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October 20, 2009 
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1 
0 
Did you ever talk to any law enforcement type 
2 
related to the Jeffrey Epstein aiminal investigation? 
3 
A No, sir. 
4 
0 
Did you remain employed from November 2004 
• 
through today continuously with Jeffrey Epstein? 
6 
A Yes, sir. 
7 
0 
Was it dscussed as to how your employment 
8 
would be altered, if at all, while Mr. Epstein was going 
9 
to be either 
while Mr. Epstein was going to be in 
10 
jail or away from the house? 
11 
A No. sir. 
12 
0 
Did you know, did you have any prior warning 
13 
before Mr. Epstein plod guilty and wont to jail? 
14 
A No, sir. 
15 
0 
All right. So it was just one day he's there 
16 
and the next day he's not. as fax as you knew? 
17 
A 
Janusz. we discuss it with Janusz, he received 
18 
a call, and then oh, Mr. Epstein is coming so is how I 
19 
know. 
20 
0 
I'm sorry. Maybe we miscommunicated there. 
21 
You're saying that Janusz received a call that 
22 
Mr. Epstein was coming to the house? 
23 
A 
Your first question was? 
24 
0 
Were you made aware of the date or time period 
25 
that Mr. Epstein would be going to court to plead guilty 
75 
A 
Yes. 
2 
0 
Where? 
3 
A hail. 
4 
0 
How do you know that? 
5 
A Through Janusz or, what's this, through the 
6 
news. 
7 
0 
SO you cid you work at his house during the 
s 
time period ^ 
9 
A Yes. 
10 
0 
Wait until I finish. 
11 
A Sony. 
12 
0 
Did you work at his house during time pored 
13 
when Mr. Epstein was in jail? 
14 
A I cid. 
15 
0 
Dicl you see Mr. Epstein during that year time 
16 
period? 
17 
A No. 
18 
0 
What was your schedule during that year t,me 
19 
period that Mr. Epstein was in jail? 
20 
A Flexible. No. Wait. The time that he was in 
21 
jail? 
22 
0 
Mont. June 30th, 2008 through sometime in 
23 
July. 2009 
24 
Do you understand the question? 
25 
THE WITNESS: Yes. 
74 
1 
to criMOS and then gong to jail so that he would no 
2 
longer be at the house, were you made aware that that 
3 
was going to take place? 
4 
A Not directly. 
• 
0 
Okay. IndirectAy then, did you knew that that 
6 
was taking place? 
7 
A No. Janusz and I talked, so... 
8 
0 
Md what old Janusz tell you about Pk. Epstein 
9 
(ONO court and after court he would be In jail and 
10 
nO longer at the house? 
11 
A We really don't know when he's gang there to 
12 
jail or Is going to art. It's just a discussion like 
13 
oh, he's going to court or something, but the date and 
14 
the time, no. 
is 
0 
rm not concerned with the date and the time. 
16 
I guess what I'm getting at just is were you told that 
17 
there was going to be a time period he was going to be 
18 
In jail? 
19 
A No. 
20 
0 
All right. There was a period of time that 
21 
was just over a year where Mr. Epstein was not in the 
22 
house, that being from June 30th, 2008 through sometime 
23 
In July of 2009. correct? 
24 
A Yes. 
25 
0 
And do you know where he was during that erne? 
1 
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9 
10 
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76 
Okay. Go ahead and answer it 
then. 
THE WITNESS: I usually come nine o'clock. 
BY MR. -
O Md you would leave? 
A At 5:00 a5:30. 
O Md whO else would be in the house during that 
year time period from June 2008 through July 2009? 
A Only Janusz and me: and the gardener, he 
passed away. 
O Who? 
A 
The gardener. 
O 
Jerome? 
A Jerome. 
O And you said he said passed away? 
A Yes. 
O When was that? 
A I remember right we came from New York, I 
cannot remember. but I remember when we came from 
New Yak, we attended his 
not burial, the ceremony in 
church. 
O Do you know how he passed away? 
A Janusz told me that he has a heart attack or 
something. 
O Okay. But it wasn't col the property while he 
• 
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EFFA_00070827 
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- Volume I 
October 20, 2009 
77 
1 
was working? 
2 
A No. 
3 
0 
Owing that year time period that Mr. Epstein 
4 
was in jail, what did you do on a day-to-day basis Mien 
5 
you were there from 9:00 to 5:00? 
6 
A I dean the house, I made inventory of the 
7 
linens, and what's this, started inventorying, making an 
8 
inventory of the silverwares. 
9 
0 
Okay. Did you talk to 
during 
10 
that time period he was in jail? 
11 
A 
Yos. 
12 
0 
And -went 
to visit him in jail numerous 
13 
times; are you aware of that? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: No. sir. 
16 
BY MR. 
17 
0 
And did 
stay in the house during 
18 
the time period where Mr. Epstein was in jail? 
19 
A 
Yes. 
20 
0 
Permanently, or did she fly in town and fly 
21 
back somewhere else? 
22 
A (Noddi 
head.) 
23 
MR. 
You have to say yes or no. 
21 
THE WITNESS: Yes. 
25 
MR 
Yes she flew in, or yes she 
1 
2 
3 
4 
5 
6 
7 
B 
10 
11 
12 
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1a 
19 
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79 
O Was it somebody from New York? 
A What, you mean when he was jail? 
O When he was In jail. 
A Story. 
O It was Story? 
A it was Story-
O This is Story Cowles? Do you know the last 
name? 
A Ideal know his last name. 
O 
And when you say she came with a person, you 
mean she came to the house with a person namedM? 
A 
Yes. 
O AndoSt u know if that person named Story 
flew in with =II rom elsewhere? 
A I don't know. 
O 
And did Story slay at the house with 
IIIIIIP 
A No. se. 
O All right So tNs is during the da he came 
over. Story came over and visited with 
A Visited? I think so. 
O Okay. Do you know the purpose for Mr. Cowles, 
at
or St 
as 
referred to him, meeting with 
at the house during the year time period 
Mien Mr. Epstein was in jail? 
1 
2 
3 
4 
6 
7 
9 
10 
11. 
12 
13 
14 
15 
16 
17 
10 
19 
20 
21 
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78 
stayed permanently? 
THE WITNESS: Not for a longer period. 
BY MR. -
O Okay. Who would she fly into town with, it 
anyone? 
A Alone. I don't know, because she just come to 
the house and that's how she's there. I didn't know who 
she came with. 
e oome to the house alone, she being 
: Again. we're talking during the 
time period when Mr. Epstein is in jail? 
THE WITNESS: Yes. 
Thank you. 
THE WITNESS: So one time she came with male 
friend. 
BY MR. 
O With a male friend? 
A 
Yes. 
O Do you knew his name? 
A I forgot it. 
O 
Was it Igor? 
A No. 
O Wash Story? 
A No. 
80 
1 
A No. 
2 
0 
What did you watch them do together, it 
3 
anything? 
4 
A 
Do the computer. 
5 
0 
All right How many computers were here in 
6 
the house during the year time period Mr. Epstein was in 
7 
jail? 
