EFTA00158250

Page 41 
1 
Q. 
And then you continue on and you're in 
2 
Mr. Epstein's bedroom? 
3 
A. 
Yes. 
4 
Q. 
On each side of his bed there is a 
5 
bathroom area. One is a shower and sauna maybe? 
6 
A. 
Right. 
7 
Q. 
And that's if you're facing his bed, it's 
8 
on the right side? 
9 
A. 
Yes. 
10 
Q. 
And inside that room with the shower and 
11 
the sauna, is that where the massage table was 
12 
always laid out? 
13 
A. 
I assume. When I mention --
14 
Q. 
When you saw it. 
15 
A. 
It was in this room. 
16 
Q. 
Okay. I am not going to ask you to guess 
17 
about anything. I just want to know when you saw 
18 
it, was that where the table was? 
19 
A. 
Yes, yes. 
20 
Q. 
All right. So, when the -- let's say 
21 
III., for instance, would come over and you would 
22 
tell 
that she's here, would 
then walk 
23 
her up that stairway that comes out of the kitchen? 
24 
A. 
Yes. 
25 
Q. 
And then at that point you just went about 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d7Sagld-3eaa-42b3-ae22-b5d3c7182dle 
3507.011 
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Page 42 
1 
doing your own business? 
2 
A. 
Correct. 
3 
Q. 
And then later that afternoon or the 
4 
following day there might be 
or some other 
5 
young female that was there to also give Mr. Epstein 
6 
a massage? 
7 
A. 
Right. 
8 
Q• 
And do you remember how many different 
9 
females, young females that were there to give him a 
10 
massage -- I don't know what else to call them so 
11 
that we both understand each other -- do you 
12 
remember how many that you saw during your 
13 
employment with Mr. Epstein? 
14 
MR. GOLDBERGER: Form. 
15 
THE WITNESS: How many? 
16 
BY MR. EDWARDS: 
17 
Q. 
Yeah. I mean are we talking about 20 or 
18 
are we talking about 100, or are we talking about, 
19 
you know? 
20 
A. 
I would say from my perspective between 10 and 
21 
15 I would say differently. 
22 
Q. 
And the time period that you remember 
23 
do they still come to the house? 
24 
A. 
No. 
25 
Q. 
Since Mr. Epstein has been on house 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
3507-011 
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Page 4 -3 
1 
arrest, have you noticed any young females there to 
2 
give him a massage? 
3 
A. 
No. 
4 
MR. GOLDBERGER: Form. 
5 
BY MR. EDWARDS: 
6 
Q. 
All right. While he was in jail but on 
7 
work release, did Mr. Epstein ever go to the house? 
8 
A. 
On the work release? 
9 
Q. 
When he was on work release 
10 
A. 
Right. 
11 
Q. 
-- did he have occasion to visit the 
12 
house? 
13 
A. 
No, no. 
14 
Q. 
Okay. He 
15 
A. 
No. I think he was visiting his office. The 
16 
only thing he was visiting was his office. 
17 
Q. 
His office in West Palm Beach? 
18 
A. 
Yes, yes. 
19 
Q. 
Which is actually in this building, right? 
20 
A. 
Yes, yes. 
21 
Q. 
So, the period of time, just so that I 
22 
understand when you would see these young females 
23 
coming to the house to give him a massage, was from 
24 
February of 2005, around when you started, through 
25 
what point in time? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2W5a9W4eaa42113-m224AdU7182the 
3507-011 
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Page 44 
1 
A. 
When police raided the house and confiscated 
2 
all the stuff, and I guess that was the end of the 
3 
visiting. 
4 
Q. 
When you say --
5 
6 
7 
8 
THE COURT REPORTER: The end of the 
visiting? 
THE WITNESS: Visiting. 
BY MR. EDWARDS: 
9 
Q. 
The end of the visiting by these young 
10 
females? 
11 
A. 
Yes. 
12 
MR. GOLDBERGER: Form. 
13 
BY MR. EDWARDS: 
14 
Q. 
