3504-022 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002615 EFTA00157568 answers in response to your questions. MR. LANGINO: Thank you. BY MR. LANGINO: Q. One thing I wasn't sure about was the date of your employment. When did you start with Mr. Epstein? A. I am not sure, sir, but I think I started full time on my salary, I was on the roll in 1991. 1991, January 1, 1991. Q. In 1991, you started full time with Mr. Epstein? A. Yes, working for him alone. I left all my clients, I left -- dissolved my company. Q. And in what year did you start part time at his house? A. 1990. '90. Q. You mentioned earlier that some of the massage therapists you paid with checks? A. Yes. Q. And some of the massage therapists you paid with cash? A. Sorry. Can you repeat the question? Q. Sure. You mentioned earlier that you paid some of the massage therapists with checks and some with cash? A. Yes, sir. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend (901-817-479-2888) | | | Electronically signed by Sandra Townsend (901-817-479-2888) | Requested / Fet. R. Conn. P. Gen) Marina | | GU 53BP303NA RESPONSE D0201 | | Q. Were there any general differences between those massage therapists that you paid with checks and those that you paid with cash? A. No, sir. It was -- when I was there always was a hundred dollars an hour rate. That was for everybody. Q. Did you ever hear Jeffrey Epstein talk about his massages? A. No, sir. Q. At one point you said that you're not -- this might be summarizing your testimony -- that you may not be the best guesser of ages. Is that something that you may have said earlier today? MR. CRITTON: Form. THE WITNESS: Yeah. Yeah. I think I -- you can be thirties, twenties. I don't know. BY MR. LANGINO: (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | [401]-017-419-2895 | saf3ca0-c08a-4d4f-b0d1-aad32ca57de | | Electronically signed by Sandra Townsend | [401]-017-419-2895 | saf3ca0-c08a-4d4f-b0d1-aad32ca57de | | FDA Confidential Treatment Requested / Facet R, Coln, P - Gej Material | GU SUPERVISION 600058 | | massage therapists that came to give massages? A. That's correct. Q. How come you said that a couple of times today? MR. CRITTON: Form. THE WITNESS: You asked me. They asked me. I think I just answer questions. BY MR. LANGINO: Q. As you reflect back in your time working for Mr. Epstein, today do you believe you turned a blind eye to some of the ages of the women or females that worked for Jeffrey Epstein with massages? MR. CRITTON: Form. THE WITNESS: Can you repeat the question? BY MR. LANGINO: Q. Sure. As you sit here today and reflect back on your time working for Jeffrey Epstein, do you believe you turned a blind eye or ignored, purposely ignored the ages of the females that gave him massages? MR. CRITTON: Form. THE WITNESS: I don't know. I don't -- I cannot -- I'm not a judge. I don't know. I don't know. I don't think so. Sincerely, I don't think so. BY MR. LANGINO: 3504-022 Page 2 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002616 EFTA00157569 Q. When you were working for Mr. Epstein, did you have any doubt that the girls who provided him messages were not of the proper age or not older than 18 years old? MR. CRITTON: Form. THE WITNESS: No. BY MR. LANGINO: Q. Did you keep up with Mr. Epstein's -- keep informed of Mr. Epstein's criminal case while it was in the paper? A. Only what was on tv. What it was on tv, that's how I found out. Q. How do you feel about Mr. Epstein today? A. I feel bad, sincerely I feel bad, because he was -- with me, with my family, with my wife, he was a very generous guy, extremely -- I don't know what the word is in English -- but he would press for perfection. I mean, and that was a very stressful job. But, otherwise, I have no problems with him at all. And I feel bad about it, what's happened in his life. Q. Have you had any contact with Mr. Epstein after you ended working there? A. After I work -- after I end working with him? Yes, I did. When this case, when this criminal case | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend [401-377-6758-2988] | | | Electronically signed by Sandra Townsend [401-377-6758-2988] | Requested / Fat. R. Crim. P. Oce] Infrared | | GU SILBP3019A_RESPONSE CODE 0003 | | started, I got home and I had a card, a business card from a police officer. I think it was from the Palm Beach Police Department. And -- and I got scared. And I was trying to find out what it's all about. Because it was an occasion with Mr. Epstein that we had a disagreement. We settled that. Everything was well and we went our friendly ways and never heard from him again. And I received this from the police department that we need to talk to you. And, so, I got scared. And I called the office in New York. I says, I would like to speak to Mr. Epstein. And he come on, and I said, I told him, I says, Jeffrey, what's going on? What's happening? I thought it was related to the problem that I had personally with him settled. And I says -- no, he says. And he says to me, no, John, it's nothing to do with that, has nothing to do with it. I've been -- I don't know if he told me I been sued or I been -- it's a problem with me, they're investigating something and I cannot talk to you. That was the end. And that's it. Q. Any other conversations with Mr. Epstein -- A. No. Q. -- since that conversation? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (481-217-476-2898) | | | | Electronically signed by Sandra Townsend (481-217-476-2898) | Jafalca0-c018e-b8f8-b8d1-ba2c2b618de | | | FOAJ Confidential Treatment Requested / Pac. R. Corn. P. Box. Material | | | | SU JUBEPCNA RESPOBNB 000004 | | | | (561) 832-7500 | PROSE COUNT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (AP1-377-405-3881) | | | | Electronically signed by Sandra Townsend (AP1-377-405-3881) | | | POE Compliance Support Requested / Fest. R. Coln. P. Gei Internal GU SUPERVISORA BOOKSTORE A. No. Q. At some points you were caught stealing from Mr. Epstein; is that true? A. We settled with him as a borrowing money from him. Okay? MR. BERGER: As what? THE WITNESS: Borrowing. MR. LANGINO: Borrowing. BY MR. LANGINO: Q. When you took the money from Mr. Epstein, -- A. Yes, sir. Q. -- did he give you permission to take that money? A. No. Q. At any point did you take a firearm from Mr. Epstein? A. No. Q. At any point did you enter