A 
They have their own personal computers 
9 
0 
Who is 'they? 
10 
A If you're asking about MI 
and Story? 
11 
0 
Right. They brought laptops with them, you're 
12 
Saying? 
13 
A 
Yes. 
14 
0 
Okay. For the period of time between 
15 
November 2004 through June of 2008. when — sorry. 
16 
Were you working at the house when the police 
17 
executed a search warrant on the house? 
18 
A No. 
19 
0 
You were not working at the house? 
20 
A I wasn't 
21 
0 
Were you aware of a search warrant being 
22 
executed on the house? 
23 
A No. 
24 
0 
Did you know that a search warrant was ever 
25 
executed on the house at 358 El Bello Way? 
0 
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October 20, 2009 
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1 
A When I came back to report. that's how I 
2 
learned. 
3 
0 
Elaborate on that for me. What do you mean. 
4 
when you came back to report that's how I learned? 
5 
A 
I reported in the afternoon. and then that's 
6 
how I learned that the police came. 
7 
0 
All right. And when were you 
you're now 
saying you came back to report and you reamed that the 
9 
police had already come to the house, right? 
10 
A Yes, slr. 
11 
0 
Prior lethal occasion, when was the previous 
12 
time that you were at the house? 
13 
A The day before. 
14 
0 
Olay. And the day before you left your shift 
15 
at roughly love o'clock? 
16 
A 
I cannot remember. I usually leave 5:00 or 
17 
510. 
18 
0 
But sometime late in the afternoon? 
19 
A Yes. 
20 
0 
And as of that time, the day before the search 
21 
warrant was issued. you had seen no police officers in 
22 
or around the house? 
23 
A 
No. 
24 
O And then the next day you reported to the job 
25 
at what time? 
83 
1 
0 
So are we talking about the day the police 
2 
went to Jeffrey Epstein's house you did not go in the 
3 
morning. but you went after lunch and the police had 
4 
already left? 
A Oh. No. When I went there nobody was there. 
6 
no policemen were around. 
7 
0 
Who was at the house then? 
8 
A 
Janusz, and Douglas, the architect. 
9 
0 Schoettle? 
to 
A 
Yes. 
11 
0 And did you have a discussion with them? 
12 
A 
No. 
13 
0 
How did you know the poke had been to the 
14 
house? 
15 
A Janusz told me. 
16 
0 
When? 
17 
A 
When I arrive. 
18 
O That's what I was asking you when I said did 
19 
you have a discussion with them, moaning Janusz and 
20 
Douglas. 
21 
A Okay. Being because them -- with Janusz only. 
22 
0 
what did he say? 
23 
A 
He said the police came and, what's this, took 
24 
away some stuff. 
25 
0 
Did he say what they took? 
82 
1 
A The next day? 
2 
O The next day. 
3 
A 
I report in the afternoon. 
4 
0 
Was there a reason why you reported in the 
5 
afternoon? 
6 
A 
Ms. Maxwell called me. 
7 
0 
When did she call you? 
A 
During that day, she said M. 
you can 
9 
report in the afternoon. 
3.0 
0 
She called you earty in the morning? 
11 
A 
Not early. 
12 
0 
Normalfy you would report to the house between 
13 
eight and nine o'clock, right? 
14 
A Yes. sir. 
15 
0 
So in order for you not to arrive at the 
16 
house, she had to have called you before eight or 
17 
nine o'clock. right? 
18 
A Yes. 
19 
0 
Okay. So approximately what time does 
20 
Ms. Maxwell call you to tell you you can report to the 
21 
house later on that thy? 
22 
A 
I cannot remember really the time. 
23 
0 
Okay. What time did you actually report to 
24 
the house? 
25 
A 
After lunch, about — maybe after lunch. 
1 
2 
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a 
9 
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84 
A 
He said pictures. 
O 
Did he tell you which pictures? 
A 
No. sir. 
O Aside from pictures, what else did the police 
take, as Janusz told you? 
A 
He did not elaborate. 
O 
All right. Prior to the police going to the 
house and taking pictures, do you remember seeing 
pictures around Mr. Epstein's house? 
A 
Yes. 
o 
Do you remember seeing pictures of naked or 
nude females around Mr. Epstein's house? 
A 
Not around, in his closet. 
O 
In Mr. Epstein's closet you would see --
describe what you would see related to females in 
pictures. 
A 
Some have topless. 
O Is this a big closet? 
A 
No. Not really big. it's just this big, not 
so big. 
O Okay. Were these pictures that could be seen 
by — strike that. 
Do you know of any other pictures of females 
that were confiscated by the police that did not come 
from Mr. Epstein's closet? 
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EFTA_00070829 
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- Volume I 
October 20, 2009 
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85 
MR. CRITTON: Form. 
THE WITNESS: Nude picture? 
BY 
O 
ny WI
CWe:tures 
that were taken by the 
police that were not taken from his closet. 
MR. CRITTON: Form. 
THE WITNESS: One. 
BY MR. 
O Where was that picture? 
A 
The hallway leading to the master bedroom. 
O And what was that picture of? 
A 
ICs like advertisement, small child. 
O A small child. When you say 'small child,' 
what age range are you talking about? 
A Maybe four. 
O What is that child in that picture who is 
maybe four doing? 
A I cannot really. like -- I don't know what's 
this, but I think the underwear was (indicating), like 
pulled down. 
MR. CRITTON: Just for the record, she's 
pointing to her rear-end, derriere. 
BY MR. -
O So in this picture that was taken by the 
police or confiscated by the police, it was in the 
1 
2 
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8v 
MR. CRITTON: Form. 
BY MR. 
O You were able to tell me the approximate age 
o4 the child in the photograph, but you're unable to 
tell me the approximate age --
A It was just a guess for four, because I could 
hardy, like. toll the ago. It was just maybe four. 
O Okay. Was there anything else in the house 
that you were told was taken by the police? 
A No. sir. 
O Pnor to the day when the Poke came to the 
house. how many computers did Mr. Epstein have in his 
house? 
MR. CRITTON: Form. predicate. 
THE WITNESS: One -- three. 
BY MR. 
O Where were those three computers located? 
A In the cabana, in one of the desks, and one in 
the little office. 
O And after the police came to the house do you 
remember seeing those computers any more" 
A No. I really did not focus on what was 
missing. only the picture that was big, and in the 
bedroom. 
86 
1 
hallway and It was of a child roughly four years old 
2 
that was pulling down her underwear and exposing her 
3 
buttock area; is that fairly accurate? 
4 
A 
Yes. Not really full, just like slightly, 
5 
that's what I remember. 
6 
0 
Okay. Are there any other photographs that 
7 
were confiscated by the police, to your knowledge? 
A No. 
9 
0 
So how many photographs had you seen peer to 
10 
the police going into Mr. Epstein's house in 
11 
Mr. Epstein's closet? 
12 
MR. CRITTON: Form. 
13 
THE WITNESS: Loss than ten. 
14 
BY MR. 
