8 I don't remember seeing nudity on 
9 
computer. 
10 
Q. All right. H 
say hers, the 
11 photographs that 
had on her computer 
12 were all of individuals who appeared -- or not 
13 appeared, but were dressed and appeared to be 
14 
modeling? 
15 
A. Yes. 
16 
Q. Would it be a correct statement that none 
17 of the women that you saw,aithe pictures of 
18 the women that you saw on 
computer were 
19 any of the girls, women, whoever came to give 
20 massages? Is that correct? 
21 
MR. EDWARDS: Object to the form. 
22 
MS. EZELL: Form. 
23 
THE WITNESS: That's correct. 
24 
BY MR. CRITTON: 
25 
Q. You said that 
you thought also had 
Page 378 
1 the number of women that you remember came over to 
2 
give massages was something eight to ten, twelve, 
3 I don't remember, what's your best recollection? 
4 
A. Can you repeat that, please? 
5 
Q. Of the women, of different women that you 
6 
knew came over to give massages during the time 
7 
that you worked for Mr. Epstein, '04 to '05, 
8 
during that time period, approximately how many 
9 
women were there? 
10 
MR. EDWARDS: Object to the form. 
11 
THE WITNESS: To give massages? 
12 BY MR. CRITTON: 
13 
Q. Yes, sir. 
14 
A. Fifteen, yeah. 
15 
Q. So something between one and lie 
16 the names you would have seen on Ms. 
17 computer along with a phone number? 
18 
MR. EDWARDS: Form. 
19 
THE WITNESS: Yes. 
20 BY MR. CRITTON: 
21 
Q. Do you remember how many you would have 
22 
seen? 
23 
A. Fifteen. 
24 
Q. Okay. 
d us earlier today 
25 that you saw 
from time to time taking 
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Page 379 
1 pictures in the dining room and the library. 
2 
A. Yes. 
3 
Q. Photographs. 
4 
A. Yes. 
5 
Q. Okay. Was she taking -- the pictures she 
6 
took were people who were clothed? 
7 
A. Yes. 
8 
Q. And were any of the pictures that she 
9 
took of any of the girls that you ever -- let me 
10 strike that. 
11 
If I understood your original testimony 
12 -- I don't want to say original. If I understood 
13 
your testimony from July 29th to what you told us 
14 
today as to the women who did come to give 
15 
massages they'd knock or somehow you would be 
16 aware that they were at the back door, you would 
17 
punch the security code and lead them into the 
18 
kitchen. 
19 
A. Yes. 
20 
Q. Okay. When you brought them into the 
21 kitchen you would say, hi, they would say hi back 
22 to you, or something to that, short greeting, 
23 
you'd offer them water, there was never any 
24 
alcohol in the whole house other than I think you 
25 
said for one person at one time. Is that a fair 
Page 381 
1 
Q. Regular conversation? 
2 
A. Yes. 
3 
Q. And, therefore, you might interject 
4 yourself back In because you've been asked to pay 
5 
someone or to let them out? 
6 
MR. LANGINO: Form. 
7 
THE WITNESS: Yes, I was called to pay 
8 
them. 
9 
BY MR. CRITTON: 
10 
Q. All right. And when you hear that 
11 conversation that would be another way that you 
12 
would know that the women were leaving? 
13 
A. Yes. 
14 
Q. And sometimes they'd leave without you 
15 even being involved, if I understood it correctly? 
16 
A. That's correct. 
17 
Q. So, the only places that you ever saw the 
18 women who came to give massages would be -- of the 
19 some fifteen women during the time you were there 
20 would be either when you let them into the house 
21 and escorted them into the kitchen or as they were 
22 
leaving? 
23 
A. Yes. 
24 
Q. And I think you described one instance 
25 earlier today is that you may have had M. in the 
Page 380 
1 statement? 
2 
A. Yes. 
3 
Q. All ri ht. You left the kitchen, you 
4 understood 
came down, and what 
5 
happened thereafter you don't have any personal 
6 knowledge whatsoever? 
7 
A. That's correct. 
8 
MR. EDWARDS: Form. 
9 
BY MR. CRITTON: 
10 
Q. At some point in time Ms. 
might 
11 contact you and say pay such and such X amount of 
12 dollars, she Is now getting ready to leave. 
13 
A. Yes. 
14 
Q. That maybe one. Another set of 
15 circumstances might be you use the word commotion, 
16 you might hear a commotion, I assume you don't 
17 mean -- well, let me ask you, when you say 
18 commotion, do you mean a disturbance, something 
19 that was seriously like raised voices or merely 
20 you just heard some people talking? 
21 
A. Conversation of people leaving. 
22 
Q. Okay. Not a commotion in the form of a 
23 disturbance but a commotion in the sense that you 
24 heard people talking? 
25 
A. Yes. 
Page 382 
1 car, in the Suburban? 
2 
A. Yes. 
3 
Q. And that's the only person that you can 
4 
remember having driven any place, that is, of the 
5 
women who were described as having given massages? 
6 
MR. EDWARDS: Objection. 
7 
MS. EZELL: Objection, form. 
B 
THE WITNESS: Sir, I have to clarify 
9 
that. I drove a lot of girls, but I don't 
10 
remember the names associated with the 
11 
faces. But this particular girl Sr 
12 
others,. whatever, I remember driving in 
13 
the Suburban, but I cannot say this was --
14 
BY MR. CRITTON: 
15 
Q. Let me clarify because what I want to be 
16 dear is, is I do remember you testifying that 
17 when some of the 20 plus year old models or 
18 females would fly in with Mr. Epstein they might 
19 want to go shopping, they might want to go to the 
20 store, they may want to go to the drug store, they 
21 may want to go to the beach, wherever they wanted 
22 to go and you would drive them. 
23 
A. Yes. 
24 
Q. All right. And then I remember in 
25 response to Ms. Ezell's questions today she asked 
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Page 383 
1 you about having driven.. and you recalled 
2 
having had her in the Suburban specifically. 
3 
A. Yes. 
4 
Q. Do you remember any of the other girls, 
5 
women who came to give massages ever having driven 
6 
them, or is.. the only one that you remember? 
7 
MR. EDWARDS: Form. 
8 
THE WITNESS: I only remember.. right 
9 
now for the fact that I was driving by the 
10 
airport and I showed her Mr. Epstein's 
11 
plane. 
12 
BY MR. CRITTON: 
13 
Q. All right. Which really takes me back to 
14 really where I started with this series of 
15 questions. 
16 
You saw the girls, the women who came In 
17 to give the massages, when they came in if you 
18 were advised or if you heard conversation and you 
19 saw them you would see them when they left? 
20 
A. Yes. 
21 
Q. And you saw.. because she was in the 
22 
Suburban on at least one occasion? 
23 
A. Yes. 
24 
Q. And, therefore, you never saw these 
25 girls, these women who gave the massages in the 
Page 385 
1 
Q. All right. Ms. Ezell asked you about Mr. 
2 
Dershowitz being present in Mr. Epstein's home, 
3 
and I think she asked -- and I think that you said 
4 
Mr. Epstein was a -- and he and Mr. Dershowitz 
5 
were friends? 
6 
A. Yes. 
7 
Q. She also I think asked was Mr. Dershowitz 
8 
ever there when one of the women who gave a 
9 
massage was present in the home? 
10 
A. I don't remember that. 
11 
Q. That's what I want to clear up. Is it 
12 your testimony that Mr. Dershowitz was there when 
13 
any of the women came to Mr. Epstein's home to 
14 
give a massage? 
15 
A. Yes. 
16 
MR. EDWARDS: Form. 
17 
BY MR. CRITTON: 
18 
Q. As to whether any of those women were 
19 ever associated with Mr. Dershowitz would it be a 
20 correct statement that you have absolutely no 
21 knowledge? 
22 
A. I don't know, sir. 
23 
Q. You don't know? 
24 
A. I don't know, sir. 
25 
MS. EZELL: Form. 
Page 384 
1 dining room or the library. Would that be a fair 
2 
statement? 
3 
A. That's correct. 
4 
MR. EDWARDS: Form. 
5 
BY MR. CRITTON: 
6 
Q. All right. So therefore, the pictures 
7 
that you saw 
taking of girls, women, 
8 
either in the dining room or library, those were 
9 
other individuals other than those who may have 
10 given or who came for massages. Is that correct? 
11 
MS. EZELL: Form. 
12 
MR. EDWARDS: Form. 
13 
THE WITNESS: It's confusing, sir, 
14 
because there were a bunch of girls. I 
15 
don't know which one they were but I saw her 
16 
taking pictures of the groups. 
17 
BY MR. CRITTON: 
18 
Q. As to whether they were people who came 
19 in on the planes or there may have been a massage 
20 girl or more than one woman who gave a massage, 
21 you just don't know as you sit here, you'd just be 
22 speculating. Is that correct? 
23 
MR. EDWARDS: Form. 
24 
THE WITNESS: I don't know. 
25 
BY MR. CRITTON: 
Page 386 
1 
BY MR. CRITTON: 
2 
Q. Okay. Were you in any way attempting in 
3 
your response to Ms. Ezell to imply that Mr. 
4 
Dershowitz had a massage by one of these young 
5 
ladies? 
6 
A. I don't know, sir. 
7 
Q. You have no knowledge? 
8 
A. No, sir. 
9 
Q. And you certainly weren't implying that 
10 that occurred, you just have no knowledge. 
11 Correct? 
12 
MR. EDWARDS: Form. 
13 
THE WITNESS: I don't know. 
14 
BY MR. CRITTON: 
15 
Q. Sorry? 
16 
A. I don't know. 
17 
Q. I think in response to one of Ms. Ezell's 
18 questions you responded that -- let me ask it this 
19 way. 
20 
You never saw Mr. Epstein ever take 
21 photographs of anyone. Would that be a correct 
22 statement? 
23 
A. Yes. 
24 
Q. Would it be a correct statement you never 
25 
saw Mr. Epstein initiate a phone call to anyone? 
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Page 387 
1 
A. To place a phone call? 
2 
Q. Yeah. Did you ever see him place a phone 
3 
call? 
4 
A. Yes. 
5 
Q. If in fact, maybe it was this way, is 
6 
that you never saw him call someone to schedule a 
7 
massage appointment. Correct? 
8 
A. That's correct. 
9 
Q. I think you said that Ms. l.
 told you 
10 that Mr. Epstein would take photographs. Did I 
11 understand you correctly? 
12 
A. I'm sorr
iyou repeat that? 
13 
Q. Did Ms. 
ever tell you that Mr. 
14 
Epstein took a photograph of anyone? 
15 
A. No, she said to me Mr. Epstein is like 
16 
he's an amateur photographer. 
17 
Q. Okay. I may have misunderstood you then. 
18 Let me clarify that testimony. 
19 
It's your testimony that Ms. 
told 
20 
you that Mr. Epstein is an amateur photographer? 
21 
A. Yes. 
22 
Q. She never told you that -- or let me 
23 
strike that. 
24 
Is it correct that she never told you 
25 that Mr. Epstein took photographs of any of the 
Page 389 
1 
Q. Of the time that you've done that 
2 
approximately how many years does that include in 
3 
your working life? 
4 
A. Eight years, ten years. 
5 
Q. All right. And have you worked for --
6 
have you been in other circumstances where you 
7 
have worked around — well, let me step back. 
8 
With all of the individuals that you 
9 
mentioned, estate manager, house manager, has this 
10 
been for individuals who have or at least appear 
11 to have substantial wealth? 
12 
A. Yes. 
13 
Q. And as part of your duties, or not duties 
14 but as part of being a house manager or general 
15 manager for an estate do you interact with other 
16 estate managers? 
17 
A. Yes. 
18 
Q. And do you assist each other from time to 
19 time if someone needs help? 
20 
A. That's correct. 
21 
Q. And I assume that you've been in other 
22 
estates in Palm Beach and probably in Fort 
23 Lauderdale and other locations? 
24 
A. Yes. 
25 
Q. As part of during your working career did 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 388 
girls, women, who came over to give him a massage? 
A. That's correct. 
Q. All right. Mr. Rodriguez, other than Mr. 
Epstein I think you told us you had worked for a 
lady named Ms. Hammond? 
A. Yes. 
Q. And you had worked for a gentleman --
A. Sidney Bowman. 
Q. Is he the gentleman from Fisher Island? 
A. No, Arturo Torres. 
Q. All right. In addition to Ms. Hammond up 
in Palm Beach you worked for other Individuals as 
well? 
A. I did it part-time but I don't have her 
name right now, sir. 
Q. During your career as a -- let me strike 
that. 
Had you worked other than those places, 
Mr. Arturo --
A. Arturo Torres, yes. 
Q. Arturo Torres, Ms. Hammond, the other 
individual you can't remember, and Mr. Epstein, 
have you worked for other individuals as an estate 
manager or general house manager? 
A. No, sir. 
Page 390 
1 you ever work in restaurant or a personal services 
2 
type business where you would provide like 
3 
catering or something like that to other wealthy 
4 
individuals? 
5 
A. I did. 
6 
Q. Give us a little of your background if 
7 
you could then, Mr. Rodriguez. 
8 
A. I work in Long Island, Montauk Lake Club 
9 
and Marina, a very exclusive country club where 
10 Mr. Nixon used to spend his summers, Richard 
11 Nixon. I worked for Leona Helmsley in New York. 
12 Very demanding lady. And then Mr. Torres in Texas 
13 in his ranch and as well as Fisher Island. And I 
14 
was a general manager of one of his restaurants in 
15 
San Antonio, Texas. This is the most high profile 
16 
people that I worked for. 
17 
Q. Okay. When you worked for Ms. Helmsley, 
18 Leona Helmsley, she used to have the Helmsley 
19 Palace and she with her husband, Harry Helmsley, I 
20 think they owned a number of real estate in 
21 addition to hotel properties. 
22 
A. That's correct. 
23 
Q. When you would -- I think you described 
24 
her as a demanding person? 
25 
A. Yes. 
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Page 391 
1 
Q. All right. In terms of these wealthy 
2 
people that you've worked for, these individuals, 
3 
do they all have, that is at least in terms of Mr. 
4 
Epstein, the way that his household was managed, 
5 
was it similar to other set of circumstances that 
6 
you've been involved with? 
7 
MR. HOROWITZ: Object to form. 
8 
THE WITNESS: They have a common ground, 
9 
yes. 
10 BY MR. CRITTON: 
11 
Q. All right. And in terms of you talked 
12 about Mr. Epstein that there was some sort of a 
13 manual or a procedure book with regard to his 
14 house. 
15 
A. House manual, yes. 
16 
Q. A house manual. Did other houses have 
17 house manuals as well? Is that reasonably -- I 
18 mean not common but it's something that you've 
19 seen before? 
20 
MR. EDWARDS: Form. 
21 
THE WITNESS: I know a lot of houses do 
22 
but that was the only estate that we have a 
23 
house manual. 
24 
BY MR. CRITTON: 
25 
Q. And other individuals like where you've 
Page 393 
1 about what they do? 
2 
MR. HOROWITZ: Object to the form. 
3 
THE WITNESS: Yes. 
4 
BY MR. CRITTON: 
5 
Q. And have you worked at other locations, 
6 
that is, in the other houses that you've worked 
7 
where they have massage tables? 
8 
A. Yes. 
9 
Q. And in those other locations where they 
10 had a massage table, were they similar to the 
11 massage table that was in Mr. Epstein's home? 
12 
A. Yes, sir. 
13 
Q. All right. Almost same make and model? 
14 
A. Same type, yes. 
15 
Q. And did other individuals in houses that 
16 you worked at and other places where you helped 
17 out other estate managers, would those individuals 
18 have massages from time to time? 
19 
A. Yes. 
20 
Q. So having a massage or a massage table in 
21 someone's house that you might -- that lives in 
22 
Palm Beach or Montauk or New York or something, 
23 
would you consider that unusual? 
24 
MR. HOROWITZ: Form. 
25 
THE WITNESS: No. 
Page 392 
1 
worked similar to Mr. Epstein -- now, Mr. Epstein 
2 
was single? 
3 
A. Yes. 
4 
Q. All right. And him having a lot of -- or 
5 
bringing a lot of attractive women and other 
6 
people to his house, I assume that didn't offend 
7 
you in any way? 
8 
MR. EDWARDS: Object to the form. 
9 
THE WITNESS: No, sir. 
10 
BY MR. CRITTON: 
11 
Q. At least based upon your experience in 
12 dealing with other individuals either of some 
13 
notoriety like Ms. Helmsley or when you said the 
14 club that you worked up is in Montauk --
15 
A. Montauk Lake Club and Marina. 
16 
Q. Right. You ran into separate and apart 
17 from Richard Nixon were there a lot of people, 
18 
corporate people, business people? 
19 
A. Yes. 
20 
Q. People of substantial resources and 
21 wealth? 
22 
A. Yes. 
23 
Q. Have you found at least in your 
24 experience that most of those people are pretty 
25 discreet about -- when I say discreet, private 
Page 394 
1 
BY MR. CRI1TON: 
2 
Q. I think you told me at least in Mr. 
3 
Epstein's home other than for one guest he didn't 
4 
have any type of alcohol in the house. Is that 
5 
correct? 
6 
A. That's correct. 
7 
Q. Was that basically you understood that 
8 
that was one of the policies and procedure, no 
9 
alcohol in the house? 
10 
A. Yes. 
11 
Q. And did you ever see any type of illegal 
12 or inappropriate drugs? 
13 
A. No, sir. 
14 
Q. And was that another policy or procedure, 
15 absolutely no drugs of any kind? 
16 
A. No smoking in the house. 
17 
Q. All right. So no drugs, no smoking, no 
18 alcohol? 
19 
A. Yes. 
20 
Q. Was that pretty typical for other Palm 
21 Beach places that you were familiar with? 
22 
A. No. 
2.3 
Q. All right. And other places you'd always 
24 find alcohol? 
25 
A. Yes. 
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Page 395 
1 
Q. All right. And you might find drugs? 
2 
A. Yes. 
3 
Q. And some pretty wild parties? 
4 
A. Yes. 
5 
Q. Now, with regard to the women who came to 
6 
give massages, of those women, of those 
7 
approximately fifteen that you described, how many 
8 of them came more than one -- more than one 
9 
occasion? 
10 
MR. HOROWITZ: Form. 
11 
THE WITNESS: 1'd say more than half. 
12 
BY MR. CRITTON: 
13 
Q. So maybe seven, eight, nine, ten? 
14 
A. Yes. 
15 
Q. Of those people that came on -- of those 
16 seven to ten that came on more than one occasion, 
17 did those individuals come on many occasions? 
18 
A. Yes. 
19 
Q. And as to the women who were -- who you 
20 understood were coming to give the massages --
21 
MR. EDWARDS: Form. 
22 
MR. CRITTON: I'm not done yet. 
23 
THE VIDEOGRAPHER: I need to go off the 
24 
record for a second. 
25 
(Thereupon, an interruption was had.) 
Page 397 
1 
MR. EDWARDS: Object to the form. 
2 
BY MR. CRITTON: 
3 
Q. And I don't know whether he asked, do you 
4 
remember a person named M.? 
5 
A. Yes. 
6 
Q. And would she call from time to time 
7 
askin if she could come to give a massage just 
B 
like M.? 
9 
MR. EDWARDS: Object to the form. 
10 
THE WITNESS: Yes. 
11 BY MR. CRITTON: 
12 
Q. So at least those two individuals, they 
13 were overtly, that is, they were asking whether 
14 they could come to give Mr. Epstein a massage. 
15 Correct? 
16 
A. The will call and they will say I need 
17 to talk to 
and 
fifteen minutes later 
18 will tell, A 
, we're going to have a massage 
19 with so and so. 
20 
Q. So either fl
 or 
would call to ask 
21 if they could come and then a massage would be set 
22 then they would show up? 
23 
A. That's correct, sir. 
24 
Q. Okay. And from time to time they would 
25 bring other people as well? 
1 
2 
3 
4 
S 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 396 
THE VIDEOGRAPHER: We're back on the 
1 
record. 
2 
BY MR. CRITTON: 
3 
Q. Mr. Rodriguez, I want to turn to the -- 
4 
stay with the women who came to give or at least 
5 
were called to give the massages. 
6 
You were shown a number of message pads, 
7 
I think Mr. Mermelstein who represents a number of 
8 
-- or at least certainly Jane Doe 2 and some 
9 
others, you were identified or shown a bunch of 
message pads that had I think In most instances 
your initials, 
Do you recall that? 
A. Yes, I do. 
Q. I think one of the individ I  that you 
identified that called often was M.? 
A. Yes. 
Q. Which is one of Mr. Edwards' dients. 
This lady called on a regular basis, or 
at least from looking at your pad she would call 
on a pretty regular basis. Is that true? 
A. Yes. 
Q. And she and others who are reflected on 
those message pads, they were calling to come to 
give massages. Correct? 
A. Yes. 
10 
11 
12 
13 
14 
15 
; 16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A. That's correct. 
Q. Both 
and..? 
A. Yes. 
Q. Of the females that -- the women that 
came to the house, did you ever see anyone force 
any of these women onto the property? 
A. No, sir. 
Q. Did you ever see anyone force them into 
the house? 
A. No. 
Q. Did you ever see anyone force them into 
the kitchen? 
A. No, sir. 
Q. Did you ever use any force, any type of 
intimidation or coercion to bring them into the 
house and get them into the kitchen? 
A. No, sir. 
Q. Did you ever observes 
using any 
force or intimidation or coercion --
A. No, I did not. 
Q. -- with any of these individuals? 
A. I did not. 
MR. EDWARDS: Object to the form. 
BY MR. EDWARD : 
Q. Did M.. -- let me use the initials 
33 (Pages 395 to 398) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182376

Page 399 
1 that way it will show up correctly. 
2 
Did M. ever use from what you saw, did 
3 
she ever use any force or coercion or intimidation 
4 
with any of the women that she brought to the 
5 
house? 
6 
MR. HOROWITZ: Form. 
7 
MR. EDWARDS: Object to the form. 
8 
THE WITNESS: No, sir. 
9 
BY MR. CRITTON: 
10 
Q. Okay. I'm just talking about what you 
11 observed during the time. And you know what I 
12 mean by force? 
13 
A. Yes. 
14 
Q. You know what I mean by intimidation? 
15 
A. Yes. 
16 
Q. Could to be verbal intimidation or 
17 
coercion, either verbally or using some form of 
18 her body, or their bodies. 
19 
A. Yeah, I understand that. 
20 
MR. EDWARDS: Form. 
21 
MR. HOROWITZ: Form. 
22 
MS. EZELL: Objection, form. 
23 
BY MR. CRITTON: 
24 
Q. When 
brought individuals to the 
25 
house, did you ever see her use any force or 
Page 401 
1 
Q. Did any of them ever appear to be 
2 
frightened? 
3 
MR. HOROWITZ: Form. 
4 
THE WITNESS: No. 
5 
BY MR. CRITTON: 
6 
Q. Did any of the women appear to be 
7 
fearful? 
8 
A. No. 
9 
Q. Did any of them appear to be 
10 uncomfortable in coming into the house? 
11 
MR. EDWARDS: Form. 
12 
THE WITNESS: No. 
13 
BY MR. CRITTON: 
14 
Q. At any time did any of them express to 
15 you verbally that they were in fear when they came 
16 into the house? 
17 
A. No, sir. 
18 
Q. Did any one of the fifteen girls that 
19 came to the back door, then into the kitchen, and 
20 prior to your leaving them in the kitchen say, Mr. 
21 Rodriguez, or Alfredo, or sir, could you get me 
22 out of here? 
23 
A. No, sir. 
24 
Q. Did any of them tell you verbally that 
25 
they were uncomfortable? 
Page 400 
1 intimidation or coercion from what you could 
2 
observe with those women who had come to give a 
3 
massage? 
4 
A. No. 
5 
MR. EDWARDS: Form. 
6 
MR. HOROWITZ: Form. 
7 
MS. EZELL: Form. 
8 
BY MR. CRITTON: 
9 
Q. With any of the fifteen women that you 
10 observed who came to the home to give massages 
11 during the time period '04 through I think you 
12 
said February of '05, the time period I think was 
13 it August, Mr. Rodriguez --
14 
A. August. 
15 
Q. -- August of '04 through February of '05? 
16 
A. March of '05. 
17 
Q. Through the beginning of March '05? 
18 
A. Yes. 
19 
Q. Okay. That's the time period I'm 
20 
focussing on. 
21 
Of the approximately fifteen women that 
22 you came to see to give massages that you let in 
23 
the back door after punching the security code, 
24 did any of them ever appear to be scared? 
25 
A. No. 
Page 402 
1 
A. No. 
2 
Q. Did anyone say help me or I'm scared? 
3 
A. No. 
4 
Q. Did all of them appear to be at least 
5 
when they came to the back door in a reasonably 
6 
good mood? 
7 
A. Yes. 
8 
Q. They all appeared to be happy? 
9 
A. Yes. 
10 
Q. Smile, I'd say interact with you verbally 
11 in your greetings? 
12 
A. That's correct. 
13 
Q. Did any one of the fifteen girls that you 
14 
observed during the August '04 through March 2005 
15 
time period from your personal observation appear 
16 to be there -- appear to be at the Epstein home 
17 not voluntarily? 
18 
MR. EDWARDS: Object to the form. 
19 
MR. HOROWITZ: Object to the form. 
20 
THE WITNESS: No. 
21 BY MR. CRITTON: 
22 
Q. Did any one of the fifteen women who came 
23 to give the massage ever tell you that they had 
24 
been forced to come to the house or coerced into 
25 
coming to the house? 
34 (Pages 399 to 402) 
Kress Court Reporting, Inc. 
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Page 403 
1 
A. No. 
2 
MR. EDWARDS: Form. 
3 
BY MR. CRITTON: 
4 
Q. For those women -- I think I need -- let 
5 
me strike that. 
6 
On some occasions you'd see the women 
7 
come down from upstairs because you would either 
8 let them out of the house or you might give them 
9 an envelope that had money in it. Is that 
10 correct? 
11 
A. Yes. 
12 
Q. Did any of those -- Mr. Edwards asked you 
13 some questions -- I think it was Mr. Edwards, 
14 whether they had sat down and had anything to eat, 
15 whether they had cereal or anything like that. 
16 
A. Yes. 
17 
Q. Did you ever observe any of those women 
18 before they went upstairs eating anything at the 
19 house? 
20 
A. Sometimes. 
21 
Q. And I think he used -- he meaning Mr. 
22 Edwards, used cereal and ice cream. 
23 
A. Yes. 
24 
Q. And he said, if I recall from the last 
25 deposition, kids like ice cream. 
Page 405 
1 
them stop and have anything to eat or did you 
2 
always see them at the end, that is they're ready 
3 
to go? 
4 
A. I didn't know, they came from downstairs, 
5 
they went to the kitchen, but I didn't know they 
6 
were there because I was in the guest house. 
7 
Q. Okay, that's my question. You only 
8 
observed them either if you heard conversation or 
9 
had called you and said would you pay such 
10 Iluch? 
11 
A. Yes. 
12 
Q. At which time you would give them the 
13 
envelope with money? 
14 
A. Yes. 
15 
Q. In that set of circumstances they were on 
16 
their way basically to leave? 
17 
A. Yes. 
18 
Q. When you saw them leave did any of them 
19 at any time, any of the ones that you saw during 
20 
August of '04 through March of '05 appear to you 
21 to be scared? 
22 
A. No, sir. 
23 
Q. Did any girls, women ever appear to have 
24 
been injured in any way? 
25 
MR. EDWARDS: Form. 
Page 404 
1 
A. Yes. 
2 
Q. Do you remember him asking you that? 
3 
A. Yes. 
4 
Q. Are you familiar that teenagers like ice 
5 
cream? 
6 
A. Yes. 
7 
Q. Are you familiar that people who are 20 
8 
and 30 years old like Ice cream? 
9 
A. Yes. 
10 
Q. Are you familiar that older people, even 
11 our age, Mr. Rodriguez, like ice cream too? 
12 
A. Yes. 
13 
Q. Okay. And when the individuals would sit 
14 there, and that is these women who would come over 
15 to give a massage and they would -- you would 
16 observe them eating, did they appear to be 
17 comfortable? 
18 
A. Yes. 
19 
MR. HOROWITZ: Form. 
20 BY MR. CRITTON: 
21 
Q. Did they appear to be Interacting with 
22 either you or the chef? 
23 
A. Yes. 
24 
Q. When any of those women would come over 
25 to give massage came downstairs, did you ever see 
Page 906 
1 
THE WITNESS: No, sir. 
2 
BY MR. CRITTON: 
3 
Q. Did anyone appear to be in shock? 
4 
A. No, sir. 
5 
Q. Was anyone ever crying? 
6 
A. No, sir. 
7 
Q. Was anyone disheveled or appeared to be 
8 unhappy? 
9 
A. No, sir. 
10 
Q. Did all of them appear, that is the ones 
11 that you saw leave the house that you had an 
12 opportunity to observe during that time period, 
13 did they appear to be approximately the same 
14 personality, same demeanor that they had had when 
15 they came into the house? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: Yes. 
18 BY MR. CRITTON: 
19 
Q. Did anyone ever tell you when they came 
20 down the stairs that they had been injured? 
21 
A. No. 
22 
Q. I'm talking about the young lady, the 
23 women who had given the massages that you saw 
24 actually leave the house, that is you had some 
25 Interaction with, either some interaction as they 
35 (Pages 403 to 406) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182378

Page 407 
1 were leaving the house, did anyone ever tell you 
2 
that they had been injured? 
3 
A. No, sir. 
4 
Q. Did they ever tell you that they had been 
5 
forced to do something against their will? 
6 
A. No. 
7 
Q. Did they ever tell you that they had been 
8 
forced to do something inappropriate? 
9 
A. No. 
10 
Q. Did they ever tell you that they had been 
11 assaulted in any way? 
12 
A. No. 
13 
Q. Did they ever tell you that they had been 
14 inappropriately touched? 
15 
A. No. 
16 
MR. HOROWITZ: Form. This is a 
17 
cumulative. He's already told you the 
18 
limited contact he had. This is totally 
19 
inappropriate line of questions. 
20 
MR. CRITTON: Is that a form objection? 
21 
MR. HOROWITZ: You're exceeding the scope 
22 
of the direct because nobody asked him --
23 
MR. CRITTON: Form, you get form in 
24 
federal court, that's what you get. Give me 
25 
your form. 
Page 409 
1 
MR. EDWARDS: Form. 
2 
THE WITNESS: No. 
3 
BY MR. CRITTON: 
4 
Q. Did you ever hear anyone yell rape or 
5 
assault or battery? 
6 
MR. HOROWITZ: Form. 
7 
THE WITNESS: No. 
8 
BY MR. CRITTON: 
9 
Q. Did you ever hear anyone yell out in 
10 anger? 
11 
A. No. 
12 
Q. You've gone online, Mr. Rodriguez, and 
13 
looked at various articles or postings that have 
14 
been made regarding these cases. Is that a fair 
15 
statement? 
16 
A. I'm sorry? 
17 
Q. If I understood your testimony from July 
18 
29th and a little bit today, is that you've gone 
19 
online and read some articles and/or what the 
20 
police report may have said, that is, you've read 
21 information that you've -- about these lawsuits 
22 after the time that you left Mr. Epstein's 
23 
employment. 
24 
A. Yes. 
25 
Q. Correct? 
Page 408 
1 
MR. HOROWITZ: Form, cumulative. 
1 
2 
MR. CRITTON: Great. Why don't you let 
2 
3 
me finish the question and then you can 
3 
4 
object to it. 
4 
5 
Could you give me back what my last 
5 
6 
question was, please? 
6 
7 
(Thereupon, a portion of the record was 
7 
8 
read by the reporter.) 
8 
9 
THE WITNESS: No. 
9 
10 
BY MR. CRITTON: 
10 
11 
Q. Did they ever tell you that they had been 
11 
12 
sexually assaulted in any way? 
12 
13 
MR. EDWARDS: Form. 
13 
14 
MR. HOROWITZ: Form. 
14 
15 
THE WITNESS: No. 
15 
16 
BY MR. CRITTON: 
16 
17 
Q. I'm sorry? 
17 
18 
A. No. 
18 
19 
Q. At any time did you hear anyone -- strike 
19 
20 
that. 
20 
21 
As to the women who came to give a 
21 
22 
massage, did you ever hear anyone scream? 
22 
23 
A. No, sir. 
23 
24 
Q. Did you ever hear anyone cry out what 
24 
25 
sounded like to you help? 
25 
Page 410 
A. Yes. 
Q. And, therefore, you have at least seen 
certain allegations and what people say occurred, 
or at least their recitation of what may have 
occurred at Mr. Epstein's home. 
A. Yes. 
Q. You have no personal knowledge one way or 
the other. 
MR. HOROWITZ: Object to the form. 
MR. EDWARDS: Form. 
BY MR. CRITTON: 
Q. Correct? 
A. That's correct. 
Q. Are you also aware that the individuals 
who have filed lawsuits want in some instance 
millions of dollars? 
A. Yes. 
Q. Okay. Are you aware that some of them 
are now claiming that they were sexually 
assaulted? 
A. Yes. 
Q. And battered? 
A. Yes. 
Q. And you have no information, no personal 
knowledge in that regard. Is that true? 
36 (Pages 407 to 410) 
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EFTA00182379

Page 411 
1 
A. Yes. 
2 
MR. EDWARDS: Form. 
3 
MR. HOROWITZ: Form. 
4 
BY MR. CRITTON: 
5 
Q. All right. Were you aware of the 
6 
backgrounds of any of these women who came over to 
7 
give massages? 
8 
MR. HOROWITZ: Form. 
9 
THE WITNESS: No, sir. 
10 
BY MR. CRITTON: 
11 
Q. Well, have you -- did any one of the 
12 
females who ever came to give massages, did they 
13 ever tell you that they were prostitutes? 
14 
A. No, sir. 
15 
Q. Did they ever tell you that they had been 
16 lead into a life of prostitution? 
17 
MR. HOROWITZ: Form. 
18 
THE WITNESS: No. 
19 BY MR. CRITTON: 
20 
Q. Did they ever tell you about their family 
21 life, whether it involved prostitution, abuse, 
22 prior posttraumatic stress syndrome, drugs, 
23 alcohol, abuse by individuals, physical abuse as 
24 well as verbal abuse? 
25 
A. No, they didn't tell me. 
Page 413 
1 the property in your car? 
2 
A. I was pulling over from Publix so I 
3 
turned around and I went to the police and say --
4 
Q. Okay. You were coming back to the home 
5 
when you saw that car there? 
6 
A. Exactly. 
7 
Q. And they sent -- they, the police, sent a 
8 
police car with you to come there? 
9 
A. Yes. 
10 
Q. Did you and the police officer walk up to 
11 the car? 
12 
A. The police went first. 
13 
Q. All right. And if I understand that, 
14 
that was in January of '05? 
15 
A. Yes. 
16 
Q. And when you did that then did you follow 
17 
behind the police officer to see who was in the 
18 
car? 
19 
A. Yes. 
20 
Q. And then you recognized that as E.? 
21 
A. Yes. 
22 
Q. And ■ 
said she had come back or was 
23 
there to get some money? 
24 
A. Yes. 
25 
Q. And did you in fact give her money? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 412 
Q. And, obviously, you have no personal 
knowledge one way or the other --
A. No, sir. 
Q. -- with regard to what their backgrounds 
were before they ever met or came in contact with 
Mr. Epstein? 
A. No, sir. 
Q. Did any person, female, who came to give 
a massage at the Epstein home, did anyone ever 
come downstairs and say, Mr. Rodriguez, or sir, 
call the police? 
MR. EDWARDS: Form. 
MR. HOROWITZ: Form. 
THE WITNESS: No, sir. 
BY MR. CRITTON: 
Q. I think you said on one occasion you saw 
someone parked in a vehicle inside the gate that 
you didn't recognize. 
A. Exactly. 
Q. You called the police? 
A. Yes, I did. 
Q. Did you go to the police or you called 
the police and they came? 
A. I went to the police department. 
Q. So how did you -- did you actually leave 
Page 414 
1 
A. Yes, I did. 
2 
Q. And I think you said you told the police 
3 
officer you recognized her? 
4 
A. Yes. 
5 
Q. Did you have to get permission to pay her 
6 
or did you just pay her? 
7 
A. No, because .told 
me already but I 
8 
forgot she was goin 
that late, so that was 
9 
my concern in calling the police. 
10 
Q. Okay. And that person who came, do you 
11 have any idea what her age was at that time? 
12 
A. That night? 
13 
Q. Right, January of '08. 
14 
A. No, no. 
15 
Q. I'm sorry, January of '05. 
16 
A. No. 
17 
Q. You mentioned some conversations that you 
18 
had had with 
who was I think she was one 
19 of the house -- the main housekeeper. 
20 
A. Yes. 
. Is 
21 
Q. And
iiac
 told you a number of thoughts 
22 
that she 
at correct?
23 
A. Yes. 
24 
Q. And as to 
25 
-- let me strike that. 
what she told you about 
37 (Pages 411 to 414 
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Page 415 
1 
I think you told us, you were asked 
2 
questions about sex toys, I think you certainly 
3 
described the back massagers. Correct? 
4 
A. Yes. 
5 
Q. I think you said the only sex toys that 
6 
you ever saw were in the armoire at the end of Mr. 
7 
Epstein's bed. 
8 
A. Yes. 
9 
Q. Okay. And whatever other sex toys that 
10 to which there was a reference, that's something 
11 that= 
told you. Is that correct? 
12 
A. That's correct. 
13 
Q. You were asked at the last deposition, I 
14 don't remember who asked the question, but whether 
15 
you had ever seen pornography on any computer. I 
16 think one of your responses was you saw some 
17 photos of a naked woman who appeared to you to be 
18 a model. 
19 
A. Yes. 
20 
Q. Okay. Do you consider every photograph, 
21 picture, painting of a naked nude woman to be 
22 
pornography? 
23 
MR. HOROWITZ: Form. 
24 
MS. EZELL: Objection, form. 
25 
THE WITNESS: I consider -- well, if it's 
Page 417 
1 
A. To bring the pictures from my computer? 
2 
Q. Let me rephrase the question. I thought 
3 
what you said last time was that as to the 
4 
pictures that you did see of naked women -- of a 
5 
naked woman or naked women on the computer, that 
6 
you've looked at those photographs through your 
7 
computer. 
8 
A. No. 
9 
Q. Okay. Then I may have misunderstood you. 
10 Was your reference to Ms. Maxwell's computer that 
11 you made at the last deposition? 
12 
A. Yes. 
13 
Q. Okay. Your computer that you had either 
14 in the staff house or that you --
15 
A. Didn't access. 
16 
Q. You couldn't access those files? 
17 
A. That's correct. 
18 
Q. All right, now I'm with you. So the 
19 photographs you've talked of the nude individuals, 
20 or the naked women, were the photographs that 
21 we've already talked about with both, I.e., in 
22 
Ms. Maxwell's computer? 
23 
A. Yes. 
24 
Q. Thank you for clearing that up. 
25 
I'm going to ask you to assume that.. 
Page 416 
1 
a frontal picture it's pornography, I will 
2 
look at my way. 
3 
BY MR. CRITTON: 
4 
Q. In your view? 
5 
A. Yes. 
6 
Q. So if you looked at -- I don't remember 
7 
whether Playboy still has -- say a Playboy that 
8 
has a frontal nudity shot of a woman, you would in 
9 
essence say that Playboy is selling pornography? 
10 
A. Yes. 
11 
Q. Therefore, every person who buys a 
12 
Playboy that has over the last umpteen tens of 
13 
years that has a frontal picture of a woman in the 
14 
nude would be purchasing pornography whether it's 
15 
from CVS, or Walgreens, or Eckerd as they existed, 
16 or any grocery store that sells them? 
17 
A. Yes. 
18 
MS. EZELL: Objection, form. 
19 
MR. EDWARDS: Form. 
20 
MR. HOROWITZ: Form. 
21 BY MR. CRITTON: 
22 
Q. The photographs -- I'm sorry, the 
23 
pictures that you saw in the computer, I think you 
24 
were able to draw those up or bring those up from 
25 
your own computer. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 418 
who you've described as having come to Mr. 
Epstein's house on three or four times a week for 
a period of time, one of her claims in this case 
is that she has been emotionally traumatized by 
her contact with Mr. Epstein. Just assume that to 
be true for purposes of this question. 
Did you ever observe any what you would 
have seen as emajapal trauma or any type of 
disturbance with 
M
 
.
 
on the many times she came 
to your house? 
MR. EDWARDS: Form. 
THE WITNESS: I didn't see any. 
BY MR. CRITTON: 
Q. Does it make sense to you that a person 
who claims emotional trauma would continue to come 
back to the house, does that make sense to you, 
sir? 
MR. EDWARDS: Form. 
MR. HOROWITZ: Form. 
MR. WILLITS: Object to the form of the 
question. 
THE WITNESS: I'm not a psychologist. 
MR. EDWARDS: Can you state your answer, 
I didn't hear it? 
THE WITNESS: Yeah, I'm not a 
38 (Pages 415 to 418) 
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Page 419 
1 
psychologist, I don't know. 
2 
MR. CRITTON: I have no further 
3 
questions. 
4 
REDIRECT EXAMINATION 
5 
BY MR. EDWARDS: 
6 
Q. Mr. Rodriguez, I don't know if we covered 
7 
this last time, I think that we did not, but can 
8 
you tell us during the period of time when you 
9 
worked at that house at El Brillo, Mr. Epstein's, 
10 what cars did he own or were in the driveway? 
11 
A. We have two Suburbans, two Mercedes 600, 
12 and a Cobra, and a motorcycle. 
13 
Q. And which, if any, did he drive? 
14 
A. He preferred the Mercedes or any of the 
15 
Suburbans. 
16 
Q. All right. Do you know where he owns 
17 
homes? 
18 
A. Yes. 
19 
Q. Where? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: Paris, New York City, El 
22 
Brillo, Saint James Island -- I'm sorry, an 
23 
Island in the Caribbean, and a ranch in New 
24 
Mexico. 
25 
BY MR. EDWARDS: 
Page 421 
1 
Q. What's the address? 
2 
A. 22 Foch Avenue, Paris. F-O-C-H. 
3 
Q. Okay. Do you know a telephone number for 
4 
Balsone? 
5 
A. No, I don't remember, sir. 
6 
Q. All right. How did it come up that you 
7 
talked to him about whether or not Mr. Epstein had 
8 
massages at that house? 
9 
A. He came on two occasions and stay with me 
10 for a week because Mr. Epstein wanted me to get 
11 into his style of running the house, and he was 
12 
good enough to give me some inside information, 
13 what he likes and doesn't like, so he told me the 
14 
same thing was in Paris. 
15 
Q. And I think that you described Mr. 
16 Epstein usually had about two massages a day, or 
17 at least we were calling them massages. 
18 
A. Yes, sir. 
19 
MR. CRITTON: Form. 
20 
BY MR. EDWARDS: 
21 
Q. And did Mr. Balsone describe it in a 
22 similar fashion --
23 
A. Yes. 
24 
Q. -- in Paris? 
25 
And did he also tell you that the girls 
Page 420 
1 
Q. Have you been to any of the other 
1 
2 
properties? 
2 
3 
A. No. 
3 
4 
Q. Do you know the house managers at any of 
4 
5 
the other properties? 
5 
6 
A. Yes. 
6 
7 
Q. And who are they? 
7 
8 
A. Balsone in Paris, good friend of mine 
8 
9 
from Brazil. And the people in New York give me 
9 
10 the briefing when I came aboard. There is a 
10 
11 couple from the Philippines. And I talked to the 
11 
12 couple that used to own the Island -- I mean who 
12 
13 
used to manage the Island, a couple from South 
13 
14 
African. Balsone was closer to me. 
14 
15 
Q. Have you talked to Balsone about whether 
15 
16 or not Mr. Epstein has massages when he is at that 
16 
17 
place? 
17 
18 
A. Yes, I did. 
18 
19 
Q. And what did he say about that? 
19 
20 
A. That he had a lot of massages over there 
20 
21 too. 
21 
22 
MR. CRITTON: Mr. Balsone was which one? 122 
23 
THE WITNESS: Baslone was the house 
23 
24 
manager of Paris, 22 Foch Avenue. 
24 
25 
BY MR. EDWARDS: 
25 
Page 422 
were very young in age that he was receiving these 
massages from? 
MR. CRITTON: Form. 
THE WITNESS: Yes. 
BY MR. EDWARDS: 
Q. Did he indicate whether or not -- or how 
old these girls were? 
A. No, he didn't told me. 
Q. Just that the age group was similar to 
the age group that he was interested in in Palm 
Beach? 
MR. EDWARDS: Form. 
THE WITNESS: Yes. 
BY MR. EDWARDS: 
Q. And did you talk to any of the house 
managers in New York? 
A. No. 
Q. Who was the house manager in New York at 
the time when you were the house manager at El 
Brillo? 
A. His nickname was Jo-Jo, but I don't 
remember. Jo-)o and his wife, but I don't 
remember his name, sir. 
Q. Do you know whether Mr. Epstein would 
have massages when he was in New York at his New 
39 (Pages 419 to 422) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182382

Page 423 
1 
York house? 
2 
A. He will have massages. 
3 
MR. CRITTON: Form. 
4 
BY MR. EDWARDS: 
5 
Q. And are we still talking about a habit of 
6 
two a day? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: I don't know that. 
9 
BY MR. EDWARDS: 
10 
Q. Okay. So for the time period when you 
11 have been familiar with Mr. Epstein and known his 
12 
habits, is it fair to say that he would have 
13 
roughly two girls a day in that same age group 
14 
wherever he was? 
15 
A. Yes. 
16 
MR. CRITTON: Form. 
17 
BY MR. EDWARDS: 
18 
Q. All right. And have you talked to 
19 
anybody that has given you similar information 
20 from his Island home? 
21 
A. No. 
22 
Q. Do you know any of the girls that have 
23 
been over to his Island? 
24 
A. Yes. 
25 
Q. And who are they? 
Page 425 
1 
Q. And is your understanding that Mr. 
2 
Epstein was intimate with any of those girls? 
3 
MR. CRITTON: Form. 
4 
THE WITNESS: Yes. 
5 
BY MR. EDWARDS: 
6 
Q. With all of them? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: Yes. 
9 
BY MR. EDWARDS: 
10 
Q. With 
as well? 
11 
A. Yes. 
12 
MR. CRITTON: Form. 
13 
BY MR. EDS' 
14 
Q. With 
15 
A. Yes. 
16 
MR. CRITTON: Form. 
17 
BY MR. EDWARDS: 
18 
Q. And the girls who would come over on the 
19 airplane? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: Yes. 
22 
BY MR. EDWARDS: 
23 
Q. Did you ever have occasion to go into the 
24 
bedroom and find the vibrators or back massagers 
25 out after Mr. Epstein was in the room with any of 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 424 
A. IC 
the girls who used to stay at the 
1 
home in El Brillo used to go over there to the 
2 
Island. 
3 
Q. When he would have these girls -- I guess 
4 
we've kind of categorized them as the girls who 
5 
would come over with him on an airplane and stay 
6 
at the house. 
7 
A. Yes. 
8 
Q. When they would be staying at the house 
9 
would he also have the local Palm Beach girls 
10 
coming over that you were told to call masseuses? 
11 
A. Yes. 
12 
Q. So these girls that came on the airplane 
13 
with him, were they also -- did they also have 
14 
knowledge that these young girls were coming over 
15 
to give massages? 
MR. CRITTON: Form. 
THE WITNESS: Yes, sir. 
BY MR. EDWARDS: 
Q. Okay. Who are he girls from the 
airplaniiiir than 
that you remember? 
A. 
There 
r
o many, sirlirt 
recall right now. But vP 
is for sure, 
was one of the main girlfriends, but I don't 
remember that. 
16 
17 
18 
19 
20 
21 
22 
23 
24 
1 25 
Page 426 
the girls that came over on the plane? 
MR. CRITTON: Form. 
THE WITNESS: Yes. 
BY MR. EDWARDS: 
Q. So that's something that would be out 
after the girls that came over on the plane or the 
girls that came over for the massages? 
A. Yes. 
MR. CRITTON: Form. 
BY MR. EDWARDS: 
Q. And at the time when you were house 
manager you had a 15-year old daughter? 
A. Yes. 
Q. Did she live down here? 
A. In New Jersey. 
Q. Okay. When Alan Dershowitz was at the 
house I understood you to say that these local 
Palm Beach girls would come over to the house 
while he was there but you're not sure if he had a 
massage from any of those girls. 
A. Exactly. 
Q. And what would he do while those girls 
were at the house? 
MR. CRITTON: Form. 
THE WITNESS: He will read a book with a 
40 (Pages 423 to 426) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182383