EFTA00188608

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EFTA00188908

Case 9:08-cv-80736-KAN, Document 291-17 Entered on FLS Docket 01/21/2015 Page 1 of 8 
EXHIBIT 18 
EFTA00188909

Case 9:08-cv-80736-KA1.. Document 291-17 Entered on PLS. Docket 01/21/2015 Page 2 of 8 
Page 1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE Ne.08•CV-130 I 19-CI V-MARRALJOHNSON 
JANE DOE NO. 2, 
Plaintiffs
JEFFREY EPSTEIN, 
Defendant. 
Relined eases 
08.80232, 08-80380,98-8038I. 08-80994. 
08-80993, 08410811,08-80893. 09-80469, 
09.80591. 09.80656,09-80802, 09-81092 
VIDEOTAPED DEPOSITION OF JUAN ALESSI 
VOLUME I 
Tuesday. September 8, 2009 
10:12 am.- 3:45 p.m. 
2139 Palm Beach Lakes Boulevard 
Wen Palm Beech, Florida 33401 
Reported By. 
Sandra W. Townsend. FPR 
Notary Public, State of Florida 
PROSE COURT REPORTING AGENCY 
West Palm Beach Office 
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On behalf of the Defendant: 
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ROBERT J. CRITTON, ESQUIRE 
RMAN. RITTON & LUTTIER 
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APPEARANCES: 
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On behalf of the Plaintiffs: 
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RICHARD WILLITS. ESQUIRE 
WILLITS. P.A. 
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STUART MERMELS1EIN. ESQUIRE 
WILLIAM J. BER 
ROTHSTEIN ROSENFELDT ADLER 
KATHERINE W. F2ELL, ESQUIRE 
PODHURSTORSECK. P.A. 
Is 
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ADAM I. LANCING. ESQUIRE 
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EXHIBITS 
NUMBER 
DESCRIPTION 
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Exhibit number I 
Photographs 
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Exhibit number 2 
Transcript 
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Exhibit number 3 
Incident Report 
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Exhibit number 4 
Incorporation Papers 
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Exhibit number 5 
Incorporation Papers 
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1 (Pages 1 to 4) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401.377.676-2895) 
EleCtron Ically signed by Sandra Townsend (401-377.876.2895) 
760564a-4a1c-4dee-87ac-479898cc7004 
EFTA00188910

Case 9:08-cv-80736-KAi',. Document 291-17 Entered on Fu Docket 01/21/2015 Page 3 of 8 
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PROCEEDINGS 
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- - - 
Deposition taken before Sandra W. Townsend, Court 
Reporter and Notary Public in and for the State of 
Florida at Large. in the above cause. 
VIDEOGRAPFIER: Today is September 8, 2009. 
The time is 12 minutes after 10:00 in the morning. 
This is the videotaped deposition of Juan 
Alessi in the matter of Jane Doe number two versus 
Jeffrey Epstein. This deposition is being held at 
2139 Palm Beach Lakes Boulevard in West Palm Beach 
Florida. 
My name is Stan Sanders. I'm the vidcographer 
representing Visual Evidence, Incorporated. 
Would the attorneys please announce their 
appearances for the record. 
MR. WILLITS: Richard Willits, representing 
MR. BERGER: William J. Berger, representing 
M., M. and Jane Doc number two. 
MR. MERMELSTEIN: Stuart Mennetstein of 
Mermelstein and Horowitz. representing Jane Does 
numbers two through eight. 
MR. LANGINO: Adam Langino, on behalf of 
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Q. All right, sir. Did you ever work for Jeffrey 
Epstein? 
A. Yes, I did. 
Q. In what capacity? 
A. Everything. I started with Jeffrey Epstein 
around 19 -- please bear with the dates because I 
trying --
Q. Sure. 
A. -- to remember. 1969 as a pan-time 
maintenance guy. 
And then 1 become a full-time employee, I 
think it was January 1, 2 -- '91, '92, so '92. Sorry. 
Q. You said you started in 1969? That would 
be --
A. No. No. No. No. No. 
Q. Okay. 
A. '99. 
Q. 1999? 
A. Yeah. 
Q. All right. And how did you happen to get that 
job? Was it through an employment agency --
A. No. 
Q. -- or an ad in the paper? 
A. I had a company at that time used to take care 
Page 6 
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MS. EZELL: Katherine Ezell from Podhurst 
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Orseck, on behalf of Jane Does 101 and 102. 
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MR. CRITTON: Bob Griffon, on behalf of 
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Jeffrey Epstein. 
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THEREUPON, 
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JUAN ALESSI, 
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having been first duly sworn or affirmed, was examined 
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and testified as follows: 
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TIIE WITNESS: I do. 
DIRECT EXAMINATION 
BY MR. WILLITS: 
Q. Good morning, sir. 
A. Good morning. 
Q. I introduced myself through the vidcographer. 
My name is Richard Willits. 
A. Okay. 
. I re resent a young lady by the name of 
A. Okay. 
Q. Is that name familiar to you at all? 
A. Whose name? 
Q. 
Do you recognize that name 
A. No. 
Q. What is your residence address, sir? 
A. My address is 
Page 8 
1 
of a lot of residents in Palm Beach. And I got to know 
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Jeffrey through Lesley Wexner. And I used to work in 
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about 20 different, 20.25 different homes in Palm Beach 
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as a maintenance guy. 
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Q. Okay. 
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A. And I have basically my own company and I do 
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repairs for them. I did home sit in for them. 
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Q. And what was -- did you work for Jeffrey 
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Epstein? What was your position when you started? 
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A. When I started, he hire me to -- he just 
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bought the house. 
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Q. I'm sorry? 
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A. He just had bought the house --
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Q. Okay. 
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A. -- where he live on El Brillo. And he hire me 
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through Mr. Wexner's references to do repair works. And 
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basically what I did the most was taking walls apart, 
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windows and stuff that he didn't want to have it, --
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Q. 1 see. 
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A. -- fix it. 
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Q. And when you started working for Mr. Epstein, 
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were you still working for other people in Palm Beach? 
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A. Yes, I did. 
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Q. Okay. And about how long a period of time did 
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you do this type of work for Mr. Epstein, the 
2 (Pages 5 to 8) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401-377-878-2896) 
Electronically signed by Sandra Townsend (401.377.676.2896) 
784afin4a-talcaldee-flec-479898“7004 
EFTA00188911

Case 9:08-cv-80736-Ktuv. Document 291-17 Entered on FLS 
Jacket 01/21/2015 Page 4 of 8 
Page 9 
maintenance and taking out walls? 
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A. It was couple months. It was couple months 
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before. 
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Q. And what was the name of your company? 
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A. Alessi Maintenance. 
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Q. And how were you paid? 
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A. By him? 
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Q. Ycs. 
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A. Usually by check or cash sometimes. 
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Q. Do you know what company actually paid your 
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company? 
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A. It was Jeffrey Epstein and Company. 
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Q. So you said you had that position for a couple 
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of months. 
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What happened next? 