15 
0 
Okay. So there were less than ten photographs 
16 
lo Mr. Epstein's closet that you remember? 
17 
A 
Yes. 
18 
0 
And what were those photographs of, these less 
19 
than ton? 
20 
A Hall nude women. 
21 
0 
Do you know the ages of those women? 
22 
A No. sir. 
23 
0 
Do you know the approximate ages of those 
24 
women 8110050 photographs? 
25 
A No. 
1 
2 
3 
4 
6 
8 
9 
10 
11 
12 
13 
14 
IS 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
88 
O Okay. But you're aware, as you told me. that 
there were these computers --
A Yes. 
O Let me finish. 
A Sorry. 
O You where aware, as you told M. that there 
wore those computers that you described as being three 
computers In Mr. Epstein's house, fight? 
A `leash:. 
O And do you know whether those were taken out 
of Mt. Epstein's house by Mr. Epstein or somebody 
associated with Mr. Epstein. or by the police? 
A I'm not aware. 
O So to the best 01 your knowledge, the police 
lock less than ten photographs from Mr. Epstein's house. 
and that should be allot the evidence or objects that 
were taken by the police from Mr. Epstein's house, to 
your knowledge? 
MR. CRITTON: Form. predicate. 
THE WITNESS: I don't know. 
BY MR. -
O I'm only asking what you do know. 
To your knowledge, what you described to me 
as -.Must want to know a list ol all the things that 
you know were taken by the police. And you've dasonbed 
0 
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- Volume I 
October 20, 2009 
• 
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89 
1 
to me I believe one photograph of this lour-year-old 
2 
child as well as less than ten photographs that were 
3 
previously in Mr. Epstein's closet. 
4 
A 
Yes. 
5 
MR. CRITTON: Form. 
6 
BY MR. -
7 
0 
Is there anything else that you know was taken 
by the police? 
9 
A No. 
10 
0 
Since Mr. Epstein has been out of jail. 
11 
guess this Is since July of 2009. what has your schedule 
12 
been? 
13 
A My schedule has changed. 
• 
0 
To what? 
15 
A From 8:00 to 3:30. 
16 
0 
6:00 a.m.? 
17 
A 
Yes, sir. 
18 
0 
And why the sctedule change? 
19 
A Because I was chosen to give breakfast. 
20 
0 
To wtorn? 
21 
A Mr. Epstein. 
22 
0 
By whom? 
23 
A Because it was Janusz was there usually gives 
24 
the breakfast, but there was a change. it was me. 
25 
0 
Okay. You don't know why that change 
91 
1 
A 
Yes. 
2 
0 
So you know what bedrooms need to be tided up 
3 
and look like SOnleOne slept there? 
• 
A 
Yes. 
5 
0 
And does it appear that 
slept in the 
6 
same bedroom as Mr. Epstein, Or some Other bedroom? 
7 
A 
Sometimes the other bedroom is also, like. 
a 
slept in. 
9 
0 
Okay. So sometimes --
10 
A 
Sometimes one bed is the master, and sometimes 
11 
the Other, what's this. is slept in. 
12 
0 
What is your understanding or the relationship 
13 
betweenMand IA. Epstein? 
14 
A Relationship? 
is 
0 
Yeah. What is your understanding of 
16 
rote in Mr. Epstein's life? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: She did not tell me that She's 
19 
his girlfriend, sO she stays there, s0... 
20 
BY MR. 
21 
0 
She didn't tell you, or she thd? 
22 
A She did not. 
23 
0 
She did not tell you. 
24 
How long haSM been around Mr. Epstein. to 
25 
the best of your memory? 
90 
1. 
occurred? 
2 
A No. 
3 
0 
Well, do you know why that change occurred? 
4 
A 
Because so that somebody 
because Janusz has 
5 
to stay later, so... 
6 
0 
Every monling now you serve breakfast to 
7 
Mr. Ecetet? 
8 
A 
Yes, sir. 
9 
0 
So that's why you're required to be there at 
10 
6:00 a.m. Is that what time he eats? 
11 
A 6:30. 
• 
0 
Tell me since Mr. Epstein has been out of jail 
13 
and bath at the house, what other people have frequently 
14 
visited and/or stayed at house? 
15 
A 
Who? 
16 
0 
Who. 
17 
A la 
Story. 
18 
0 
And where does NC Epstein sleep in the house 
19 
since he's been out of jail? 
20 
A 
Where? In the master bedroom. 
21 
0 
All right. And where doesMsleep? 
22 
A I'm not aware if 
IOW not see d they 
23 
sleep together or... 
24 
0 
Well, you tidy up the house the following day. 
25 
correct? 
92 
1 
A 
Since a few months I started working there 
2 
0 
Okay. So that's late 2005 you're talking 
3 
about, or 2004? Sorry. 
4 
A 2005, I mink. 
• 
MR. CRITTON: 2005? 
6 
MR 
She said 2005. 
7 
MR. CRITTON: Okay. 
8 
BY MR. 
9 
0 
And what was your understanding back then why 
10 
she was at the house with Mr. Epstein? 
11 
A Understanding? I thought she is his 
12 
girlfriend. 
13 
0 
Ghislaine Maxwell, when she hired you or 
14 
Interviewed you, told you that she, Ghislaine. was 
15 
Mr. Epstein's girlfriend. right? 
16 
A 
Yes. 
17 
0 
And then a month or two after you began 
la 
working at Mr. Epstein's house= is also around the 
19 
house and you believed that she was Mr. Epstein's 
20 
girlfriend? 
21 
A I want to 
before I did not know that. she 
22 
was just a visitor. 
23 
0 
Okay. When was it that you started, you were 
24 
led to believe. Or based on your observations you 
25 
believed thatEllwas a girlfriend of Mr. Epstein? 
• 
0 
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- Volume I 
October 20, 2009 
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93 
A 
2006. No. Wait. When he was in jail. 
Q All right. When Mr. Epstein was in jail 
between June 2008 and July of 2009 is the first time 
that you began to believe that
 was a girlfriend of 
Mr. Epstein? 
A 
Yes. That's just my own, but she did not tell 
me that she's the girlfriend. 
O Did anybody tell you that? 
A 
No. 
O Prior to that period of time when Mr. Epstein 
was in jail, what was your understanding as to 
relationship to Mr. Epstein or role in Mr. Epstein's 
life? 
A 
A Mend. 
Q 
What did she do when she was at the house 
prior to Mr. Epstein going to jail, = 
what did 
A 
What did she do? 
O 
What did IMIo 
around the house prior to 
Mr. Epstein going to jail? 
A Go shopping. 
O 
Anything else? 
A 
That's what I know only. 
O 
Do you remember a person named 
95 
1 
A 
Yes, 
2 
0 
Have you ever been told that
was 
3 
purchased from her family by Mr. Epstein? 
4 
A No. 
• 
Q Have you ever been told that 
serves as a 
6 
lesbian sex slave for Jeffrey Epstein? 
7 
A No. 
