EFTA00101322

Page 161 
I 
A. 
Absolutely. 
2 
Q. 
-- with his secretary? 
3 
A. 
Yes. 
4 
Q. 
And did she take notes? 
5 
A. 
Yes, she did. 
6 
Q. 
Pardon me? 
7 
A. 
She did. 
8 
Q. 
She took notes. Just by pen and paper? 
9 
A. 
Pen and paper. 
10 
Q. 
Not a machine like the court reporter? 
11 
A. 
No. 
12 
Q. 
Were you taped? Did somebody tape record you? 
13 
A. 
No. 
14 
Q. 
Did he show you the notes that she took down? 
15 
A. 
No. 
16 
Q. 
Typed up and show you the transcript? 
17 
A. 
No. 
18 
Q. 
No? Now, how long was Mr. Critton at your 
19 
house then? 
2.0 
A. 
For about half an hour. 
2.1 
Q. 
And did you know that he was coming? Did he 
22 
call ahead of time? 
23 
A. 
Yeah. 
24 
Q. 
And, so, what did you expect was going to 
25 
happen? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676-2895) 
Electronically signed by Sandra Townsend 001-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000437 
afc3ca0-c86e-4b9f-8d01-ba2Obcao87de 
EFTA00101402

Page 162 
1 
A. 
He was going to come in and ask questions 
2 
about this case. 
3 
Q. 
So what did he say? 
4 
A. 
Same questions that you guys are asking me, 
5 
exactly the same questions. 
6 
Q. 
Nothing more? 
7 
A. 
Basically what you saw, what you did, what 
8 
your job description was, what you did, how you start 
9 
your day, how was your day and how was -- what time you 
10 
started, what time you finish and what you did, and what 
11 
was your responsibilities. And that was it. 
12 
Q. 
Okay. And were you paid anything for that? 
13 
A. 
Absolutely not. The only money that I got, it 
14 
was from you for this $47 check for coming in here. 
15 
Q. 
Okay. 
16 
A. 
And I will take no money from nobody. 
17 
Q. 
Okay. Were there -- were there any other 
18 
times that you talked to either Mr. Critton or anybody 
19 
from his office? 
20 
A. 
No. 
21 
Q. 
You described every time that you've ever 
22 
talked to either Mr. Critton or people from his office? 
23 
A. 
No, sir. 
24 
Q. 
You've described all those times that you've 
25 
talked to Mr. Critton or people from his office? I'm 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-876-2895) 
Electronically signed by Sandra Townsend (401.377.676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000438 
WOcatricno.O9(4O1-banbcao87O 
EFTA00101403

Page 163 
1 
not asking the question clearly. 
2 
Did you talk to Mr. Critton any other time? 
3 
A. 
No. I talked to Mr. Critton twice, once in my 
4 
house, once yesterday. 
5 
Q. 
Now, how about Mr. Jack Goldberger, 
6 
Mr. Epstein's criminal defense attorney, did you ever 
7 
talk to him? 
8 
A. 
No. 
9 
Q. 
Did you ever talk to Alan Dershowitz about any 
10 
of these matters? 
11 
A. 
No, sir. 
12 
Q. 
Or Roy Black? 
13 
A. 
No, sir. 
14 
Q. 
Now, I'm just going back over some different 
15 
things that you mentioned. 
16 
You said that there was a Roladex that you 
17 
created of names of women? 
18 
A. 
Not it was a name just woman. It was 
19 
companies, air condition companies. It was cleaning 
20 
companies. It was suppliers. And it was -- it was a 
21 
Roladex that I left it there. 
22 
Q. 
Did you have a list of girls on your Roladex? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: No. We had a list of girls in 
25 
a 
in a -- in a sheet with plastic that we have 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401377.676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000439 
3afc3ca0-c86e-4b91-8d01-ba2Obcao87do 
EFTA00101404

