EFTA00310278

Page 427 
1 
glass of wine by the pool, stay inside. 
2 
BY MR. EDWARDS: 
3 
Q. Did he ever talk to any of the girls? 
4 
A. I don't know, sir. 
5 
Q. Certainly he knew that they were there? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: I don't know, sir. 
8 
BY MR. EDWARDS: 
9 
Q. Do you know how Snows 
Mr. 
10 Epstein? 
11 
A. No, sir. 
12 
Q. Or how long she's known him? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: She was on board two years 
15 
or a year and a half before I came on board. 
16 
BY MR. EDWARDS: 
17 
Q. Okay. 
18 
A. So it's probably 2003 or 2. 
19 
Q. All right. You mentioned this Otrix 
20 system. 
21 
A. Yes. 
22 
Q. Is that a system that was used to operate 
23 
the phones and the computers? 
24 
A. The computers mainly. 
25 
Q. All right. But you then also described 
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 429 
usually it's Yahoo dot corn or at Bellsouth dot 
net. 
A. It was very uncommon. I don't remember, 
sir. 
Q. Did everybody in the -- I think you 
called it the organization, did everybody have 
e-malls? 
A. Yes. 
Q. Okay. Would that include 
A. Yes. 
Q. All right. And did Mr. Epstein have an 
e-mail? 
A. Yes. 
Q. Did you ever correspond with Mr. Epstein 
by e-mail? 
A. Yes. 
MR. EDWARDS: You can go ahead. 
THE WITNESS: That's the only one that I 
remember. 
THE VIDEOGRAPHER: Okay, we're off the 
record. 
(Thereupon, a recess was had.) 
THE VIDEOGRAPHER: We're back on the 
record with tape number four. 
BY MR. EDWARDS: 
Page 428 
1 some system where someone would call on the 
2 
telephone and that would be automatically 
3 
downloaded to the computer? 
4 
A. Yeah, you can retrieve who called in a 
5 
transcript written who called, what's the message, 
6 
the time so you have it on a piece of paper, you 
7 
can print it out. 
8 
Q. Is it your understanding that is also 
9 
part of the Citrix system? 
10 
A. Yes. 
11 
Q. All right. Did you have an e-mail? 
12 
A. Right now, yes. 
13 
Q. No, when you were working at — 
14 
A. Yes, I did. 
15 
Q. 
16 
An- dhldridlinhave 
an e-mail? 
17 
A. Yes. 
18 
Q. And did all of the e-mails end the same 
19 
way such as Epstein's house dot com or something? 
20 
A. Yes. 
21 
Q. Okay. What wa 
e-mail? 
22 
A. I don't remem 
23 
Q. What was your e-mail? 
24 
A. Staff house -- I don't remember, sir. 
25 
Q. Do you recall how it ended? I mean 
Page 430 
1 
Q. Mr. Rodriguez, what was Mr. Epstein's 
2 
e-mail? 
3 
A. Jeep project at something -- Jeep 
4 
project -- I can't remember it right now. 
5 
Q. Okay. In the course of this next 10 or 
6 
15 minutes --
7 
A. I can recall. 
8 
Q. -- if it comes to you just tell me. So 
9 it was Jeep project --
10 
A. Like Jeep, the brand name Jeep, Jeep 
11 project at — I can't remember. 
12 
Q. Okay. Was that his only e-mail to your 
13 
knowledge? 
14 
A. No. 
15 
Q. He had other e-mail addresses? 
16 
A. Yes. 
17 
Q. Do you know what any of his other e-mail 
18 
addresses were? 
19 
A. No, I don't remember. 
20 
Q. Do you know who the carriers were for the 
21 other e-mail addresses owned by Jeffrey Epstein? 
22 
A. No, sir. 
23 
Q. Whether it was Yahoo or hot mail or --
24 
A. No, none of those. 
25 
Q. Okay. Was this Jeep project e-mail run 
41 (Pages 427 to 430) 
Kress Court Reporting, Inc. 
EFTA00310318

Page 431 
1 through the Citrix system? 
2 
A. Yes. 
3 
Q. Okay. And was there a certain company 
4 
that came out and fixed the actual Citrix system? 
5 
A. Yes. 
6 
Q. And who was that? 
7 
A. We used to have our own in-house 
8 
technician from Ohio. 
9 
Q. The same guy you were telling us about 
10 
before? 
11 
A. Yes. 
12 
Q. All right. He would fix the video 
13 equipment or the --
14 
A. Computers mainly. 
15 
Q. And if the Citrix system broke down too 
16 then he would be in charge of it? 
17 
A. He was the only one dealing with this, we 
18 couldn't hire anybody else. 
19 
Q. Do you know why that is? 
20 
A. No. It was too many lines into the house 
21 from many properties. 
22 
Q. And do you know who that person is, 
23 remember his name now? 
24 
A. I don't remember, sir. 
25 
Q. I understood you to say at some point in 
Page 433 
1 
at the house did any of these girls, these local 
2 
Palm Beach girls come over to the house as well? 
3 
A. They were earlier, sometimes they will 
4 
leave and he will stay for dinner. 
5 
Q. All right. And you remember there was 
6 
one time where maybe= stayed for dinner with 
7 
David Copperfield? 
8 
A. That's correct. 
9 
Q. Was there ever a time where 
. and 
10 David Copperfield were In a bedroom 
ether? 
11 
A. I don't think Mr. Copperfield went 
12 upstairs. 
13 
When the police came to the driveway with 
14 =in 
the car, what did yoe tell the police, if 
15 
anything, that you were paying El for? 
16 
A. They asked me whose this people, and I 
17 
said they're a masseuse. 
18 
Q. Okay. Why would you tell them that 
19 they're a masseuse, that's the name you were 
20 
supposed to call them? 
21 
MR. CRITTON: Form. 
22 
THE WITNESS: Yes. 
