| 1 | out -- |
| 2 | A. No. |
| 3 | Q. -- of his briefcase? |
| 4 | A. It was twice. |
| 5 | Q. When was the other time? |
| 6 | A. Couple weeks before. |
| 7 | Q. What time of day was that? |
| 8 | A. At night. |
| 9 | Q. And how much did you take out the first time? |
| 10 | A. It was a total of $6,300. |
| 11 | Q. That's for both times? |
| 12 | A. Yeah. |
| 13 | Q. Can you break them down? |
| 14 | A. I think one time was $1,500. Another time was the rest. |
| 15 | Q. Now, you left in December of 2002 and then there were these two incidents that you just described? |
| 16 | A. Uh-huh. |
| 19 | Q. Did you have any contact with Mr. Epstein in between leaving his employment and the first of these two instances? |
| 22 | A. None. |
| 23 | Q. And as far as you knew, did anybody see you take the money on either occasion? |
| 25 | A. None. |
PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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Q. And, so, when you saw the card from the police, you assumed it had to do with these two instances?
A. Yes, sir.
Q. And there was no other reason why you thought it had to do with Mr. Epstein?
A. No, sir.
Q. And when you called him, did you discuss these two incidents with him?
A. When I call Mr. --
Q. You said you got the card --
A. No.
Q. -- and then you called him?
A. No, we did not discuss that money or nothing involved.
I ask him, what's going on, Jeffrey? What's happening? I got this and I thought that this was all over.
No, he says, it has nothing to do with that money.
Q. Did you ever read the incident report by the police, the Palm Beach Police Department? Did you ever read it?
24 A. No.
MR. CRITTON: Regarding what?
PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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MR. BERGER: Regarding these incidents.
BY MR. BERGER:
Q. You never read it?
A. No.
Q. Let me hand you this.
MR. CRITTON: Is there an extra copy?
MR. BERGER: Yeah.
BY MR. BERGER:
Q. What I'm showing you, have you ever seen this before?
A. No.
MR. BERGER: Let's have this marked as Exhibit 3, please.
MR. CRITTON: Can I keep this?
(Exhibit number 3 was marked for identification purposes.)
BY MR. BERGER:
Q. It appears to be about 20 pages and it has, Palm Beach Police Department Incident Report, on the top page.
Turn to the third page.
And you see where it starts the narrative, the paragraph? Do you see where that starts?
A. Yes, sir.
Q. And it says: "On Sunday, October 5, '03 at
Electronically signed by Sandra Townsend (401-377-676-2895)
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approximately 8:24 hours, I was dispatched to a burglary at 358 El Brillo Way."
Do you see that?
A. Yeah.
Q. Now, October 5, 2003, do you recall that that was about when the time you took the money from Mr. Epstein's briefcase was?
A. Yes. I don't recall. But if they say it, I have to agree with it.
Q. Well, you left in December of 2002. And before I showed you this document, you said that these incidents occurred about three or four months later. So apparently they occurred more than three or four months later; is that correct?
A. Apparently, yes.
Q. Well, now after -- after looking at this, sir, do you actually recall that it occurred more than three or four months later?
A. After looking at this?
Q. Yeah.
A. It could be.
Q. But do you actually remember it being more than three or four months?
A. I don't remember if it was more than three months.
(561) 832-7500
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Q. Okay. Okay. Now, if you look further down, you'll see it says, quote, Epstein further advised a black Glock handgun was taken from the book shelf located behind the desk, unquote.
Do you see that?
A. Yes.
Q. Did you take a black Glock handgun from him?
A. Absolutely not.
Q. Do you know if anybody did?
A. No, sir.
Q. Is this the first time that you ever heard that Mr. Epstein may have told the police --
A. No. This question I was asked by the police.
Q. Okay. Now, you see the next sentence? It says: "Epstein advised he suspected cash had been taken from his briefcase on two other occasions while he was in town for the weekend. The first was over the Labor Day weekend, August 30 to September 1. The second time was a weekend in mid-September 2003."
Do you see --
A. Yeah.
Q. -- the mention of those two incidents?
A. Uh-huh.
Q. Yes?
A. Uh-huh.
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Q. You've got to say yes or no.
A. Yes, sir.
Q. Now, look up at the top of that paragraph. You see where it says: "After" -- it's about the fourth sentence -- "Epstein advised that on Saturday evening, October 4, 2003, he left his briefcase at his desk and went to bed at approximately 12:30 a.m. Epstein said when he left his briefcase, it contained approximately $5,000 U.S. currency."
A. Uh-huh.
Q. Do you see that?
A. Yes.
Q. And then it goes further on, it says -- after a sentence or two, it says: "Epstein stated at approximately 7:15 hours on Sunday, October 5, 2003, while sitting at his desk, he noticed the briefcase had been opened and some of the cash was missing. Epstein believed approximately $3,500 was taken from the briefcase."
Do you see that?
A. Yes.
Q. Now, when you read this whole paragraph here, do you agree that Mr. Epstein is -- and assuming that the police took this down accurately -- that Mr. Epstein is describing three separate instances --
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Q. -- where he believes money was taken?
MR. CRITTON: Form.
THE WITNESS: I don't agree with this.
BY MR. BERGER:
Q. No?
A. No.
Q. Well, he says: "The first" -- at the bottom, it says: "The first was over Labor Day weekend, August 30 to September 1, 2003."