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A. Then Mr. Epstein asked me to, if I wanted to 
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be his employee, because I was going from one house tc 
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another house to another house, one hour here. I was 
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just running around Palm Beach all day. 
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So he asked me if I would just work for him, 
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exclusively for him. 
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Q. Okay. 
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A. And we agreed with the terms and I become a 
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full-time employee as a maintenance guy. And I was 
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taking care of everything, as far as maintenance. 
Page 11 
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about seven months before -- after I become a full-time 
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employee. 
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Q. Okay. And how did Ms. Maxwell come into the 
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picture? 
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A. It was his girlfriend, his main girlfriend. 
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Q. Okay. Had you known her before she became --
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A. No. 
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Q. -- your --
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A. Never know her before. 
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Q. I'm sorry. I didn't get a chance to finish my 
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question. 
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Would you have referred to her as your 
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supervisor or your superior or what would you have 
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called Mrs. Maxwell? 
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A. I used to call her Ghislaine. 
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Q. Okay. And how was it explained to you that 
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you were now to deal with Ms. Maxwell, as opposed to 
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Jeffrey Epstein? 
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A. She would tell me, I am going to take care of 
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the house. 
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Q. Okay. That was explained to you by 
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Ms. Maxwell? 
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A. Uh-huh. 
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Q. Is that a yes? 
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A. Yes. 
Page 10 
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Then my job changed little by little to house 
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man, estate manager, and then to a majordomo. 
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Q. Okay. When you first agreed to terms with 
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Mr. Epstein and you first started working for him full 
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time, what were those terms, do you remember? 
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A. The terms is basically was how much -- he 
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asked me how much I was making in all the properties. 
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And I says, well, I make this -- this amount 
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of money. 
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And he says, fine. 
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Q. And how much was that, did he pay you? 
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A. Around $45,000. I think I started with 45. 
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Q. Okay. And when you started to work for him as 
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a full-time employee, did you have anybody that you 
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reported to or did you deal directly with Mr. Epstein? 
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A. At the beginning with Mr. Epstein, directly to 
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him. 
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Q. Did that change? 
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A. Later on, yes. 
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Q. And how did that change? 
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A. When Ms. Maxwell, Ghislaine Maxwell came to 
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the picture. 
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Q. Okay. About when was it that she came into 
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the picture? 
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A. Exactly date, I cannot remember. But it was 
Page 12 
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Q. And when Ms. Maxwell started assuming 
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responsibility for the house, did your duties change at 
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that time? 
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A. Not much. 
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Q. Okay. 
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A. Not much. 
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Q. And at that time when Ms. Maxwell started 
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taking responsibility for the house, what were your 
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duties? 
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A. Basically I was still doing the maintenance 
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work. 
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Q. Okay. 
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A. Was doing -- they were trying to remodel the 
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home and they would told mc. okay. tear down this wall. 
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We want to see how it's going to look. Or put this 
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windows and tear down -- we had a fishing tank. We took 
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it out -- I took it out. A kitchen on the second floor. 
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I took it out. So it was basically dismantling the 
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house. 
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Q. Okay. And about how long a period of time did 
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that project last? 
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A. I would says, six to seven months. 
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Q. Okay. And after the remodeling slacked off or 
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stopped, did your duties then change? 
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A. Yeah. Increasingly they change. 
3 (Pages 9 to 12) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401.377.676.2895) 
Electronically signed by Sandra Townsend (401.377.676.2896) 
76ef6648-4a1c-kle447ac-479898cc7004 
EFTA00188912

Case 9:08-cv-80736-KAiv, Document 291-17 Entered on FLt. Docket 01/21/2015 Page 5 of 8 
Page 45 
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MS. EZELL: I'm going to ask -- I don't know 
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whether you've still been serially designating 
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Exhibits or whether we're doing them separately for 
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deposition. 
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MR. CRITTON: I think we cannot trust that 
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people will do them serially. I'd do them with 
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each one. 
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MS. EZELL: Then would you mark this, please, 
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as Exhibit I to this deposition. 
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And I'm just going to state on the record that 
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I will keep that original. We will not attach it 
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to the deposition. 
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(Exhibit number I was marked for 
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identification purposes and retained by Counsel for the 
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Plaintiffs.) 
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TI IE WITNESS: Yes, that's --
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BY MS. EZELL: 
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Q. Can you identify that -- the young woman in 
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those pictures? 
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A. Yes. 
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Q. Who is it? 
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A. That's'. -- I. Now that you says R., that 
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is M. definite, a hundred percent. 
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MR. CRITTON: Let me just note my objection, 
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as I did in A. Rod's deposition or Mr. Rodriguez's 
Page 47 
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ages --
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A. No. 
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Q. -- of the young women that came there? 
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A. Absolutely not. Absolutely not. 
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Q. And, so, you never really focused on that or 
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particularly thought about it if they seemed young? 
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MR. CRITTON: Form. 
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THE WITNESS: I don't -- I didn't see that 
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many young girls, you know, young, underage girls 
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at the house. I never saw except the two girls 
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that I mentioned that I think it was underage was 
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N. for sure because she was still in high school. 
THE WITNESS: Could have been. But, you know 
I am not -- I don't think 1 am a very good judge of 
ages. If you ask me how old you arc. I really 
couldn't tell you. 
MR. CRITTON: Kathy thinks she's 25. 
MS. EZELL: In my dreams. 
TIIE WITNESS: Now, again. I must tell you, I 
was never told to check any i.d.s on any of the 
people who work at the house. 
BY MS. EZELL: 
Q. I understand that. And. so. I think I'm just 
trying to establish that you didn't consider it part of 
your job description to worry about or consider the 
Page 46 
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deposition, that I know you're going to confiscate 
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Exhibit number I. I think it's inappropriate. I 
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think I should be allowed to have a copy of 
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Exhibits that arc being used in deposition. But 
S 
I'll file a motion with the Court so we don't get 
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into a pulling match over your Exhibits. 
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MR. BERGER: I would ask that the court 
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reporter initial that. 
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MS. EZELL: Sure. 
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Oh, you did? 
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MR. WILLITS: She marked it. 
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MR. BERGER: Did she put her initials or did 
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she just put a number or a letter? 
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MR. CRITTON: She's nodding that she did 
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everything that she usually does, which means, 
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initials, date and number. 
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MR. MERMELSTEIN: You can talk. 
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MR. WII.LITS: But when you talk, use your 
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initials. 
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BY MS. EZELL: 
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Q. How old did you think M. was at the time she 
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began coming to Mr. Epstein's home? 
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A. She could have been 17, 18, 19. 
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Q. Could she have also been 15? 
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MR. CRITTON: Form. 
Page 48 
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And she -- she had dinner with her mother, a couple 
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times with her mother. And she become an actress. 
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She's an actress and she has done movies. And he 
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help her in her career. 
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That's the only girl that I knew she was young 
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because she was going to high school and I pick her 
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up from high school sometimes. But she was not a 
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massage therapist. She will go for dinner. And 
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they will go for the movies and she sang sometimes 
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because she was a singer. So she sung at the 
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house. Beautiful girl. Very talented. 