• 
Sum Mr. Epstein has been out of Far 
9 
indicated that the frequent visitors are 
10 
and Story; right? 
11 
A 
Yes, sir. 
12 
0 
And does Story stay at the house? 
13 
A No. 
14 
0 
How often is Story at the house? 
15 
A Often. Like they come in the morning, they 
16 
gay a few hours, then leave. 
17 
0 
Who is 'they'? 
18 
A 
and Story. 
19 
0 
And is that on a daily basis? 
20 
A Not always. 
21 
0 
Do you know it 
or Story 
do you know 
22 
if 
is staying at Mr. Epstein's house now? 
23 
A No. 
24 
0 
You don't know, or she's not? 
25 
A No. she's not. 
94 
1 
A 
2 
0 
Yes. 
3 
A 
I remember a name 
but the family 
4 
name. n0. 
• 
0 
Md Aral did 
ti.o at Mr. Epstein' 
6 
house, if anything? 
7 
A 
Alfredo told me that 
a personal 
• 
assistant. 
9 
0 
Similar to ==', 
10 
A 
Yes. 
11 
0 
Was there an hi 
that you observed that 
12 
would distinguish 
from 
terms of 
13 
the role that they played In Mr. Epstein's life? 
14 
A Nol really. 
15 
0 
Is that somebody who you believe scheduled 
16 
Mr. Epstein for massages with the females. 
17 
A 
I donl knOw. 
18 
0 
Md were you ever told that by anybody that 
19 
_was 
also involved in sex acts with minor females 
20 
at Mr. Epstein's house? 
21 
A No. 
22 
MR. CRITTON: Form. 
23 
BY MR. 
24 
0 
Am I the first person that has said that In 
25 
your presence? 
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 
96 
o 
Do you know where she is Staying,
A 
Not now. no. 
.You 
O Do you know, have you witnessed stay talking 
with Mr. Epstein al Mr. Epstein's house? 
A 
Yes. 
Q And where do those conversations bike place? 
A In the breakfast room. 
O 
And when those conversations are taking place 
in the breakfast room between Story and Mr. Epstein, is 
also there? 
A 
There are times when she's Mere, there is 
times that she's not there. 
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1 
2 
3 
9"/ 
0 
All right. So there are times that Story 
talks directly with Mr. Epstein in the breakfast room 
and is just two of them? 
2 
3 
99 
mean do you know if she flies in from New York or flies 
in from LA, or where she lives down the street in 
Palm Beach? 
4 
A 
Yes. 
5 
0 
All right. And there are times when Story 
0 
What does She do when she's In Palm Beach? 
6 
talks with Mr. Epstein in the breakfast room and 
6 
A Go to the beach. 
is also there? 
A 
Yes. 
7 
8 
0 
Did you know her prior to — had you seen her 
prior to Mr. Epstein going 10 jail? 
9 
0 
Are there limes when= is also involved in 
9 
A No, sir. 
10 
conversations Mier° Story and Mr. Epstein are talking 
to 
0 
Other than 
are there any other 
11 
with one another In the breakfast roan? 
11 
visitors that you have witnessed or observed? 
12 
A 
Yes 
12 
A 
Sultan. 
13 
0 
Are there times when all four of them, that 
13 
0 
Who is that? 
14 
meanin2M, `Story. 
and Mr. Epstein, are WI 
14 
A 
Sultan. 
15 
conversing together in the breakfast roan? 
15 
0 
S-U-L-T-A-N? 
16 
A 
Yes. 
16 
A 
Yes. 
17 
0 
Have you overheard the conversations? 
17 
0 
Is that a female? 
IS 
A No. 
18 
A 
A male. 
19 
0 
Do you know or have you been made aware of 
19 
0 
Do you know what Sultan does? 
20 
them talking about the allegations concerting 
20 
A No, slr. 
21 
Mr. Epstein and female masseuses? 
21 
0 
Do you know why he's ever at the house? 
22 
A No, sir. 
22 
A No. 
23 
0 
Since Mr. Epstein has been out of jail in July 
23 
0 
How often Is Sultan there? 
34 
01 2009. have you seen any females coming over to give 
24 
A I saw him two times. 
25 
Mr. Epstein a massage? 
25 
0 
And is that somebody that you saw prior to 
98 
100 
1 
A No, sir. 
1 
Mr. Epstein going to jail? 
2 
0 
Do you know why that is? 
2 
A No. sir. 
3 
A I don't know, sir. 
3 
0 
So the Ilml time you saw him was sometime 
4 
0 
Does 
`
h
a
v
e
 
you seen 
keeping a 
4 
after Mr. Epstein got out ol jail? 
s 
schedule of females or masseuses? 
5 
A 
Yes, sir. 
6 
A No, sir. 
6 
0 
Any other visitors that you've seen since 
7 
0 
Since July of 2009, has Jeffrey Epstein spent 
7 
Mr. Epstein's been out of jail in July? 
a 
every night at the Palm Beach house, to your knowledge? 
A Rosa. 
9 
MR. CRITTON: Form. predicate. 
9 
0 
And who is Rosa? 
10 
THE WITNESS. I leave at 3:30. So... 
10 
A 
She's also a friend. 
11 
BY MR. 
11 
0 
A friend of whom? 
12 
0 
When you arrive every morning at 6:00 a.m., 
12 
A 
Mr. Epstein. 
13 
has Mr. Epstein been there every day? 
13 
0 
And where does she come Iran? 
14 
A 
Yes, sir. 
14 
A 
I did not ask her, I NO not know. 
15 
0 
Aside from =,= 
and Story, have there 
15 
0 
M right. Is it somebody that a driver has 
16 
been any other visitors that are regular visitors of 
16 
to go pick up from the airport, or she flew from 
17 
Mr. Epstein since he's been out ol jail? 
17 
somewhere? 
18 
A Some female friends. 
18 
A Yes. Janusz. 
19 
0 
Who would those people be? 
19 
0 
Janusz picks these people up from the airport? 
20 
A Difficult names. 
20 
A 
Yes, sir. 
21 
0 
who? 
21 
MR. CRITTON: Form. 
22 
A I don't know their... 
22 
BY MR. 
23 
0 
Do you know where she comes from? 
23 
0 
And when I say %hese people.' I'm talking 
24 
A No. 
24 
abouts 
Sultan, and Rosa all are driven by 
25 
0 
And I don't mean her country of origin. I 
25 
Janusz to the house? 
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101 
MR. CARTON: Form. 
2 
THE WITNESS: I !lid not see Janusz dnve, but 
3 
what's this. 
4 
BY MR. 
0 
But that's what you understand? 
6 
A Yea. 
7 
MR. CRITTON: Form, speculation. 
8 
BY MR 
9 
0 
Any other visitors? 
10 
A mars all can remember. 
11 
0 
Do you know hew Old Rosa IS? 
12 
A 
She. what's this. 
13 
0 
Excuse me? 
14 
A 
I don't knew her age. but she looks 5ke, 
15 
what's this. 
16 
0 
Did you say 'whets this*? 
17 
A What? 