23 
BY MR. EDWARDS: 
24 
Q. And for these massages you were paying 
25 
between 300 and 500 dollars each time? 
Page 432 
1 time that you saw photographs of some of the girls 
2 
that were at the house to give massages on 
3 
Ms. Maxwell's computer. 
4 
A. Yes. 
5 
Q. And --
6 
MR. CRITTON: Form to the last question. 
7 
BY MR. EDWARDS: 
8 
Q. And do you know which of the girls? 
9 
A. No, sir. 
10 
Q. Was In one of them? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: I cannot guarantee that, I 
13 
cannot say hundred percent, sir. 
14 
BY MR. EDWARDS: 
15 
Q. Was. one of them? 
16 
A. Could be, s= 
17 
Q. How about
18 
A. It's the same thing, I cannot say a 
19 hundred percent, sir. 
20 
Q. I think that you used the phrase there 
21 were so many girls. 
22 
A. Yes, sir. 
23 
Q. That you're not sure which ones you saw? 
24 
A. No, sir, so many names. 
25 
Q. Okay. While David Copperfield was ever 
Page 434 
1 
A. Yes, sir. 
2 
Q. And that's usually for an hour up in the 
3 
bedroom with Mr. Epstein? 
4 
A. More or less, yes. 
5 
Q. You never told your 15-year old daughter 
6 at the time that she could come over to Mr. 
7 
Epstein's for $500 an hour? 
8 
A. No, sir. 
9 
MR. CRITTON: Form. 
10 BY MR. EDWARDS: 
11 
Q. Why is it that you never asked your 
12 daughter to come over if it's just a massage? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: My daughters are too clean 
15 
for that, sir. 
16 BY MR. EDWARDS: 
17 
Q. Too dean to give a massage? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: They are good students, 
20 
they are in another type of environment, 
21 
sir, we are poor but you know, they're good 
22 
students. 
23 
BY MR. EDWARDS: 
24 
Q. It's because you knew there was more than 
25 
a massage going on in the bedroom? 
42 (Pages 431 to 434) 
EFTA00310319

Page 435 
1 
MR. CRITTON: Form. 
2 
THE WITNESS: Yes, sir. 
3 
BY MR. EDWARDS: 
4 
Q. What are some of Mr. Epstein's companies, 
5 if you know the names? 
6 
A. Well, he was the Price -- Price Corn, it 
7 
was one of his companies, he had a phone company 
8 
in Palm Beach. A lot of offshore companies that 
9 I don't recall, sir. 
10 
Q. When you say Price Com --
11 
A. Price dot Com, he owned that for awhile. 
12 
And the local phone company in Palm Beach was his 
13 
but then he sold it again. But there is too many. 
14 
Q. As house manager you're obviously at his 
15 
house every single day, did you inquire as to what 
16 he did in terms of making money? 
17 
A. No, sir, I only got through the Internet 
18 
because I put his name on Google and then I find 
19 out the rest of his companies. 
20 
Q. So during the day when he would go to the 
21 cabana I think that you described last time that 
22 he would work there? 
23 
A. He would work there. 
24 
Q. Do you know what he would do in terms of 
25 
working? 
Page 437 
1 
telephone numbers of various girls that were 
2 
referred to as masseuses, did that also give you 
3 
access to the girls that were coming over to Mr. 
4 
Epstein's house in Paris and New York and New 
5 
Mexico? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: We used to have a book in 
8 
every car, in every plane, in every boat 
9 
that Mr. Epstein with all the names of all 
10 
these people so it was not necessarily a 
11 
secret. 
12 
BY MR. EDWARDS: 
13 
Q. When we're talking all these people, are 
14 
we talking about --
15 
A. Masseuses and, you know, chefs, the 
16 important people in the life of Mr. Epstein, you 
17 
know, used to have a black book with all the 
18 names. 
19 
Q. So there were many black books? 
20 
A. Yes. 
21 
Q. And do you know where those black books 
22 are now? 
23 
A. There were tons of those in the house 
24 but, you know, I don't know. 
25 
Q. Okay. And did each one of them have 
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 436 
A. No, that was very private. I would put 
his coffee 
• uld shut the door. 
Q. An. 
had a work station or 
work comer - TT 
house? 
A. Yes. 
Q. What did she do in terms of work? 
A. She will set appointments for comedy 
shops, movies. I will get the tickets but, you 
know, she was appointments for the masseuse, or 
travel arrangements with the pilots, that type of 
thing. 
Q. And would she keep track of all of the 
girls who were coming to his house in Palm Beach 
or at the other houses as well? 
MR. CRITTON: Form. 
THE WITNESS: All of the houses. 
BY MR. EDWARDS: 
Q. All right. So if he was going to be in 
Paris and he wanted girls over in that house she 
would keep track of that as well? 
MR. CRITTON: Form. 
THE WITNESS: Exactly. 
BY MR. EDWARDS: 
air
nd when you talked about seeing 
computer 
and seeing the names and 
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 438 
handwritten names and numbers or were these 
computer printouts so they were the same? 
A. They were very organized. Once In awhile 
they used to be updated, so we used to have these 
books with obsolete dates, you know, so we discard 
them and have the new ones. 
Q. By obsolete dates are you saying that 
there were girls that came over and then they no 
longer came over anymore? 
A. That's correct. 
MR. CRITTON: Form. 
BY MR. EDWARDS: 
Q. Okay. So if a girl that was coming over 
for a period of time got too old and was no longer 
able to come over and somebody else took her place 
then her page would disappear from that book? 
MR. CRITTON: Form. 
THE WITNESS: I believe so, sir. 
BY MR. EDWARDS: 
Q. You were asked about other homes that you 
worked at for other wealthy people and asked if 
these other homes had a massage table. 
A. Yes. 
Q. And you said that they did? 
A. Yes. 
43 (Pages 435 to 438) 
EFTA00310320

Page 439 
1 
Q. And you said that that was -- the massage 
2 
table was similar in kind to that used by Mr. 