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That's the only girl that I know that it 
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was -- I would says, underage. 
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BY MS. EZELL: 
15 
Q. Okay. Did -- who told you that 
was a 
16 
massage therapist? 
17 
A. Nobody. 
18 
Q. Did you assume that she was a massage 
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therapist because you were told she was coming to give t 
20 
massage? 
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A. No. I assumed she was a massage therapy 
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because I was -- I drove Ms. Maxwell to Mar-a-lago. 
23 
Donald Trump's residence. And I wait in the car while 
24 
Ms. Maxwell got a -- I think it was a facial or massage. 
25 
I don't know. But that day I remember this girl,,., 
12 (Pages 45 to 48) 
PROSE COURT 
Electronically signed by Sandra Townsend (401.377.676-2895) 
Electronically signed by Sandra Townsend (401-377.676.2895) 
REPORTING AGENCY, INC. 
76e1564a4a1c-4dee-B7ac-479898cc7004 
EFTA00188913

Case 9:08-cv-80736-KAlvi Document 291-17 Entered on FLS,. Docket 01/21/2015 Page 6 of 8 
Page 69 
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MR. CRITTON: Fonn. 
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THE WITNESS: No, not that I can remember. 
3 
BY MS. EZELL: 
4 
Q. Do you know if he and Mr. Epstein were 
5 
involved in any businesses together? 
6 
A. Mr. Epstein, I never knew what businesses he 
7 
was involved. He will -- I was completely shut off of 
8 
all of the business, except for the office, transfer of 
9 
communications or faxes. But I have no idea of the 
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relationship with other business partners. 
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Q. Did you ever have to deal with his -- the 
12 
office in New York with someone named Lesley in New 
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York? 
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A. The secretary? 
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Q. Yes. 
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A. Yeah. I would call -- I would call Lesley 
17 
almost every day or other secretaries, they live in New 
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York. Basically it came a point when Mr. Epstein will 
19 
call New York and New York call me to do things for 
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Mr. Epstein. But he was on the phone or busy or 
21 
something and he would call the office and the office 
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will send me an c-mail or call me or -- it was a 
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constant report with the office in New York. 
24 
Q. And did you in turn sometimes call New York to 
25 
get a message to Mr. Epstein? 
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Page 71 
Diane's secretary, she stay there for a week with her 
kids and we took care of her. 
Who else? Mr. Trump. That's a celebrity. 
Mr. Robert Kennedy, Junior. Mr. Frederick Fekkai. 
Q. Who is that? 
A. Fekkai, Frederick Fckkai, the famous 
hairstylist. Who else? I don't think I can remember 
anymore. 
Q. David Copperfield, the magician? 
A. No, I never saw him. 
Q. You never saw him. 
Now, would these -- the people that you named 
were all people that you saw visiting in the home? 
A. Yes. Also was a Noble Prize winners, the -- I 
can't remember his name. It was an old gentleman. He 
was a Noble Prize, chemistry, I think, or mathematics. 
There was a couple -- a couple of those, very -- also, 
we had at one time at the house, it was a reunion of 
very Noble Prize winners. But I don't know. They're 
not famous, I guess. I can't remember their names. 
Very important people. 
Q. Was that a dinner or a reception? 
A. I think it was a lunch. 
Q. A lunch. 
President Clinton, did you ever --
Page 70 
1 
A. Yes. 
2 
Q. Did you ever overhear Mr. Epstein talking to 
3 
any people that you would consider celebrities? 
4 
A. Yes. I knew some -- many celebrities. 
5 
Q. Who -- what celebrities did you understand 
6 
that he spoke with? 
7 
A. He spoke to it? 
8 
Q. Ycs. 
9 
A. I don't know who he spoke to because I never 
10 
listen to his conversations. But I saw guests at the 
11 
house that were celebrities. 
12 
Q. Who did you see at house? 
13 
A. Many. It was senators. It was Senator 
14 
Mitchell. George Mitchell. It was Prince Andrew. It 
15 
was Princess Sarah. 
16 
Q. Princess? 
17 
A. Sarah. the wife of Andrew. 
18 
Q. Sarah Ferguson? 
19 
A. Ferguson. 
20 
And it was a couple Misses. Misses Yugoslavia, 
21 
Miss Germany that I don't even know the names. But they 
22 
were a lot of queens and other famous people that I 
23 
can't remember. It was a very famous lawyers that I'm 
24 
sure you know. Alan Dershowitz, who spend at the house 
25 
couple times. And he slept them. Ile -- Princess 
Page 72 
1 
A. I met President Clinton on Mr. Epstein's plane 
2 
in the last, I think it was the last month or just 
3 
before I left -- I left. I met President Clinton in 
4 
Miami at his plane. We drove him to Miami. 
5 
Q. And do you know, was that a trip -- were they 
6 
going on a trip to Africa? 
7 
A. I hear about it, but it was not when I was 
8 
there. 
9 
Q. So that was not the time that you drove --
10 
A. No, I was already out. 
11 
Q. And Kevin Spacey, did you ever meet him? 
12 
A. No. I hear about it on the news, but I never 
13 
met him. 
14 
Q. Were Prince Andrew and Princess Sarah friends 
15 
of Ms. Maxwell? 
16 
A. Both of them. 
17 
Q. Both Ms. Maxwell and Mr. Epstein? 
18 
A. Yeah. 
19 
Q. Did -- did they ever have massages when they 
20 
were there? 
21 
A. Prince Andrew did. I think Sarah was there 
22 
only once and for a short time. I don't think she slept 
23 
in there. I cannot remember. I think she was visiting 
24 
Wellington and she came to the house and we met her. 
25 
But Prince Andrew, yes, Prince Andrew spent weeks with 
18 (Pages 69 to 72) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401.377.678.2895) 
Electronically signed by Sandra Townsend (401-377478-2895) 
76e1564a-4a1c-4dee-87ac-479898cc7004 
EFTA00188914

Case 9:08-cv-80736-KAIvi Document 291-17 Entered on FLL.. Docket 01/21/2015 Page 7 of 8 
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Page 73 
us. 
Q. Where would he sleep? 
A. In the main room, the main guest bedroom. 
That was the blue room. 
Q. And, so, when he would come and slay, during 
that time would he frequently have massages? 
MR. CRITTON: Form. 
THE WITNESS: I would says, daily massages. 
They have a daily massage. 
BY MS. EZELL: 
Q. Was it sometimes more than one a day? 
A. I can't remember if he had more than one, but 
I think it was just a massage for him. We set up the 
tables and --
Q. Do you have any recollection oft. 
coming to 
the house when Prince Andrew was there? 
A. It could have been, but I'm not sure. 
Q. Not sure. When Mr. Dershowitz was 
visiting, --
A. Uh-huh. 
Q. -- how often did he come? 
A. He came pretty -- pretty often. I would says, 
at least four or five times a year. 
