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and I receive a call from Alfredo, and he told me not to 
answer any call from New York. 
Q 
Did he tell you why? 
A 
He said I'm going to help you and you help me. 
So I did not know what he means by that. And then I 
receive a call from one of the secretary, so they said 
where are you, 
and I said the mall. 
Q 
Were you in the mall? 
A 
Yes. 
Q 
All right. was it your day off? Were you 
working that day, did you have to pick something up? 
A 
I was off. 
Q 
Okay. So you said the secretary called you 
and you told her exactly where you were? 
A 
Yes. 
Q 
Did ohe ack you -- and then what happened 
next? Let me ask you this question, did she ask you 
where Mr. Rodriguez was? 
A 
She did. 
Q 
And what did you say? 
A 
I don't know, but I chink I mentioned that I 
receive a call from him. 
Q 
Did he want you to cover for him? 
MR. 
Object to the form. 
THE WITNESS: i did not tell Helen that he 
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190 
asked me to cover for him. 
BY MR. CRITTON: 
Q 
Okay. And if I understood your testimony, he, 
Mr. Rodriguez said if you get a call from New York, 
simply don't answer it? 
A 
Yes. 
• 
Because that way what, no one could ask where 
you were or anybody else was? 
A 
Yes. 
Q 
That's what you understood? 
A 
That's what I 
MR. CRITTON: 
very much, ma'am. 
THE WITNESS: 
REDIRECT 
understand. 
That's all I have. Thank you 
You're welcome. 
BY MR. 
• 
I have some follow-up questions. 
Have you ever met with Mr. Critton before? 
A 
Yes. 
Q 
When was that? 
A 
Yesterday. 
• 
And where was that? 
A 
In his office. 
• 
And who called that meeting? 
: That's privileged. 
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BY MR. 
• Q 
Okay. Was it your idea to meet with 
Mr. Critton? 
A 
No, sir. 
Q 
Okay. So when Mr. Critton sat down and said 
ma'am, I'm Bob Critton and I represent Mr. Epstein, 
that's something you already knew from yesterday, right? 
A 
Yes. 
Q 
Okay. SO that was just a show for everybody 
else in this room to make it seem like you had not met 
before? 
MR. CRITTON: It was for the record. 
THE WITNESS: No, sir. 
BY MR. 
Q 
Okay. What did you talk about with 
Mr. Critton? 
MR. CRITTON: That's privileged. 
MR. 
: You represent Ms. --
MR. CRITTON: She's my employee. 
BY MR. 
 
vo you understand this to be your aLLorney, 
Mr. Critton? 
MR. CRITTON: Well, I am her attorney. 
is her personal lawyer, I'm her attorney vis-a-vis 
her employment with Mr. Epstein, and that was a 
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October 20, 2009 
192 
privileged communication. 
MR. 
: This case has got nothing to 
do with employment. 
MR. CRITTON: I don't care. Take it up with 
the judge. If I'm wrong, I'm wrong. 
MR. 
: i assume you don't have 
authority with you here? 
MR. CRITTON: Pardon? 
MR. 
: I assume that means you have 
no authority as we sit here today? 
MR. CRITTON: What? Am I supposed to give you 
authority? Take it up with the judge. 
BY MR. 
Q 
Okay. At this meeting with you and 
Mr. Critton, was 
also there? 
A 
He is. He was. 
Q 
Who else was at the meeting, who else was in 
the room with you? 
A 
Only 
and Mr. Critton and me. 
Q 
How long did the meeting last? 
A 
About an hour. 
• 
Did you ever cry about a picture of the Pope 
next to a girl in Mr. Epstein's house? 
A 
No. 
• 
All right. Now, you testified that 
0 
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193 
Mr. Rodriguez on one occasion asked you to cover for 
him? 
A 
Not to answer the phone call from New York. 
Q 
You don't 
know why he told 
you not 
to answer 
the phone call from New York? 
A 
He mentioned -- he said that one day I'm, 
like, help you, and the other day... 
Q 
You help me? 
A 
Yes. 
Q 
You don't know what that means, though? 
A 
No. 
Q 
And the time where there was some 
confrontation between, or there was some dispute over 
Jerome the gardener being at work or not being at work, 
that's something that Mr. Rodriguez tried to bring you 
into? 
A 
Yes. 
Q 
And was that with Mr. Epstein or with 
Ms. Maxwell or Ms. 