Mr. Epstein's property when you were not allowed to be there? A. Yes. Q. And was that the incident where you took some money from him? A. Yes. Q. Can you explain to me how you and Mr. Epstein came to an agreement that the cops would not be called? A. He called me and he say, John, we need to talk. I says, okay. Where? And -- and we met at a luncheonette in Palm Beach and we have a friendly conversation. He asked about my kids, about my family. Then -- is this related to Mr. Epstein's case? Q. It is. A. Because I prefer to keep this -- this -- I was not incriminated. I was not -- I went to the police department. I made my statement and there was no charges filed. I don't think I would like to continue with this. MR. CRITTON: Let me just put on the record as I think it's completely irrelevant, immaterial, it's not calculated to lead to the -- THE WITNESS: And it was after -- MR. CRITTON: Let me just finish putting my objection on. As I understand it, it occurred long before he ever got the card from the police. I think you're harassing him. I think you're trying to intimidate him and I think it's inappropriate. BY MR. LANGING: 3504-022 Page 3 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002617 EFTA00157570 And I want to end it there. I have no -- nothing -- I think my stay there, in reflecting the job, I was not paid well enough for what we did. And too late now. Q. The overall theme of my question is: The fact that Mr. Epstein chose not to get you in trouble with the police further, trouble with the police -- A. Uh-huh. Q. -- so many years ago, has today that caused you or pressed upon you to maybe soften your testimony or change your testimony at all? A. Absolutely not. Q. Have you ever spoken with any independent investigators regarding the actions, the criminal actions that occurred at Jeffrey Epstein's home? A. Yes. Q. When did that occur? A. Right after I receive a card from the police department, when I call Jeffrey and I ask him, what's going on? He says, I cannot talk to you. Somebody will talk to you. And then I got a call from this guy that I cannot recall his name now. Talked to me and we met at Carabbas. And we talked -- what? -- about 15 minutes. And he asked me questions just like you guys are asking me and I says exactly the same answers. And he says, well, there's an investigation against Jeffrey. You has nothing to do with it. You | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend (405-371-6788) | | | Electronically signed by Sandra Townsend (405-371-6788) | | | FOR CONTACT TERMMENT REQUESTED / Fed. R. Conn. P. Bix) Material | | | GU SUBPOENA RESPONSE 003017 | | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | Electronically signed by Sandra Townsend (409-371-4798-2882) Electronically signed by Sandra Townsend (409-371-4798-2882) [Fax Complaint Number Requested / Fed. R. Conn. P. Gee] [Mail Id] GU (SUPERIORESPONSE 000571) have nothing to do, nothing to worry about it, but if you want to hire a lawyer to protect yourself. And I asked -- my question to him was, I don't want to get incriminated into something that, you know, somebody trvining to incriminate me for --for my job. And he says, no, no, no. But if you want to get a lawyer, that's fine. And that's where I got Mr. Murrell and he just came to us, to sign this, to -- that was the end of it. Q. Who got Mr. Murrell for you? A. Who got it? Mr. Epstein. Q. When you met with this investigator at Carabbas, -- A. Yes. Q. -- did he record your conversation -- A. No. Q. -- in any way? After this meeting at Carabbas, did you meet with any other investigators? A. No. Q. After -- during your inspection of the massage room after these massages had been completed with Mr. Epstein, -- A. Ub-huh. Q. -- do you remember seeing any -- anything that you would describe as blood? A. No, never. Q. Do you remember seeing anything that you would describe as a sexual fluid? A. No, never. Q. When you worked for Jeffrey Epstein, the woman that you were married to, what is her name or -- what is her name? A. The woman that I was married to? Q. I think -- the reason I'm asking is because earlier today when you first spoke, I thought I remembered you saying that you -- both you and your wife -- A. That's my -- Q. -- worked for Mr. Epstein? A. It's still my wife. It's still my wife. We didn't -- we got two ways away from a divorce and the lawyers were taking my money by pipeline. Q. And what is her name? A. And we decide not to divorce and we still together. Q. Sorry. I missed that. But what is her name? A. Maria Alessi Q. Let me just look through my notes to see if I have any other questions. Page 4 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002618 EFTA00157571 A. Yes, we did at the same time. Q. You testified that you would come into the bedroom and clean up after messages; is that correct? A. That's correct. Q. Did you -- were there occasions where you had your wife help you with that? A. No. No. Q. Were there -- did she have occasion to go into the master bedroom? A. It was occasions before that she will help to set up the tables once in a while, set up the oils and the tables. But I will do the clean up after. Q. Is there a reason for that? A. I was more involved into the final appearance of the house. And it was my responsibility to make sure that every room was perfect after they left and before they went to bed. Q. Was there anyone else who assigned your wife work other than you? A. No. Ms. Maxwell, sometimes she would tell my wife, go buy some stuff, go get this and go get that. She was mostly -- my wife was mostly out of the house. She was -- this house was Mr. Epstein would says, go get me this book, go get me this magazine, go get me tickets, movie tickets for this show and this show and | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (461-201-878-2895) | | | | Electronically signed by Sandra Townsend (461-201-878-2895) | | | | FOA Confidential Treatment Requested / Fast R. Crin. P. Gei Material | | | | GU SUPERVISION RESPONSE 008/075 | | | this show. And she would have to travel -- and I was on the phone with my wife constantly, buy this, get this, get this -- and the food, and the food because it was a five-star hotel. Q. Did Ms. Maxwell or Mr. Epstein ever instruct your wife to do housecleaning tasks? A. No. I was blamed for everything. Q. You were