Okay. Well, I mean, after that point in 
15 
time he has had other visitors in the house, right? 
16 
You're just talking about no more visiting from the 
17 
young females that were there to give him a massage? 
18 
MR. GOLDBERGER: Form. 
19 
THE WITNESS: Yes. 
20 
BY MR. EDWARDS: 
21 
Q. 
Okay. So, your testimony is that these 
22 
young females providing Mr. Epstein a massage, as 
23 
you were told, occurred from the point in time when 
24 
you started working in February of 2005 through the 
25 
time that the search warrant was executed on his 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
3507.011 
Page 44 of 200 
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Page 45 
1 
house? 
2 
A. 
Correct. 
3 
Q. 
And have you known Mr. Epstein to receive 
4 
a massage since the search warrant was executed on 
5 
his house? 
6 
A. 
No, I don't remember. 
7 
Q. 
You don't remember or it hasn't happened? 
8 
A. 
I don't remember. Well, he, he didn't visit 
9 
the house, I guess, after search warrant. 
10 
Q. 
Okay. After the search warrant was 
11 
executed, where did he go, Mr. Epstein? 
12 
A. 
I think he spent time in New York. 
13 
Q. 
Okay. 
14 
A. 
I don't remember visiting him. Maybe once. 
15 
Q. 
Okay. So, then is it also your testimony 
16 
that not only was the visiting from the young 
17 
females ended at the point in time of the search 
18 
warrant, but Mr. Epstein, after the search warrant 
19 
was executed, he didn't stay at the house until he 
20 
was out of his office jail sentence and on house 
21 
arrest? 
22 
MR. GOLDBERGER: Form. 
23 
THE WITNESS: I mean after this the house 
24 
has been under renovation, so there was nothing 
25 
going on. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2W5a9W4eaa42b3-m22-bUft71WWle 
3507.011 
Page 45 of 200 
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Page 46 
1 
BY MR. EDWARDS: 
2 
Q. 
I understand there may be some other 
3 
reasons for it. I'm just trying to get a time 
4 
period when Mr. Epstein was gone from the house. 
5 
A. 
Right. 
6 
Q. 
And I'm understanding your testimony as 
7 
from the search warrant being executed to the point 
8 
in time where he is on house arrest and now living 
9 
at that house, he was not at the house for you to 
10 
observe him? 
11 
A. 
Yes. 
12 
Q. 
That's true? 
13 
A. 
True. 
14 
Q. 
Okay. So, during that period of time, 
15 
it's your belief that he was living in New York or 
16 
somewhere else? 
17 
A. 
Correct. 
18 
Q. 
Okay. And do you know the housekeeper in 
19 
New York? Or the house manager in New York, sorry? 
20 
A. 
Yes, rich Barnett. 
21 
Q. 
Rich Barnett? 
22 
A. 
Yeah, Barnett. B-a-r, Barnett. I don't know 
23 
how to spell it. 
24 
Q. 
Okay. Have you talked to him? 
25 
A. 
Yes. I met him a few times when I was there. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
NrSeild4ezta4211.1-m224AdUntadle 
3507.011 
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Page 47 
1 
Q. 
Okay. Do you know whether Mr. Epstein had 
2 
any massages when he was staying in New York in the 
3 
time period after the search warrant was executed 
4 
and before he was released on house arrest? 
5 
A. 
I don't know. 
6 
Q. 
Okay. That, is that a topic that you have 
7 
discussed with Rich Barnett? 
8 
A. 
No. 
9 
Q. 
All right. As you noticed different 
10 
underage -- sorry, strike that. As you noticed 
11 
different young females coming with frequency to 
12 
Mr. Epstein's house to provide him a massage, did 
13 
you ever question why they were coming? 
14 
A. 
No. 
15 
MR. GOLDBERGER: Form. 
16 
BY MR. EDWARDS: 
17 
Q. 
Do you know how Mr. Epstein knew or met 
18 
these young females? 
19 
A. 
No. 