A 
Ms. -- again? 
Q 
Okay. My understanding is that it was 
Mr. Rodriguez who is saying 
is a witness 
to whether or not Jerome was at work that day? 
A 
Correct. 
Q 
And who was he saying that to? 
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194 
A 
To Jerome. 
Q 
Okay. So he's telling Jerome hey, Ms. 
is a witness to you not being here? 
A 
Yes. 
Q 
Okay. And you said don't use my name any 
more? 
A 
Because Jerome talked to me and he said, he 
mention to me what Alfredo told him, so I went to 
Alfredo and talked to Alfredo. 
Q 
Okay. And prior to the police coming to the 
house, there was a massage table inside Mr. Epstein's 
bedroom, right? 
A 
Yes. 
Q 
was that massage table there after the police 
came to the house? 
A 
No. 
Q 
Okay. So before when you told us all they 
took were photographs, do you know whether or not the 
police also took a massage table? 
MR. CRITTON: Form. 
Strike that, withdraw the form. 
THE WITNESS: 
I cannot always remember, 
like... 
: Hold on. Do you understand his 
question? 
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BY MR. 
Q 
Do you know if the police took the massage 
table? 
A 
No. 
Q 
You don't know who took the massage table out 
of the house? 
A 
No. 
Q 
Okay. We were talking about a time period 
where you worked one day and then the following day you 
came in in the afternoon because you had received a call 
from Ghislaine Maxwell. Do you remember that scenario? 
A 
Yes. 
Q 
When you received the call from 
Ghislaine Maxwell, you didn't know at that time that the 
police had ever been to the house, right? 
A 
No. 
: Hold on. 
She didn't answer the question that you asked. 
MR. 
I thought she had already said 
no. 
: I think the way yuu asked it, 
it may have been nonresponsive, so why don't you 
ask it again so it's clear. 
BY MR. 
O 
Okay. At the time when Ghislaine Maxwell 
•
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October 20, 2009 
196 
called you to tell you you didn't have to come in until 
the afternoon, at that point in time you didn't know 
that the police had ever been to the house, right? 
A 
No. 
Q 
You found out for the first time that the 
police came to the house when you arrived in the 
afternoon to show up for work, right? 
A 
Correct. 
Q 
Okay. That call from Ghislaine Maxwell, your 
schedule at that time was to show up, at the time when 
this telephone call is taking place, was to show up at 
eight in the morning or so, right? 
A 
Correct. 
Q 
So that call from Ghislaine Maxwell was 
actually the night before she called you and said don't 
come in until the next afternoon, right? 
A 
I think in the same day. 
Q 
All right. You told me earlier that she 
didn't call that early, but she obviously called 
sometime before you got to work? 
A 
Yes. 
Q 
All right. what time did she call? 
A 
I cannot remember. You know, I have problem 
with remembering days and what's this. 
Q 
I can understand problems with memory. But 
S 
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197 
when you say that you show up at eight o'clock, were you 
a punctual employee to where you showed up on time? 
A 
I am. 
Okay. Do you remember that day if you were 
scheduled to work eight or nine? 
A 
I think nine. 
Q 
Okay. I had understood your testimony, and we 
can go back and look at the record some other time, I 
• 
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understood --
A 
I get confused, because during that time my 
schedule was like sometimes eight -- I go nine, 
sometimes I go eight. 
• 
How did you find out around that time whether 
you were supposed to report at eight or nine? 
A 
Because we were told that we don't -- don't 
baby the house. So since Mr. Epstein is not there, so I 
report between eight or nine. 
Q 
Okay. So when you say that you were a 
punctual employee, that means that if you were supposed 
to show up at eight you showed up at least by 
eight o'clock, and if you were supposed to show up at 
nine, you showed up at least by nine o'clock, right? 
A 
Yes. 
Q 
All right. Did you have a cell phone at the 
time? 
A 
I do. 
• 
Did Ghislaine Maxwell call you on the cell 
phone, or did she call you on your house phone? 
A 
Cell phone. 
• 
Were you already in the car on the way to 
Mr. Epstein's house? 
A 
Q 
And were you already ready for work, ready to 
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go to work? 
A 
Yes. 
Q 
And what did Ms. Maxwell say on the telephone 
other than you can show up in the afternoon, anything? 
A 
That's it. 