blamed for everything? A. I was blamed for the good and the bad. Q. Did you -- during the time your wife was there, did you also have a hired housekeeper? A. We have a crew of housecleaners. We have a crew of people that would come to the house and do a serial -- I mean, deep cleaning, you know, to the house. Q. Was that every day? A. Once a week -- no, it was twice a week. It was Tuesday and Fridays. It depends on Mr. Epstein’s schedule because he didn’t -- he didn’t want nobody at the house while he was at the house. So we have to rearrange days for the clean-up crew to come in. And I usually did that. As soon as they left I bring the cleaning crew, get the house ready and -- and get set for them for the next trip. Q. Did you have a housekeeper who did | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Banda Townsend (491-377-470-3888) | Electronically signed by Banda Townsend (491-377-470-3888) | Jafc3ca8-c89a-4b8f-8d11-ba29caa87de | | Electronically signed by Banda Townsend (491-377-470-3888) | POA Confidential Treatment Requested / Pac. R. Crim. P. Rxl Material | GI JUSTA RESPOWERC 000378 | 3504-022 Page 5 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002619 EFTA00157572 housekeeping tasks on an everyday basis while you were employed there? A. No. Before my wife went in? Q. No. After your wife. A. No. No. Not a full-time housekeeper. Q. But you said your wife was hired after the housekeeper left? A. Yes. Q. But -- so the person who left before your wife came, was she doing housekeeping chores? A. Yes, she was doing the housekeeping chores. Q. Well, who did it then after your wife became employed there, because she wasn't doing the housekeeping? A. I was. I was doing it and then we hire people for to help us. Q. So you were the main person doing the housecleaning? A. Yeah. Q. And during -- between that time that your wife started and when you left the employment, was there a separate housekeeper employed during that time? A. No. Full time? No. Q. Full-time housekeeper? Page 102 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | HB1-777-475-2895 | | | Electronically signed by Sandra Townsend | HB1-777-475-2895 | | **FOR COMMUNICATION REQUESTED / Fed. R. Conn. P. 6e) Material** **GU SILBERGINA RESPONDENCE IDS?** A. No. Q. What about a part-time housekeeper? A. No. Like I told you, daily basis we call this company. And then they will come in with four or five girls and clean the whole house. Q. This is the crew you were talking about? A. The crew. Q. But the crew didn't come when Mr. Epstein was there? A. Right. Q. So on an everyday basis when Mr. Epstein was there, you were the only person who was cleaning? A. Me -- yeah, or my wife will help. Q. At your instruction? A. That's right. Q. But you don't ever remember her cleaning up after massages? A. No. No. Q. Is it possible that you instructed her to clean up? A. It's possible, but -- MR. CRITTON: Form. Asking him to speculate. BY MR. MERMELSTEIN: Q. You can answer. A. It's possible. Q. When girls would come to give a massage, where would they come in the house? Would they come to the front door? A. Mostly came to the back kitchen door. Q. The back kitchen door? A. Uh-huh. Q. Okay. And is there a bell there? Would they knock or how would they -- A. There's a door bell. Q. A door bell? They would ring the door bell? A. Uh-huh. Q. And who generally would answer the door? A. Me or my wife. Q. So you would let them in? A. Uh-huh. MR. CRITTON: Stuart, can I just ask you? You use the term, girls. I assume you just mean, that means female woman. It can mean anything? It has no age bracket to it? MR. MERMELSTEIN: That's correct. I'm not referring specifically to ages right now. THE WITNESS: No. BY MR. MERMELSTEIN: Q. So as I understand it, the girl would come to the kitchen entrance, which is the service entrance, | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Towerwood (801-371-6798, 2001) | | | | Electronically signed by Sandra Towerwood (801-371-6798, 2001) | Jafh3cau0-b55e-b84d-b841-loa22tcaus1de | | | PDA Confidential Treatment Requested / Fst. R. Crim. P. Kejl Material | | | | GJ/SUBREQN RESPONSE 00079 | | | ## correct? A. Uh-huh. Q. You have to say yes or no. A. Yes, sir. Q. If you answer uh-huh, that's not clear, so you have to answer yes or no. A. Okay. Q. And you would typically open the door? A. Yes, sir. Q. And what would happen then? A. Then I will keep her in the kitchen and go to Mr. Epstein and find out where they want to have the massage, or if it was for him or for Ms. Maxwell. And I immediately, if they were reunite girls that are -- they will know exactly where to go. And I will go up with them, set the tables, and they will wait for him or her to go in the room and they sit there until they come up. Q. So did you generally already know that they were coming at the time that they knocked on the door? A. Yes, uh-huh. Q. So you had an appointment schedule? A. Yeah. Because most of the times I was doing the calling, you know. I called J., come in at 3:00 this afternoon. And she will told me, no, I cannot, get somebody else. And I knew it the time they were coming. | (561) 832-7500 | PROSE COUNT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Banda Tewaswala (HP1-ITT-675-189E) | | | | Electronically signed by Banda Tewaswala (HP1-ITT-675-189E) | POE Certificate (Requested) | Batchc04-c08e-49f9-8d01-ba2b0cae27de | | | TEWASWALA TRANSFER (Resolved) | Material | | | SUBSIDIARY RESOURCE 00038 | | 3504-022 Page 6 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002620 EFTA00157573 | 1 | So I was expecting them most of the time. | | 2 | Q. So you would expect them, they would come in and then you would escort them upstairs? | | 3 | A. Uh-huh. | | 4 | Q. So -- | | 5 | A. I'm sorry, sir. | | 6 | Q. Yes? | | 7 | A. Yes. | | 8 | Q. But first you would find Mr. Epstein and check to see if he's ready or find Ms. Maxwell to check to see if she's ready? | | 9 | A. Yes. | | 10 | Q. And which staircase would you -- would you take them up? | | 11 | A. Either way. | | 12 | Q. You would take them either the main staircase or the servant staircase? | | 13 | A. Yes. | | 14 | Q. Why would you take the main staircase, since you're already in the kitchen? | | 15 | A. That's what I says, either way. We can go through the main staircase or we go to the kitchen staircase. So