20 
MR. GOLDBERGER: Form. 
21 
BY MR. EDWARDS: 
22 
Q. 
Did you tell anybody about these young 
23 
females coming to the house to provide Mr. Epstein a 
24 
massage prior to the search warrant being executed? 
25 
MR. GOLDBERGER: Form. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2e5aMd4eaa-Oh3tUflUdle 
3507-01I 
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Page 48 
1 
THE WITNESS: No. 
2 
BY MR. EDWARDS: 
3 
Q. 
Did you have any knowledge of what was 
4 
going on inside the bedroom with these young females 
5 
and Mr. Epstein? 
6 
MR. GOLDBERGER: Form. 
7 
THE WITNESS: No. 
8 
BY MR. EDWARDS: 
9 
Q. 
Did anybody in the house, 
10 
anybody else in the house back in 2005 and 
11 
before the search warrant was executed, speak about 
12 
the purpose for these young females to be at the 
13 
house? 
14 
A. 
A massage. 
15 
Q. 
That's the only thing that was ever said? 
16 
A. 
Yes. 
17 
MR. MERMELSTEIN: Brad, would you mind if 
18 
we could take a break for a few minutes? 
19 
MR. EDWARDS: That's fine. We can take a 
20 
break. 
21 
(A brief recess was held.) 
22 
BY MR. EDWARDS: 
23 
Q. 
When was the first time that you were told 
24 
that there was something more than a massage going 
25 
on inside the bedroom with Mr. Epstein? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
wmagmaimi-m3aan-bmumadia 
3507-011 
Page 48 of 200 
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EFTA _00006712 
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Page 
1 
MR. GOLDBERGER: Form. 
2 
THE WITNESS: Nobody told me nothing about 
3 
this. 
4 
BY MR. EDWARDS: 
5 
Q. 
Well, at some point in time the police 
6 
talked to you, didn't they? 
7 
A. 
No, they didn't talk to me. They just shoo 
8 
up. 
9 
Q. 
Oh, really? 
10 
A. 
Yeah. And they read me a piece of paper that 
11 
they have a search warrant issue by the judge and this 
12 
was the only moment I, I learn what was going on and --
13 
Q. 
That's what I am saying. I'm not 
14 
saying -- I asked a bad question or there was some 
15 
miscommunication. I don't mean did somebody -- did 
16 
Mr. Epstein or 
or one of them tell you what 
17 
was going inside the bedroom. I'm not asking that. 
18 
You already told me that the only thing that they 
19 
ever told you was that it was a massage. 
20 
A. 
Right. 
21 
Q. 
Okay. I am saying when is the first time 
22 
that anybody including the police, U.S. Attorney's 
23 
office, FBI, whoever you talked to, when was the 
24 
first time that anybody else told you that there was 
25 
something more than a massage going on inside 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2C5a9W4eaa42b3-m22-bMWIWWle 
3507.011 
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Page 5C 
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Mr. Epstein's bedroom with these young females that 
2 
were there to, as you learned or were told, to give 
3 
him a massage? When was the first time? 
4 
MR. GOLDBERGER: Form, form. 
5 
THE WITNESS: The moment they were in the 
6 
house that they show up that it was the purpose 
7 
8 
9 
10 
BY 
11 
12 
13 
14 
15 
executed a search warrant and as we entered onto the 
16 
property, we encountered the house manager, Janusz, 
17 
who was in the guest portion of the house? 
18 
A. 
Right. 
19 
Q. 
And you remember that 
20 
A. 
Yes. 
21 
Q. 
-- when they executed the search warrant. 
22 
And what do you recall exactly happening when they 
23 
were executing the search warrant? Who approached 
24 
you? What did they show you? 
25 
A. 
I was at that time at my desk doing my 
of the search warrant. So, this is when I 
learn. Before that I didn't know anything 
about what was going on beside the massage. 
MR. EDWARDS: 
Q. 