3 
Epstein? 
4 
A. That's correct. 
5 
Q. And others had massage oils and that was 
6 similar in kind to Mr. Epstein's as well? 
7 
A. Yes. 
8 
Q. And you didn't think that the massage 
9 table at a home was unusual? 
10 
A. No. 
11 
Q. All right. Did any of the other houses 
12 where you worked have masseuses that were 14, 15, 
13 and 16 years old? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: No, sir. 
16 BY MR. EDWARDS: 
17 
Q. And did any of the other homes where you 
18 worked have different girls of that age coming 
19 every single day? 
20 
A. Yes. 
21 
MR. CRITTON: Form. 
22 BY MR. EDWARDS: 
23 
Q. They had different girls? 
24 
A. Yes. 
25 
Q. Okay. And how old were the girls that 
Page 441 
1 
MR. EDWARDS: I don't have anything else. 
2 
MS. EZELL: I have a few. 
3 
EXAMINATION 
4 
BY MS. EZELL: 
5 
Q. Mr. Rodriguez, I may have missed 
6 
something. Did you say that there weren't any 
7 
wild parties ever at El Brillo Way? 
8 
A. I never saw what was going on inside the 
9 
house, Ma'am. 
10 
Q. So you don't know wether there were or 
11 were not? 
12 
A. No, ma'am. 
13 
Q. There wasn't just one massage table 
14 
there; was there? 
15 
A. We used to have two and we have an extra 
16 reserve, I think there were three In the house. 
17 
Excuse me, I'll take that back. All the bedrooms 
18 
used to have one. 
19 
Q. Okay. Ihanl
u. 
20 about a girl name 
21 
A. No, no, ma
22 
Q. And those pictures on Ms. Maxwell's 
23 computer, did you ever see one of a girl naked in 
24 
a hammock? 
25 
MR. CRITTON: Form. Asked and answered. 
Did you ever hear 
Page 440 
1 would come to these other homes? 
2 
A. They seem older. 
3 
Q. Older than the ones that would come to 
4 
Mr. Epstein's home? 
5 
A. Yes. 
6 
Q. And did you ever work at a place where 
7 
there would be girls calling up on the phone to 
8 
say I have girls to bring him and --
9 
A. No, sir. 
10 
Q. -- coming over in teams --
11 
A. No. 
12 
Q. -- or pairs? 
13 
A. No. 
14 
Q. So there were a lot of things about Mr. 
15 Epstein's house and his arrangement that were very 
16 unusual compared to the other places where you 
17 worked? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: Yes. 
20 
BY MR. EDWARDS: 
21 
Q. And there were no drugs and alcohol or no 
22 wild parties at Mr. Epstein's house, that is 
23 
somewhat different from some of the other places 
24 where you worked? 
25 
A. Yes. 
Page 442 
1 
THE WITNESS: I saw on a book not on a 
2 
computer. 
3 
BY MS. EZELL: 
4 
Q. You saw a picture of a girl naked in a 
5 
book or on a book? 
6 
A. The book was done for Nadia and she was 
7 
on the hammock, that's the only one I saw. 
8 
Q. I'm sorry, the book was done for Nadia? 
9 
A. She was on the cover. 
10 
Q. Then there were other people inside the 
11 book? 
12 
A. Yes, ma'am. 
13 
Q. And in that book there was a picture of a 
14 girl naked in a hammock? 
15 
A. Yes. 
16 
Q. Where did Nadia keep that book? 
17 
A. There were a few of those examples but I 
18 don't know where she kept it. 
19 
Q. Was it laying around the house somewhere? 
20 
A. Yes. 
21 
Q. Downstairs? 
22 
A. Downstairs, yes, ma'am. 
23 
Q. Did Nadia keep scrapbooks or photograph 
24 
books --
25 
A. Yes. 
44 (Pages 439 to 442) 
EFTA00310321

Page 443 
1 
Q. -- of friends, girls? 
2 
A. Yes, ma'am. 
3 
MR. CRITTON: Form. 
4 
BY MS. EZELL: 
5 
Q. Do you remember there being a young man 
6 ,who would bring girls to the house named Tony 
7 
Figueroa? 
8 
A. No, ma'am. The only person that I saw 
9 
that night A. was at the house, she was driving 
10 
the car, but I didn't see any males. 
11 
MR. CRITTON: You said he, he being whom? 
12 
BY MS. EZELL: 
13 
Q. I didn't quite understand that either. 
14 
Tony Figueroa was driving. 
15 
A. She was with this girl that night, A. I 
16 think that's the only time I saw a male at the 
17 
house, ma'am. 
18 
Q. And you're talking about the night when 
19 you came and found the old car in the driveway? 
20 
A. Exactly, yes, with the police, yes. 
21 
Q. How did you remember that it was Tony 
22 
Figueroa? 
23 
A. It's the only person, male that I 
24 remember. 
25 
Q. But you don't know his name? 
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 445 
eras 
like.", she was 
and me, I guess. She was to hell, 
Q. And is that what your understanding was 
as to whatiMa did? 
A. I'm sorry? 
Q. Was it 
there to he 
A. 
Q. 
understanding that 
with her duties? 
was. 
was. Okay. 
ve you spoken to any lawyers or 
investigators about this case since you were 
deposed last? 
A. No, ma'am. 
Q. I believe Mr. Critton was askin 
questions relating to the incident when 
was 
in a car in the driveway and you went 
t the 
police and he was speaking of that time as being 
in January of '05. Do you remember when it was? 
A. I will put that in that month, ma'am, but 
I cannot guarantee. 
Q. Let me just show you something that we 
can mark as the next exhibit. 