Page 164 
1 
all the massage therapists. It was two pages or 
2 
three pages of people in a plastic sheet that we 
3 
had it where -- by the telephones. That was it. 
4 
BY MR. BERGER: 
5 
Q. 
Have the names? 
6 
A. 
Names and phones. 
7 
Q. 
Telephone numbers? 
8 
A. 
Uh-huh. 
9 
Q. 
What about addresses? 
10 
A. 
No, no addresses. 
11 
Q. 
What about dates? 
12 
A. 
No, sir. 
13 
Q. 
And who prepared the list? 
14 
A. 
Either Ms. Maxwell -- Ms. Maxwell. 
15 
Q. 
Was it typed? 
16 
A. 
Yeah. They were types. 
17 
Q. 
No. Typed. 
18 
A. 
Yeah. 
19 
Q. 
Who typed it? 
20 
A. 
I don't know who type it, but it came from New 
21 
York. 
22 
Q. 
The list? 
23 
A. 
Yeah. 
24 
Q. 
Did you -- did you give the information that 
25 
went into the list? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000440 
3afc3ca0-c860-4b9f-8d01-ba20bcae87de 
EFTA00101405

Page 165 
1 
A. 
No. 
2 
Q. 
Where was the list kept? 
3 
A. 
In many places. It was in Mrs. Maxwell's 
4 
desk. It was one in the kitchen, one in my office, one 
5 
in my room because sometimes I was in my room and I have 
6 
to call. these people. It was one in the new house when 
7 
they build the new house. It was all over. And it was 
8 
also those -- those files for the house -- the house 
9 
running operation. 
10 
Q. 
Was it the same list that was in all those 
11 
places? 
12 
A. 
13 
Q. 
14 
A. 
15 
Q. 
16 
A. 
17 
Q. 
18 
didn't take a copy with you? 
19 
A. 
Not at all. 
20 
Q. 
And when you worked for Mr. Epstein, you 
21 
didn't write notes about what you did and what you saw? 
22 
A. 
No. 
23 
Q. 
No? 
24 
A. 
No. I had too much to do. 
25 
Q. 
You didn't put anything in a computer about 
Basically, yes. 
Was the list updated? 
Yes. 
Did you keep a copy of the list? 
No, I don't have a copy of the list. 
When you left Mr. Epstein's employment, you 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000441 
3atc3ca0-c86e-4b91-8d01-ba20bcae87de 
EFTA00101406

Page 166 
1 
what you saw at the house? 
2 
A. 
No, sir. 
3 
Q. 
Did you ever talk to your wife about what you 
4 
saw at the house? 
S 
A. 
Like what? Saw about what? 
6 
Q. 
About the dildos. About the massages. Did 
7 
you ever talk to your wife about that? 
8 
A. 
Yeah. And that's one of the reasons that I 
9 
never send my wife after -- this hap -- these dildos and 
10 
things like that happened right at the end of my stay 
11 
there. It never happened before. Right at the last 
12 
couple months before I left. And that --
13 
Q. 
And that's when young girls --
14 
MR. CRITTON: Let him finish his answer. 
15 
THE WITNESS: And my -- my worry about was 
16 
that my wife will panic. And I never send her up 
17 
there to clean up the rooms or anything else. 
18 
BY MR. BERGER: 
19 
Q. 
Is that when young girls started coming to the 
20 
house? 
21 
MR. CRITTON: Form. 
22 
THE WITNESS: One girl that I can think of. 
23 
BY MR. BERGER: 
24 
Q. 
Just one? 
25 
A. 
One girl. That girl that she show me the 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000442 
3atc3ca0-c86.3-4b91-8d01-ba20bcae87de 
EFTA00101407

Page 167 
1 
picture. 
2 
Q. 
V.R.? 
3 
A. 
That's the only one that I can think she was 
4 
young, but I don't know how old. 
5 
Q. 
Do you still have the transcript from -- from 
6 
the police in front of you, from the State Attorney's 
7 
Office? 
8 
It's below that. It's at the bottom. Keep 
9 
going. 
10 
You see? Turn to page 9. 
11 
Page 9. Now, look at me. It says, page 10, 
12 
but it also says page 9. 
13 
So you got page 9? 
14 
A. 
Page 9 and page 10. 
15 
Q. 
Okay. 
16 
A. 
Oh, okay. Page 9. Okay. 
17 
Q. 
I want you to see page 9. 
18 
MR. CRITTON: You want the transcript page 9? 
19 
MR. BERGER: Yeah. 
20 
BY MR. BERGER: 
21 
Q. 
Let me just make sure you're on the right 
22 
page. Yeah. 
23 
Look at line 13. 
24 
It says, answer: "No, sir. Mostly no. We 
25 
saw one or two young ones in the last year." 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401.377.676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000443 
3afc3ca0-c86e-4b91-8d01-ba20bcae87de 
EFTA00101408