All right. It looks like by the police 
report, and this is an 87 page police, Palm Beach 
Police Department Incident Report, says on 
October 20th, 2005, at 9:36, the Investigations Unit 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
zersagie-seaa-42b3-ae22-bsdaenutte 
3507-011 
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Page Si 
1 
paperwork. And I saw through the window a couple 
2 
uniform -- I would say not uniform but with the badges 
3 
on their chest, guys. And they entered my office and 
4 
they introduced themselves and they told me that they 
5 
have a search warrant for the property. 
6 
So, they ask me to step outside and they 
7 
put me in the front of the wall and videotape 
8 
reading search warrant for me. 
9 
Q. 
They read the search warrant to you? 
10 
A. 
Right. 
11 
Q. 
And when they first arrived to the 
12 
house -- obviously when police all arrive at the 
13 
house, it tells you that they have reason to believe 
14 
that something illegal had happened there? 
15 
A. 
Correct. 
16 
MR. GOLDBERGER: Form, form. 
17 
BY MR. EDWARDS: 
18 
Q. 
I mean, that's, from your observations and 
19 
your knowledge you knew that the police believed 
20 
something illegal had happened in the house? 
21 
MR. GOLDBERGER: Form. 
22 
THE WITNESS: Right. 
23 
BY MR. EDWARDS: 
24 
Q. 
And at that moment when you see these 
25 
police at the house executing a search warrant, did 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
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1 
2 
3 
4 
you know exactly what it was that they were there 
for? 
A. 
No. 
Q. 
So, in your mind it could have been 
5 
somebody killed somebody or there were drugs or 
6 
anything; you had no idea? 
7 
MR. GOLDBERGER: Form. 
8 
THE WITNESS: Right. 
9 
BY MR. EDWARDS: 
10 
Q. 
But you had observed over a period of time 
11 
with great frequency these young females coming to 
12 
Mr. Epstein's house, right? 
13 
A. 
Right. 
14 
MR. GOLDBERGER: Form. 
15 
BY MR. EDWARDS: 
16 
Q. 
And did something go off in your mind that. 
17 
something about that must be why the police are 
18 
here? 
19 
MR. GOLDBERGER: Form. 
20 
THE WITNESS: No. 
21 
BY MR. EDWARDS: 
22 
Q. 
Okay. Well, that's -- you would agree? 
23 
A. 
I am sorry. I was shocked when I saw them. 
24 
Q. 
Okay. You were shocked. Well, weren't 
25 
you told prior to the search warrant being executed 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
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1 
that police at some point in time would be coming to 
2 
the house? 
3 
A. 
No. 
4 
Q. 
You weren't? 
5 
A. 
No. 
6 
Q. 
All right. Do you remember there being 
7 
computers, a lot of computers in the house prior, 
8 
sometime prior to the search warrant being executed? 
9 
A. 
Yes, yes. 
10 
Q. 
And at the time the search warrant was 
11 
executed those computers had already been removed 
12 
from the house, right? 
13 
A. 
Right. 
14 
Q. 
It was -- they were removed from the house 
15 
within a month of the search warrant being executed, 
16 
do you remember that? 
17 
MR. GOLDBERGER: Form. 
18 
THE WITNESS: I don't remember exactly how 
19 
long before, but yes. 
20 
BY MR. EDWARDS: 
21 
Q. 
Do you know why they were removed from the 
22 
house? 
23 
A. 
No. 
24 
Q. 
Were you told why computers were being 
25 
taken out of the house when they were taken? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d75891d-Usa-42b3-ae22-bSd30182dle 
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Page 54 
1 
A. 
(Witness shakes head.) 
2 
Q. 
And I'm sorry. 
3 
A. 
No. 
4 
Q. 
I understood you when you shook your head. 
5 
A. 
I realize what you told me but I am sorry. 
6 
Q. 
I told you it was easy to forget. 
7 
Do you remember who it was that personally 
8 
removed the computers and equipment from the 
9 
property? Was it Mr. Epstein, was it a lawyer, was 
10 
it, do you remember? 
11 
A. 
It was 
12 
Q. 