You see it says that at the bottom? The very bottom.
August 30 to September 1, 2003." Do you see that?
A. Uh-huh.
Q. Yes or no?
A. Yes.
Q. And then it says: "The second time was a weekend in mid-September 2003."
Do you see that?
A. Yes.
Q. And then above, do you see where he talked about October 4, 2003? You see mention of that? Or October 5, 2003?
PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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A. Right here.
Q. Right in the middle, it says: "Epstein stated at" -- yes.
A. No. I don't agree with this. I never saw this.
Q. I'm not asking -- that's not what I'm asking.
What I'm saying, sir, do you see though that the police report refers to three instances; is that correct?
A. No.
Q. Okay. But it's correct that the police report refers to three instances, correct?
MR. CRITTON: Form.
BY MR. BERGER:
Q. The police talk about three instances, right?
A. That's correct.
MR. CRITTON: Form.
BY MR. BERGER:
Q. Now, how many times did you take cash from Mr. Epstein?
A. Twice.
Q. So do you have any idea what he's talking about here?
A. No.
Q. Now, the first time that you took cash, was it
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A. I can't remember.
Q. Or September -- mid-September 2003?
A. I can't remember.
Q. Okay. Is the third incident accurate where it talks about October 5 or October 4, 2003?
A. I don't know if it's accurate or not, but I know that I went to the house twice.
Q. Not three times?
A. Not three times.
Q. Any idea why Mr. Epstein would talk about three times?
A. No idea, sir.
Q. And any idea why he would talk about a Glock handgun?
A. No, sir.
MR. CRITTON: Form.
BY MR. BERGER:
Q. Now, you said that -- that you had a -- okay. I've put this aside. I'm going to ask you another question, so why don't you -- I don't want to distract you.
Now, you said that your disagreement or your falling out with Mr. Epstein was after you left his employment. Do you remember saying that?
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A. Yes. After -- after this incident.
Q. And what did that disagreement have to do with? Did it have to do with these incidents?
A. Of course. I screw it up.
Q. Okay. And do you know who Mr. Adam Fetterman is?
A. Yes.
Q. Who is he?
A. He's mv lawyer.
Q. And did Mr. Epstein pay for Mr. Fetterman's legal services for you?
A. No. I pay on my own pocket.
Q. Now, let me ask you some questions about some property in Palm Beach County,
Do you remember that in or around 1983 you and your wife bought a home at in Royal Palm Beach?
A. I didn't bought it. I build it.
Q. You built it. You didn't buy it?
A. No.
Q. And do you remember that in April of 1995, you and your wife purchased a single-family home in -- on
PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1. Q. It was a lot. Okay.
2. A. Yes, we purchase that.
Q. Okay.
MR. CRITTON: What was the first date you gave about built home?
MR. BERGER: July 1983.
MR. CRITTON: Thank you.
BY MR. BERGER:
Q. And does the purchase price of $22,600; is it correct --
A. Sounds familiar.
Q. -- for the -- for the s that correct?
Uh-huh.
Yes or no?
What date was that?
April of 1995.
That's correct.
Now, do you recall that in December of 1997 your wife bought apartment number 1902 at
. That's correct.
. -- in West Palm Beach; is that right?
. Yes, sir.
. And does the purchase price of $105,000; is
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that accurate?
A. That's correct.
Q. Now, do you recall that in November of 1998 you and your wife bought apartment 1901 at
A. Yes.
A. That's correct.
Q. And the purchase price was $159,000?
Q. So in -- so did you -- as of November of 1998, did you own both apartment 1902 and apartment 1901 at
A. Yes. But I didn't own the house in Royal Palm Beach. I didn't -- I sold that. With that money we bought that apartments.
Q. You built the house at the Royal Palm Beach address?
A. Yes.
Q. After buying the lot?
A. Yes. We bought the lot years, years back.
Q. Now, in October of 2001, do you remember
buying a multi-family residential property at n Wellington?
A. I still have it.
Q. And do you remember the purchase price being $310,000?
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1. A. Yes, sir.
2. Q. And this is while you worked for Mr. Epstein, correct? 2001, October 2001?
3. A. Yeah.
4. Q. And you still own it; is that what you said?
5. A. Yes.
6. Q. And is that a rental apartment building?
7. A. Yeah, it's a rental.
8. Q. And now, do you recall that in September of 2002 you and your wife purchased a multi-family residential property at West Palm Beach?
9. A. That's correct.
10. Q. And the purchase price was $590,000? Do you remember that?
11. A. Yes.
12. Q. And then in October of 2004 you bought the -- you bought a multi-family residential property -- strike that.
13. In October of 2004 your wife purchased a multi-family residential property at Drive, Boynton Beach?
14. A. That is not correct. That is a house.
15. Q. That's where you live now?
16. A. That's where we live now.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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Q. And that's just a single-family home?