Page 168 
1 
Do you see that? 
2 
MR. CRITTON: Form. It's taken out of 
3 
context. There's no question. 
4 
BY MR. BERGER: 
5 
Q. 
Do you see those words? 
6 
A. 
Did they seem -- did they seem young to you? 
7 
No, sir, mostly were no. We saw two young ones in the 
8 
last year. 
9 
Q. 
Well, it actually says, "we saw one or two 
10 
young ones in the last year." 
11 
A. 
"We saw one or two young ones in the last 
12 
year. Before that they were all adults." 
13 
Q. 
The one or two young ones in the last year 
14 
that you're referring to, who are they? 
15 
A. 
One was V. and the another one was N.B. 
16 
Q. 
Don't write on that. Okay? Don't write on 
17 
that with your pen. 
18 
Look at paragraph -- look at line 19. 
19 
A. 
Yes. 
20 
Q. 
It says, quote, I remember one girl was young, 
21 
unquote. 
22 
Do you see that? 
23 
A. 
Yeah. 
24 
MR. CRITTON: Form. 
25 
BY MR. BERGER: 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-28951 
Electronically signed by Sandra Townsend (401.377.876-2895 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000444 
3afc3ca0-c860-4b91-8d01-ba2Obcao87do 
EFTA00101409

Page 169 
1 
Q. 
Who were you referring to? 
2 
A. 
3 
Q. 
And then you see under that at line 22, it 
4 
says, quote, but I imagine she was 16, 17. In my 
5 
judgment she was 16, 17, unquote. 
6 
Do you see that? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: Yeah. 
9 
BY MR. BERGER: 
10 
Q. 
Were you referring to 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: I think so, yeah. 
13 
Oh, can I read this again? 
14 
BY MR. BERGER: 
15 
Q. 
Sure, go ahead. Take your time. 
16 
A. 
"During the last year while you were working 
17 
for him, what do you mean, they look young? Did they 
18 
look like they were still in high school? Yes. And the 
19 
only one that I knew was in high school was N. I 
20 
remember one girl was young. We never ask her how old 
21 
she was. I never asked N. how old she was. I think she 
22 
was in the last year of high school. 
23 
Right. Understand. 
24 
Question. 
25 
But I imagine she was 16, 17. I don't know. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401.377.676.2895) 
EOM Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000445 
WOc4-aft-4b91.43O1-ImNIxacVde 
EFTA00101410

Page 170 
1 
In my judgment she was 16, 17." 
2 
I was talking about, I was referring about N. 
3 
at that time. 
4 
Q. 
So at line 22, look at line 22. 
5 
A. 
Yes, sir. 
6 
Q. 
It says, quote, but I imagine she was 16, 17, 
7 
unquote. 
8 
You were referring to who? 
9 
A. 
To N. 
10 
Q. 
Okay. You can put that down. 
11 
You mentioned Joe Joe. You said Joe Joe was 
12 
the house man in New York? 
13 
A. 
Yes. I met Joe Joe. 
14 
Q. 
And do you know his full name? 
15 
A. 
Joe Joe work with his wife. They were 
16 
Funtanella (phonetics), Funtanella. Joe Joe and Lynn 
17 
was his wife, Funtanella. 
18 
Q. 
When is the last time you talked to them? 
19 
A. 
Wow. Never talked to them again in over ten 
20 
years. 
21 
Q. 
Now, you mentioned in response to Ms. Ezell's 
22 
questions, you said something abou 
father. Do you 
23 
remember talking about that? 
24 
A. 
Uh-huh. 
25 
Q. 
How do you know that person was her father? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377.676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000446 
3afc3ca0-c86e-469f-ScI01-ba20bcae87de 
EFTA00101411