we use both. | | 16 | Q. Okay. Well, I'm talking specifically to escort a girl upstairs. | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | HHF-377-479-0295 | | | Electronically signed by Sandra Townsend | HHF-377-479-0295 | | | FDA Confidential Treatment Requested / Fed. R. Crin. P. 6(1) Material | | | | QJ15BSP039A1RESP039D0081 | | | A. I escort the girls up there either way, both ways. Q. And, so, when you walked to the upstairs bedroom, let's take the example of when Mr. Epstein is getting a massage? A. Yes. Q. Mr. Epstein wouldn't be up there yet; is that correct? A. That's correct. Q. He would be downstairs somewhere? A. Uh-huh. Q. Would there be a place -- MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. -- where he would normally be while, you know, he's waiting for the massage to be set up and ready? A. Yes. Q. Where is that? Where would he be? A. Either at his desk or the pool house. Q. And those were on the first floor? A. Yes. Q. And, so, when you arrived at the top of the stairs with the girl for the massage, what would you do then? A. Go back to my duties. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Barbara Townsend | [801] DTT-479-2888 | | | Electronically signed by Barbara Townsend | [801] DTT-479-2888 | | | PDIA Confidential Treatment Requested | Fac. R. Cnm. P. Exx. Material | | | DJU BJBPOENA MISSPERMEN 000001 | | | | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend(449)-317-876-2895] | | | | Electronically signed by Sandra Townsend(449)-317-876-2895] | | | | FOA Confidential Treatment Requested / Fed. R. Grin, P. Gee (Material | | | | GU SUPERPOIGNE RESPONSE 000/85 | | | Q. You would just leave? Would the massage table already be set up? A. He knew already that the girls -- the girl went upstairs and it was up to him to come up. Q. Did you have conversations with any of these girls? A. Sometimes. Q. What kind of things would you talk about? A. Regular things. Nothing that I can remember. Nothing. Just... Q. Did any of them ever tell you their ages? A. No, sir. Q. Did any of them ever assure you that they were 18? MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. Or over? A. No, sir. Q. No one ever mentioned anything about age? A. No, sir. Q. How did the girls appear to you? Did they appear to be very young? MR. CRITTON: Form. THE WITNESS: Again, the same question you ask me. Everybody ask me the same thing. They could have been 16 or 20. Most of them were, I would say, over 20. And some woman, it was over 60. And one time she came to the door. The husband was waiting outside. And Ms. Maxwell saw this woman, that somebody recommend her. And Maxwell says to me, John, you have to find an excuse. We don't want her. So I had to pay this woman and find an excuse that they going to have to go. And she -- they never had a massage with her. But there was -- most of them were womans. They were not girls. BY MR. MERMELSTEIN: Q. So the woman who was over 60 was sent away; she was rejected, correct? MR. CRITTON: Form. THE WITNESS: It was -- I was told to send her away. BY MR. MERMELSTEIN: Q. And it was your understanding when you were told to send her away, it was because of her age, correct? MR. CRITTON: Form. THE WITNESS: I don't know. I don't know. I was told to send her away. 3504-022 Page 7 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002621 EFTA00157574 BY MR. MERMELSTEIN: Q. What was your understanding as to why they were sending her away? MR. CRITTON: Form. Asked and answered nine times now. MR. MERMELSTEIN: He hasn't -- he hasn't answered my question yet. MR. CRITTON: He has. MR. MERMELSTEIN: Go ahead. THE WITNESS: Why? BY MR. MERMELSTEIN: Q. Please answer the question. A. Can you repeat the question? Q. What was your understanding as to why they sent her away? MR. CRITTON: Form. THE WITNESS: My understanding was either they were busy or they didn't want her. BY MR. MERMELSTEIN: Q. What was your understanding as to why they didn't want her? MR. CRITTON: Form. Harassing. THE WITNESS: I don't know. I didn't -- I didn't make too much of it. BY MR. MERMELSTEIN: | (561) #32-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) #32-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | [881] 777-476-2898 | 2aaf3cad0-0b9e-d6f9-b0d1-a2d2cae8%7da | | Electronically signed by Sandra Townsend | [881] 777-476-2898 | POA Confidential Treatment Requested / Fast, R. Grin, P. Gipi Material | | GU JSLSBPB-RESPONSE CODE: | | | Q. But every other woman or female who came over to give a massage was much, much younger, correct? A. Yes. Q. So this 60 year old woman was a significant exception, correct? MR. CRITTON: Form. Argumentative. BY MR. MERMELSTEIN: Q. You can answer. A. I don't know how to answer that question. You ask me to -- Q. Let me ask you this. MR. CRITTON: Why don't you let him answer the question before you interrupt him. BY MR. MERMELSTEIN: Q. All right. Go ahead. Please answer. It didn't look like you were -- A. I don't know how to answer that question, you asking me what is your opinion of that. And I told you, my opinion of that, either they saw the girl -- I don't think Mr. Epstein ever saw the woman. But Ms. Maxwell saw the woman in the kitchen. And she told me, John, pay her and send her away. Q. Okay. A. That was it. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | [491] 837-476-2395 | | | Electronically signed by Sandra Townsend | [491] 837-476-2395 | Requested | Fec. R. Cim. P. Exc. Materials | | | GU JUBILIO DE LA RESERVA | 000388 | Q. So Ms. Maxwell looked at the woman? A. Right. Q. Did she have a conversation with her? A. No. Q. She just looked at her and then said to you to send her away, correct? A. Yeah. Pay her and send her away. Q. Do you recall seeing women who came to give massages who were in their 50s? A. Yes. Q. There were women in the 50s? A. Yes. Q. How often did that happen? A. Not too often, but it was -- it was woman that they were in the 50s. I says, again, could have been 49, 45. I don't know. I don't know the ages, but it older woman. Q. How many middle-age women do you recall coming over to give massages? MR. CRITTON: Form. THE WITNESS: I don't remember how many, but I would say was, I would says, in the 40s. And she came very, very often. And I understand she was a massage specialist and a yoga instructor, too, at the same time. So that was one of -- and there was another woman that she was supposed to be a teacher at the school of massage therapy that I can't remember her name. But that's it. I mean... BY MR. MERMELSTEIN: Q. So those two you remember who were older? A. Two. And it was a couple guys that were older that -- some guys that were older, too, guys. Q. Did Mr. Epstein ever have massages done by men? A. Yes Q. And did Mr. Epstein ever have massages done by these older women? A. Yes. Q. When you escorted the female in this case for the massage to the upstairs bedroom -- correct? -- you would then leave? A. Yes. Q. You would then walk back downstairs? A. Yes. Q. Correct? And would you then -- would you -- you had already told Mr. Epstein that she's there, correct? A. That's correct. 