A. That's a single-family home.
Q. Okay. And now, did Mr. Epstein contribute any money to the purchase of any of these properties?
A. He contribute the -- he contribute the $20,000 towards the purchase of the first property.
Q. Well, the first property was back in 1983?
A. No. No. The first property at
Q. That's apartment 1902?
A. 1902.
Q. Did he contribute any other money towards any of the other properties?
A. No.
Q. So you paid $590,000 for the property at without the assistance of Jeffrey Epstein?
A. That's correct. I had a loan, took a big loan on that.
Q. So he had absolutely nothing to do with your purchase of that property?
A. Nothing.
Q. And he contributed nothing towards any -- to the purchase of any of the other properties that I mentioned?
25 A. Nothing.
PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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Q. Okay.
MR. BERGER: Mark this as Exhibit 4, please.
(Exhibit number 4 was marked for identification purposes.)
BY MR. BERGER:
Q. Look at Exhibit 4, sir. It's two pages. And it's from Florida Department of State, Division of Corporations?
A. Yeah.
Q. And would you turn to the next page, the second page?
On the second page, do you see your signature and your wife's?
A. Yes.
Q. And do you recognize this as an application for registration of a fictitious name?
A. Yes.
Q. And is that -- did you and your wife apply for registration of a fictitious name?
A. Right. This was done by our lawyer, Fetterman.
Q. And was that done in January of 2003? Look in the upper right.
A. Yes.
Q. Is that correct?
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A. Uh-huh.
Q. Yes?
A. Yes.
Q. And the fictitious name was Properties, correct?
A. That's correct.
Q. And did Jeffrey Epstein have anything whatsoever to do with the registration of this fictitious name?
Q. The next Exhibit, sir, has papers from the Department of State, Division of Corporations. Do you see it makes reference to___Up at the top.
It says: "Detail by officer/registered agent name." And then under that it says, "Florida limited liability company."
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A. Where is that, sir? Just point it.
Q. Then it says, is that right?
A. Yes, sir.
Q. Then do you see the next couple pages includes a letter from Adam Fetterman to the Department of State? Do you see that?
A. Yes, sir.
Q. And then the next -- the next page is an articles -- articles of organization for Florida limited liability company. Do you see that?
A. Yes, sir.
Q. And then on the very last page, is that your signature?
A. Yes, sir.
Q. Okay. Is that your application to organize the Florida limited liability company,
A. Yes. I just sign it. This was done by the lawyer.
Q. Did Jeffrey Epstein have anything to do with the creation of this company?
A. Absolutely nothing.
Q. Did Jeffrey Epstein pay for Mr. Fetterman's services to do this?
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A. Absolutely no.
Q. Now, this was -- this it appears to have been incorporated in August of 2003. Do you recall that? Does that sound correct?
A. Yeah.
Q. And between December of 2002, when you left Mr. Epstein's employment, and August of 2003, when you incorporated did you speak to Jeffrey Epstein?
A. Never spoke again.
Q. Or with anybody on his behalf, such as his staff or an investigator for him? Anybody?
A. Nothing.
Q. Okay. Did you go to his home between January and August of 2003?
A. No. Except twice, the two incidents that it happened.
Q. But those -- and those happened later, after August of 2003, correct? Those happened either --
A. Yeah. I never went to the home for any reason to talk to him or to anybody.
Q. Okay. So in September and October when you went to Mr. Epstein's house --
Q. -- uninvited, --
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A. Uh-huh.
Q. -- you just assumed that he would have money in his briefcase?
A. I assume.
Q. You hadn't talked to him in nine months; is that your testimony?
A. That's my testimony.
Q. And you said that you needed that money because of a woman that you were mixed up with?
A. That's correct.
Q. What's her name?
A.
Q. And where does she -already forgot the name.
A. I'm sorry.
Q. Where is she now? Where does she live?
A. I have no idea. She left -- she left the state. She was a girl from Brazil. The biggest mistake of my life.
Q. And then you said during the questioning of one or two of the attorneys that you entered into a separation agreement with Mr. Epstein that included a confidentiality agreement and a release. Do you
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remember saying that?
A. Yeah.
MR. CRITTON: Form.
BY MR. BERGER:
Q. And those were signed by you?
A. And Mr. Epstein.
Q. And was that signed after the October incident?
Q. When you left?
A. No. This was signed in January 2003.
A. Right after I left.
Q. Okay.
A. Right after I left, it was done through the office in New York. Mr. Epstein never spoke to me again. It was done through the lawyers in New York. They send me the paper via Fed Ex. They send us a check. That was the end of it. That happened in January, January 2003.
Q. Do you have a copy of those documents?
A. Not in here.
Q. Do you have them at home?
A. Yes, I do.
Q. And let me just make sure I know what the documents are.
There's a separation agreement?
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A. Just a separation agreement.
Q. And that includes a confidentiality provision?
A. It was a -- there's a provision inside.
Q. And it also includes in it a release or is the release separate?
A. I don't know. Lawyer terms. I'm not familiar with that.
Q. Did you have a lawyer represent you in connection with that?
A. No. I never need it.
Q. And you said Mr. Epstein paid you $30,000 to you and $20,000 to your wife?
A. That's correct.
Q. And how was that paid to you?
A. Cash -- I mean, check. It was a check but it was taken -- taxes were taken out. So it was minus taxes.
Q. Was it one check for each of you?
A. Yes.
MR. CRITTON: Can we take a five-minute break?
MR. BERGER: Sure.
MR. CRITTON: Do you want to finish one line of questioning?
MR. BERGER: No, go ahead. Go ahead.
VIDEOGRAPHER: Off the record at 2:15.