Page 171 
1 
A. 
Because either she told me or Ms. Maxwell told 
2 
me that her father used to work at Donald Trump's place. 
3 
And she -- I think he is the one who bring her to the 
4 
house that afternoon, the first time I saw 
rive in 
5 
at this -- Donald Trump's house. 
6 
Q. 
Now, you said you know -- you knew who Alan 
7 
Dershowitz or you know who Alan Dershowitz is, right? 
8 
A. 
Many times. 
9 
Q. 
And he was at the house? 
10 
A. 
He's been at the house a lot of times. 
11 
Q. 
Was he ever at the house when there were naked 
12 
women at the house? 
13 
A. 
No. 
14 
Q. 
No? 
15 
A. 
They were never naked woman at the house, sir. 
16 
I remember one occasion when one English 
17 
girl -- I think she was English or German girl -- came 
18 
to the house. And usually in Europe they use topless, 
19 
they don't wear anything. But she was taking the sun 
20 
outside and she came to the house with nothing on and I 
21 
chase them out. I says, not in this house. You don't 
22 
do it. You go outside, put the towel and come in here. 
23 
Because she came to get something from the kitchen 
24 
wearing nothing. And I did not allow that. 
25 
Q. 
But when Alan Dershowitz was there, were there 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401477476-2895) 
Electronically signed by Sandra Towngea64intalla6289 
ireatgrent Requested / Fed. 
GJ SUBPOENA RESPONSE 000447 
0c 3carl-c86e4b9f-8O1-banbcaende 
EFTA00101412

Page 172 
1 
any women that were topless? 
2 
A. 
No, not that I can remember. 
3 
Q. 
What about when Prince Andrew was there? 
4 
A. 
Not that I can remember, sir. 
5 
Q. 
Did you ever see Alan Dershowitz walking 
6 
around naked? 
7 
A. 
No, sir. 
8 
Q. 
How about Prince Andrew? 
9 
A. 
No, sir. 
10 
Q. 
You mentioned your divorce, that it cost -- it 
11 
cost money. Did Jeffrey Epstein pay for anything 
12 
connected with the divorce? 
13 
A. 
Absolutely nothing. 
14 
Q. 
Let me go back for a minute to the 
15 
confidentiality provision in the separation agreement. 
16 
Did you -- did you discuss with anybody why 
17 
there had to be a confidentiality provision? Did you 
18 
talk to somebody about that? 
19 
A. 
No. No. I discuss it with Mr. Epstein when 
20 
he told me, he finally come out and says,-- 
I know 
21 
they were going to try to replace us. And -- and we got 
22 
upset because I was not ready to leave yet. But at the 
23 
same time we were expecting to be left out. And I left 
24 
there before they decide to let me go. 
25 
And I went to -- I remember very clearly, I 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401.377.676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000448 
3a1c3ca0-c860-4b91-8d01-ba20bcao87do 
EFTA00101413

Page 173 
1 
went to his office in the pool house and it was -- I 
2 
talk to him and says, 
- I went with some faxes 
3 
that came to my office and they were people interviewing 
4 
for my job. So I feel very pissed about it. 
5 
And I went to his office and said, Jeffrey, 
6 
what is this? And what is this? And what is this? 
7 
He says, well, that's Ghislaine. I'm not 
8 
involved into that. 
9 
And I says, okay. We're going to leave, 
10 
Jeffrey 
That's it. We're done. And what you going to 
11 
do for me? 
12 
And he says, well, what you want? 
13 
And I says, give me at least a year's salary. 
14 
And that's what it turn out to be, around 
15 
$50,000, plus the van. 
16 
And he says, okay 
ish you good luck 
17 
And the last day I was there we shake hands and we left. 
18 
But my relationship with him, it was good. It 
19 
was friendly. At the beginning of the -- my job was 
20 
very friendly. Then he changed when Ms. Maxwell come 
21 
in. I didn't like to work for her. She was a bitch. 
22 
And she make us life hell. And that's why we left. But 
23 
it was not with Mr. Epstein. 
24 
Q. 
Do you know why there was a confidentiality 
25 
provision in your agreement? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676-2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000449 
3afc3ca0-c86e4b9f41d01-ba2Obcae87de 
EFTA00101414

Page 174 
1 
A. 
No. That's lawyer stuff. I don't know. 
2 
MR. BERGER: Okay. That's all I have. 
3 
CROSS EXAMINATION 
4 
BY MR. CRITTON: 
5 
Q. 
Mr. Alessi, my name is Bob Critton, as you 
6 
know, and I represent Mr. Epstein. 
7 
A. 
Yes, sir. 
8 
Q. 
You've been -- this deposition started at 
9 
10:00. It's almost -- it's closing in on 3:00 but for 
10 
about 45 minutes or an hour that we took for lunch. I'm 
11 
going to try to be relatively brief so we can get you 
12 
out of here. Okay? 
13 
A. 
Okay, sir. 
14 
Q. 
You've been asked questions by five different 
15 
lawyers who represent various Plaintiffs in this case. 
16 
A. 
Yes, sir. 
17 
Q. 
In some instances you've been asked the same 
18 
question multiple times? 
19 
A. 
Yes, sir. 
20 
0. 
The testimony -- you've also been asked a 
21 
number of questions about your separation from 
22 
Mr. Epstein sometime at the end of December of '02 and 
23 
the entrance or your entering into a separation 
24 
agreement with him? 
25 
A. 
Uh-huh. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401377.676.2895) 
Electronically signed by Sandra Townsend (401.377.676.2895) 
afc3ca0-c86e-41,91-8d01-ba2Obcae87de 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000450 
EFTA00101415