Q. And how long would he stay typically? 
A. Two, three days. 
Page 75 
1 
MR. LANGINO: Go ahead. Sure. 
2 
BY MS. EZELL: 
3 
Q. You said that you set up the massage tables. 
4 
And would you also set up the oils and the towels? 
5 
A. Yes, ma'am. 
6 
Q. And I think I read one time you said they used 
7 
40 or 50 towels a day? 
8 
MR. CRITTON: Form. 
9 
THE WITNESS: That's correct. There was a 
10 
tremendous amount of work in the house, especially 
11 
laundry towels, because they were -- we have 
12 
towels, piles of towels. And they use in the pool. 
13 
There was a lot of people in the pool and there 
14 
were a towel that went in the floor, we have to go 
15 
and pick it up, wash it. So it was — it was a lot 
16 
of towels, yes. 
17 
BY MS. EZELL: 
18 
Q. And did you ever have occasion to go upstairs 
19 
and clean up after the massages? 
20 
A. Yeah, uh-huh. 
21 
Q. Did you ever find any vibrators in that area? 
22 
A. Yes. I told him, yes. 
23 
MS. EZELL: And did you ask that? I'm sorry. 
24 
MR. CRITTON: Ycs. 
25 
MS. EZELL: I don't know how I missed that. 
Page 74 
1 
Q. Did he have massages sometimes when he was 
2 
there? 
3 
A. Yes. A massage was like a treat for 
4 
everybody. If they want it, we call the massage and 
5 
they have a massage. 
6 
Q. Now, Mr. Trump had a home in Palm Beach, 
7 
correct? 
8 
A. Uh-huh. 
9 
Q. So he didn't come and stay there, did he? 
10 
A. No, never. 
11 
Q. He would come for a meal? 
12 
A. He would come, have dinner. He never sat at 
13 
the table. He eat with me in the kitchen. 
14 
Q. Did he ever have massages while he was there? 
15 
A. No. Because he's got his own spa. 
16 
Q. Sure. 
17 
MS. EZELL: I don't have any other questions 
18 
right now. I'd just like to reserve if something 
19 
comes up to ask. But, otherwise, you may go ahead. 
20 
MR. LANGINO: It is noon, so I don't know what 
21 
everybody else's schedule is. I don't know how 
22 
you're feeling. 
23 
THE WITNESS: I am fine. 
24 
MS. EZELL: I do have another question. May I 
25 
ask it? 
Page 76 
1 
BY MS. EZELL: 
2 
Q. Since I did miss it, if you don't mind, let me 
3 
just ask you again. 
4 
Would you describe for me what kinds of 
5 
vibrators you found? 
6 
A. I'm not familiar -- not too familiar with the 
7 
names, but they were big dildos, what they call the big 
8 
rubber things like that (indicating). And I used to go 
9 
and put my gloves on and pick them up, put them in the 
10 
sink, rinse it off and put it in Ms. Maxwell --
11 
Ms. Maxwell had in her closet, she had, like, a laundry 
12 
basket, one of those laundry basket that you put laundry 
13 
in. She have full of those toys. And that was -- and 
14 
that was me being professional, leaving the room ready 
15 
for bed when he would come back to the room again. 
16 
Q. Okay. 
17 
A. That happened a few times, few times. 
18 
Q. Were there other sex toys that you found in 
19 
the area --
20 
A. No. 
21 
Q. -- sometimes? You mentioned she kept them in 
22 
a basket in her closet? 
23 
A. She kept them in her basket. She had some 
24 
videos there and she have a costume there. I know that 
25 
she bought it, that she brought it with her. 
19 (Pages 73 to 76) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401377476.2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
76ef564a4a1e-4doe-87ac-479898cc7004 
EFTA00188915

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Page 77 
1 
Q. What kind of costume? 
2 
A. I don't know. It was a black, shiny costume. 
3 
I never saw it on her. 
4 
Q. Was it leather? 
5 
A. No. I think it was like a vinyl. But we were 
6 
very fussy about touching any of that stuff. We just... 
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MS. EZELL: No other questions. Thank you, 
B 
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sir. 
THE WITNESS: You're welcome. 
MR. LANGINO: I shouldn't have more than a 
half hour's worth of questions, if everybody is 
okay to power through. 
MR. BERGER: I probably have a half hour to an 
hour. 
MR. LANGINO: Okay. 
MR. BERGER: Unless you cover what I cover. 
MR. MERMELSTEIN: I could say the same thing, 
so probably less than that. 
MR. LANGINO: So I guess my question is --
MR. BERGER: I think we ought to take a break. 
MR. LANGINO: That was my question. 
MR. BERGER: We're going to take a break. 
Do you have any problem with that? 
THE WITNESS: No. Whatever you guys want to 
do. 
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Page 79 
CERTIFICATE OE OATH 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
I, the undersigned authority, certify that 
JUAN ALESSI personally appeared before me and was dul 
sworn on the 8th day of September, 2009. 
Dated this 19th day of September. 2009. 
ciaMtlikl
VV
aAA 
est/ 
Sandra W. Townsend, Court Reporter 
Notary Public - State of Florida 
My Commission Expires: 6/26/12 
My Commission No.: DD 793913 
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(Lunch recess.) 
(Continued to Volume II.) 
Page 78 
CERTIFICATE 
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STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
Sandra W. Townsend. Cow Reporter and 
Notary Public in and for the State of Florida at Large. 
6 
do hereby certify tint the aforementioned witness was by 
me first duly sworn to testify the whole trutli. that I 
7 
was authonzed to and did report said deposition in 
stenotype; and that the foregoing pages numbered Ito 
a 
78. inclusive. are a nue and correct transenption of 
my shorthand notes of said deposition. 
I further certify that said deposition was 
10 
taken at the time and place htteinabove set forth and 
Mal the taking of said deposition was commenced and 
11 
completed as hereinabove set out. 
12 
I further certify that lam not attorney or 
counsel of any of the parties. nor am I a relative or 
13 
employee Many attorney or counsel of party connected 
with the action. nor am I financially interested in the 
14 
84,808. 
16 
The foregoing certification of this transcript 
does not apply to any reproduction of the same by any 
16 
means unless under the direct control and/or direction 
of the certifying reposer. 
9 
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20 
Dated this 19th day of September. 2009. 
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Sandra W Townsend, Cowl Reposer 
Page 80 
20 (Pages 77 to 80) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401-377-676.2896) 
Electronically signed by Sandra Townsend (401-377.676.2895) 
7640564.4alcakkke-87m47989Occ7004 
EFTA00188916

f • 
EFTA00188917

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EXHIBIT 19 
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Page i 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
3 
JANE DOE NO. 2, 
Case No: 08-CV-80119 
4 
Plaintiff, 
5 
Vs 
6 
JEFFREY EPSTEIN, 
7 
Defendant. 
/ 
8 
JANE DOE NO. 3, 
Case NO: 08-CV-80232 
9 
10 
Plaintiff, 
Vs 
11 
JEFFREY EPSTEIN, 
12 
Defendant. 