I would just ask that if -- yes, the name 
is in here that we redact it to show just the 
was 
Page 444 
1 
A. No, no, no, Ma'am. 
2 
Q. Got you. Thank you. 
3 
MR. CRITTON: Can I ask one quick? 
4 
There was a man with. 
you don't know 
5 
who It was? 
6 
THE WITNESS: That's the only male that's 
7 
been to the house, so when she asked me the 
8 
question I assume, you know. 
9 
MR. CRITTON: Do you know who Tony 
10 
Figueroa is? 
11 
THE WITNESS: No, sir. 
12 
MR. CRITTON: Okay. Now I think I 
13 
understand. Thank you. Sorry, Cathy. 
14 
MS. EZELL: That's okay. 
15 
BY MS. EZELL: 
16 
Q. I asked y 
chefs name 
17 could have been 
nd I was wrong, I 
18 
wanted to ask you a different name. 
19 
Could it have been 
7 
20 
A. I don't remember his last name. 
21 
Q. Do you remember an assistant of some sort 
22 who worked there for awhile when you were there 
23 named 
24 
A. Yes. 
25 
Q. What did she do? 
Page 446 
1 initials. 
2 
MR. EDWARDS: We're going to attach this; 
3 
right? 
4 
MS. EZELL: Yes. 
5 
MR. CRITTON: You're going to let us have 
6 
this one? 
7 
MS. EZELL: Yes. With initials. 
8 
(Exhibit No. 9 was marked for 
9 
Identifkation.) 
10 BY MS. EZELL: 
11 
Q. Have you ever seen this report? 
12 
A. I saw it typed, not handwritten like 
13 this. 
14 
Q. Did the police bring you one that was 
15 typed? 
16 
A. No, the only time I saw my own report was 
17 on the Internet because my daughter told me do you 
18 know that you're in Palm Beach and this and that, 
19 so I was in New York on vacation and that's why I 
20 read it but this is the first time I'm looking at 
21 this. 
22 
Q. Okay. 
23 
MR. HOROWITZ: Do you have extra copies? 
24 
MS. EZELL: I do, I don't want to give 
25 
them out, I'd rather -- I don't mind them 
45 (Pages 443 to 446) 
EFTA00310322

Page 447 
1 
attaching it to the deposition as long as it 
2 
has just the initials. 
3 
THE WITNESS: This is the report when I 
4 
called to the police to the house? 
5 
BY MS. EZELL: 
6 
Q. Let me let you look at it, I'd rather you 
7 
tell us if it is. 
8 
A. This is why I was fired. This is the 
9 
reason I was let go. 
10 
MR. CRITTON: There is no question right 
11 
now. I'm sure there will be. 
12 
MR. EDWARDS: I'll ask it if you want. 
13 
THE WITNESS: I'm thinking out bud. 
14 
BY MS. EZELL: 
15 
Q. Did you notice the date on this report? 
16 
A. November 28th, yes, ma'am. 
17 
Q. And do you have any reason to believe 
18 that that's not accurate? 
19 
A. No, that's it, yeah. 
20 
Q. And as you look at other information on 
21 the report do you see anything else that's not 
22 accurate? 
23 
A. Let me finish reading this, please. 
24 
Q. Sure. 
25 
MR. CRITTON: Let me just object to the 
Page 449 
1 
Q. Can you tell me what you mean by that? 
2 
A. Mr. Epstein used to give a lot of gifts 
3 to the police department, so we used to have 
4 
certain leeway in terms of speeding or some other 
S 
things. So he used to put a baseball cap Palm 
6 
Beach Police Department on the dashboard. 
7 
So when he saw I called the police for my 
8 
own safety because I was carrying cash, I 
9 
explained that to him, and he say why you called 
10 the police, and I said because I saw a dunker in 
11 the driveway and it's dark. In Palm Beach there 
12 is no nights. So I called for my own safety. I 
13 
was coming from Publix buying my groceries and I 
14 
had cash in my pocket. And I said I called the 
15 
police because I was concerned about my own 
16 safety. 
17 
And I recognized the girl and I figured 
18 
because I remember 
told me earlier that day 
19 -- it was a hectic day, he just left Palm Beach 
20 and I was catching up with my breath, you know, I 
21 went to buy my groceries, and I explained that. 
22 
So he was upset that this will spill, you know, to 
23 
the public or the street. But I didn't realize 
24 this was written or something, you know. 
25 
Q. You were not fired though until sometime 
Page 44e 
1 
form. Can I look at your copy, please? 
2 
THE WITNESS: This is the first time I 
3 
saw this. 
4 
BY MS. EZELL: 
5 
Q. Have you had a chance now to read it? 
6 
A. Yes, ma'am. 
7 
Q. Okay. Does this report accurately 
8 
describe what occurred that evening? 
9 
A. Yes, ma'am. 
10 
MR. CRITTON: Form. 
11 BY MS. EZELL: 
12 
Q. Did you overhear the conversation between 
13 
A.H. and the policeman? 
14 
A. Yes, ma'am. 
15 
Q. And is that part accurate as well? 
16 
A. Yes. 
17 
Q. And then your conversation with Mr. --
18 with Officer Munyan --
19 
A. Yes, ma'am. 
20 
Q. -- is that accurately reported here as 
21 well? 
22 
A. Yes, ma'am. 
23 
Q. Now you stated that this is why you got 
24 
fired. 
25 
A. Yes, ma'am. 
Page 450 
1 in March? 
2 
A. Exactly, yes. But he gave me -- Mr. 
3 
Epstein used the word I'm going to give you -- he 
4 
make fun of my Spanish and he said (speaking in 
5 
Spanish). 
6 
And I said, yes, Mr. Epstein. Okay, I'll 
7 
give you one more chance. And I said what's going 
8 on. But, you know, it meant a few words, I 
9 
couldn't talk to him too much, but this was it. 
10 
Because, you know, I have to say this for 
11 myself, you know, I never did something illegal, I 
12 
was working hard to please him and sometimes more 
13 than I was supposed to, many hours beyond my 
14 duties, and so — but he was concerned about this. 