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(Brief recess.)
VIDEOGRAPHER: We're back on the record at 2:21.
BY MR. BERGER:
Q. How many times have you talked with investigators of Mr. Epstein?
A. One time.
Q. And that's the one time that you've mentioned already?
A. Yes.
Q. And have you met -- talked to Mr. Critton before today?
A. Oh, wait a minute. Sorry. I have to go back on that. Twice. One time when the criminal case started when they, like, find the card and Jeffrey says, I cannot talk to you, somebody will call you. I talked the investigator that I told you.
And the second time was, I guess, you -- I don't know who was it, but they send -- they send me the -- I don't know if it was an investigator or they just give me your notice that I was going to be subpoena.
MR. CRITTON: I think that came from Mr. Willits' office.
MR. WILLITS: Jack Hill's office.
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MR. CRITTON: That wasn't an investigator. It was a subpoena server?
THE WITNESS: Yeah.
BY MR. BERGER:
Q. Process server. Process server.
Now, this is Mr. Robert Critton. Have you talked to him before today?
A. Yes, sir.
Q. How many times have you talked to Mr. Critton?
A. Once in my house. And we talk about ten minutes yesterday? Monday? Monday?
Q. Yesterday?
A. Yesterday.
Q. Okay. And what did you discuss?
A. Discuss the same questions that you telling me. And he told me basically, say the truth. Tell the truth, nothing but the truth. And be firm and be -- speak your mind and don't be afraid.
I thought that this incident about my life never would have come out. I wish it would have never come out. But I guess it come out and it's too late.
Q. Well, you know what this case is about, don't you?
A. Of course. I think it's a case against Mr. Epstein. But it's not a case against me, is it?
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Q. No.
Q. No.
A. Oh.
Q. And you know it's --
(Brief interruption.)
BY MR. BERGER:
Q. And you know it's a serious case for the people that are bringing it?
THE COURT: Form.
THE WITNESS: Absolutely.
BY MR. BERGER:
Q. So you had this conversation with Mr. Critton yesterday?
A. Not about the seriousness, no.
Q. No. No. But the conversation that you had with Mr. Critton was yesterday, correct?
A. Yes. Told him he -- he told me basically he was going to be here, that a bunch of lawyers were going to ask me questions and that I should be truthful and nothing else, basically.
Q. Well, what else did he say?
A. What else did Mr. Critton says? Nothing. He asked me about my health, because I was in the hospital this week. He asked me how I felt.
And I says, well, I want to get this done. I want to get it over, done, and go on with my life for
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the rest of my life. I want to finish with this. I don't want nothing to do with Jeffrey Epstein or this case, once and for all.
| 4 | Q. Did you talk to him about the confidentiality agreement that you mentioned? |
| 6 | A. No. |
| 7 | Q. Or the separation agreement? |
| 8 | A. No. |
| 9 | Q. Or the arrest? |
| 10 | A. No. |
| 11 | Q. Or the $30,000 that you were paid? |
| 12 | A. No. |
| 13 | Q. Did he tell you that this case that we're here about-- |
| 15 | A. $30,000 where? What $30,000? |
| 16 | Q. You said you were paid $30,000 and your wife was paid $20,000. |
| 18 | A. Yes. Yes. The separation agreement. No. |
| 19 | No. |
| 20 | Q. You didn't talk about that? |
| 21 | A. No. |
| 22 | Q. Did he tell you there were young women suing Mr. Epstein? Did he tell you that yesterday? |
| 24 | A. No. He mentioned to me that it was a lot of lawsuits against Mr. Epstein, criminal and civil suits. |
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And -- not yesterday, but when he was in my house with his secretary.
Q. Not yesterday?
A. Not yesterday.
Q. When was he was at your house with the secretary?
A. About two months ago, a month and a half ago.
Q. You can't look to him to answer. You've got to answer.
A. I cannot remember exactly the date, but I would say it was about a month ago.
Q. Maybe I misunderstood. Was Mr. Critton at your house yesterday?
A. No. He called me yesterday.
Q. He called you yesterday?
A. Yes, sir.
Q. And you talked for about ten minutes yesterday on the phone?
A. No more.
Q. Did you tell me everything that you and Mr. Critton talked about yesterday?
A. Yes.
Q. Now, he visited your house --
A. Yes.
Q. -- a month and a half or two months ago --
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| 1 | A. | Absolutely. |
| 2 | Q. | -- with his secretary? |
| 3 | A. | Yes. |
| 4 | Q. | And did she take notes? |
| 5 | A. | Yes, she did. |
| 6 | Q. | Pardon me? |
| 7 | A. | She did. |
| 8 | Q. | She took notes. Just by pen and paper? |
| 9 | A. | Pen and paper. |
| 10 | Q. | Not a machine like the court reporter? |
| 11 | A. | No. |
| 12 | Q. | Were you taped? Did somebody tape record you? |
| 13 | A. | No. |
| 14 | Q. | Did he show you the notes that she took down? |
| 15 | A. | No. |
| 16 | Q. | Typed up and show you the transcript? |
| 17 | A. | No. |
| 18 | Q. | No? Now, how long was Mr. Critton at your house then? |
| 19 | A. | For about half an hour. |
| 20 | Q. | And did you know that he was coming? Did he call ahead of time? |
| 21 | A. | Yeah. |
| 22 | Q. | And, so, what did you expect was going to happen? |
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A. He was going to come in and ask questions about this case.