Page 175 
1 
Q. 
Correct? 
2 
A. 
Yes. 
3 
Q. 
And subsequently there was an incident in 2003 
4 
that you've described in some detail, based on the 
5 
questions that have been asked, and you and Mr. Epstein 
6 
reached an amicable agreement; you repaid him the monies 
7 
that you had taken and you parted? 
8 
A. 
Yes. 
9 
Q. 
Is that a fair statement? 
10 
A. 
And I will have to add something to that. 
11 
When we talk at the luncheonette, we have coffee, he 
12 
says, 
if you were not my best employee that I ever 
13 
have and that you would not take care of my mother, I 
14 
would have put you away. And that's the way he come out 
15 
to me. 
16 
And I says, I like you and let's -- just pay 
17 
me back in one or two weeks, because I send the money 
18 
back and it got lost. So he give me another -- not him, 
19 
but his lawyer says, you got another month to pay. So 
20 
between I got the money -- the money order was lost in 
21 
the mail. So I send it back. I pay everything, $6,310. 
22 
I think it was 6310. And that was it. 
23 
Q. 
And I'm more interested, not so much in the 
24 
detaillIIIIIIIIIIIIllb ut the color, so to speak, the 
25 
lawyers have put on this, is, is that as a result of 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377476.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000451 
00ca-a6e4b91-8M1-baWbcaoncle 
EFTA00101416

Page 176 
1 
your separation from Mr. Epstein in late-2002 and the 
2 
incident in 2003, that somehow you have colored your 
3 
testimony to help Mr. Epstein today. 
4 
And my question to you is: Have you told us 
5 
the truth today as to every question that's been asked 
6 
and the questions that are going to be asked of you? 
7 
A. 
To every one of you. 
8 
MR. WILLITS: Object to the form of the 
9 
question. 
10 
BY MR. CRITTON: 
11 
Q. 
And with regard to the agreements that you 
12 
entered into with Mr. Epstein, in particular the 
13 
confidentiality agreement, you were asked a question by 
14 
Ms. Ezell whether you understood that you're not bound 
15 
by confidentiality today. And you responded in the 
16 
affirmative, right? You understand that you're to tell 
17 
us -- to answer every question fully to the best of your 
18 
knowledge? 
19 
A. 
Absolutely. 
20 
Q. 
And that you have done today? 
21 
A. 
Yes. 
22 
Q. 
Okay. 
23 
MR. WILLITS: Object to the form of the 
24 
question. 
25 
BY MR. CRITTON: 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377476-2895) 
Electronically signed by Sandra Townsend (401-377-676.2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000452 
3afc3ca0c866-4b91-8d01.tia2Obcae87do 
EFTA00101417

Page 177 
1 
Q. 
You told us off the record -- and I don't know 
2 
whether it was on the record, so I want to be clear 
3 
because you've been sitting here a long time. You're 
4 
currently under care and treatment for having 
5 
chemotherapy; is that correct, sir? 
6 
A. 
Yes, I have. 
7 
Q. 
And I think you told us earlier that you were 
8 
in the hospital two days last week? 
9 
A. 
Last week, yeah. 
10 
Q. 
And, so, we've -- you've done great. You've 
11 
probably done better than the lawyers today. But you'd 
12 
like to get this over today and finished? 
13 
A. 
I hope so. 
14 
Q. 
All right. There have been a lot of questions 
15 
about your job description and duties at Mr. Epstein's. 
16 
And if I understood it correctly, is basically, once you 
17 
became the full-time house manager, you were responsible 
18 
for all aspects of the operation of the El Brillo 
19 
residence? 
20 
A. 
I was. 
21 
MR. WILLITS: Object to the form of the 
22 
question. 
23 
BY MR. CRITTON: 
24 
Q. 
And during the time that you were responsible 
25 
for all aspects of the El Brillo residence, that 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-876.28951 
Electronically signed by Sandra Townpefig 
au f-&8
 Rnuested / Fed. 
afc3ca0c86e-41,9f43d01-ba20bcaeli7de 
GJ SUBPOENA RESPONSE 000453 
EFTA00101418

Page 178 
1 
included not only maintenance and repair, but 
2 
appropriate staffing, laundry, cleaning, shopping, 
3 
cooking, whatever -- whatever needed to be done at the 
4 
home? 
5 
A. 
That's correct. 
6 
MR. WILLITS: Object to the form of the 
7 
question. 
8 
BY MR. CRITTON: 
9 
Q. 
And during the time that you were there as the 
10 
full-time -- as the house manager from 1992 up until 
11 
December of 2002, you did all those different types of 
12 
responsibilities; is that a fair statement? 
13 
A. 
Yes. 
14 
MR. WILLITS: Object to the form of the 
15 
question. 
16 
BY MR. CRITTON: 
17 
Q. 
And at some point -- let me strike that. 
18 
The original deal, so to speak, that you cut 
19 
was with Mr. Epstein; that is, when you became the 
20 
full-time house manager; is that true? 
21 
A. 
That's true. 
22 
Q. 
And some point within 
what? 
a year or 
23 
so, I think Eva 
Eva 
24 
A. 
Eva. 
25 
Q. 
Anderson --
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000454 
3afc3catil-c868-4b9148d01-ba20bcae87de 
EFTA00101419

Page 179 
1 
A. 
Left. 
2 
Q. 
was no longer Mr. Epstein's -- Dr. Eva 
3 
Anderson was no longer Mr. Epstein's girlfriend, --
4 
A. 
That's correct. 
5 
Q. 
-- and a new girlfriend came in and that was 
6 
Ghislaine Maxwell? 
7 
A. 
That's correct. 
8 
Q. 
And when Ms. Maxwell came in, she, in essence, 
9 
took over as your immediate supervisor? 
10 
A. 
That's correct. 
11 
Q. 
During the time that you worked for 
12 
Mr. Epstein, did you have a good, excellent, fair, what 
13 
was -- how would you describe your relationship with 
14 
him? 
15 
A. 
Good, excellent or fair. 
16 
I will think good. 
17 
Q. 
And did you interact with him very much or 
18 
does he interact with anybody very much? 
19 
A. 
He doesn't interact very much. At the early 
20 
years, yes, he did come to the kitchen and we used to 
21 
sit down in the kitchen and he would discuss my kids, my 
22 
family, his family, and he will talk to me. 
23 
At the end of my stay there, it was -- I 
2.4 
was -- we were told not even to look at his face. Not 
25 
even to -- this was done by -- this was even done by, 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401.377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000455 
3afc3ca0-c860-4b91-8d01-ba2Obcae87de 
EFTA00101420

Page 180 
1 
they hire a Countess from Europe to write this book and 
2 
to write ideas of how the house of royalty should be. 
3 
And that's the way Ms. Maxwell wanted the house to run, 
4 
as a royal house. And I was pissed off at that and I 
5 
never agreed with that and I never went with the book. 
6 
I threw the book away. And that was it. 
7 
MR. CRITTON: Let me move as non-responsive to 
8 
my question. Move to strike. 
9 
MR. WILLITS: He should allowed to finish what 
10 
he thinks is responsive to your question, even if 
11 
you don't agree. 
12 
BY MR. CRITTON: 
13 
Q. 
Were you finished, sir? 
14 
A. 
Yes, I finish. 
15 
MR. CRITTON: See, he's finished. 
16 
MR. WILLITS: He wasn't, but okay. 
17 
BY MR. CRITTON: 
18 
Q. 
I'm trying to -- listen carefully to my 
19 
question because I'm trying to get you out of here 
20 
sooner rather than later. 
21 
If I understood your testimony is, is that, 
22 
you had -- you considered your relationship with 
23 
Mr. Epstein to be good during those years? 
24 
A. 
Good. 
25 
Q. 
And would you describe your relationship with 
(561) 632-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000456 
3afc3caSc86e-41)9(-13d01-ba2Obcael17de 
EFTA00101421