15 
And I say, Mr. Epstein, you told me 
16 
safety is the paramount of this house, in this 
17 case it was me, but obviously he didn't care about 
18 me, it was his safety. 
19 
MR. CRITTON: Form. Move to strike. 
20 
BY MS. EZELL: 
21 
Q. Can you translate for me what you said a 
22 moment ago in -- I don't know --
23 
A. In Spanish he said "conose" amnesty, but 
24 he used the word "conose amnistia", I'll give you 
25 amnesty so you have a chance to continue working 
46 (Pages 447 to 450) 
Kress Court Re•.rtin• Inc. 305-866-7688 
EFTA00310323

Page 451 
1 with me. 
2 
But I didn't ask him why. He just came 
3 
fast. You're always in the run, you have to be on 
4 
your toes, and the next thing he said I took the 
5 
wrong Suburban and they let me go. 
6 
But I never find out what happened 
7 
because I have to say this. Being so many people 
8 
in the house I didn't know if I displease one of 
9 the girls, or something I said or I did, I don't 
10 think so. So they let me go very mysteriously. 
11 But this is it. 
12 
Q. I understood you to say that Mr. Epstein 
13 gave lots of gifts to the police department. 
14 
A. Yes, ma'am. 
15 
Q. And you said something about a baseball 
16 cap. 
17 
A. Well, the police department used to give 
18 us in retribution dozens of baseball caps with the 
19 Palm Beach Police Department, you put one of those 
20 on the dashboard you don't get a ticket 
21 
Q. Oh. 
22 
A. Stuff like that. Key rings and so on and 
23 so forth. There Is -- everybody knows this, I 
24 don't think it's a secret. Mr. Epstein give 
25 
$85,000 simulator for the police to shoot, you 
Page 453 
1 her do you believe under the influence of drugs? 
2 
A. No. 
3 
Q. Did you ever see steroids in the house? 
4 
A. No. 
S 
MR. LANGINO: Thank you. 
6 
MR. EDWARDS: Do you have anything, 
7 
Richard? 
8 
MR. WILLITS: Yes. 
9 
MR. EDWARDS: Okay, shoot. 
10 
EXAMINATION 
11 BY MR. WILLITS: 
12 
Q. Mr. Critton asked you several questions 
13 about the females who you were told to refer to as 
14 masseuses. And when he asked you those questions 
15 he referred to them often as women. 
16 
Did you think of those masseuses as 
17 
women? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: Yes. 
20 BY MR. WILLITS: 
21 
Q. Why? 
22 
A. Because I saw them, they were females. 
23 
Q. What is your definition of a woman? 
24 
A. Person of the opposite sex, I'm a male. 
25 
Q. Is a three-year old a woman? 
Page 452 
1 know, and it was returned after the scandal broke 
2 out. 
3 
MR. CRITTON: Move as nonresponsive to 
4 
any question. Move to strike. 
5 
MS. EZELL: I don't have any other 
6 
questions. 
7 
EXAMINATION 
8 
BY MR. LANGINO: 
9 
Q. Mr. Rodriguez, do you know where the main 
10 
server, the main computer server was located 
11 inside the house? 
12 
A. In the garage. 
13 
Q. Do you know the names of any of the 
14 programs — computer programs --
15 
MR. WILLITS: I am missing something. 
16 
Whose questioning now? 
17 
MR. LANGINO: Adam Langino. 
18 
BY MR. LANGINO: 
19 
Q. Do you know the names of some of the main 
20 computer programs that are used as part of your 
21 routine as the house manager of the house? 
22 
A. The main computers? 
23 
Q. Programs. 
24 
A. Besides Ci ' 
• 
25 
Q. Regarding 
did you ever see 
Page 454 
1 
A. Yes. 
2 
Q. Okay. 
3 
MR. WILLITS: I don't have any other 
4 
questions. 
5 
MR. EDWARDS: I do but only just to 
6 
follow-up with this police report that we've 
7 
just been provided which I'm not sure if it 
8 
has a designation. 
9 
MR. CRITTON: Exhibit 9. 
10 
MR. EDWARDS: Okay. 
11 
EXAMINATION 
12 
BY MR. EDWARDS: 
13 
Q. You were asked by 
1ton aboutM 
14 
who we were referring to a 
in this 
15 deposition, and her date of 
s 12/30/86. 
16 And Mr. Critton was indicating to you earlier that 
17 at the time that you had this dealing with her in 
18 the driveway that she was 18 years old. It 
19 appears that this occurred November 28, 2004, 
20 which would indicate that she is 17 years old. 
21 
I think the question that was asked of 
22 you is, are you surprised by that, so I'll ask you 
23 the same question? 
24 
A. No, sir. 
25 
Q. All right. This report that you have 
47 (Pages 451 to 454) 
EFTA00310324

Page 455 
1 indicated Is accurate or accurately reflects the 
2 
events of that night, I want to make sure that Mr. 
3 
Willits hears and that we go through it and you 
4 
can elaborate on any part of It. Okay. 
5 
On Sunday, 11/28/2004, at approximate!),
6 
19:00 hours, so we're talking about 7:00 at night, 
7 
the property manager of 358 El Brillo Way, Alfredo 
8 
Rodriguez, came to the station to complain there 
9 
was a strange vehide parked in the driveway. 
10 
A. Yes. 
11 
Q. That's true? 
12 
A. Yes. 
13 
Q. When Officer Koemer and I, this is 
14 
Officer Munyan talking, arrived at 358 El Brillo, 
15 
we located a white female later identified as 
16 A.H., date of birth 12/30/86 waiting in the 
17 
driveway. 
18 
A. That's correct. 
19 
Q. Okay. 
20 
MR. CRITTON: Form. Are you asking him 
21 
whether the statement is correct or that 
22 
you're reading it correctly? 