Q. So what did he say?
A. Same questions that you guys are asking me, exactly the same questions.
exactly the same questions.
Q. Nothing more?
A. Basically what you saw, what you did, what your job description was, what you did, how you start your day, how was your day and how was -- what time you started, what time you finish and what you did, and what was your responsibilities. And that was it.
Q. Okay. And were you paid anything for that?
A. Absolutely not. The only money that I got, it was from you for this $47 check for coming in here.
Q. Okay.
A. And I will take no money from nobody.
Q. Okay. Were there -- were there any other times that you talked to either Mr. Critton or anybody from his office?
A. No.
Q. You described every time that you've ever talked to either Mr. Critton or people from his office?
A. No, sir.
Q. You've described all those times that you've talked to Mr. Critton or people from his office? I'm
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not asking the question clearly.
Did you talk to Mr. Critton any other time?
A. No. I talked to Mr. Critton twice, once in my house, once yesterday.
Q. Now, how about Mr. Jack Goldberger, Mr. Epstein's criminal defense attorney, did you ever talk to him?
A. No.
Q. Did you ever talk to Alan Dershowitz about any of these matters?
A. No, sir.
Q. Or Roy Black?
A. No, sir.
Q. Now, I'm just going back over some different things that you mentioned.
You said that there was a Roladex that you created of names of women?
A. Not it was a name just woman. It was companies, air condition companies. It was cleaning companies. It was suppliers. And it was -- it was a Roladex that I left it there.
Q. Did you have a list of girls on your Roladex?
MR. CRITTON: Form.
THE WITNESS: No. We had a list of girls in a -- in a -- in a sheet with plastic that we have
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all the massage therapists. It was two pages or three pages of people in a plastic sheet that we had it where -- by the telephones. That was it.
BY MR. BERGER:
Q. Have the names?
A. Names and phones.
Q. Telephone numbers?
A. Uh-huh.
Q. What about addresses?
A. No, no addresses.
Q. What about dates?
A. No, sir.
Q. And who prepared the list?
A. Either Ms. Maxwell -- Ms. Maxwell.
Q. Was it typed?
A. Yeah. They were types.
Q. No. Typed.
A. Yeah.
Q. Who typed it?
A. I don't know who type it, but it came from New York.
Q. The list?
A. Yeah.
Q. Did you -- did you give the information that went into the list?
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1 A. No.
| 2 | Q. Where was the list kept? |
| 3 | A. In many places. It was in Mrs. Maxwell's desk. It was one in the kitchen, one in my office, one in my room because sometimes I was in my room and I have to call these people. It was one in the new house when they build the new house. It was all over. And it was also those -- those files for the house -- the house running operation. |
| 4 | Q. Was it the same list that was in all those places? |
| 5 | A. Basically, yes. |
| 6 | Q. Was the list updated? |
| 7 | A. Yes. |
| 8 | Q. Did you keep a copy of the list? |
| 9 | A. No, I don't have a copy of the list. |
| 10 | Q. When you left Mr. Epstein's employment, you didn't take a copy with you? |
| 11 | A. Not at all. |
| 12 | Q. And when you worked for Mr. Epstein, you didn't write notes about what you did and what you saw? |
| 13 | A. No. |
| 14 | Q. No? |
| 15 | A. No. I had too much to do. |
| 16 | Q. You didn't put anything in a computer about |
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what you saw at the house?
A. No, sir.
Q. Did you ever talk to your wife about what you saw at the house?
A. Like what? Saw about what?
Q. About the dildos. About the massages. Did you ever talk to your wife about that?
A. Yeah. And that's one of the reasons that I never send my wife after -- this hap -- these dildos and things like that happened right at the end of my stay there. It never happened before. Right at the last couple months before I left. And that --
Q. And that's when young girls --
MR. CRITTON: Let him finish his answer.
THE WITNESS: And my -- my worry about was that my wife will panic. And I never send her up there to clean up the rooms or anything else.
BY MR. BERGER:
Q. Is that when young girls started coming to the house?
MR. CRITTON: Form.
THE WITNESS: One girl that I can think of.
BY MR. BERGER:
Q. Just one?
A. One girl. That girl that she show me the
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1 picture.
Q. V.R.?
A. That's the only one that I can think she was young, but I don't know how old.
Q. Do you still have the transcript from -- from the police in front of you, from the State Attorney's Office?
It's below that. It's at the bottom. Keep going.
You see? Turn to page 9.
Page 9. Now, look at me. It says, page 10, but it also says page 9.
So you got page 9?
A. Page 9 and page 10.
Q. Okay.
A. Oh, okay. Page 9. Okay.
BY MR. BERGER:
1. Q. Let me just make sure you're on the right page. Yeah.
It says, answer: "No, sir. Mostly no. We saw one or two young ones in the last year."
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Do you see that?
MR. CRITTON: Form. It's taken out of context. There's no question.
BY MR. BERGER:
Q. Do you see those words?
A. Did they seem -- did they seem young to you? No, sir, mostly were no. We saw two young ones in the last year.
Q. Well, it actually says, "we saw one or two young ones in the last year."
A. "We saw one or two young ones in the last year. Before that they were all adults."
Q. The one or two young ones in the last year that you're referring to, who are they?
A. One was V. and the another one was N.B.
Q. Don't write on that. Okay? Don't write on that with your pen.
Look at paragraph -- look at line 19.