18 
0 
rm sony. We're just I think 
19 
miscommunicating here. 
20 
A Okay. 
21 
0 
I was asking the age of the person that you've 
22 
described as Rosa 
23 
A I did not ask her age. 
24 
0 
How do you know the names of 
25 
and Rosa? 
Sultan. 
103 
a 
massage from any of these females? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: I do not know. 
4 
BY MR. 
5 
0 
I'm just going to ask you it you can identify 
6 
any GI these people in this book. If you can, okay, if 
.7 
YOU carrot, It's line. 
e 
MR. CRITTON: I want to mark thine, please. 
9 
MR. 
Wel. if she can identify them 
10 
I'll mark them. 
11 
MR. CRITTON: No. no. I want them identified, 
12 
because if She Can't lelenbly them that's 
13 
significant to me as well. So can we mark those as 
14 
a composite? 
15 
MR. 
I can mark them as a composite. 
16 
and we can either copy them hem as black and white 
17 
or whatever. 
le 
MR. CRITTON: That's fine. 
19 
(Plaintiff's Exhibit No. I was marked for 
20 
identification.) 
21 
BY MR. 
22 
0 
Do you know who this is. have you ever seen 
23 
her before? 
24 
A No. 
25 
MR. CRITTON: And we'll call this Exhibit 1.A. 
102 
1 
A What's this? Janusz. 
2 
0 
Okay. Any other visitors aside from those 
3 
three people that you have just Wed. and the frequent 
4 
Nsilors: i== 
and Story? 
A 
That's all I can remember. 
6 
0 
Has Ohislaine Maxwell come to visit since 
7 
Mr. Epstein's been out of jail? 
A No. sir. 
9 
0 
Do you know if they frequently talk with one 
10 
another? 
11 
A I don't know, sir. 
12 
0 
Do you know what the relationship is or has 
13 
been between Ghislaine Maxwell and Mr. Epstein? 
14 
A 
No. 
15 
MR. CRITTON- Form. 
16 
BY MR. 
17 
0 
In the five years or so that you've worked at 
18 
Mr. Epstein's house. what other persons besides 
19 
Mr. Epstein have received massages from these females. 
20 
from these female masseuses? 
21 
MR. CRITTON: Form. 
22 
THE WITNESS: I don't know. 
23 
BY MR. 
24 
0 
Do you know of any other visitors whO have 
25 
frequented Mr. Epstein's house that have also received a 
104 
MR 
2 
"C.—D1 
3 
MR. CRITTON: Yeah. 
4 
BY MR. 
5 
0 
What was your response? 
6 
A No. 
7 
0 
Never seen her before? 
e 
A No. 
9 
MR. CRITTON: Can you tell us who they are? 
10 
MR. 
Can I tel you? 
a 
MR. CRITTON: Yes. 
12 
MR. 
No. 
13 
MR. CRITTON: Okay. 
14 
MR. 
She may be able to tell you. 
Is 
BY MR. 
16 
0 
Have you ever seen her before? 
17 
MR. CRITTON. That's 1.8. 
is 
BY MR. 
19 
0 
This is 1.B. 
20 
A 
No. 
21 
0 
That's not somebody that you recognize as 
22 
anybody working on Mr. Epstein's staff. pointing at 
23 
picture 1-B? 
24 
A 
No 
25 
0 
Okay. I.C. is that somebody that you 
And then the next page will be 
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EFFA_00070834 
EFTA01247557

- Volume I 
October 20, 2009 
• 
• 
105 
I 
recognize --
2 
A No. 
3 
Q 
as anybody who has ever boon lo 
4 
Mr. Epstein's house in the pest five years? 
5 
A No. 
6 
0 
1.O. do you lux3wW4I0 that is? 
7 
A No. 
B 
Q You don't remember seeing her come to 
9 
Mr. Epstein's house? 
10 
A No. 
11 
0 
1-E, do you know who that is? 
12 
A No. 
13 
0 
In the live years Mat you worked there, you 
14 
never remember seeing her come to Mr. Epstein's house? 
15 
A No. 
16 
0 
Do you know who this is? 
17 
A I remember this. 
18 
0 
You remember her? 
19 
MR. CRITTON: Are you talking I -F? 
20 
BY MR. 
21 
0 
Let's make sure we're right. 1-F. 
22 
A Yes. 
23 
0 
Al right. when do you remember seeing her? 
24 
A I cannot remember the dates, you know, but I 
25 
remember seeing her. 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21. 
22 
23 
24 
25 
107 
A I cannot remember. 
MR. CRITTON: This is 1-I now? 
MR. 
This is I-1 
THE WITNESS: I cannot remember. 
BY MR. -
O By Mat I moan you've been able to tell me no, 
no. no. no, no. When you say I don't remember, does 
that mean maybe you have? 
A Maybe, because the eyes. 
Q Okay. So that's somebody who may look 
'smiler to you but you don't know why? 
A Yes. 
O Okay. Is that somebody you remember seeing al 
Mr. Epstein's house; I mean, Is that where the 
famibarity comes from? 
A Maybe. 
O Okay. Do you recognize that person? 
A TharsM 
O And that's the person that you've been 
describing as= 
throughout this deposition? When 
you've talked aboutM that's the person you're 
talking about? 
A Yes. 
What mother are we on now? 
MR. CRITTON: 
106 
1 
0 
Do you remember her name? 
2 
A No. 
3 
0 
Does the name 
ref resh your recollection 
4 
as to who this person is? 
5 
A 
6 
0 
You remember a 
7 
A I remember a names 
but I don't know if 
Walls 
9 
0 
Okay. And where do you tHnk that you saw 
10 
this person? 
11 
A In the house. 
12 
0 
Do you know why she was there? 
13 
A No. 
14 
0 
Is that one of the people that was giving a 
15 
massage, or Is that somebody else? 
16 
A I do not know. I do not !mow. 
17 
MR. CRITTON: I'm sorry. 
le 
THE WITNESS: No I do not see this. 
19 
BY MR. 
2o 
0 
1-G. that's not somebody you remember seeing? 
21 
A No. 
22 
0 
I -H. do you remember seeing that person? 
23 
A No. 
24 
0 
This is a hard picture to decipher maybe, but 
25 
do you remember seeing that face? And that's I -I. 
108 
1 
2 
Ma 
MS 'J.' 
3 
BY MR. 
4 
0 
Do you know who that Is, have you ever seen 
s 
that person? 
6 
A 
Yes. 
7 
0 
Where have you seen him? 
a 
A In the house. 
9 
MR. CRITTON: This is IV now? 
10 
BY MR. 
11 
0 
This is 1-K 
12 
What have you seen him doing in the house? 
11 
A He came with his family. 
14 
0 
Every time that he's been in the house he's 
15 
come with his family? 
16 
A No, no, no. He came with his family to spend 
17 
a week. 
18 
0 
Okay. And did his family come to the house as 
19 
well? 
20 
A 
Yes. They stay there. 
21 
0 
They stayed at the house? 
22 
A This is Mr. Dershowitz? 