23 
BY MR. EDWARDS: 
24 
Q. No, the statement is correct. 
25 
A. Yes. 
Page 457 
1 
Did you get that impression that H. was 
2 
very nervous in her car when the police showed up? 
3 
A. Yes. 
4 
Q. Was that an indication to you that she 
5 
realized that there were police there and that 
6 
there was some form of illegal activity that she 
7 
was involved in at Jeffrey Epstein's house? 
8 
MR. CRITTON: Form. 
9 
THE WITNESS: Yes. 
10 
BY MR. EDWARDS: 
11 
Q. H.'s cell phone rang, she answered it 
12 quickly, said, in quotes, "I can't talk, I can't 
13 
talk, I'm at school, I got to go." 
14 
Did you hear that part of it? 
15 
A. Yeah. 
16 
Q. Okay. That's obviously a lie. Right? 
17 
MR. CRITTON: Form. 
18 
BY MR. EDWARDS: 
19 
Q. She's saying she's at school when really 
20 
she's right in front of Jeffrey Epstein's house? 
21 
A. Yes. 
22 
Q. And again, another indication that she's 
23 doing something she shouldn't be doing. Right? 
24 
MR. CRITTON: Form. 
25 
MS. EZELL: Object to the form. 
Page 456 
1 
Q. That's what you understood me to ask you? 
2 
A. Yes. 
3 
Q. Okay. Rodriguez arrived at that time and 
4 
stated he did remember 
vas there to pick up --
5 
was coming there to pi 
an envelope the 
6 
homeowner, Jeffrey Epstein, left for her. 
7 
And that's correct as well. Right? 
8 
A. Yes. 
9 
MR. CRITTON: Form. 
10 
BY MR. EDWARDS: 
11 
Q. This document right here, is it 
12 refreshing your recollection as to that night? 
13 
A. Yes. 
14 
MR. CRITTON: Form. 
15 
BY MRJDWARDS: 
16 
Q. Rodriguez quickly entered the house then 
17 returned with a sealed envelope wit= first 
18 
name on It. 
19 
A. Yes. 
20 
Q. Do you remember who wrote her first name 
21 on that envelope? 
22 
A. I did. 
23 
Q. Okay. The envelope 
peared to have 
nervous 
" 
24 money in it, in my opinion, 
was very 
25 with us standing there. 
Page 458 
1 
BY MR. EDWARDS: 
2 
Q. If she was a masseuse and was at 
3 
someone's house in relation to pick up money from 
4 
a massage she had given, that's not the typical 
5 
answer that you would expect. Right? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: That's right. 
8 
BY MR. EDWARDS: 
9 
Q. Okay. It didn't shock you or surprise 
10 you as Mr. Critton asked you earlier that she 
11 would make up a tale or a lie about her 
12 
whereabouts considering what she was doing. 
13 Right? 
14 
A. No. 
15 
MR. CRITTON: Form. 
16 
BY MR. EDWARDS: 
17 
Q. Then hung up, talking about Ms.• I 
18 
asked her who it was on the phone, she stated it 
19 
was her mom. I asked her how she knows Epstein, 
20 H. stated the 
s at Abercrombie 
21 & Fitchin the 
Mall, she met 
22 Epstein through a female friend at work, Epstein 
23 allows them to come over any time and use the 
24 
house and pool. Then she quickly left. 
25 
Did you hear that conversation? 
48 (Pages 455 to 458) 
Kress Court R- •ortin• Inc. 305-866-7688 
EFTA00310325

Page 459 
1 
A. Yes, they were next to me. 
2 
Q. Okay. Is that the entire substance of 
3 
that conversation between Ms. Nand the police 
4 
officer? 
5 
A. Yes. 
6 
Q. She didn't mention that she comes over to 
7 
his house and goes Into a bedroom with Mr. 
8 
Epstein. Right? 
9 
MR. CRITTON: Form. 
10 
THE WITNESS: No. 
11 BY MR. EDWARDS: 
12 
Q. And she didn't tell the police officer 
13 
that she is a masseuse; did she? 
14 
A. No. 
15 
Q. And that didn't surprise you either; did 
16 It? 
17 
A. No. 
18 
MR. CRITTON: Form. 
19 
BY MR. EDWARDS: 
20 
Q. I then asked Rodriguez what was in the 
21 envelope, Rodriguez was hesitant but -- what is 
22 that word? 
23 
A. But then. 
24 
Q. But then I said it was drugs and he 
25 
quickly said it was money. Is that accurate? 
Page 461 
1 
Q. I asked what kind of job H. performs, 
2 
Rodriguez smiled and says she is a massage 
3 
therapist. 
4 
A. Yeah. 
5 
Q. Why did you tell him that? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: Because I understood she 
8 
came to give massage. 
9 
BY MR. EDWARDS: 
10 
Q. Well, that's what somebody had told you? 
11 
A. Yes. 
12 
Q. At this point in time though you knew 
13 
that more was going on than a massage? 
14 
MR. CRITTON: Form. 
15 
BY MR. EDWARDS: 
16 
Q. Right? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: That's right. 
19 
BY MR. EDWARDS: 
20 
Q. I asked -- this is the police officer 
21 talking, I asked which muscle she rubbed. 
22 
Do you remember the police officer asking 
23 
that? 
24 
A. Yes. 
25 
Q. And you knew what he was implying. 
Page 460 
1 
A. That's correct. 
2 
Q. When he first asked you what was in the 
3 
envelope were you nervous? 
4 
A. No, because I was trying to — I didn't 
5 
want to disclose these private things with the 
6 
police so that's why I was concerned about that. 
7 
Q. When you're talking about private things, 
8 
the fact that there are young girls coming over? 
9 
MR. CRITTON: Form. 
10 
THE WITNESS: It was late, you know, 
11 
exactly. 