Q 
All right. And did you ask why? 
A 
No. I just thought that maybe she's giving 
like half a day off, so I was happy. 
Q 
Was Ghislaine Maxwell calling you from 
New York, or was she in West Palm Beach? 
A 
I don't know where she was calling me. 
Q 
When you arrived at the house in West Palm 
Beach, was Ghislaine Maxwell there? 
A 
NO. 
: You mean the house in 
Dalm Beach. 
BY MR. 
Q 
Well, that's the house you went to work to 
that day, right? 
MR. 
. Okay. Understood. 
BY MR. 
; 
Q
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200 
A 
7 
A 
Yes. 
8 
Q 
Okay. So Ghislaine Maxwell is calling you 
10 
that morning then sometime either just before 7:30 or 
just before 8:30 in the morning to tell you don't have 
11 
to show up until the afternoon; is that right? 
12 
A 
Yes. 
13 
Q 
And as we sit here today, you don't remember 
14 
whether it was just before 7:30 or just before 8:30? 
15 
A 
To be honest, sir, I cannot remember. 
16 
O 
All right. Is it fair to say that it might 
17 
have been even the night before? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: No. 
20 
BY MR. 
21 
Q 
You're sure that it was that morning? 
22 
A 
I think I'm sure it was that morning. 
23 
Q 
Okay. You seem to remember specifically 
24 
getting a telephone call from her and it was early 
25 
morning before you showed up for work? 
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201 
A 
I cannot remember if it was early, but I got a 
call. I don't know the time. 
Q 
All right. Your schedule, just so that we're 
on the same page here, you were either supposed to show 
up at eight or at nine o'clock, and you can't tell us 
which one, right? 
A 
Yes, sir. Because I don't how to explain 
this. 
Q 
And you were not in the car at the time when 
you received the telephone call from Ghislaine Maxwell, 
right? 
A 
Yes. 
Q 
So we can all presume, it's a very safe 
presumption at this point that the telephone call from 
Ghislaine Maxwell was made to you prior to 8:30 in the 
morning on that. particular morning, right? 
A 
Yes. 
Q 
Okay. Do you punch a clock so that we could 
figure out what time you were supposed to be at the 
house? 
A 
No. 
Q 
Anybody keep a track of time? 
A 
Nn. 
Q 
You've been asked a lot of questions about the 
various females that showed up to the house to give 
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massages, and the only reason you ever knew that they 
2 
were allegedly giving massages is that somebody told you 
3 
that, right? 
4 
A 
Correct. 
S 
Q 
These females that showed up didn't show up 
6 
MR. CRITTON: Form. 
7 
BY MR. 
8 
-- with massage cards or hand you cards or 
9 
give you any other indication that they were giving a 
10 
massage other than somebody else told you that? 
11
MR. CRITTON: Form. 
12 
THE WITNESS: Correct. 
13 
BY MR. 
14 
Okay. And when these females would show up, 
15 
they were of very young age; wouldn't you agree with 
16 
that? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: They may look young, but I did 
19 
not ask their age. 
20 
BY MR. 
21 
You know what a thirty year old looks like or 
22 
a forty year old or a fifty year old, and that's not 
23 
this classification of females that we're talking about, 
24 
is it? 
25 
MR. CRITTON: Form, argumentative, 
0 
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repetitious. 
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THE WITNESS: Yes. 
BY MR. 
Q 
You think that there were thirty year olds 
that showed up to give massage? 
A 
No. Because there are people that look young 
but, you know, they may be older than what they, how 
they look. 
Q 
And in the period of time from November 2004 
through the time that Mr. Epstein went to jail, which is 
2008, you testified that he received from these females 
two to three massages or visits from these females per 
day every day, right? 
MR. CRITTON: Form. 
THE WITNESS: I said not every day. I 
remember that, my answer. 
BY MR. 
Q 
Okay. But almost every day, fair? 
MR. CRITTON: Form. 
THE WITNESS: Yes. 
SI MR. 
• 
Okay. we're talking about -- and two of those 
females that you remember over this four-year period you 
remember being repeat visitors and that came more than 
one time, correct? 
• 
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204 
A 
Yes. 
MR. CRITTON: Form. 
BY MR. 
Q 
The other ones --
MR. CRITTON: Hold on. I want to put one 
thing on the record. 
MR. IIIIIIIIII: 
I don't break you up like this 
every time. 