All right. And I am of the understanding 
13 
that there were several computers that were removed 
14 
from the house, correct? 
15 
MR. GOLDBERGER: Form. 
16 
THE WITNESS: Yes, three of them. 
17 
BY MR. EDWARDS: 
18 
Q. 
Three? And to your knowledge 
19 
removed all of them? 
20 
A. 
She show up one day with gentleman. I don't 
21 
remember his name. And she told me that they are moving 
22 
out those computers. 
23 
Q. 
And where were the computers? Which rooms 
24 
were the computers in that were removed by 
25 
and this gentleman you're describing? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d75891d-Uaa-42b3-ae22-0.5d3c7182dle 
3507-011 
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Page 55 
1 
A. 
One was in cabana. One, the other second one 
2 
was in living room and one was in small office next to 
3 
the kitchen. 
4 
Q. 
All right. In your time at the house 
5 
prior to that, is it fair to say those computers had 
6 
never been removed before? 
7 
A. 
I remember that there was to bring some new 
8 
ones to replace them at some point. I don't know 
9 
remember exactly if it was for upgrading, but they 
10 
change computers very often I would say. 
11 
Q. 
All right. But the computers -- the 
12 
removal by 
and this individual, that wasn't 
13 
done -- we're talking about a different -- that's 
14 
not a time where they were replacing computers. 
15 
This was just removing computers from the house? 
16 
A. 
Yes. 
17 
Q. 
And did you receive any explanation as to 
18 
why the computers were being removed from the house? 
19 
A. 
No. 
20 
Q. 
Did you ever have occasion to use any of 
21 
the three computers that were removed from the 
22 
house? 
23 
A. 
No. I never, I never, you know, touch them, 
24 
never use them. I have my own computer in my office, so 
25 
I use this computer. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
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Page 56 
1 
Q. 
Is your computer in your office 
2 
A. 
Yes. 
3 
Q. 
Let me finish. Is the computer in your 
4 
office linked up with the three computers that were 
5 
removed from the house? Meaning, can you look at 
6 
the system and see what is on those three computers? 
7 
A. 
No, no. 
8 
Q. 
Is it your understanding that those three 
9 
computers are linked with one another or do you 
10 
know? 
11 
A. 
I don't know, but I, I doubt it. They are 
12 
separate I guess. 
13 
Q. 
Okay. Were you aware that Mr. Epstein 
14 
used a Citrix program to link various computers? 
15 
Did you know that? 
16 
A. 
Yeah. I use Citrix too in my computer fox 
17 
exchanging e-mails and get through Internet. 
18 
Q. 
Okay. So, is it your understanding that 
19 
the only connection then through Citrix with these 
20 
computers, these various computers that were in 
21 
Mr. Epstein's home, was for e-mail purposes? 
22 
A. 
Yes. 
23 
Q. 
Okay. To your knowledge, you're not 
24 
familiar with those computers sharing other files or 
25 
information? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75a9td4eaa42b3-m22-b5dUTIOIMU 
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Page 57 
1 
2 
3 
4 
5 
6 
A. 
No. 
Q• 
That's not something that you were, you 
were privy to? You weren't, you weren't in the loop 
of the sharing of information in the house in terms 
of the computers being connected through any server? 
A. 
I don't really know what, how, how to answer 
7 
your question because Citrix is for the whole 
8 
organization to exchange e-mail between employees. 
9 
Q. 
All right. You used the term? 
10 
A. 
So, even my computer is connected to Citrix. 
11 
I can receive mail and I can e-mail information to 
12 
employee within organization. But I don't know if you 
13 
can see to each computer what is going on on another 
14 
computer. 
15 
Q. 
You don't know about --
16 
A. 
Is that your question? 
17 
Q. 
You don't know about shared files? 
18 
A. 
No. 
19 
Q. 
You only know that the one computer can 
20 
e-mail the other? 
21 
A. 
Right. 
22 
Q. 
But that can happen with any two computers 
23 
in the world pretty much. You can send e-mails to 
24 
each other, right. 