12 
BY MR. EDWARDS: 
13 
Q. I'll let you answer. What are the 
14 private things that you were nervous to tell the 
15 
police? 
16 
A. This was inside the compound, the 
17 
property itself, so you have to keep 
18 confidentiality, and the police was there, that's 
19 why. Not that I was doing something wrong but I 
20 
was trying to keep them --
21 
Q. I'm not suggesting that you were doing 
22 
something wrong. 
23 
A. Exactly. So he asked me is there any 
24 drugs there, and I said, no, it's just money. 
25 That's all I said. 
Page 462 
1 
Right? 
2 
MR. CM-17ON: Form. 
3 
THE WITNESS: Yeah. 
4 
BY MR. EDWARDS: 
S 
Q. That it was obvious to him that she was 
6 
over there to sexually please Mr. Epstein. Right? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: That's correct. 
9 
BY MR. EDWARDS: 
10 
Q. And that's coming from a police officer 
11 who's not the house manager. Right? 
12 
MR. CRITTON: Form. 
13 
THE WITNESS: That's right. 
14 
BY MR. EDWARDS: 
15 
Q. You knew right away what he was asking 
16 and you say, Rodriguez laughed said, in quotes, 
17 "off the record, he, Epstein, has many young girls 
18 
come over for that," end quote. 
19 
Do you remember telling him that? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: Yes. 
22 
BY MR. EDWARDS: 
23 
Q. And when you were saying come over for 
24 
that, it was --
25 
A. Massage or something. 
49 (Pages 459 to 462) 
Kress Court Re r•rtin• Inc. 305-866-7688 
EFTA00310326

Page 463 
1 
Q. -- to sexually please Mr. Epstein. 
2 
Right? 
3 
MR. CRITTON: Form. 
4 
THE WITNESS: Yes. 
5 
BY MR. EDWARDS: 
6 
Q. I mean, that's what you were telling the 
7 
police officer. 
8 
MR. CRITTON: Form. 
9 
THE WITNESS: Yes. 
10 
BY MR. EDWARDS: 
11 
Q. Okay. There's always a different girl at 
12 the pool or inside with him when he's here. 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Yes. 
15 
MS. EZELL: You left out a word, young. 
16 BY MR. EDWARDS: 
17 
Q. Sorry, I'll read the last sentence again. 
18 
There's always a different young girl at 
19 
the pool or inside with him when he's here. 
20 
Do you remember telling the police 
21 officer that? 
22 
A. Yes. 
23 
MR. CRITTON: Form. 
24 
BY MR. EDWARDS: 
25 
Q. And that's true. Right? 
Page 465 
1 
Q. And as to -- it was read to you by Mr. 
2 
Edwards and he then asked you a number of 
3 
questions whether you remembered something. 
4 
Correct? 
5 
A. Yes. 
6 
Q. Okay. Just so I'm clear, he's asking you 
7 
to speculate on what may or may not have occurred 
8 
upstairs in the bedroom. I want to be very dear. 
9 
Mr. Rodriguez, were you ever up in the 
10 
bedroom to observe whatever went on between a 
11 masseuse and Mr. Epstein or anyone else for that 
12 matter at any time? 
13 
MR. HOROWITZ: Form. 
14 
THE WITNESS: No, sir. 
15 
BY MR. CRITTON: 
16 
Q. And so when Mr. Edwards asked you, you 
17 were aware that sexual activity or may have been 
18 
sexual activity occurring upstairs, you have no 
19 
personal knowledge, you're just speculating; 
20 aren't you, sir? 
21 
MR. HOROWITZ: Form. 
22 
MR. EDWARDS: Object to the form. 
23 
THE WITNESS: I never saw them. 
24 
BY MR. WILLITS: 
25 
Q. And therefore you can only speculate --
Page 464 
1 
A. Yes. 
2 
Q. When he's at the house there is always a 
3 
young girl inside with him. 
4 
MR. CRITTON: Form. 
5 
BY MR. EDWARDS: 
6 
Q. Right? 
7 
A. That's right. 
8 
Q. Okay. And whether the company line is to 
9 
call them a masseuse, you knew that these girls 
10 were young and were up in the bedroom with Mr. 
11 Epstein to sexually please Mr. Epstein. 
12 
MR. CRITTON: Form. 
13 
THE WITNESS: That's right. 
14 
MR. EDWARDS: I don't have anything else. 
15 
We've already attached this; right? Here is 
16 
the one that can be attached. 
17 
MR. WILLITS: Who is next? 
18 
MR. CRITTON: Me. 
19 
RECROSS EXAMINATION 
20 
BY MR. CRITTON: 
21 
Q. Mr. Rodriguez, looking at Exhibit 9 which 
22 is the police report that was prepared on November 
23 
28, 2004, this is the first time you've seen it. 
24 
Correct? 
25 
A. That's correct. 
Page 466 
1 
MR. WILLITS: Object to the form. 
2 
MR. CRITTON: I need to ask the question 
3 
first. 
4 
MR. WILLITS: It was the earlier 
5 
question. 
6 
BY MR. CRITTON: 
7 
Q. All right. If you did not see what was 
8 
going on you can have no personal knowledge. 
9 
True? 
10 
MR. HOROWITZ: Object to the form. 
11 
MR. EDWARDS: Object to the form. 
12 
THE WITNESS: Yes. 
13 
BY MR. CRITTON: 
14 
Q. And, therefore, what you're doing is 
15 
speculating or guessing what may have been 
16 occurring. True? 
17 
MR. HOROWITZ: Form. 
18 
MR. EDWARDS: Form. 
19 
MR. WILLITS: Form. 
20 
THE WITNESS: I use my age together. 
21 BY MR. CRITTON: 
22 
Q. I'm not saying that you don't, but 
23 
without having personal knowledge you're best 
24 
guessing what may have occurred up there between 
25 Mr. Epstein and one of the massage women, or for 
50 (Pages 463 to 466) 
Kress Court Reporting, Inc. 305-866-7688 
EFTA00310327

Page 467 
1 that matter anyone else who was upstairs? 
2 
A. Yes. 
3 
MR. HOROWITZ: Form. 
4 
MR. EDWARDS: Form. 
5 
MR. WILLITS: Object to the form. 
6 
MR. CRITTON: Thank you. 
7 
MS. EZELL: I just have a couple of 
8 
questions. 
9 
EXAMINATION 
10 BY MS. EZELL: 
11 
Q. Following up on that, you did however see 
12 this same young woman asleep naked in the sauna? 
13 
A. Yes, ma'am. 
14 
Q. And you did along withand 
and 
15 -- and you did also find sex toys and massagers of 
16 various kinds and creams scattered around on 
17 several occasions after these young women had been 
18 upstairs with Mr. Epstein? 
19 
MR. CRITTON: Object to form, asked and 
20 
answered about six times. 
21 
THE WITNESS: Yes. 
22 
MS. EZELL: No other questions. 
23 
MR. EDWARDS: Sorry, last one. It has 
24 
nothing to do with this report. 
25 
EXAMINATION 
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 469 
A. Yes. 
MR. EDWARDS: Nothing else. 
MR. WILLITS: Is It my tum? 
MR. EDWARDS: Yes. 
EXAMINATION 
BY MR. WILLITS: 
Q. Mr. Rodriguez, you mentioned the last 
time about a lady who watus 
professional 
masseuse by the name of 
Do you remember 
that? 
A. 
Q. 
A. 
Q. 
A. 
Yes, I do remember. 
Did you ever pay her? 
Yes, sir. 
Okay. How much did you pay her? 
It was between 200 and 500, sir, but 
somew 
-- between those two amounts. 
Q. 
A. Yes, sir. 
MR. WILLITS: Okay. I don't have any 
other questions. 
MR. CRITTON: You have a right to read 
this deposition when the other part is typed 
and make any changes that you want. Would 
you like to do that? It's your right a 
hundred percent. The court reporter can 
Page 468 
1 BY MR. EDWARDS: 
2 
Q. During Mr. Critton's questioning he asked 
3 
you about whether or not we had ever shown you a 
4 
previous taped statement that you had given to a 
5 
police officer, and we did not do that; did we? 
6 
A. No. 
7 
Q. We can represent to you that we don't 
8 
have It to show It to you otherwise we would like 
9 
to do that. 
10 
However, he asked you did you tell the 
11 police officers at that time that the girls 
12 
appeared to be 18 years or older, and I believe 
13 
that you said when you gave the statement to the 
14 
police that you did; right, say that? 
15 
A. Yes. 
16 
Q. And I wrote, I put it in quotes, you said 
17 that because you were fearful of reprise from 
18 
Ms. Maxwell and Mr. Epstein. 
19 
A. That's correct. 
20 
MR. CRITTON: Form. 
21 BY MR. EDWARDS: 
22 
Q. Okay. Is everything that you've said 
23 
today and told us today, is it true? 
24 
A. Yes. 
25 
Q. To the best of your knowledge? 
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 470 
provide you or whoever set your 
deposition --
THE WITNESS: I tried to be truthful. 
MR. CRITTON: All you have to do is tell 
her you would like to waive. Do you waive 
the reading and signing? 
MR. EDWARDS: You can either read or you 
can waive reading? 
THE WITNESS: I don't understand what I 
have to do. 
MR. CRITTON: Why don't we go off the 
record and you can explain it to him. 
MR. EDWARDS: We can go off the record. 
THE VIDEOGRAPHER: Off the record. 
(Thereupon, a discussion was held off the 
record.) 
THE WITNESS: Waive. 
(Thereupon, the deposition was concluded 
at 5:30 p.m.) 
51 (Pages 467 to 470) 
EFTA00310328

Page 471 
1 THE STATE OF FLORIDA, 
) 
2 
COUNTY OF DADE. 
3 
4 
5 
I, the undersigned authority, certify 
6 
that ALFREDO RODRIGUEZ personally appeared before 
7 
me on the 7th day of August, 2009 and was duly 
8 
sworn. 
9 
10 
WITNESS my hand and official seal this 
11 18th day of August, 2009. 
12 
13 
14 
15 
MICHELLE PAYNE, Court Reporter 
16 
Notary Public - State of Florida 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 472 
1 
2 
The Stara Of Hada, 
) 
3 Canty Of Dade. 
5 
4 
1, MICHEUE PAYNE, Cart Reporter and 
Wary Public el and for tho Rats ce Florida at 
6 
large, do hereby any that I was trot/wetted W 
end dd stenographimly react the deposticro of 
AuRED0 R0DRIGun; that a review of the transott 
was not raised; and that the foregoing pages, 
8 ninibenxt from 270 b 472, Wise?, are a true 
and owed trtrectice4M of my sten:cradle notes 
9 ce said deposittn. 
10 
Metter catty that sad deposition was 
taken at the time and place hereinaboyo set forth 
and Mat the taking of mid deposten wee 
=moved and completed as heminatme set out. 
12 
Lithe, notify that 1 am not an 
13 attorney or coussel of any d the parttea, rear am 
a relative or employee of any ateciney 
14 cctnsel ce petty corrected with the anion, nor am 
I linencbly Int/meted al the adka. 
15 
the foregoing ontifiegeon d this 
16 Utniatt does not apply to any rcatelUdion of 
the sane by any means unless under the drod 
17 anted and/or drecticei of the certifying 
reporter. 
IS 
DATED des 18th day of August, 2009. 
19 
20 
CERTIFICATE 
21 
14O1E112 PAYNE, tart Reporter 
22 
23 
24 
25 
52 (Pages 471 to 472) 
Kress Court Reporting, Inc
EFTA00310329