9 
MR. CRITTON: well, this ie the testimony that 
10 
you covered for almost three hours earlier today, 
11 
it's the same, it's not recross, it doesn't cover 
12 
anything that everybody else touched on in their 
13 
cross. I'm sorry, 1 mean it's not redirect. It's 
14 
the same material that you covered before. 
15 
MR. 
: 
Mark this point in the 
16 
deposition, too. 
17 
MR. CRITTON: Please do. 
18 
MR. 
: Thank you. 
19 
RIC MR. 
20 
Q 
The other girls that are coming on nearly an 
21 
everyday basis as females under the idea that they're 
22 
going to give Mr. Epstein a massage, besides the two 
23 
that you've described as repeat masseuses, are different 
24 
faces every day, right? 
25 
MR. CRITTON: Form. 
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205 
THE WITNESS: Yes. 
BY MR. 
Q 
So if you're only seeing them one time, that 
could be the reason why you can't think back and 
remember these particular faces of every single one of 
these female girls, right? 
MR. CRITTON: Form, leading. 
THE WITNESS: Yes. 
BY MR. 
Q 
Okay. So did you ever wonder how it was that 
so many different young-looking female girls arrived at 
Mr. Epstein's house, how he got in touch with this many 
girls? 
MR. CRITTON: Form. 
BY MR. 
ce 
Did you ever wonder? 
MR. CRITTON: Form. 
THE WITNESS: It was strange, but that's his 
life, so I was there to work, to do my job. 
BY MR. 
• 
Okay. But while you were dviuy nun jvb, you 
knew -- look, you didn't witness anything, like 
Mr. Critton said, what was going on behind closed doors, 
but you knew that there was sex going on between 
Mr. Epstein and these young girls? 
• 
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206 
MR. CRITTON: Form, argumentative. 
THE WITNESS: I did not see, I did not go 
upstairs and notice. 
BY MR. 
• 
I know you didn't see. You're still employed 
by Mr. Epstein, right? 
A 
I am. 
• 
Mr. Epstein has hired you an attorney, 
obviously? 
A 
Yes. 
Q 
You want to keep your employment with 
Mr. Epstein, right? 
MR. CRITTON: Form. 
THE WITNESS: If he'll fire me, I -- you know, 
they told me to tell, to be honest, to tell the 
truth, my lawyers. 
BY MR. 
• 
Yeah. 
A bunch of these girls are all alleging that 
ML. Epstein was upstairs having sex with them and/or sex 
acts with them, and that these were not massages taking 
place. You're aware of those allegations now, right? 
A 
Now I'm aware. 
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MR. CRITTON: Form. 
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BY MR. 
Q 
And had you ever heard that during these sex 
sessions that Mr. Epstein would then offer these young 
girls money, cash money to be subjected to sex; had you 
ever heard that? 
MR. CRITTON: Form. 
THE WITNESS: I heard now. 
BY MR. 
Q 
And that if they agree to bring their friends 
who are also of that same age group, that each friend 
they brought over to his house he would then pay them 
for recruiting a new friend. Did you know that? 
MR. CRITTON: Form. 
THE WITNESS: No. 
BY MR. 
Q 
Now it all kind of makes sense how he gets all 
these young little girls over to his house, right? 
MR. CRITTON: Form, argumentative. 
BY MR. 
• 
And nobody in the house has ever denied day of 
what I'm saying, have they? 
MR. CRITTON: Form. She didn't even answer 
the last question and you're continuing on with 
your argument. 
• 
0 
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BY MR. 
• 
Has anybody? 
A 
I did not hear them talk about it, so I 
cannot. 
Q 
So now that you know what's going on in your 
boss's house, are you still going to stay employed with 
him? 
MR. CRITTON: Form, argumentative, serves no 
purpose. 
THE WITNESS: Yes. 
MR. 
Okay. Perfect. I don't have 
anything else. 
THE WITNESS: But if he fires me, you know. 
MR. 
BY MR. 
RECROSS
Just a couple of questions. 
• 
Tnis meeting that you had with Mr. Critton and 
yesterday, where did it take place? 
A 
In Mr. Critton's office. 
Q 
Mr. Critton's office? 
A 
Yes, sir. 
Q 
And was it Mr. critton's office who called you 
to advise you of the time and where to go for the 
meeting? 
A 
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