A. Yes.
Q. It says, quote, I remember one girl was young, unquote.
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Q. Who were you referring to?
Q. And then you see under that at line 22, it says, quote, but I imagine she was 16, 17. In my judgment she was 16, 17, unquote.
Do you see that?
MR. CRITTON: Form.
THE WITNESS: Yeah.
BY MR. BERGER:
Q. Were you referring to MR. CRITTON: Form.
THE WITNESS: I think so, yeah.
Oh, can I read this again?
BY MR. BERGER:
Q. Sure, go ahead. Take your time.
A. "During the last year while you were working for him, what do you mean, they look young? Did they look like they were still in high school? Yes. And the only one that I knew was in high school was N. I remember one girl was young. We never ask her how old she was. I never asked N. how old she was. I think she was in the last year of high school.
Right. Understand.
Question.
But I imagine she was 16, 17. I don't know.
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In my judgment she was 16, 17."
I was talking about, I was referring about N. at that time.
Q. So at line 22, look at line 22.
A. Yes, sir.
Q. It says, quote, but I imagine she was 16, 17, unquote.
You were referring to who?
A. To N.
Q. Okay. You can put that down.
You mentioned Joe Joe. You said Joe Joe was the house man in New York?
A. Yes. I met Joe Joe.
Q. And do you know his full name?
A. Joe Joe work with his wife. They were Funtanella (phonetics), Funtanella. Joe Joe and Lynn was his wife, Funtanella.
Q. When is the last time you talked to them?
A. Wow. Never talked to them again in over ten years.
Q. Now, you mentioned in response to Ms. Ezell's questions, you said something about father. Do you remember talking about that?
A. Uh-huh.
Q. How do you know that person was her father?
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A. Because either she told me or Ms. Maxwell told me that her father used to work at Donald Trump's place. And she -- I think he is the one who bring her to the house that afternoon, the first time I saw drive in at this -- Donald Trump's house.
Q. Now, you said you know -- you knew who Alan Dershowitz or you know who Alan Dershowitz is, right?
A. Many times.
Q. And he was at the house?
A. He's been at the house a lot of times.
Q. Was he ever at the house when there were naked women at the house?
A. No.
Q. No?
A. They were never naked woman at the house, sir.
I remember one occasion when one English girl -- I think she was English or German girl -- came to the house. And usually in Europe they use topless, they don't wear anything. But she was taking the sun outside and she came to the house with nothing on and I chase them out. I says, not in this house. You don't do it. You go outside, put the towel and come in here. Because she came to get something from the kitchen wearing nothing. And I did not allow that.
Q. But when Alan Dershowitz was there, were there
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any women that were topless?
A. No, not that I can remember.
Q. What about when Prince Andrew was there?
A. Not that I can remember, sir.
Q. Did you ever see Alan Dershowitz walking around naked?
A. No, sir.
Q. How about Prince Andrew?
A. No, sir.
Q. You mentioned your divorce, that it cost -- it cost money. Did Jeffrey Epstein pay for anything connected with the divorce?
A. Absolutely nothing.
Q. Let me go back for a minute to the confidentiality provision in the separation agreement.
Did you -- did you discuss with anybody why there had to be a confidentiality provision? Did you talk to somebody about that?
A. No. No. I discuss it with Mr. Epstein when he told me, he finally come out and says,- I know they were going to try to replace us. And -- and we got upset because I was not ready to leave yet. But at the same time we were expecting to be left out. And I left there before they decide to let me go.
And I went to -- I remember very clearly, I
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went to his office in the pool house and it was -- I talk to him and says, - I went with some faxes that came to my office and they were people interviewing for my job. So I feel very pissed about it.
And I went to his office and said, Jeffrey, what is this? And what is this? And what is this?
He says, well, that's Ghislaine. I'm not involved into that.
And I says, okay. We're going to leave, Jeffrey. That's it. We're done. And what you going to do for me?
And he says, well, what you want?
And I says, give me at least a year's salary.
And that's what it turn out to be, around $50,000, plus the van.
And he says, okay wish you good luck. And the last day I was there we shake hands and we left.
But my relationship with him, it was good. It was friendly. At the beginning of the -- my job was very friendly. Then he changed when Ms. Maxwell come in. I didn't like to work for her. She was a bitch. And she make us life hell. And that's why we left. But it was not with Mr. Epstein.
Q. Do you know why there was a confidentiality provision in your agreement?
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A. No. That's lawyer stuff. I don't know.
MR. BERGER: Okay. That's all I have.
CROSS EXAMINATION
BY MR. CRITTON:
Q. Mr. Alessi, my name is Bob Critton, as you know, and I represent Mr. Epstein.
A. Yes, sir.
Q. You've been -- this deposition started at 10:00. It's almost -- it's closing in on 3:00 but for about 45 minutes or an hour that we took for lunch. I'm going to try to be relatively brief so we can get you out of here. Okay?