3504-022 Page 8 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002622 EFTA00157575 Q. And at some point later then Mr. Epstein would come upstairs, correct? A. That's correct. Q. And where would you go? A. To my duties, to the kitchen or to my office. Q. And I think you testified earlier that the doors of the bedroom would be closed during this massage? A. He would close the door. Q. So Mr. Epstein, when he would arrive upstairs, would close the door? A. Yes, sir. Q. And about how long would the massage last generally? A. Usually an hour. Q. And what would happen at the end? A. They would come down. Most of the repeat girls, they would bring the towels themselves and dump it by the kitchen by the laundry room we had there, in order to help us. Other girls, they just left it up there and they would come down. Either Mr. Epstein will pay or I will pay them. Q. Did they -- A. Or Ms. Maxwell will pay them. Page 114 Electronically signed hp Sandra Teewandell 4817-375-4829B5) Electronically signed hp Sandra Teewandell 4817-375-4829B5) Safety3ca0-c88e-4b8d-8d91-1a280caa87e9 FDA Confidential Treatment Requested / Fort, R. Crin, P. 6jej Material GU S18BP00N4.USR18P00N1.0009E Q. Did Mr. Epstein walk down with the girls or did he stay upstairs? A. Sometimes, sometimes no. Sometimes he took a nap or he took a shower. I don't know what they did in the room. I don't know. I don't know. Sometimes he went down right away. Sometimes he stay up there. Q. So when they came down, they would go to the kitchen; is that correct? Q. And were you there waiting for them or did you have -- A. My office was right next to the kitchen, so I was there -- and the kitchen was the focal point of the house basically. So they have to go to the kitchen either to get pay or to go to their cars. Q. Did you converse with any of the girls when they came down after the massage? Q. Did you ever observe a girl who appeared upset, surprised, shocked, anything of that nature when they came down? | (soil) | 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | 465-377-4752-0885 | | | | Electronically signed by Sandra Townsend | 465-377-4752-0885 | | | | FDA Confirmation Treatment Requested | I.Pac. R. Cem. P. Bio Material | | | | GU SUSPENDA RESOURCES | 002390 | | | A. A hundred dollars a massage. Q. A hundred dollars a massage? Were there ever any exceptions? A. That's the -- I never pay any more than a hundred dollars per massage. Q. Were there times when two girls came? A. Two girls came at the same time? Q. Correct. A. Yeah. There were times when two girls come in at the same time and one will go to one room, the other will go to the other room. Or one -- I would set up two tables in his room or I will ask him, where you want to set the massages? He will told me, set in the blue room and set them in my room. Or set them in Ghislaine's room and the red room, depends on who people were there. But there were times where two of the girls at the same time, yes. Q. Was there ever occasions where there was a girl who waited downstairs while one -- while the other girl went upstairs? A. No. Q. That never happened? A. I cannot remember. Q. Was there ever an occasion where you paid a girl who waited and didn't actually give a massage? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend (881-777-8758, 2888) | | | Electronically signed by Sandra Townsend (881-777-8758, 2888) | FOA Confidential Treatment Requested / Fed. R. Crin, P. Gee] Material | | GJ SUPPONDA RESPONSE 003981 | | A. No. Q. That never happened? A. Never happened. Q. You mentioned that Mr. Epstein put you in contact with Mr. Murrell; is that correct? MR. CRITTON: Form. THE WITNESS: Not Mr. Epstein. BY MR. MERMELSTEIN: Q. Huh? A. It wasn't Mr. Epstein. Q. Mr. Epstein's investigator put you in contact with Mr. Murrell? A. That's correct. He gave me his name. Q. And did you pay Mr. Murrell out of your own pocket? A. No, I didn't pay nothing. Q. Who is -- what was your understanding as to who was paying for Mr. Murrell? A. I don't know. I don't know who was paying for it. Q. You never asked Mr. Murrell who was paying his bill? A. No, he never send me a bill. Q. Did you think that Mr. Murrell was doing it for free? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Trownered [481-157-478-2988] | Electronically signed by Sandra Trownered [481-157-478-2988] | Jafalcaid-c988e-468f-ba1b39caad7de | | POA Confidential Treatment Required / Fed. R. Corm. P. Bux Material | POA Confidential Treatment Required / Fed. R. Corm. P. Bux Material | GI SUBPOENA RESPONSIBLE 000929 | 3504-022 Page 9 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002623 EFTA00157576 A. I don't know. Q. You don't know. As far as you know, Mr. Murrell could have been providing you legal services for free? A. No, I don't think it was provided me for free. I don't think he ever -- that question ever come out of Mr. Murrell. I was in Mr. Murrell's office for about ten minutes. And he says, well, I meet you tomorrow there -- and that's it -- in order to protect you so they don't incriminate you in any way. We left it at that. He never send me a bill. He never send me -- I never talk to Mr. Murrell again, never saw him again. Q. And you never had any kind of understanding with him as to how -- A. No. Q. -- how his bill was going to be paid? A. No. Q. Did you sign any kind of what we call, a retainer agreement, anything where you hired him? A. No. MR. CRITTON: Just so you know, you have an attorney -- nobody's going to tell you this apparently. You have an attorney/client privilege. Any | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Rachel Tweedall [481-377-651-2995] | | | | Electronically signed by Rachel Tweedall [481-377-651-2995] | | | | FOA Confidential Treatment Requested / Fed. R. Crim, P. Gosl Material | | | | OJ SLEMONT RESPECTS DOCUMENT | | | conversation that you had with Mr. Murrell, you and your wife, is completely protected, as long as you want to assert that privilege. You can either assert it or not assert it. That's your right. But nobody's apparently going to tell you that, at least Mr. Mermelstein is not going to tell you that. MR. MERMELSTEIN: Well, I was trying to avoid -- MR. CRITTON: Well, you're asking questions of what he said. MR. MERMELSTEIN: I'm not asking them what they said. MR. CRITTON: Same thing. MR. MERMELSTEIN: I'm asking him how he got paid. MR. CRITTON: No, you were -- read back your questions where you were. Anyhow, that's a right you have, so... So much for the law. MR. MERMELSTEIN: I was not asking him what was said during any conversation. I asked him if he signed a retainer. That's a fair question. BY MR. MERMELSTEIN: Q. Do you remember a girl who came to give | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend | 409-371-485-2880 | | Electronically signed by Sandra Townsend | 409-371-485-2880 | FOR CORRECTIONS Requested | Fax, R. Corm, P. Bix, Material GU SUSPENDA DE CONTOURS (2023) 1. massages there by the name of ___? Does that name sound familiar at all? 2. A. No. 3. Q. Do you remember an ___? 4. A. No. 5. Q. What about a ___? Do you remember anyone by the name of ___? 6. A. No. 7. Q. Was it frequent that girls would come just once and not appear again? 8. A. Frequently. 9. Q. These girls that would come, would they come with their own equipment or supplies? 10. A. No. Some girls, they come in with a table, the new girls they come in with a table. And I would told them, no, you don't need the table. They will leave it in the kitchen because we have tables in every room in the house. 11. Q. Some of the girls, the first time they came they didn't have anything, right? 12. A. They come with that table, one of the tables they hang it in the shoulders, portable tables. But we didn't have portable tables in the room. They were all custom-made tables. 13. Q. Did some girls come without -- for the first time without any supplies at all, whether equipment or lotions or anything of that nature? A. Probably. Q. Did you have a question in your mind as to whether they were professional at this business? A. No. Q. At massaging? A. No. Q. Why not? A. It was not my job. MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. You just didn't think about it? MR. CRITTON: Form. THE WITNESS: If I was told that a girl is coming, my job was to open the door, let her in and let Mr. Epstein decide where he wants his massage. And that was the end of it. BY MR. MERMELSTEIN: Q. Are you aware that sexual conduct between an adult male and an underage female is criminal; it's against the law? MR. CRITTON: Form. THE WITNESS: Of course I do. BY MR. MERMELSTEIN: 3504-022 Page 10 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002624 EFTA00157577 Q. Did you have any concerns while you were working there that criminal acts were occurring with the girls who were coming to the door? MR. CRITTON: Form. THE WITNESS: I had no idea what was going on between them. BY MR. MERMELSTEIN: Q. Let me just give you some other names. Tell me if you recognize any of these names. A. (Nods head.) Q. Name does not ring a bell? A. (Nods head.) MR. CRITTON: You have to answer out loud. BY MR. MERMELSTEIN: Q. You need to say yes or no. A. No. Q. ? A. Can you repeat that? Q. would be the first name. would be the second name? A. No. Q. ? A. No. Q. ? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 A. No. Q. ? A. No. None of those girls' -- Q. None of those girls ring a bell at all? A. -- name familiar to me. Either they came one time, one day and they didn't even told me their names or -- or he paid for it that I don't have -- but none of those names sound familiar to me. Q. You testified that there were -- about the sex toys that you would pick up after -- after there were massages, correct? MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. The vibrators, correct? MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. You can answer. A. Yes. Q. And you mentioned there was a basket with these vibrators or toys in them, correct? A. Yes. Q. Where was the basket kept? A. In Ms. Maxwell's closet. Q. And that was in the master bedroom? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (401-871-479-2895) | | | | Electronically signed by Sandra Townsend (401-871-479-2895) | | `Safe3ca-b-c8e-e48f-b-891-1ba20c8a85de` | | FOA Confidential Treatment (Requested / Fact, R. Crim. P. Bia) Material | | | | LI 832P01MA RESPOWER 000308 | | | MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. Or off the master bathroom? A. Her bathroom. Q. Huh? A. Her bathroom. Q. And the closet was -- the entrance to the closet was in her bathroom? A. That's correct. Q. And it was a portable basket, she could move it around, correct? A. Uh-huh. Q. You have to say yes or no. A. Yes, sir. Q. And -- and that's where the, I think you used the word dildo, correct? That's where they were located? A. Yes, sir. Q. Was there occasions where you would -- the dildo, one or more dildos would be out and you would clean them up after a massage that only Mr. Epatain had, not Ms. Maxwell? A. It was -- I will says that it was about three or four occasions that I had to take this dildos and put it back where they supposed to be. And I took it with | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (409-317-4769-2895) | | Satc3ca8-c89a-488b-88d1-b020ca87fde | | Electronically signed by Sandra Townsend (409-317-4769-2895) | FOA Confidential Treatment Requested / Fed. P. Crin. P. Koej Material | | | GU SUPERDNA RESPONSE (000-399) | | | gloves and towels and stick it in the sink and throw it in there. Sometimes Ms. Maxwell will have a massage. And sometimes I find it after she's supposed to have a massage, those things. And also when Mr. Epstein had the massage. So I don't know who use it on who. Because sometimes they all disappear up there, Mr. Epstein, Ms. Maxwell and whoever was up there. Q. So as I understand it, you couldn't isolate a particular instant where -- A. I