/ 
13 
JANE DOE NO. 4, 
Case No: 08-CV-80380 
14 
15 
Plaintiff, 
Vs. 
16 
17 
JEFFREY EPSTEIN, 
Defendant. 
18 
/ 
19 
JANE DOE NO. 5, 
Case No: 08-CV-80381 
20 
Plaintiff, 
21 
Vs 
22 
JEFFREY EPSTEIN, 
23 
Defendant. 
/ 
24 
25 
Kress Court Reporting, Inc. 305-866-7688 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00188919

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Page 2 
Page 4 
i 
JANE DM NO. 6, 
Case No: 08EV-80994 
1 
VIDEOTAPED 
2 
Plaintiff, 
2 
DEPOSITION 
3 
Vs 
3 
of 
4 
JEFFREY EPSTEIN, 
4 
ALFREDO RODRIGUEZ 
5 
Defendant. 
5 
/ 
6 
taken on behalf of the Pleintiffs pursuant 
6 
7 to a Re•Notice of Taking Deposition (Duces return) 
JANE DOE NO. 7, 
Case No. 08-CV-B0993 
8 
7 
9 
... 
Plaintiff, 
10 APPEARANCES: 
8 
II 
Vs 
MERMELSTEIN & HOROWITZ, P.A. 
9 
12 
BY: STUART MEFtMELSTEIN, ESQ. 
10 
JEFFREY EPSTEIN, 
Defendant 
il 
I 
14 
Attorney on ane 
2, 3, 4, 5, 
12 
13 
C.M.A., 
Case No: 08U40811 
Plaintiff, 
6, and 7. 
II Vs 
IS
15 
JEFFREY EPSTEIN, 
16 
ROTHSTEIN ROSENFELDT ADLER 
16 
Defendant. 
BY: BRAD J. EDWARDS, ESQ., and 
/ 
17 
CARA HOLMES E 
17 
JANE ME, 
Case No: 08-CV-80893
18 
19 
Plaintiff, 
Attoa or Jane Doe an 
Vs 
20 
20 
21 
21 
JEFFREY EPSTEIN, 
22 
POOHURST ORSECX 
BY: KATHERINE W. EZELL 
Defendant. 
22 
/ 
I 
23 
24 
24 
Attorney 
ane 
101 and 102. 
25 
25 
Page 3 
Page 5 
1 JANE DOE NO. II, 
Case No: 08-CV-80969 
1 
2 
Plaintiff, 
APPEARANCES: 
3 
Vs 
2 
4 
3 
LEOPOLD-KLNIN
JEFFREY EPSTEIN, 
5 
Defendant. 
4
SQ. 
I 
6 
I 
JANE DOE NO. 101, 
Case No: 09-CV-80591 
Attorney or
7 
6 
Plaintiff, 
7 
T 
8 
Vs 
8 
9 
9 
Attorney or . A 
JEFFREY EPSTEIN, 
to 
10 
BURMAN, 
LLITTIER & 
Defendant. 
I I 
L IPTON,
C
COLEMAN, IP 
11 
i 
Y. 
RT CCITT N ESQ. 
12 
JANE DOE NO. 102, 
Case No: 09-CV-80656 
12 
13 
14 
IS 
Plaintiff, 
Vs 
JEFFREY EPSTEIN, 
13
Attorney o• /e ley pst n. 
16 
Defendant. 
:.:
/ 
It 
17 
ALSO PRISENI: 
18 
17 
19 
JOE IANGSAM, VIDEOGRAPHER 
20 
18 
19 
■ 
20 
22 
11:00 a.m. to 5:30 p.m. 
21
22 
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24 
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EXHIBITS 
1 Message pad 
2 Documents 
INDEX OF EXAMINATION 
WITNESS 
DIRECT 
CROSS 
ALFREDO RODRIGUEZ 
(By Mr. Mermelstein) 
12 
(By Mr. Edwards) 
157 
(By Mr. Langino) 
260 
INDEX OF EXHIBITS 
PAGE 
72 
115 
Page 6 
Page 8 
1 
Doe right here on the copy you gave me. I'm 
2 
missing which Jane Doe this is. 
3 
They're all different case numbers. Do 
4 
you want me to go through each case number? 
5 
MR. CRITTON: I'm going to note my 
6 
objection. Obviously if this deposition 
7 
gets played -- not obviously, I'm going to 
8 
object to the litany of each one so I don't 
9 
know how we can separate it out. Maybe if 
10 
and when at the time of trial and depending 
11 
on how the Court determines what comes in 
12 
and what doesn't with regard to the 
13 
consolidated aspects of this. I have no 
14 
great idea other than just saying Jane Doe 
15 
versus Epstein, et al, or something like 
16 
that, or Jane Doe, et al. 
17 
MS. EZELL: Couldn't we just say and 
18 
those cases which have been consolidated 
19 
with it for Discovery purposes? 
20 
MR. EDWARDS: Although there is cases 
21 
here that have cross noticed this from state 
22 
court that haven't been consolidated so that 
23 
may not work. You may have to read them 
24 
all, if it works out your way that will just 
25 
get edited out, at least he will have read 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
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Page 7 
Deposition taken before 
PAYNE, Court 
Reporter and Notary Public in and for the State of 
Florida at Large, in the above cause. 
THE VIDEOGRAPHER: This is the case of 
Jane Doe No. 2, plaintiff, versus Jeffrey 
Epstein, defendant. Jane Doe No. 3, 
plaintiff, versus Jeffrey Epstein, 
defendant. Jane Doe No. 4, plaintiff, 
versus Jeffrey Epstein, defendant. And Jane 
Doe No. 5, plaintiff, versus Jeffrey 
Epstein, defendant. Jane Doe No. 6, 
plaintiff, versus Jeffrey Epstein, 
defendant. Jane Doe No. 7, plaintiff, 
versus Jeffrey Epstein, defendant. CMA, 
plaintiff, versus Jeffrey Epstein, 
defendant. And Jane Doe, plaintiff, versus 
Jeffrey Epstein, et al, defendant. And Jane 
Doe -- is there a shorter thing that we can 
do here? It's also missing this one right 
here. 
MR. MERMELSTEIN: Do we have a problem 
with saying Jane Doe 2 and the Epstein and 
related cases? 
THE VIDEOGRAPHER: I'm missing this Jane 
Page 9 
1 
that caption, every caption. Right? Is 
2 
there a better suggestion? 
3 
MR. CRITTON: No. There may be a better 
4 
suggestion if he starts this is such and 
5 
such day, it's the deposition of Mr. 
6 
Rodriguez in the case such and such, and we 
7 
can almost fill it in depending on which 
8 
tape it goes, how it fills in, at least 
9 
well have the context of the first and 
10 
depending on whether the Judge reads it in 
11 
from a consolidated or they all come 
12 
related, I have no great idea. 
13 
MR. EDWARDS: I was thinking if he read 
14 
every one of them and it was the seventh in 
15 
line then you just would edit it so you 
16 
would only read that one. 