A. Okay, sir.
Q. You've been asked questions by five different lawyers who represent various Plaintiffs in this case.
A. Yes, sir.
Q. In some instances you've been asked the same question multiple times?
A. Yes, sir.
Q. The testimony -- you've also been asked a number of questions about your separation from Mr. Epstein sometime at the end of December of '02 and the entrance or your entering into a separation agreement with him?
A. Uh-huh.
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Q. Correct?
A. Yes.
Q. And subsequently there was an incident in 2003 that you've described in some detail, based on the questions that have been asked, and you and Mr. Epstein reached an amicable agreement; you repaid him the monies that you had taken and you parted?
A. Yes.
Q. Is that a fair statement?
A. And I will have to add something to that. When we talk at the luncheonette, we have coffee, he says, if you were not my best employee that I ever have and that you would not take care of my mother, I would have put you away. And that's the way he come out to me.
And I says, I like you and let's -- just pay me back in one or two weeks, because I send the money back and it got lost. So he give me another -- not him, but his lawyer says, you got another month to pay. So between I got the money -- the money order was lost in the mail. So I send it back. I pay everything, $6,310. I think it was 6310. And that was it.
Q. And I'm more interested, not so much in the details but the color, so to speak, the lawyers have put on this, is, is that as a result of
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your separation from Mr. Epstein in late-2002 and the incident in 2003, that somehow you have colored your testimony to help Mr. Epstein today.
And my question to you is: Have you told us the truth today as to every question that's been asked and the questions that are going to be asked of you?
A. To every one of you.
MR. WILLITS: Object to the form of the question.
BY MR. CRITTON:
Q. And with regard to the agreements that you entered into with Mr. Epstein, in particular the confidentiality agreement, you were asked a question by Ms. Ezell whether you understood that you're not bound by confidentiality today. And you responded in the affirmative, right? You understand that you're to tell us -- to answer every question fully to the best of your knowledge?
A. Absolutely.
Q. And that you have done today?
23 MR. WILLITS: Object to the form of the question.
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Q. You told us off the record -- and I don't know whether it was on the record, so I want to be clear because you've been sitting here a long time. You're currently under care and treatment for having chemotherapy; is that correct, sir?
A. Yes, I have.
Q. And I think you told us earlier that you were in the hospital two days last week?
A. Last week, yeah.
Q. And, so, we've -- you've done great. You've probably done better than the lawyers today. But you'd like to get this over today and finished?
A. I hope so.
Q. All right. There have been a lot of questions about your job description and duties at Mr. Epstein's. And if I understood it correctly, is basically, once you became the full-time house manager, you were responsible for all aspects of the operation of the El Brillo residence?
A. I was.
MR. WILLITS: Object to the form of the question.
BY MR. CRITTON:
Q. And during the time that you were responsible for all aspects of the El Brillo residence, that
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included not only maintenance and repair, but appropriate staffing, laundry, cleaning, shopping, cooking, whatever -- whatever needed to be done at the home?
## A. That's correct.
MR. WILLITS: Object to the form of the question.
BY MR. CRITTON:
Q. And during the time that you were there as the full-time -- as the house manager from 1992 up until December of 2002, you did all those different types of responsibilities; is that a fair statement?
MR. WILLITS: Object to the form of the question.
Q. And at some point -- let me strike that.
The original deal, so to speak, that you cut
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A. Left.
Q. -- was no longer Mr. Epstein's -- Dr. Eva Anderson was no longer Mr. Epstein's girlfriend,--
A. That's correct.
Q. -- and a new girlfriend came in and that was Ghislaine Maxwell?
A. That's correct.
Q. And when Ms. Maxwell came in, she, in essence, took over as your immediate supervisor?
A. That's correct.
Q. During the time that you worked for Mr. Epstein, did you have a good, excellent, fair, what was -- how would you describe your relationship with him?
A. Good, excellent or fair.
I will think good.
Q. And did you interact with him very much or does he interact with anybody very much?
A. He doesn't interact very much. At the early years, yes, he did come to the kitchen and we used to sit down in the kitchen and he would discuss my kids, my family, his family, and he will talk to me.
At the end of my stay there, it was -- I was -- we were told not even to look at his face. Not even to -- this was done by -- this was even done by,
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they hire a Countess from Europe to write this book and to write ideas of how the house of royalty should be.
And that's the way Ms. Maxwell wanted the house to run, as a royal house. And I was pissed off at that and I never agreed with that and I never went with the book.
I threw the book away. And that was it.
MR. CRITTON: Let me move as non-responsive to my question. Move to strike.
MR. WILLITS: He should allowed to finish what he thinks is responsive to your question, even if you don't agree.
BY MR. CRITTON:
Q. Were you finished, sir?
A. Yes, I finish.
MR. CRITTON: See, he's finished.
MR. WILLITS: He wasn't, but okay.
BY MR. CRITTON:
Q. I'm trying to -- listen carefully to my question because I'm trying to get you out of here sooner rather than later.
If I understood your testimony is, is that, you had -- you considered your relationship with Mr. Epstein to be good during those years?
A. Good.
Q. And would you describe your relationship with
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Ms. Maxwell as not being as good?
A. Yes.
Q. When -- you were -- you had an opportunity over lunch, Mr. Berger gave you a copy of a statement that you gave to the State Attorney's Office on November 21, 2005, we've marked as Exhibit, I think, Exhibit --
MR. CRITTON: What did we mark it as, 2?