25 
A. 
Yes. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthla hopkins (601.051-976.2934) 
Electronically signed by cynthla hopkins (601.051-976.2934) 
Electronically signed by cynthla hopkins (601.051-976.2934) 
(561) 832-7506 
2W5a9W4eaa42113-m224,MUTISIMIe 
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Page SE 
1 
Q. 
You have used the term organization, you 
2 
can share within the organization. What do you --
3 
just so I can understand what you're calling the 
4 
organization, what do you mean by that word? 
5 
A. 
People employed by Jeffrey Epstein. There are 
6 
a few groups of people, his office in New York and I 
7 
guess 
8 
Q. 
Who are those people by name that you 
9 
would consider within the Jeffrey Epstein 
10 
organization? 
11 
A. 
His accountant, his --
12 
Q. 
Who is that? 
13 
A. 
Bella Klen. 
14 
Q. 
What is it? 
15 
A. 
Bella Klen. K-l-i-n. E-n, I'm sorry. 
16 
Q. 
Bella, B-e-1-1-a? 
17 
A. 
Yes. 
18 
Q. 
Is that somebody in New York? 
19 
A. 
Yes. 
20 
Q. 
Is that a male or female? 
21 
A. 
Female. 
22 
Q. 
And you understand that's his accountant? 
23 
A. 
Right. 
24 
MR. GOLDBERGER: Just to get the spelling 
25 
correct is it K-l-e-i-n? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d7M9ftlaw4211.1-m224WWIWWle 
3507.011 
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Page 59 
1 
THE WITNESS: K-1-e-n. 
2 
MR. MERMELSTEIN: K-1-e-n. 
3 
BY MR. EDWARDS: 
4 
Q. 
And in addition to Bella Klen, who else 
5 
would you have considered to be in Jeffrey Epstein's 
6 
organization? 
7 
A. 
8 
Q. 
9 
A. 
10 
Q. 
11 
A. 
12 
Q. 
13 
A. 
14 
Q. 
15 
A. 
16 
Q. 
17 
A. 
18 
Q. 
19 
A. 
Yes 
20 
Q. 
What do you understand her role to be? 
21 
A. 
Secretary I would say. 
22 
Q. 
Did she also schedule appointments for 
23 
these young females to come to Jeffrey Epstein's 
24 
house? 
25 
MR. GOLDBERGER: Form. 
Rich Kahn. Richard Kahn. 
And how do you spell the last name? 
K-a-h-n. 
And where is he located? 
New York office. 
What does he do? 
I guess he was involved with the accounting. 
And who else? 
Leslie. I would think I would say secretary. 
Leslie Groff? 
Yes. 
And is she also in the New York office? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
Ninagld-Uaa42b3-m224,MUTIMMU 
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Page 60 
1 
THE WITNESS: I don't know. 
2 
BY MR. EDWARDS: 
3 
Q. 
We'll go back to that but I tell you why I 
4 
ask. If you don't know then you don't know, but in 
5 
the course of Mr. Epstein's -- you're aware that he 
6 
did plead guilty to a couple felonies in state 
7 
court, right? 
8 
A. 
Right. 
9 
Q. 
Well, in the course of the negotiation 
10 
with the federal government and the U.S. Attorney's 
11 
Office, they, the agreement between Mr. Epstein and 
12 
the U.S. Attorney's office mentions people that are 
13 
called co-conspirators of Epstein. And Leslie Groff 
14 
is named as one of those co-conspirators. 
15 
Do you know what involvement, if any, that 
16 
she had with the crimes that were being 
17 
investigated? 
18 
A. 
No. 
19 
Q. 
Okay. 
20 
A. 
I am not aware of this. 
21 
Q. 
Okay. The other people mentioned as 
22 
co-conspirators are 
, and 
23 
So we'll get to them in a minute 
24 
but first just so we stay on the track of who was in 
25 
the organization, is 
and 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
3507.011 
Pagc 60 of 200 
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