17 
MR. CRITTON: I'm okay with that too. 
18 
THE VIDEOGRAPHER: On page number three 
19 
there is something missing on the top here. 
20 
Do you want me to read each case number 
21 
separately? 
22 
MR. MERMELSTEIN: I don't think it's 
23 
necessary. 
24 
MR. EDWARDS: I don't think it's 
25 
necessary either. 
3 (Pages 6 to 9) 
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Page 10 
1 
THE VIDEOGRAPHER: So just go through 
2 
just the names. 
3 
MR. MERMELSTEIN: That's sufficient. And 
4 
there is a cross notice for one of the state 
5 
cases? 
6 
MR. LANGINO: That would be our case. 
7 
MR. MERMELSTEIN: So he's got that 
8 
notice? Off the record. 
9 
(Thereupon, a discussion was held off the 
10 
record.) 
11 
THE VIDEOGRAPHER: This is the case of 
12 
Jane Doe No. 2, plaintiff, versus Jeffrey 
13 
Epstein, defendant. Jane Doe No. 3, 
14 
plaintiff, versus Jeffrey Epstein, 
15 
defendant. Jane Doe No. 4, plaintiff, 
16 
versus Jeffrey Epstein, defendant. Jane Doe 
17 
No. 5, plaintiff, versus Jeffrey Epstein, 
18 
defendant. Jane Doe No. 6, plaintiff, 
19 
versus Jeffrey Epstein, defendant. Jane Doe 
20 
No. 7, plaintiff, versus Jeffrey Epstein, 
21 
defendant. CMA, plaintiff, versus Jeffrey 
22 
Epstein, defendant. Jane Doe, plaintiff, 
23 
versus Jeffrey Epstein, et al, defendant. 
24 
Jane Doe 3, plaintiff, versus Jeffrey 
25 
Epstein, et al, defendant. Jane Doe No. 
Page 12 
1 
Jeffrey Epstein. 
2 
MR. WILLITS: Richard Willits on behalf 
3 
of plaintiff C.M.A. 
4 
MR. EDWARDS: And Brad Edwards on behalf 
5 
of plaintiffs M. and M. 
6 
Thereupon, 
7 
ALFREDO RODRIGUEZ, 
8 
having been first duly sworn or affirmed, was 
9 
examined and testified as follows: 
10 
DIRECT EXAMINATION 
11 BY MR. MERMELSTEIN: 
12 
Q. Can you state your full name for the 
13 record, please? 
14 
A. My name is Alfredo Rodriguez. 
15 
Q. And where do ou live? 
16 
A. I live in 
18 
Q. Are you currently employed? 
19 
A. No. 
20 
Q. Okay. When was the last time you were 
21 employed? 
22 
A. December of 2008. 
23 
Q. Was there a time you were employed in 
24 
Palm Beach, Florida? 
25 
A. Yes, I was. 
Page 11 
1 
101, plaintiff, versus Jeffrey Epstein, 
2 
defendant. Jane Doe No. 102, plaintiff, 
3 
versus Jeffrey Epstein defendant. •, 
4 
plaintiff, versus Jeffrey Epstein, 
5 
defendant. 
6 
This is in the Circuit Court of the 15th 
7 
Judicial Circuit in and for Palm Beach 
8 
County, Florida. 
9 
This is the deposition of Alfredo 
10 
Rodriguez. Today is July the 29th, starting 
11 
time -- the year 2009, starting time 
12 
approximately 11:16 a.m. 
13 
Will attorneys please state their 
14 
appearance? 
15 
MR. MERMELSTEIN: Stuart Mermelstein for 
16 
plaintiffs Jane Doe 2, Jane Doe 3, Jane Doe 
17 
4, Jane Doe 5, and Jane Doe 6, and Jane Doe 
18 
7. 
19 
MR. EDWARDS: Brad Edwards for plaintiff 
20 
Jane Doe. 
21 
MR. LIINO: Adam Langino on behalf of 
22 
plaintiff, ■ 
23 
MS. EZELL: Cathy Ezell on behalf of Jane 
24 
Doe 101 and 102. 
25 
MR. CRITTON: Bob Critton on behalf of 
Page 13 
1 
Q. When was that? 
2 
A. I began on September of 2004. 
3 
Q. And where were you employed? 
4 
A. I work -- well, I have several employers 
5 
in Palm Beach. One of them was Jeffrey Epstein. 
6 
Q. By several employers in Palm Beach you 
7 
mean --
8 
A. Different employers. 
9 
Q. At the same time? 
10 
A. No, different times. From 2005 to 2006 I 
11 was employed by Dana Hammond. 
12 
Q. Donna Hammond? 
13 
A. D-A-N-A, Hammond. Or Aimes is her single 
14 
name. Dana Aimes Hammond. 
15 
Q. Dana Aimes Hammond? 
16 
A. Yeah. 
17 
Q. That was in Palm Beach? 
18 
A. Yes. 
19 
Q. And in September 2004 you were employed 
20 
by whom? 
21 
A. Jeffrey Epstein. 
22 
Q. Did Mr. Epstein employ you as an 
23 
individual or through any business or corporate 
24 
entity? 
25 
A. As an Individual. 
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1 
Q. Sure, go ahead and answer however you 
1 
A. No, exactly. 
2 
want. 
2 
MR. CRITTON: Form. 
3 
MR. CRITTON: Form. 
3 
BY MR. EDWARDS: 
4 
THE WITNESS: I don't think it was right. 
4 
Q. I think that the next time you're 
5 
BY MR. EDWARDS: 
5 
mentioned in the report, I believe it's page 70. 
6 
Q. Did you ever voice that opinion that you 
6 
MS. EZELL: Off the record briefly. 
7 
didn't think that it was right that these young 
7 
(Thereupon, a discussion was had off the 
8 
girls were over behind dosed doors upstairs with 
8 
record.) 
9 
Mr. Epstein In his bedroom? 
9 
BY MR. EDWARDS: 
10 
MR. CRITTON: Form. 
10 
Q. Page 64. It says, Alfredo Rodriguez 
11 
THE WITNESS: I been asked that question 
11 resides in Miami had eluded, meaning you were 
12 
before. 
12 
trying to evade or avoid service of process 
13 
BY MR. EDWARDS: 
13 
servers previously and was not served the 
14 
Q. Excuse me? 
14 investigative subpoena. 
15 
A. I been asked that question before. 
15 
This is an investigator saying you just 
16 
Q. By whom? 
16 
weren't home or something. Right? 
17 
A. Palm Beach Police Department. 
17 
A. But I never elude anybody. 
18 
Q. Did you give the same answer that you did 
18 
Q. You never intentionally tried to avoid 
19 not think it was right? 
19 
the police officers? 
20 
MR. CRITTON: Form. 
20 
A. No, no, never. 
21 
THE WITNESS: Yes. 
21 
Q. Okay. 
22 
BY MR. EDWARDS: 
22 
MR. CRITTON: So much for the police 
23 
Q. And what about it to you aside from the 
23 
report. 