cannot. Q. -- Ms. Maxwell wasn't there, only Mr. Epstein had gotten a massage and then you found the sex toys? A. I cannot isolate that. Q. But it's possible that either Mr. Epstein used it or Ms. Maxwell used it; is that correct? MR. CRITTON: Form. Form. THE WITNESS: I have no idea to know. MR. MERMELSTEIN: All right. I have nothing further. MR. BERGER: How about if we take a break? Would you like a break for a couple minutes? THE WITNESS: No, that's fine. MR. BERGER: Mr. Willits, would it be possible if I could sit there, because I've got a couple 3504-022 Page 11 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002625 EFTA00157578 Exhibits I'm going to show him? MR. WILLITS: Sure. MR. BERGER: Thanks. CROSS EXAMINATION BY MR. BERGER: Q. Okay. Good afternoon, sir. A. Afternoon, sir. Q. My name is William J. Berger and I represent three of the Plaintiffs in this case. Did you ever hear of the name ■, a young woman named ■? A. No, sir. Q. How about a young woman named ■? A. No, sir. Q. Okay. You know, you've referred several times to a falling out or a disagreement that you had with Mr. Epstein? A. Yes. Q. Was that in -- was that the year that you left his employment? A. Right after -- right after I left. Q. So you had a falling out with him after you left his employment? A. Yes. Q. Well, why did you leave his employment? Page 126 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sanita Tewasandi (441-371-478-3885) | | | | Electronically signed by Sanita Tewasandi (441-371-478-3885) | FOA Confidential Treatment Requested / Fed. R. Crin. P. 6(es) Material | bafc3ca8-c88e-bd8f-b891-ba23bca8/78de | | | GUJ SIBP03PA RESPONDENT 008418 | | A. Why? Q. Yeah. A. Because I was sick. I was extremely sick. sick of the job and we had enough. We had good pay, but we had enough of the job, especially because of Ms. Maxwell's attitude towards us. Q. Now, you said you had good pay, but we had enough. What was your pay in 2002? A. 2002, right before I left? I think it was 50, either 55, something like that. And my wife was 30 or 35. I could be wrong. Q. So you think that you were paid $55,000 in 2002? A. Uh-huh. Q. Is that correct? A. That's correct. Q. And you believe your wife was paid how much? A. Thirty, $30,000. Q. $30,000 in 2002? A. Uh-huh. Q. Is that correct? A. Yes, sir. Q. How about 2001, what was your salary and your | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | (405)-317-896-2885 | safc3ca8-cd8e-4b8f-bd1-ba12bcc4a8e | | Electronically signed by Sandra Townsend | (405)-317-896-2885 | POIA Confidential Treatment Required / Fac. R. Crim. P. Bui) Material | | | CU BUPROENA RESPONSES 000402 | | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend (801-371-4782-2883) | | | Electronically signed by Sandra Townsend (801-371-4782-2883) | | **FDA Confidential Treatment Requested / Facil. R. Grin, P. Gee Material** **GU SUEPOENA RESPONSE 006483**
wife's?
A. Same thing.
Q. Okay. And in 2000?
A. I was at the same. It never -- we never got raises. We never got --
Q. I think you said at the very beginning --
A. Yes.
Q. -- of the deposition that you were paid 45,000 when you were first hired full time?
A. Yeah.
Q. In 2002, you were earning 55,000?
A. Uh-huh.
Q. So you did get some raise?
A. Yeah. In the matter of 11 years. Yeah, but we didn't get a raise every six months or every year in any specific date. And the raises were set by the company. Automatically they would come from New York. It was not a negotiate point between me and Mr. Epstein.
Q. And then you said earlier with me, you said we had enough, you and your wife. You said, we had enough; is that correct?
A. That's correct.
Q. What do you mean by that?
A. It was extremely stressful job. It was a lot of pressure on us -- on me, on me -- I have to
correct -- on me. Everything was blamed on me. If a chef cook a bad meal, it was my fault. And if the table was not proper set royalty style, it was my fault. And the hours were terrible, never have a holiday, Saturdays and Sundays. We were working between 60 and 70 hours a week. And my health was, I think, the most important thing. And also the relation with my wife, it was a big factor in us leaving the company. Q. Now, you said that you were blamed for things? A. Yes, sir. Q. Who would blame you? Who is it that would say that you were blamed? A. I don't know who did the blaming, but I will get my ass chewed out by Ms. Maxwell -- Q. She was the one? A. Most of the times, yes. Q. Who else did that? A. Sometimes I had disagreements with him. Q. "Him," being, who? A. Mr. Epstein. Q. About what? A. Simple things. For me, it's stupid things, nothing -- if this paper -- if this pencil was not put in right there, they will complain. Q. Okay. And is it correct that you left the | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend (481-777-6798) | | | Electronically signed by Sandra Townsend (481-777-6798) | 2afc0a8-cd8e-4b91-b891-ba20ca87de | | POJA Confidential Treatment Request / Fict. R. Crim. P. Bai Material | | | GI SUBJ RESOURCE 00040 | | 3504-022 Page 12 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002626 EFTA00157579
1employment of Mr. Epstein in December of 2002? Does that sound correct?
3A. That's correct.
4Q. And the -- now, were you arrested in 2003?
5A. I was never arrested.
6Q. You did speak to the police?
7A. Yes.
8Q. And you did have your statement taken at the State Attorney's Office?
10A. Yes.
11Q. But you -- but that was by an Assistant State Attorney, correct?
13A. Yes.
14Q. The questioning?
15A. (Nods head.)
16Q. Is that correct?
17A. That's correct.
18Q. You spoke separately with police officers though, correct?
20MR. CRITTON: Form.
21BY MR. BERGER:
22Q. In other words, the date of that statement is in October of 2003; is that correct?
24A. Yes.
25Q. And by "that statement," I mean, the
Page 130
transcript that I gave you earlier?
A. At what date, sir?
MR. MERMELSTEIN: 2005.
MR. BERGER: I'm sorry. You're correct.
Thank you. Sorry.
THE WITNESS: 2005.
MR. BERGER: In fact, let's -- Ms. Reporter, would you mark the transcript if anybody needs it?
MR. CRITTON: It's Exhibit 2 now?
MR. BERGER: Is that how you're doing it, just consecutively?
MR. CRITTON: Yeah, let's do it; otherwise, it's going to be an awful mess, have five different Exhibit number 1s by everybody.
(Exhibit number 2 was marked for identification purposes.)