THE WITNESS: At what page?
MR. WILLITS: Yes. It was 2.
MR. CRITTON: Thank you.
BY MR. CRITTON:
Q. No, just statement, the whole statement.
You had an opportunity to look at it over lunch?
A. Yes.
Q. And that's a statement you gave back on November 21st of 2005?
A. Uh-huh.
Q. Is that correct?
A. That's correct.
Q. And at that time you were there with Mr. Murrell, who was your attorney. And you gave a statement and I think as well your wife spoke with the State Attorney's Office?
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A. That's correct.
Q. And whatever questions the State Attorney asked of you at that time, I assume you fully answered; is that correct?
A. Absolutely.
Q. And then page 9 where Mr. Berger took you with regard to the questions -- and before I get -- I'm going to come back to page 9 in a minute.
But if I understood your earlier testimony in response to one of the lawyers who asked you questions, is, there were a number of European women, all who you deemed to be 20-plus years old, that would travel with Mr. Epstein to various places and as well would come to the house from time to time?
A. That's correct.
Q. And I think you testified in response to Mr. Berger's questions today, is that the only female that you understood that came to the house during the time that you were the house manager who you knew to be under the age of 18 was N.B.?
A. That's correct.
Q. And you knew she was under 18 because you would pick her up from high school?
A. That's correct.
Q. And that's a young girl who I think you
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A. 16，17.
Q. And I think you said she never was involved in giving any massages to Mr. Epstein?
A. I don't think so, never.
Q. And the times that you saw her, Mr. Epstein was mentoring her on a career which ultimately turned into her becoming an actress?
A. I think so. Yeah, that was the main purpose.
Q. And on multiple occasions when she would be over, she would be over there at Mr. Epstein's home with her mother; is that correct?
A. Yes, that's correct.
Q. And of the girls that came or the women that came to give massages to Mr. Epstein over the years you were there, I think you've described on page 9 of your deposition that you may have seen a hundred or 200 different massage therapists?
A. It could be less. I don't think it's more than 200, but it could be less than 200, yes. It was -- it was 11 years or 12 years or 13 years of constant people going in and out and people that were coming to the house, he will bring for another state, he will bring in his planes. People that it came from Europe, massage therapists, there were men and woman. They live
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in Miami, we -- so it was so many that I cannot remember how many.
Q. Okay. And I understand that. I'm just referring back to your statement where it says at page 9, line 9, the question was: "Yeah. Yeah. Not the same girl. I mean, during 11 years I probably saw a hundred, 200 different massage therapists."
Do you see that?
A. Yes.
Q. All right. And if I understood your testimony is, the ones the -- that is, of the massage therapists, as you've just described, you saw some men?
Q. You saw more women?
Q. And all of the women, at least from your viewpoint, were 18, 19 or older?
MR. CRITTON: Why don't you change your tape right now.
VIDEOGRAPHER: Off the record at 2:54.
(Brief recess.)
VIDEOGRAPHER: We're back on the record at 24 2:55.
25 BY MR. CRITTON:
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Q. In the 11 years that you worked for Mr. Epstein, with regard to the massage therapists -- and I'm talking about all of them, women, men, the ones that were 18, 19, 20, or the ones that were older -- did you ever see -- or, first of all, did you ever hear any complaints about -- from the massage therapists about the massage they had given to Mr. Epstein?
A. No.
Q. Did you ever see a massage therapist during those 11 years that appeared to you to be distraught?
A. Never.
Q. To be in some form of a shock?
A. Never.
Q. To be scared?
A. I never see anybody scared.
Q. Did you ever see someone who looked like they were upset or crying?
A. No, sir.
Q. I think you, in response to Mr. -- well, not sure who asked the question -- but they -- you were asked whether you ever spoke to the individuals --
A. Yes.
Q. -- when they came down. And I think you said from time to time you might have some small talk with
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them afterward?
A. Yeah.
Q. Did you usually see them if they came down?
A. Yeah.
Q. So you would have had an opportunity to observe their appearance, correct?
A. That's correct.
Q. Have you seen people who look distraught, in shock, scared, upset, angry in the past -- not massage therapists -- have you seen people in your life experiences?
A. Oh, yeah, yes.
MR. MERMELSTEIN: Object to the form.
BY MR. CRITTON:
Q. So if -- well, let me ask it this way: In your life experiences before you worked for Mr. Epstein, and, in fact, during the time you worked for Mr. Epstein, have you seen individuals not associated with Mr. Epstein who appeared to be distraught, in shock, scared, upset, angry or injured?
A. Yes.
MR. MERMELSTEIN: Object to form.
BY MR. CRITTON:
Q. Have you seen people who appeared to you to have been traumatized by a particular event?
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MR. MERMELSTEIN: Object to form.
THE WITNESS: Yes.
BY MR. CRITTON:
Q. Have you seen people who seem to be -- well, I assume you've seen people who have yelled or screamed as a result of some event that had occurred in your presence?
A. Yes.
Q. On the massage therapists that you saw at Mr. Epstein's house from 1992 up until the time you left in December of '02, did you ever see any type of reaction, distraught, shock, scared, upset, crying, disheveled, injured, disoriented, yelling or screaming for help at any time?
A. No, sir.
Q. Once the massage -- once -- let me strike that.