24 
fact that you had a daughter roughly the same age, 24 
BY MR. EDWARDS: 
25 
what besides that told you that it wasn't right? 
25 
Q. All right. The bottom of page 70 says, I 
Page 195 
Page 197 
1 
MR. CRITTON: Form. 
1 brought Mr. Rodriguez to the interview room. 
2 
THE WITNESS: Ask me your question again. 
2 
Were you taken to an interview room, to a 
3 
BY MR. EDWARDS: 
3 
room in the police department? 
4 
Q. My question is, why is it your opinion 
4 
A. This was in the District Attorney's 
5 
that it wasn't right for these young girls to be 
5 
Office. 
6 
up in Mr. Epstein's --
6 
Q. Oh, it was at the State Attorney's 
7 
A. It wasn't. 
7 
Office? 
8 
MR. CRITTON: Form. 
8 
A. Yes. 
9 
BY MR. EDWARDS: 
9 
Q. Okay. Was a State Attorney there as 
10 
Q. It wasn't right? 
10 
well? 
11 
A. It wasn't. 
11 
A. Yes, Mrs. Weiss. 
12 
Q. And why not? 
12 
Q. Daliah Weiss? 
13 
MR. CRITTON: Form. 
13 
A. Young lady, Weiss. D-E-I-S-S. 
14 
THE WITNESS: Because I'm a father, I 
14 
Q. Okay. I have D-A-L-I-A-H, Daliah Weiss, 
15 
have two daughters. 
15 
W-E-I-S-S. 
16 
BY MR. EDWARDS: 
16 
A. Yes. 
17 
Q. And given Mr. Epstein's wealth and power 
17 
Q. That's her? 
18 and influence, is that something that you as a 
18 
A. Yeah. 
19 
father could have seen your daughters doing at 
19 
Q. Okay. Did she ask you any questions? 
20 
that age? 
20 
A. Both of them. 
21 
MR. CRITTON: Form. 
21 
Q. Okay. So it was both -- if there is a --
22 
THE WITNESS: I don't think that my 
22 
I think you said earlier there is a taped 
23 
daughters would be doing that. 
23 
statement, there is a tape of this? 
24 
BY MR. EDWARDS: 
24 
A. Yes. 
25 
Q. You would hope not. 
25 
Q. If we listen to that tape if we ever get 
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1 that tape it's going to be Assistant Attorney 
2 
Weiss and Detective Recarey asking questions? 
3 
A. Yes. 
4 
Q. It says, during the sworn taped statement 
5 
Mr. Rodriguez stated he was employed by Jeffrey 
6 
Epstein for approximately six months. 
7 
I think we already talked about that. 
8 I'm skipping ahead a little bit. 
9 
If Rodriguez needed to relay a message to 
10 Epstein he would have to notify Epstein's 
11 secretary Lesley in New York who would then notify 
12 Epstein's personal assistant Sarah who would relay 
13 
the message to Epstein. 
14 
A. Yeah. 
15 
MR. CRITTON: Form. 
16 
BY MR. EDWARDS: 
17 
Q. That's pretty much the process you 
18 described? 
19 
A. Yes, it was normal procedure. 
20 
Q. Rodriguez stated Epstein did not want to 
21 see or hear the staff when he was in the 
22 
residence? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: That's correct. 
25 
BY MR. EDWARDS: 
Page 200 
1 friends, I will say, yeah. 
2 
Q. Then you mentioned that you typed into 
3 
Google, I guess you Googled Prince Andrew and Bill 
4 
Clinton. Why would you pick those names, were 
5 
they associated with Mr. Epstein? 
6 
A. Yes. 
7 
Q. And what is your understanding as to how 
8 Prince Andrew is associated with Jeffrey Epstein? 
9 
A. Because there were pictures with him 
10 
together. 
11 
Q. In the house? 
12 
A. Yes. 
13 
Q. Many pictures or are we talking about 
14 one? 
15 
A. Many pictures. 
16 
Q. Were these pictures that looked that 
17 appeared to be at social events, at Mr. Epstein's 
18 house or where? 
19 
A. Mrs. Maxwell took him to England to 
20 introduce him to the royalty. 
21 
Q. Is it's your understanding that Ghislaine 
22 
Maxwell knew Prince Andrew and introduced --
23 
A. Yes. 
24 
Q. Is it also your understanding that at 
25 
some point in time Ghislaine dated or had a 
Page 199 
I 
Q. That's something you agree with? 
2 
A. Yes. 
3 
MR. CRITTON: Form. 
4 
BY MR. EDWARDS: 
5 
Q. Rodriguez advised Mr. Epstein had many 
6 
guests. 
7 
In addition to the girls who are roughly 
8 
C. and T. age who had come to the house to have a 
9 
good time, who were some of the other guests that 
10 you know of, if you know their name? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: I mentioned Alan 
13 
Dershowit. 
14 
BY MR. EDWARDS: 
15 
Q. That's a lawyer from Harvard? 
16 
A. Yes. The magician, David Copperfield, 
17 some other lawyers from New York, you know. There 
18 were some other guests. 
19 
Q. And how frequently would these other 
20 guests come over? 
21 
A. Once a month, something like that. 
22 
Q. Okay. So If it's only once a month and 
23 you were only there six months you're saying you 
24 only saw six guests come over In addition to --
25 
A. They have people, you know, they have 
Page 201 
1 romantic relationship with Prince Andrew? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: I don't know that. 
4 
BY MR. EDWARDS: 
5 
Q. Do you know around what time period it 
6 
was that Mr. Epstein was introduced to Prince 
7 
Andrew? 
8 
A. 2003, I believe. 
9 
Q. How do you know that? 
10 
A. I've heard dates. 
11 
Q. From people in the Epstein group? 
12 
A. Yes. 
13 
Q. Okay. 
14 
MR. CRITTON: Let me note my objection, 
15 
move to strike, it's based on -- his 
16 
testimony is based on hearsay. 
17 
BY MR. EDWARDS: 
18 
Q. During the six month period of time when 
19 you worked directly for Mr. Epstein, how often did 
20 Mr. Epstein get together with or hangout with 
21 Prince Andrew; if you know? 
22 
A. I didn't see him once. 
23 
Q. You never saw Prince Andrew at the house? 
24 
A. No, no, he called. 
25 
Q. I'm sorry, how often would he call? 
51 (Pages 198 to 201) 
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14 
2 
3 
4 
Page 270 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
JANE DOE NO. 2, 
CASE NO: 08-CV-80119 
Plaintiff, 
5 
Vs. 
6 
JEFFREY EPSTEIN, 
7 
Defendant. 
8 
9 
JANE DOE NO. 3, 
CASE NO: 08-CV-80232 
10 
Plaintiff, 
Vs. 
CONDENSED 
11 
12 
JEFFREY EPSTEIN, 
13 
Defendant. 
14 
JANE DOE NO. 4, 
CASE NO: 08-CV-80380 
15 
Plaintiff, 
16 
Vs. 
17 
JEFFREY EPSTEIN, 
18 
Defendant. 
19 
20 
JANE DOE NO. 5, 
CASE NO: 08-CV-80381 
21 
Plaintiff, 
22 
VS 
23 
JEFFREY EPSTEIN, 
24 
Defendant. 
25 
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Page 271 
1 JANE DOE NO. 6, 
CASE NO: 08-CV-80994 
2 
Plaintiff, 
3 
Vs. 
4 
JEFFREY EPSTEIN, 
5 
Defendant 
6 
JANE DOE 110. 7, 
CASE IC: 08CV•80993 
7 
Pain" 
8 
Vs. 
9 
JEFFREY EPSTEIN, 
10 
Defendant. 
11  
12 C.M.A., 
CASE NO: 08CV-80811 
13 
Ptaindff, 
14 Vs. 
15 JEFFREY EPSTEIN, 
16 
Defendant. 
17 
JANE DOE, 
CASE NO: 06-0/.80893 
18 
Mkt" 
19 
Vs. 
20 
JEFFREY EPSTEIN, 
21 
Defendant. 
22  
13 
24 
25 
1 
IN THE CIRCUIT COURT OF THE 15TH 
JUDICIAL CIRCUIT IN AND FOR 
2 
PALM BEACH COUNTY, FLORIDA 
3 
CASE NO. 502008CA037319)COCXMB AB 
4 
B.B., 
S 
Plaintiff, 
6 
Vs. 
7 
JEFFREY EPSTEIN. 
8 
Defendant. 
9  
10 
11 
12 
1031 Ives Dairy Road 
Suite 228 
13 
North Miami, Florida 
August 7, 2009 
14 
1:15 p.m. to 5:30 p.m. 
15 
16 
CONTINUED 
17 
VIDEOTAPED 
18 
DEPOSITION 
19 
of 
20 
ALFREDO RODRIGUEZ 
21 
22 
taken on behalf of the Plaintiffs pursuant 
23 to a Re-Notice of Taking Continued Videotaped 
24 Deposition (Duces Tecum) 
25 
- - • 
Page 273 
Page 272 
1 JANE DOE NO. II, 
CASE NO: 08-CV-80469 
2 
Plaintiff, 
3 
Vs. 
4 
JEFFREY EPSTEIN, 
5 
Defendant. 
JANE DOE NO. 101 
CASE NO: 08-CV-80591 
Plaintiff, 
Vs. 
JEFFREY EPSTEIN, 
Defendant 
11  
12 JANE DOE NO. 102, 
CASE NO: 08-CV-80656 
13 
Plaintiff, 
19 Vs. 
15 JEFFREY EPSTEIN, 
16 
Defendant. 
6 
7 
8 
9 
10 
17 
18 
19 
20 
21 
22 
23 
29 
25 
1 APPEARANCES: 
2 
3 
MERME€STEIN & HOROWITZ, PA 
5 
omeg or ane 
2, 3, 4, 5, 
6 
6, and 7. 
7 
8 
ROTTSIFIN ROSENFELDT AMER 
ESQ. and 
9 
10 
11 
• 
nor
 orJane 
an 
12 
And 
13 
14 
PCOHURST ORSEOC 
15 
IligiCLL, 
ESQ. 
16 
me/ or 
ne 
101 and 102. 
17 
18 
tEOPOLD-KUVIN 
IS 
ESQ. 
20 
21
rney or
22 
23 
24 
25 
Page 274 
2 (Pages 271 to 274 
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Case 9:08-cv-80736-Kr,i0 Document 291-18 Entered on FL. J Docket 01/21/2015 Page 10 of 
14 
1 APPEARANCES: 
2 
3 
I 
6 
7 
8 
ARD W LUIS ESO. 
nomey forC.M.A.
Appeared via telephone. 
BURMAN, CRITTON, RIMER & 
COLEMAN, LLP 
ESQ. 
9 
or 
11 
12 
13 
ALSO PRESENT: 
14 
3OE LANGSAM, VIDEOGRAPHER 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 275 
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 
Page 277 
Deposition taken before
AYNE, Court
1 6PDAYNE, 
Reporter and Notary Pub 
n an 
r the State of 
Florida at Large, in the above cause. 
THE VIDEOGRAPHER: This is a continuation 
of the deposition of Alfredo Rodriguez. 
Today is Friday, August the 7th, the year 
2009, starting time approximately 1:15 p.m. 
Will the court reporter please swear in 
the witness? 
Thereupon, 
ALFREDO RODRIGUEZ, 
having been first duly sworn or affirmed, was 
examined and testified as follows: 
MR. CRITTON: Before we get started just 
with regard to Ms. Ezell represents Jane Doe 
101 and 102, the alleged time of her 
Incidents as of least have been plead In the 
complaint for 101 is '99 -- I'm sorry, '98 
through 2002, with Jane Doe 102 the Spring 
of -- Spring/Summer of 2003. Mr. Rodriguez 
never even began employment until '04 and 
'05. I think her questioning I think -- I 
can't say she doesn't have standing based on 
the court order, but I would say It's 
1 
2 
3 
4 
5 
6 
7 
B 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
as 
CONTINUED INDEX OF EXAMINATION 
WITNESS 
DIRECT CROSS REDIRECT RECROSS 
ALFREDO RODRIGUEZ 
(By Ms. Ezell) 
278 
441, 467 
(By Mr. Willits) 334 
453, 469 
(By Mr. Crltton) 
338 
464 
(By Mr. Edwards) 
419, 459, 468 
(By Mr. Langlno) 
452 
CONTINUED INDEX OF EO118115 
PlAINTIFFS 
PAGE 
3 Drawing 
315 
Photograph 
327 
5 Photograph 
331 
6 Photograph 
331 
7 Photograph 
331 
8 Photograph 
331 
9 Report 
446 
(Exhibits 4, 5, 6, 7, and 8 were retained by Ms. 
Ezell.) 
Page 276 
Page 278 
1 
completely irrelevant and immaterial and has 
2 
no probative value with regard to this 
3 
particular witness based upon the two 
4 
clients at least that are in suit at this 
5 
point in time. 
6 
MS. EZELL: As Mr. Critton well knows I 
7 
represent a number of other clients whose 
8 
cases have not been filed and I believe we 
9 
do have standing to ask questions, and I do 
10 
intend to do that today. 
11 
EXAMINATION 
12 
BY MS. EZELL: 
13 
Q. Mr. Rodriguez, you stated last time that 
14 
there were guests at the house, frequent guests, 
15 
friends from Harvard. 
16 
Do you remember that testimony? 
17 
A. Yes, ma'am. 
18 
Q. And was there a lawyer from Harvard named 
19 Alan Dershowitz? 
20 
A. Yes, ma'am. 
21 
Q. And are you familiar with the fact that 
22 
he's a famous author and famous lawyer? 
23 
A. Yes, ma'am. 
24 
Q. How often during the six months or so 
25 that you were there was Mr. Dershowitz there? 
3 (Pages 275 to 278 
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