BY MR. BERGER:
Q. You see Exhibit 2? It's a transcript; is that correct?
A. That's correct.
Q. Is that the transcript of the sworn statement that you gave to the Assistant State Attorney in 2005?
A. Yes, sir.
Q. And during the lunch break, did you have an opportunity to read it?
| (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Tremonton | A91-777-478-2986 | | | Electronically signed by Sandra Tremonton | A91-777-478-2986 | | **FOREIGN CONTAINMENT REQUESTED / Fac. R. Cohn, P. Bai Material** **SU JUISPENA RESOURCES GROUP** A. Yes, sir. Q. And do you remember that you were placed under oath when you gave that statement? A. Yes, sir. Q. And is everything that you say in here truthful and correct? A. As far as I know, yes, sir. Q. Okay. Now, in connection with the incident in October of 2003 involving Mr. Epstein's house and your entering his house, that incident? A. It was in October 2003? Q. When do you remember that it was? A. I can't remember. Q. Okay. All right. You spoke with police officers in connection with that though, correct? A. I went to the Palm Beach Police Department. Q. Why did you go to the -- A. I speak to one officer. Q. And why did you go there? A. Because Mr. -- when I spoke to Mr. Epstein and we settle the dispute, Mr. Epstein says, you just need to go to the police department and make a statement. MR. WILLITS: Could I have Exhibit number 2, please? Thank you. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | [491-377-6756-2895] | | | Electronically signed by Sandra Townsend | [491-377-6756-2895] Requested / Fed. R. Crin, P. Gejl | [591c3a8-c16e-4991-bd01-lx25bcaad7de | | GU SUPERPOENA RESPONSE 008417 | | | ## BY MR. BERGER: BY MR. BERGER: Q. Let me see if I understand this correctly. I think you testified earlier that you found a card or you were given a card from a police officer; is that correct? A. That's correct. Q. And as a result of that, you called Mr. Epstein, correct? A. That's correct. Q. Before you got that card, did you have any idea that the police were involved in your life? A. No. MR. CRITTON: Form. BY MR. BERGER: Q. And you called Mr. Epstein after you got that card, correct? A. Yes. Q. Now, how did you get it? Was it mailed to you? A. No. It was putted in my door. I was not home. And they went to my house and they left it in the door. Q. And did it have a note on it, please call? A. Yes. Q. Or was it just a card? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend [AB1-JTT-475] (2009) | Electronically signed by Sandra Townsend [AB1-JTT-475] (2009) | | | Electronically signed by Sandra Townsend [AB1-JTT-475] (2009) | POA Confidential Treatment (Requested) / Fed. R. Crim. P. Box Material | Ref7ca8-c88e-49b1-b4d1-ba29cac7de | | GU JISR CONFIDENTIAL RESPONSE 00040 | | | 3504-022 Page 13 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00002627 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157580 A. It was a -- it was a Palm Beach Police Department, please call. Q. Okay. And you didn't call though; you called Mr. Epstein first, right? A. Yeah. Because I was scared. Q. Why were you scared? A. Because I thought it was of the incident that happens previously. Q. And what was that incident? A. You know that incident. Q. I'd like to hear you describe it for me. A. That incident is, I went to the house and I got some money. Q. What time of day did you go to the house? A. Night. Q. Was anybody home? A. No. Q. Where did you get the money? A. Out of his bag. Q. Out of his? A. Bag. Q. Bag. Briefcase? Bag? A. Briefcase. Q. Briefcase? A. Yes. Q. Now did you -- did you know that there was money in the briefcase? A. Yes. Q. Now did you know that? A. Because I replenish that case many times before. Q. Now, how many months after you left Mr. Epstein's employment did this occur? A. I don't have -- I would says, three to four months. Q. I would just ask a favor of you. The court reporter needs to see your face so she can understand what you're saying. She's looking -- you put your hand in front of your mouth. That's all. Now, when you worked for Mr. Epstein, did you learn that he kept money in that briefcase? A. Yes. Q. And, so, when you went to his house on that occasion, did you just assume that there would be money in the briefcase? A. Yes. Q. And -- and did you take money out of that briefcase? A. Yes. Q. Now, is that the only time that you took money | (561) 832-7500 | PROSE COUNT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | 801-37-479-2890 | 3aht3za9-c86e-4b8f-8901-ba08cce87de | | Electronically signed by Sandra Townsend | 801-37-479-2890 | POIA-Confidential Treatment Requested / PIC. R. Otr. P. Buc. Material | | | GU SUBPORNA RESPOWER 000418 | | out -- A. No. Q. -- of his briefcase? A. It was twice. Q. When was the other time? A. Couple weeks before. Q. What time of day was that? A. At night. Q. And how much did you take out the first time? A. It was a total of $6,300. Q. That's for both times? A. Yeah. Q. Can you break them down? A. I think one time was 81,500. Another time was the rest. Q. Now, you left in December of 2002 and then there were these two incidents that you just described? A. Uh-huh. Q. Did you have any contact with Mr. Epstein in between leaving his employment and the first of these two instances? A. None. Q. And as far as you knew, did anybody see you take the money on either occasion? A. None. 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, John, 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? A. No. MR. CRITTON: Regarding what? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandie Townsend | (491) 377-475-2888 | | Electronically signed by Sandie Townsend | (491) 377-475-2888 | | POPA, Certification & Treatment Requested | Fic. R. Crim. P. Bix) Material | | GJ SUBROSA RESPOWER 000412 | | 3504-022 Page 14 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002628 EFTA00157581 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 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Tawersandi (901-271-8708) | | | | Electronically signed by Sandra Tawersandi (901-271-8708) | FDA Confidential Treatment Requested / Fed. R. Orn. P. Gej Material | Jaf3c3a4-489e-4581-8901-ba202ca8f7de | | | OJ SLIBMP3_RESPONDENTS.DOOR3 | | approximately 8:24 hours, I was dispatched to a burglary at 35B E1 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 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Tewnsen (491-777-478-2986) | | | | Electronically signed by Sandra Tewnsen (491-777-478-2986) | | 3aafc3ca8-cf89e-4d91-bd81-8a202ca6e4de | | FOA Confidential Treatment Requested / Fac. R. Corn. P. Bai Material | | | | GU SUBPORNA RESPORENC 002141 | | | 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. Oh-huh. Q. Yes? A. Oh-huh. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Bandra Townsend (481-1-574-479-2898) | | 3a3c1c08-c08e-44f9-bd1-ba30bcae87de | | Electronically signed by Bandra Townsend (481-1-574-479-2898) | FOA Confidential Treatment Requested / Fed. R. Crin. P. Gej Interim | GJ SUPOGNA RESPONSE 00419 | 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 -- | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (wf1-37749-2881) | