EFTA00182476

Original Transcript 
IN THE CIRCUIT COURT OF THE FIFrEENTII JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CIVIL, DIVISION 
L.M., 
Plaintiff, 
vs. 
CASE No. 
502008CA0280513OOOCMB AB 
JEFFREY EPSTEIN, 
Defendant. 
DEPOSITION OF 
VOLUME H 
October, 20, 2009 
10:10 a.m. 
515 N. Flagler Drive 
Suite 200-P 
West Palm Beach, Florida 33401 
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida 
S 
ESQUIRE 
•n Al noel. Vall•Compny 
Toll Free: 866.709.8777 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
wvnv.esoulresolutIons.com 
EFTA00182476

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EFTA00182477

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CIVIL DIVISION 
CASE No.502008CA028051XXXXMB AB 
L.M., 
-vs-
JEFFREY EPSTEIN, 
Plaintiff, 
Defendant. 
DEPOSITION OF 
VOLUME II 
Tuesday, October, 20, 2009 
10:10 - 3:30 p.m. 
D15 N. Flagler Drive, Suite 200-P 
West Palm Beach, Florida 33401 
Reported By: 
Teresa Whalen, RPR, FPR 
Notary Public, State of Florida 
West Palm Beach Office 
Job #118991 
• 
0 
ESQUIRE 
Toll Free: 866.709.8777 
Facsimile. 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
way.esquIresoludons.com 
EFTA00182478

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October 20, 2009 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
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CASE No.08-CV-80119-CIV-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
Related cases: 
08-80232, 08-80380, 98-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-81092 
 
/ 
DEPOSITION OF 
VOLUME II 
Tuesday, October 20, 2009 
10:10 - 3:30 p.m. 
515 N. Flagler Drive, Suite 200-P 
West Palm Beach, Florida 33401 
Reported By: 
Teresa Whalen, RPR, FPR 
Notary Public, State of Florida 
West Palm Beach Office 
Job 11118991 
Phone: 
ESQLTLRE 
Toll Free: 866.709.8777 
Facsimile: 561.394.2621 
Suite 600 
4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
www.esquiresolutlons.com 
EFTA00182479

- Volume II 
October 20, 2009 
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APPEARANCES: 
On behalf of the Defendant: 
ROBERT D. CRITTON, JR., ESQUIRE 
BURMAN CRITTON LUTTLER & COLEMAN, LLP 
303 Banyan Boulevard, Suite 400 
West Palm Beach, Florida 33401 
Phone: 
On behalf of Plaintiff L.M.: 
BRADLEY J. EDWARDS, ESQUIRE 
CARA L. HOLMES, ESQUIRE 
ROTHSTEIN ROSENFELDT ADLER 
401 E. Las Olas Boulevard, Suite 1650 
Fort Lauderdale, Florida 33394 
Phone: 
On behalf of the Witness: 
BRUCE E. REINHART, ESQUIRE 
LAW OFFICE OF BRUCE E. REINHART 
250 S. Australian Avenue, Suite 1400 
West Palm Beach, Florida 33401 
Phone: 
On behalf of Defendants/Jane Does 2 - 8: 
STUART S. MERMELSTEIN, ESQUIRE 
MERMELSTEIN & HOROWITZ, P.A. 
18205 Biscayne Boulevard, Suite 2218 
Miami, Florida 33160 
Phone: 
On behalf of Plaintiff in related Case No. 08-80811 
JACK HILL, ESQUIRE (Partially via speakerphone) 
SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: 
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4440 PGA Boulevard 
Palm Beach Gardens, FL 33410 
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EFTA00182480

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- Volume II 
October 20, 2009 
WITNESS: 
134 
INDEX 
DIRECT 
CROSS 
REDIRECT 
RECROSS 
BY MR. EDWARDS: 
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190 
BY MR. MERMELSTEIN: 
135 
208 
BY MR. HILL: 
156 
BY MR. CRITTON: 
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EXHIBITS 
NUMBER 
DESCRIPTION 
PAGE 
DEPENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 
103 
DEFENDANT'S EX. 2 COMPOSITE PHONE MESSAGE BOOK 
147 
DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 
162 
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- Volume II 
October 20, 2009 
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PROCEEDINGS 
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Deposition taken before Teresa Whalen, 
Registered Professional Reporter, Florida 
Professional Reporter, and Notary Public in and for 
the State of Florida at Large, in the above cause. 
(Mr. Hill joined the proceedings in person.) 
CROSS ( 
BY MR. MERMELSTEIN: 
O 
Good afternoon. Is it all right if I call you 
A 
Yes. 
Q 
Okay. My name is Stuart Mermelstein, I also 
represent some plaintiffs in these cases, and it is my 
turn to ask you some questions. 
We were talking about when Mr. Epstein was in 
jail, which was between June 30th of 2008 and July of 
2009; correct? 
A 
Yes. 
Q 
Now, during that time you weal. Lu work your 
regular schedule at 358 El Brillo Way; is that correct? 
A 
Yes. 
• 
So you were working basically --
MR. CRITTON: She's not finished. 
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October 20, 2009 
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BY MR. MERMELSTEIN: 
Q 
I'm sorry. Go ahead. 
MR. REINHART: Do you need to expand on your 
answer? 
BY MR. MERMELSTEIN: 
Q 
Were you finished? 
A 
I worked regular hours, but sometimes there 
are times that I report eight, sometimes I report 
nine o'clock. 
Q 
And I believe 
A 
It's flexible. 
Q 
Okay. And it was after he left jail that you 
started working at 6:00 a.m., correct? 
A 
Yee. 
Q 
So whether you start work at eight or nine is 
your choice? When you say "it's flexible," it means you 
can chose whether to come at eight or nine? 
A 
Yes. When he was not there. 
Q 
Okay. It didn't matter whether you there at 
eight or nine when he was not there, correct? 
A 
No. 
Q 
And what kind of things did you do at the 
house -- let me ask the question this way. 
How were your duties different when he was not 
there during the time he was in jail from when he would 
CIO 
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October 20, 2009 
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come there before he went to jail? 
A 
When he was in jail? 
• 
Yes. 
A 
I clean the house. 
Q 
You had less to clean, is that fair to say, 
because Mr. Epstein, I assume, based on your testimony, 
there were much fewer people in the house than before, 
correct? 
A 
Yes. I made inventory of the linens. 
Q 
I'm sorry? 
A 
Of the linens, I made inventory of the linens. 
Oh. Inventory of the linens? 
A 
Inventory. 
Q 
Okay. So you did that. And what else did you 
do to fill the time? 
A 
Wash the clothes that was in storage, you 
know. 
Q 
You washed clothes in storage? 
A 
Yes. Because it was right there, so I just 
wash it and then press if it needs pressing. 
Q 
So he has clothes stored outside of Lhe house? 
A 
No. In the house. 
Q 
In the house. Okay. So even if they hadn't 
been worn, you washed them, correct? 
A 
And press them. 
• 
0 
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October 2C, 20C9 
138 
MR. CRITTON: Form. 
THE WITNESS: Yes. 
BY MR. MERMELSTE:N: 
Q 
What other type of things did you do while he 
wasn't there? 
A 
If there are plants, I attend to the plants. 
Q 
Okay. Is that something you didn't do before 
he went to jail? 
A 
I do that also when before he went to jail. 
0 
Okay. 
A 
If there are orchids or plants in the house, 
then I attend to it. 
Q 
I guess my question is what kind of projects 
did you work on when he was not there to fill your time 
after he went to jail? 
A 
Cleaning, tidying, just going around the 
house. If I see something that needs painting, I tell 
Janusz. 
Q 
Now, are you paid on the basis of a yearly 
salary, or are you paid weekly or monthly; how does that 
work? 
A 
We are paid twice a month. 
Q 
Okay. That's when you receive your pay? 
A 
Yes. 
Q 
I guess my question is this: Say you have to 
0 
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October 20, 2009 
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139 
take a half a day of work off, do you get paid for that? 
A 
Yes. In my situation. 
Q 
I'm sorry. In your what? 
A 
In my situation 
I 
was paid. 
Q 
Okay. So you're on like a fixed salary, if 
you miss some time you still get the same amount of 
money, correct? 
A 
Yes. 
Q 
And I take it that during the period in which 
Mr. Epstein was in jail, you continued to receive the 
same salary, plus a raise, I assume, at the beginning of 
the year; correct? 
A 
Yes. 
Q 
So you continued to receive the same salary 
that you did before Mr. Epstein went to jail, correct? 
A 
Yes, sir. 
Q 
Did Mr. Epstein ever pay bonuses or any extra 
money to you? 
A 
Yes. 
Q 
What kind of bonuses did you receive? 
A 
Yearly bonus. 
Q 
You get a yearly bonus. When is that paid, is 
that paid at holiday time, Christmas time? 
A 
After the year. 
Q 
At the end of the year? 
• 
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October 20, 2009 
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A 
At the end of the year. 
Q 
At New Years? 
A 
New Years. 
Q 
And this past year, when 2008 became 2009, how 
much of a bonus did you receive? 
A 
I did not receive any. 
Q 
And what about before that, what kind of bonus 
did you receive? 
A 
The yearly bonus. 
• 
Okay. What would be the amount of the yearly 
bonus? 
A 
Oh. For me? The last one I receive was 
5,000. 
• 
Okay. So this would be in addition to your 
salary of $42,000? 
A 
Yes. 
Q 
And this $5,000 bonus you would have received 
in or about January 2008; is that correct? 
A 
Not eight. 
Q 
Pardon? 
A 
Not eight. We did not get any bonus in 2008. 
Q 
Okay. So when was the last time you received 
a $5,000 bonus? 
A 
I think 2007. 
Q 
So it's been two years since you've gotten a 
0 
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October 20, 2009 
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bonus; is that correct? 
A 
Let me see. Yes. 
Q 
Okay. Did Mr. Epstein explain to you why he 
wasn't giving you a bonus in the last two years? 
A 
He did not personally told us. 
Q 
Did someone tell you why you were not getting 
a bonus? 
A 
Janusz was informed, and Janusz informed me. 
Q 
Okay. Did Janusz give you a reason why you 
weren't getting a bonus? 
A 
Because of the economy, that's what he said. 
• 
Any other reason that he gave? 
A 
No, sir. 
Q 
Did you receive a $5,000 bonus for 2006 and 
2005? 
A 
It was different, it gradually increased. 
• 
Okay. 
A 
It was not the same amount. 
Q 
What was the bonus in 2006 and 2005? 
A 
2005 was 2,000. 
Q 
Uh-huh. 
A 
And then the next is 5,000 and 5,000. 
• 
Okay. So correct me if I am wrong, but in 
January 2005 you received a $2,000 bonus? 
A 
Yes. 
• 
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Q 
And at that point in time you had really just 
started a month and a half before? 
A 
No. I want to correct that. I receive a 500 
after I started there November. 
Q 
Yes. November of 2004 you started? 
A 
At Christmas I receive, after Christmas I 
receive $500. 
Q 
Okay. So in January of 2005 you receive $500, 
correct? 
A 
Yes. 
Q 
Then in January 2006 you received how much? 
A 
2,000. 
Q 
And in January 2007 you received 5,000; is 
that correct? 
A 
Yes. 
Q 
And in January 2008 you received no bonus? 
A 
No. 
Q 
Is that correct? 
A 
Correct. 
Q 
Correct, you received no bonus? 
A 
No bonus. 
Q 
And the same in January 2009, correct? 
A 
Correct. 
Q 
Has Mr. Epstein advised you, discussed with 
you at all how much of a bonus you're going to receive 
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1IIIIIIIIIIIII- Volume II 
October 20, 2009 
143 
after the holidays this year? 
A 
No, sir. 
Q 
Has anyone discussed with you what bonus you 
will receive after the holidays this year? 
A 
No. 
0 
Do you have any expectation as to what kind of 
bonus you'll receive? 
A 
I don't -- I did not expect anything. 
Q 
You testified earlier about a 
who is the 
housekeeper in New York, correct? 
A 
Yes. 
Q 
Now, when was the first time you met III in 
person? 
A 
In person? When I went to New York. 
Q 
And when was the first time you went to 
Now York? 
A 
In 2006. 
Q 
2006. And was the reason you went to New York 
in 2006 for Ms. Maxwell's party? 
A 
No. It was III I think had a surgery. 
Q 
Okay. And you were there to cover fur her 
while she had surgery? 
A 
Yes. 
Q 
And how long were you there? 
A 
I cannot remember, but after her surgery, then 
• 
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we left to Palm Beach. 
Q 
Okay. You don't remember how long it was? 
A 
I cannot remember, because I've been there 
like four times, or more than four times. 
Q 
More than four times? 
A 
Yes. 
Q 
Okay. So this first time when she had her 
surgery, you were the housekeeper then in New York while 
she was out, correct? 
A 
Yes, sir. 
Q 
But did she come into the house in New York 
and that's how you met her while she was recovering, or 
how was it that you met her at that time? 
A 
We met her before her surgery, I met her 
before her surgery. 
see. Then she went and had her surgery. 
Now, when you traveled to New York, did you go 
on Mr. Epstein's plane? 
A 
No, sir. 
Q 
How did you travel to New York? 
A 
Commercial. 
Q 
So Mr. Epstein purchased you a ticket on an 
airline to fly to New York? 
MR. CRITTON: Form. 
THE WITNESS: Yes, sir. 
0 
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BY MR. MERMELSTEIN: 
O 
Now, let's talk about the other times that you 
went, you traveled to New York. When was the next time 
afLeL 
Lecover.ed fLum lies sulyety Uiat you went to 
New York? 
A 
I think when she went to the Philippines. 
O 
Okay. She went for like a vacation to go to 
visit her family? 
A 
No. I'm not really good. There was time I 
went there because I think I sometimes interchange, but 
T went there one time herAuse to rover up for 
Ms. Maxwell's housekeeper. 
Q 
Okay. 
A 
And when she was having a party. 
Q 
Okay. So those are two separate times? 
A 
Yes. Two separate times. 
Q 
Both relating to Ms. Maxwell? 
A 
No. The first one was -- first one to cover 
up for III. 
Q 
Right. I understood that. But after that, 
when you came back --
A 
There was a time -- I don't know the sequence, 
but you know, there was a time I have to cover up for 
Ms. Maxwell's housekeeper. 
Q 
I see. What's her name? 
• 
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October 20, 2009 
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A 
Q 
And then there was another time where you went 
to work for this party that she had, correct? 
A 
Yes. 
Q 
Okay. And the fourth time? 
A 
When III went to the Philippines. 
• 
Okay. About how long were these visits each 
time? 
A 
Sometimes a week, two weeks, then there was a 
time I stayed there for like a month. 
Q 
Which was that, when she had her surgery, III 
had her surgery, or was this a different time? 
A 
Oh, what's this? Let me see. I cannot 
really, what's this? 
Q 
Take your time, take your time. 
A 
Oh. When, what's this, Ms. Maxwell's 
housekeeper, I was to cover up for her because tor jury 
duty. And then she was not part of the jury, so my stay 
there was, like, extended. That's how I was able to 
help with the party. 
• 
She did not get on the jury? 
A 
Yes. she was called. 
• 
But you stayed anyway to help with the party? 
A 
Yes. 
Q 
I think I understand. Now, have you ever, 
0 
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147 
while you've been employed by Mr. Epstein, traveled 
anywhere else for work? 
A 
No, sir. 
Q 
Those trips to New York was the only time 
you've traveled? 
A 
Yes, sir. 
Q 
You've never gone to New Mexico or to the 
Virgin Islands for Mr. Epstein? 
A 
No. 
(Plaintiff's Exhibit No. 2 was marked for 
identification.) 
BY MR. MERMELSTEIN: 
Q 
Let me show you what's been marked Exhibit 2. 
Does it look like the paper that you were talking about 
earlier where you wrote the names and the time? 
A 
Yes, sir. 
Q 
Okay. So this is kind of a notebook or a 
message pad notebook that was I think you said located 
by the pantry? 
A 
Yes, sir. 
Q 
Can you look through this and Lell me if any 
of these, point out any of those that are in your 
handwriting? 
MR. REINHART: Take your time, look at each 
one, and just tell him if you see any that you 
• 
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- Volume II 
October 20, 2009 
148 
recognize your handwriting. 
MR. CRITTON: You asked her to identify if she 
sees anything in her writing? 
MR. MERMELSTEIN: Yes. 
THE WITNESS: (Shaking head.) 
BY MR. MERMELSTEIN: 
Q 
Okay. I understand your response is that you 
reviewed the various message slips included in Exhibit 
No. 2 and none of them are your writing, correct? 
A 
Yes, correct. 
• 
But you do recall writing messages on this 
type of pad for Mr. Epstein, correct? 
A 
Correct. 
MR. CRITTON: Stuart, that was exhibit what at 
Mr. Rodriguez's deposition? 
MR. MERMELSTEIN: Exhibit 1 at Mr. Rodriguez's 
deposition. 
MR. CRITTON: Okay. 
BY MR. MERMELSTEIN: 
O 
In the period 2004 to 2008 before Mr. Epstein 
went to jail, do you recall whether there were females 
who were sitting at the pool in the home at 358 
El Brillo Way who were topless? 
A 
There was one time. 
• 
One time you remember. Tell me what happened 
0 
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