23 
0 
Right. And hew many times have you seen 
24 
Mr. Dershowitz at the house in the time period that you 
25 
were them? 
• 
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- Volume I 
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109 
1 
A Two times. 
2 
O AM one of the times he was with his family? 
3 
A Yes. 
4 
0 
And the other time is it safe to presume then 
that he was alone? 
6 
A Yes. 
7 
0 
During the tine that he was with his family. 
do you remember it Mr. Epstein received any massages 
9 
from females? 
10 
A No. 
11 
0 
You dont remember, or he did not? 
12 
A Oh. he was there when Mr. Epstein was not in 
13 
the house. 
14 
0 
Mr. Dershowltz and his family were in the 
15 
house when Mr. Epstein was not in the house/ 
16 
A Yes. They spend a week there. 
17 
0 
And Mr. Epstein was not in South Florida, you 
18 
moan. not in Palm Beach? 
19 
A No. 
20 
MR. CRITTON: That's correct? 
21 
BY MR. 
32 
0 
That's correct, my statement is correct? 
23 
A Correct. 
24 
So no, he was not in the house? 
25 
THE WITNESS: He was not in the house. 
111 
1 
in the house? 
2 
A I cannot remember. 
3 
0 
Do you know if Mr, Dershowitz has ever been in 
4 
the houSe when the females would ume to the house to 
s 
give Mr. Epstein a massage? 
6 
A I told you, I do not lincnv. 
7 
0 
You don't remember that? 
$ 
A I don't remember that. 
9 
0 
Okay. Do you know it Mr. Dershowitz has 
10 
received a massage while staying at Mr. Epstein's house? 
11 
A No. 
12 
0 
You don't know? 
13 
A I don't know. 
14 
0 
Do you know who that is? 
15 
MR. CRITTON: Let's get a letter now. or this 
16 
is going to be a mess. 
17 
MR. 
Not really, they're all in 
Is 
order. 
19 
MR. CRITTON: For the record, you're going how 
20 
about this person, and nobody is going to know who 
21 
you're talking about. This Is 'L.* 
22 
MR. 
Yeah. 
23 
BY MR. 
24 
0 
Who Is i-L? 
25 
A 
1-L? 
110 
1 
BY MR. 
2 
0 
So Mr. Dershowitz and his family were 
3 
occupying the house in Palm Beach. and during that 
4 
period of time Mr. Epstein was not staying at tie 
Palm Beach house? 
6 
A No. 
7 
0 
That's correct? 
A I think he was in Nil. 
9 
0 
Oh. okay. This is a time period when 
10 
Mr. Epstein was in Mir? 
13. 
A (Nodding head). 
12 
0 
That Mr. Dershovntz was at the house? 
13 
A 
Yes. 
14 
0 
Okay. Other than that time period 
there 
15 
was another lime period when Mr. Dershowltz was at the 
16 
house and he was not with his famay? 
17 
A 
Yes. 
18 
0 
And how long ago was that? 
19 
A Ch. I cannot remember when. 
20 
0 
All right. Was it before Mr. Epstein went to 
21 
jal? 
22 
A 
I think after. 
23 
0 
So you think again Mr. Epstein was not in the 
24 
house. To the best of your memory. has Mr. Dershowitz 
25 
been in the house at the same time Mr. Epstein has been 
112 
1 
0 
Who is this? 
2 
A Oh. Thars Ms. Maxwell. 
3 
0 
That's Ghislaine Maxwell? 
4 
A Yes, sir. 
5 
0 
That's somebody who you know? 
6 
A 
Yes, sir. 
7 
0 
And you've seen her at the house before? 
B 
A 
Yes. 
9 
0 
All right. And that's the same Ms. Maxwell 
1 ci 
that hired you into the position, correct? 
11 
A 
Yes. 
12 
0 
Do you remember seeing this person? 
13 
A Mars Igor. 
14 
MR. CRITTON: 
15 
BY MR. 
16 
0 
This is 144. 
17 
And how do you know Igor? 
18 
A 
He's now in the house. 
19 
0 
He's now in the house? 
20 
A 
Yes. 
21 
0 
But when we listed the people, I wanted you to 
22 
list for me all of the people 
23 
A 
I forgot. rm sorry. I forget Igor. 
24 
0 
Is there anybody else that you think you 
2s 
forgot? 
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- Volume I 
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• 
• 
113 
1 
A I think this is the only one I forgot. 
2 
O And what is his role in Mr. Epstein's life, if 
3 
you know? 
4 
A He's a [Miter and he is trainer. 
5 
O Trainer? 
6 
A (Nodding head). 
O What do you mean by that? 
8 
A Because I saw him telling Mr. Epstein, one 
9 
more lap. 
10 
O One more lap where? 
11 
A In the swimming pool. And he said he's a 
12 
trainer. 
13 
O Who said he's a trainer? 
14 
A Igor. 
is 
O Igor toil you dial he's a trainer? 
16 
A 
Yes. 
17 
O Okay. Do you know who that is? 
18 
A No. 
19 
O Never seen her before? 
20 
A Never. 
21 
O All fight. 
22 
MR. CRITTON That's It' 
23 
BY MR. 
24 
O That's . 84.*
25 
Do you ever remember a gil named l=reming 
115 
1 
A Because he aged. 
2 
MR. CRITTON: He aged? 
3 
THE WITNESS: He aged. 
4 
MR. CRITTON: Okay. 
5 
And this is *P.-
6 
BY MR 
7 
O This is 1›.• 
e 
And this is, just so that you know. a fairly 
9 
recent photograph of him, and you haven't seen him in 
10 
how long? 
11 
A After he left Mr. Epstein's employ. 
12 
O So It's been numerous years since you've seen 
13 
this person? 
14 
A Yes. 
15 
O So in fairness to you, that may be the reasor 
16 
why you didn't recognize this particular person? 
17 
A Yes. 
18 
O Okay. And if any of these preVious 
19 
photographs were taken recently and you hadn't seen the 
20 
person for five years. then that would be a possibility 
21 
as to why you don't recognize that person anymore? 
22 
MR. CRITTON: Form 
23 
(Telephone ringing.) 
24 
MR. 
25 
MR. 
11.4 
1 
to the nOuSe? 
2 
A =I? 
I heard= 
3 
O But you never remember seeing somebody M the 
4 
house that somebody referred to as=? 
5 
A 
No. I don't know their names if they come, I 
6 
don't know their names. 
7 
O But the name in this photograph, which is It' 
8 
you don't remember seeing her? 
9 
A No. sir. 
L0 
O Do you know vtho Mat is? 
11 
A 
Yes. sir. 
12 
O Who is that? 
13 
A My employer. 
14 
O And that is Mr. Epstein? 
15 
A Mr. Epstein. 
16 
O All right. So Mr. Epstein is 'Or 
17 
A Correct. 
18 
MR. CRITTON: Right. 
19 
BY MR. 
20 
O Do you know who that is? 
21 
A I don't know. 
22 
O Do you remember Alfredo Rodriguez? 
23 
A Oh. That's At redo? Oh. yes. 
24 
O Now that you look at the photograph. does it 
25 
look like Alf redo Rodriguez? 
116 
MR. MI 
Hey, guys. I got cut off. Sorry. 
2 
BYMIIMMEMMI: 
O This is T.* That was Alfredo Rodriguez. 
4 
you've seen him In the house? 
5 
A Yes. 
6 
O How many months was Alfredo Rodriguez working 
7 
there overlapping your employment? 
8 
A I started November, December, and then —
9 
about three months. 
10 
O Okay. Do you know who that is? 
11 
A Oh. You got that from my Facebook? 
12 
O Do you know who that Is? 
13 
A That's me. 
14 
O Okay. You recognIze that. 
15 
MR. CRITTON: That was *O.' 
16 
THE WITNESS: Thank you. 
17 
a 
You made the book 
18 
THE WITNESS: My niece made it for me. 
19 
MR. CRITTON: Next is 'R.' 
20 
BY MR... 
21 
O 
you 
who this person is who is labeled 
22 
1-R? 
23 
A No. 
24 
O Never seen that person before? 
25 
A No. 
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„ 
- Volume I 
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I17 
119 
1 
0 
Has Mr. Epstein had anyone in the house that 
1 
0 
Okay. Other than on the news. anybody around 
2 
you remember by the name of Martin? 
2 
the house ever say that? 
3 
A No. 
3 
A President Clinton? No. Lyn and Jojo. 
4 
0 
Have you ever been on Mr. Epstein's planes? 
4 
0 
Lyn and Jojo. What did they say? 
5 
A No. 
A Oh. not him. It's Kerry, Senator Kern'. they 
6 
0 
Do you know this person who we are labeling 
6 
have a picture. 
7 
1-S? 
7 
0 
Senator Kerry? 
8 
A No. 
A 
Yes. Clinton? Let me see. Oh, no. 
9 
0 
You've never seen that person before? 
9 
0 So Lyn and Jojo, at some point In time, told 
10 
A 
Never. 
10 
you that Senator Clinton (sic) was at the New Yak 
al 
0 
Do you know the name Leslie Wexner? 
11 
house? 
12 
A 
I heard that one. 
12 
MR. CRITTON: No. Senator Kerry. 
13 
0 
When did you hear about Leslie Wexner? 
13 
BY 
14 
A In the news, it was in the news. 
14 
0 
or Kerry. Sorry. 
15 
0 
Other than in the news, you have no idea who 
15 
A Remember when I was in New York she showed 
16 
Leslie Wexner is? 
16 
me a picture of them with Senator Kerry or Clinton, I 
17 
A 
No. 
17 
don't know, you know. 
18 
0 
Have you seen that person before? 
18 
0 
So either Kerry or Clinton was in a picture 
19 
MR. CRITTON: This Is 1-T. 
19 
with who? 
20 
BY MR. 
20 
A 
With Lyn and Jojo. 
21 
0 
1-T. 
21 
O And this picture was PaPatiedlY taken at the 
22 
A 
This is the Duke of. what's this? 
22 
New York house of Mr. Epstein? 
23 
0 
Prince Andrew. Have you ever seen 
23 
MR CRITTON: Form. 
24 
Prince Andrew in Mr. Epstein's house? 
24 
THE WITNESS: I don't know if it's In the 
25 
A 
No. 
25 
house, but they showed me a picture. 
118 
120 
1 
MR. CRITTON: Next one is 'U.*
1 
BY MR. 
2 
BY MR. 
2 
0 
Oka 
a 
0 
I -U, have you ever seen this person? 
3 
This is 'W.*
4 
A 
No. No. sir. 
4 
-
BY MR. 
5 
0 
That's not somebody you recognize as ever 
5 
0 
1-W, have you ever seen this person? 
6 
being at Mr. Epstein's house? 
6 
A 
No. 
7 
A 
No. 
7 
0 
No? 
a 
0 Do you know who this is? 
A 
No. 
9 
A 
President Clinton. 
9 
0 
Do you know anybody by the name of 
10 
0 
Have you ever seen President Clinton in the 
10 
Cecelia Stein? 
11 
house? 
11 
A 
Cecelia Stein? I heard about it. 
12 
A 
No. 
12 
0 
How have you heard about her? 
13 
MR. CRITTON That was 'V'? 
13 
A Cecelia Stein. I know Cecelia that works in 
14 
MR. 
That's eV.-
14 
the Office. 
15 
MR. CRITTON: 1-V is Clinton. 
15 
O 
Works in what office? 
16 
MR. 
*V' was Clinton. 
16 
A 
New York. 
17 
BY MR. 
17 
0 
You think she still works in that office? 
15 
0 
Have you ever seen him at the house? 
18 
A 
I don't know. 
19 
A 
No. 
19 
0 
When was the last time you remember her 
20 
0 
Have you ever seen him at all in person, 
20 
working in that office? 
21 
Mr. Clinton? 
21 
A 
I don't know. I just heard her name. 
22 
A 
No. 
22 
0 
Okay. Through whom? 
23 
0 
Have you ever heard that Mr. Clinton was ever 
23 
A 
Sometimes I think when I was in New York I 
24 
at Mr. Epstein's house? 
24 
answer a phone call, so that's... 
25 
A 
On the news. 
25 
0 
You remember a time -- did you ever hear of 
0 
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1 2 1 
her being relocated to some other location? 
A No. 
MR. CRITTON: We an at 1-X now. 
BY MR 
1 
2 
3 
4 
12.3 
0 
Do you know if he's a business associate or 
partner of Mr. Epstein? 
A No. 
0 
Had you seen him prior to this time that you 
5 
O So 1-X is MM? 
5 
recentty saw him alter Mr. Epstein was out of jal? 
6 
A 
Yes, sir. 
6 
MR. CRITTON: Form. 
7 
0 
And you recognize-? 
7 
THE WITNESS: I cannot remember. 
A 
Yes. 
BY MR. 
9 
0 
Okay. Do you know who that is? 
9 
0 
Okay. Do you think that the first time that 
10 
A 
I saw him on magazines. 
10 
you ever saw this person was recently, when Mr. Epstein 
11 
0 
David Copperfield, do you know who that is? 
11 
got out of jail? 
12 
A Oh. yes. 
12 
A 
Yes. 
13 
O And have you seen him at Mr. Epstein's house 
13 
0 
Okay. 
14 
ever? 
14 
MR. CRITTON: So this is AA. 
15 
A No, sir. 
15 
BY MR. 
16 
0 
Do you know Mr. Epstein to be friends with 
16 
0 
Do you know who this is? 
17 
David Copperfield? 
17 
A No. 
18 
A No. 
IS 
0 
Have you ever seen him before? 
19 
0 
If Alfredo Rodriguez remembers him performing 
19 
A No. 
20 
magic in Mr. Epstein's living room, you weren't at the 
20 
0 
All right. 
21 
house at that time? 
21 
A He's an actor? 
11 
MR. CRITPON: Form. 
22 
0 
Have you ever heard of the name Todd Meister? 
23 
THE WITNESS: No. Because I did not see him. 
23 
A No. 
24 
BY MR. 
34 
0 
That's not somebody you've ever taken a 
25 
0 
y. 
you ever remember anyone patenting 25 
message for that's called? 
122 
124 
1 
a Mgt show In Mr. Epstein living room? 
1 
A 
No. 
A No. 
2 
0 
Okay. The next one is Be. Do you know who 
3 
MR. 
What are we at? 
3 
that is? 
4 
MR. CRITION: Z.
4 
A 
That's Story. 
BY MR 
0 
Story Cowles? 
6 
0 
Do you know this? 
6 
A 
Yes. I don't know Ns family name, but Story. 
7 
A Yes. What's his name. 
7 
0 
When is the first time that you remember 
8 
0 
Jean Luc Brunel. Do you know who that is? 
8 
seeing Story? 
9 
A 
Yes. 
9 
A First time? Mr. Epstein was in jail. 
10 
0 
How do you know hirn? 
10 
0 
Okay. And was than as a result of him bein 
11 
A 
He comes to the house. 
11 
at the house with 
, Story and Ms. 
12 
0 
He comes to the house. When you say -he canes 12 
A No. I don't think so. He came without 
13 
to the house' you've worked since November of 2004. 
13 
he came first without M. 
14 
five years when has he Come to the house? 
14 
0 
And did he knock on the door? 
15 
A He came after At Epstein got out of jail. 
15 
A 
Yes. 
16 
0 
And what 64 he do there? 
16 
0 
Or does he have a key? 
17 
A He talked to Mr. Epstein, had breakfast. 
17 
A 
I think he knows the combination. 
18 
0 
How long did he stay? 
18 
0 
There is a combination to one of the doors to 
19 
A 
About a day. 
19 
gel access to the house? 
20 
0 
Okay. So he stayed overnight at the house? 
20 
A 
Yes. 
21 
A 
Yes. 
21 
0 
And Story Cowles is one of the people who has 
22 
0 
And was he accompanied by any females? 
22 
the combination? 
23 
A No. 
23 
A Yes. 
24 
0 
Do you know what he does for a living? 
24 
0 
Who are the other people that have the 
25 
A No. 
25 
combination to get in Mr. Epstein's house? 
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125 
1 
A Me 
2 
0 
Excuse me? 
3 
A Mc. 
4 
O Okay. 
A Janusz 
6 
0 
Okay. 
7 
A le7f. 
9 
( 
P2' aga 
10 
0 
Who is that? 
11 
A 
12 
0 
And when Story came to Mr. Epstein's house 
13 
weevil., 
how long ago was that, do you remember? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: How long ago? 
16 
BY MR. 
17 
0 
Yes. Was Mr. Epstein in lad, was it before 
18 
he went to jail? 
19 
A Ch. The other day ho carne withOtta. 
20 
0 
But the other day Is not the first time you've 
21 
seen Story. right? 
22 
A 
Yes. 
23 
0 
The other day was the first time you'Ve seen 
24 
Story? 
25 
A No, no, no, na lead he on eilhoutMl. 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
need a break? 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
MR. 
MR. CRITTON 
MR 
127 
All right. 
Are you done? 
Probably. 
Do you need a second? Do you 
Can we take a break? 
(Brief recess in proceedings.) 
MR. 
do you have questions. 
too? 
THE WITNESS: I'm hying to get a photograph 
of somebody over there. I don't know if Esquire s 
going to be able to pant d, if they've got a 
color copier, or if I've lust got to run it over. 
How much longer do youall plan on going, do 
you know? 
MR. CRITTON: About another fifteen minutes. 
I don't know. How long have you got, about 
ten? 
About ten, fifteen. 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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24 
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126 
O Right. This whole back and forth staled with 
me asking you when is the first time that you ever saw 
Story. And I thought you responded by telling me that 
he came to the house for the first time without. 
I don't want to put words in your mouth. we'll start 
over. 
A Okay. 
O When Is the first time you saw Story? 
A 
When Mr. Epstein was in jail. 
O Do you know why he came to the house? 
A No. 
O Do you know who he talked to when he was 
there? 
A MB. 
O And what did he talk Ict= 
about? 
A I do not know. 
O Did he talk to
 about Jeffrey being in 
Ian 
MR. CRITTON: Form. She said she didn't know. 
THE WITNESS: I did not hear anything. 
BY MR. 
O Where did they talk? 
A In the kitchen. 
ESQUIRE 
1 
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13 
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128 
MR. CRITTON: I may have ten minutes worth of 
questions. 
MR. 
Well be another thirty minutes 
at least. 
MR.. 
I might just get in the car and 
shoot over there. 
MR. 
I think we're taking a break 
right now anyway. 
MR. CRITTON: Well, if we're going to lake a 
break, then I want to do a lunch break. Fve got 
some stuff I have to do. If we're only going to be 
fifteen or twenty minutes, that's fine. But if 
we're going to go another half hour, let's take a 
lunch break. 
MR. 
It's going to lake a while. 
MR. CRITTON: So lets take a lunch break. 
(Brief recess in proceedings.) 
(Continued to Volume 
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- Volume I 
October 20, 2009 
129 
• 
• 
1 
STATE OF FLORIDA 
2 
COUNTY OF PALM BEACH 
3 
4 
S 
I the fakirs good authority. certify that 
6 
personally appeared before me al the 20th 
7 
Cif October, 2009, and was duty Sweat 
9 
Dated this 30th day of October. 2009. 
10 
11 
12 
13 
14 
Teresa Whalen, APR. FPR 
15 
Notary Pubic Slate of Flonda 
My Commission Expires. 4/25/11 
16 
My Commission No.: DD 644533 
17 
Job # 118991 
16 
19 
20 
21 
22 
23 
24 
25 
130 
CERTIFICATE 
2 
STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
Teresa Whalen. Regstcrad Protessfonal 
Reporter and Notary Public in and tor the Stale of 
6 
Flonda at Large. do hereby candy that the 
afctemenocned withess was by me Scst duly sworn to 
testify the whole truth that I was sues:M/0010 
and ad report said depostiOn in stenotype, and 
8 
that the foregoing pages are a true and correct 
transcription Of my shorthand notes of said 
9 
deposition.
10 
I further codify that said deposition was 
taken at the time and place hereinabove set forth 
11 
and trial the taking of said deposition was commenced 
and completed as hereinabOve Set Out, 
12 
I further certify that lain not attorney or 
13 
counsel of any of the parties. nor am I a relative or 
employee of any attorney a counsel of party connected 
14 
with the action. nor am I Mena* interested in the 
action. 
15 
The foregoing canniest= of this transcript 
16 
does not appty to any reproduction of the same by any 
meare unless under the direct control andfor d rectIon 
17 
0l the certrlyng repater. 
16 
19 
Dated this 30th day of October, 211:03 
20 
21 
22 
Teresa Whalen, RPR, FPR 
23 
Job 6 118991 
24 
25 
• 
0 
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