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IN THE CIRCUIT COURT OF THE 
SEVENTEENTH JUDICIAL CIRCUIT 
IN AND FOR BROWARD COUNTY, 
FLORIDA 
CASE NO.: CACE 15-000072 
EDWARDS, a aL, 
Plaintiffs I Counterclaim Defendants, 
v. 
DERSHOWITZ, 
Defendant / Counterclaim Plaintiff. 
AFFIDAVIT O 
REGARDING KNOWLEDGE OF ALAN M. DERSHOWITZ 
A. Introduction 
1. My name is 
I make this declaration voluntarily and without 
compensation on personal knowledge concerning Alan Dershowitz and his visits at 
my former employer Jeffrey Epstein's home in Palm Beach, Florida. 
2. I worked for Mr. Epstein from January 1991 to December 2002 as a full-time 
employee performing maintenance services and then also became the manager for the 
home on 358 El Brillo Way in Palm Beach, Florida. 
3. Since Mr. Epstein was investigated and arrested, I have spoken with police, 
investigators, and attorneys concerning my time working for Mr. Epstein. 
4. On September 8, 2009, I gave a deposition in the case captioned Jane Doe No. 2 v. 
Jeffrey Epstein, Case No. 08-CV-80119 in which I truthfully answered the questions 
posed by the attorneys. I also gave a sworn statement on November 21, 2005 to 
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Detectivaaf 
the Palm Beach P.D. during their investigation of Mr. 
Epstein. 
5. I have reviewed the statements that Bradley Edwards and Paul Cassell attribute to me 
in their papers in the cases against the Government and against Mr. Dershowitz. 
Because I do not believe they accurately reflect the statements 1 previously made, I 
submit this affidavit to have my statements accurately reflected and made clear on the 
record. 
B. Summary of My Knowledge of Massages at Mr. Epstein's Palm Beach Home 
6. As I stated in my deposition, a massage was like a treat for all the guests at Mr. 
Epstein's home. Mr. Epstein usually received his massages in his private suite, but 
guests would also be given massages in their respective rooms or by the pool area. 
7. There were between fifty (50) to one hundred (100) masseuses — mostly women but 
also some men - who would come to give massages during this time. I provided 
names of masseuses in my deposition. 
8. As I stated in my deposition, I was unaware of any masseuses being under the age of 
18. I believed that the females' age ranged from overage to maybe mid-forties. As I 
stated in my deposition, I received as a gift a massage from a male masseuse at Mr. 
Epstein's home in Palm Beach. 
9. In my deposition, I was asked about cleaning up after massages. I stated that when I 
cleaned Mr. Epstein's bedroom suite, which included the bathroom of Ms. Maxwell, 
after massages, I would, on occasion, find vibrators and sex toys. I have specific 
recollection of finding these items in the sink of Ms. Maxwell's bathroom. I did not 
state or imply that vibrators or sex toys were found after massages in other rooms 
used by guests because that was not the case. Guests having massages did not have 
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massages in Mr. Epstein's private bedroom suite. This area was private and off-limits 
to guests, which I explained to the lawyers during my deposition. As I said in my 
deposition, massage tables were located in almost every room, including guest rooms 
and by the pool. I never found, and never heard anyone in the house finding, a 
vibrator or a sex toy in the same room where any guest, including Alan Dershowitz, 
had a massage. 
10. The following statement made la
attorneys in a filing on January 
21, 2015 is not accurate and is a misrepresentation of what I said in my deposition: 
"The private, upstairs room where Dershowitz got his 'massages' was one that 
contained a lot of vibrators — Maxwell had 'a laundry basket . . . full of those toys' in 
that room." 
C. Summary of My Interaction with Alan M. Dershowitz 
11. During the approximate thirteen years I worked for Mr. Epstein, I believe I saw Mr. 
Dershowitz visit Mr. Epstein's Palm Beach home approximately four or five times a 
year. I recall driving him to the airport on multiple occasions. 
12. At the time, I understood that Mr. Dershowitz was a famous lawyer. His visits to the 
house would typically involve a group of intellectuals or business men in social, but 
professional type gatherings. 
13. I can recall that Mr. Dershowitz had a massage on at least one occasion during a visit 
to Mr. Epstein's home in Palm Beach (although I cannot recall that Mr. Dershowitz 
received a massage on more than one occasion). I do not recall Mr. Dershowitz being 
massaged by anyone who I thought was less than 18 years old. I have no reason to 
doubt Mr. Dershowitz's statement that this massage was done by a woman named 
who was in her forties. In fact, I do remember a masseuse namedMhat 
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lived in Palm Beach, though I do not know her last name. As I have said, I never saw 
Mr. Dershowitz around young girls. I have also explained that there were masseuses, 
both male and female, that were in their mid-forties. 
14. I never saw Mr. Dershowitz do anything improper or be present while anyone else 
was being improper. 
15. Before asking me about Jeffrey Epstein speaking to celebrities at the house, the 
attorney for "Jane Doe 102" asked me about Jean Luc Brunel, Mark Epstein, Daniel 
Estes, Matt Groening, and Leslie Wexner. I then listed Senator Mitchell, Prince 
Andrew, Princess Sarah Ferguson, Miss Yugoslavia, Miss Germany, Alan 
Dershowitz, Princess Diana's secretary with her children, Mr. Trump, Mr. Robert 
Kennedy, Jr., Frederik Fekkai, and a couple Noble prize winners as celebrities that I 
had seen while working for Mr. Epstein. I also mentioned a reunion of Nobel prize 
winners that was held at the house, and that I met President Clinton at Mr. Epstein's 
plane the last month that I was working for Mr. Epstein. 
C. Summary of My Interaction with 
16. The first time I saw 
vas at Mar-a-Lago where I believed she 
worked in the spa. I only recall seeinfl
ome to Mr. Epstein's house 
during the last year that I worked for Mr. Epstein. During this time, I believe she 
visited Mr. Epstein's home in Palm Beach two or three times a week. 
17. I never saw any photographs of 
in Mr. Epstein's house. I was 
shown a photo of
luring my deposition, and I recognized the woman 
in the photo 
18. As I stated in my deposition, 1 am not sure whether 
house when Prince Andrew was there. 
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19. I was never asked by any attorneys it 
came to the house when Mr. 
Dershowitz was there. If I had been asked, I would have answered that I never saw 
i
ltt the house when Mr. Dershowitz was there. 
20. The following statement made b 
attorneys and their own attorney 
in a filing on December 4, 2015 is not accurate and is a misrepresentation of what I 
said in my deposition: es 
able to identify a photograph ofM 
as 
someone who was at the mansion as the same time as Dershowitz." 
21. As far as I can recall, since I gave my deposition in 2009, [have never been asked by 
Brad Edwards or Paul Cassell about my knowledge regarding 
or 
Alan Dershowitz or about my 2009 deposition testimony. 
I understand that I am swearing or affirming under oath to the truthfulness of the 
claims made in this affidavit and that the punishment for knowingly making a false 
statement includes fines and/or imprisonment. 
Dated: January 13, 2016 
STATE OF  
EC-40 et—% 0A-
COUNTY OF  
taln—ki  
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Sworn 
by 
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Ass eiris•Co• 
TARY PUBLIC or DEPUTY CLERK 
/- rr 
A- S . C-A 
c-L-c-r7 
[Print, type, or stamp commissioned name of 
notary or clerk.] 
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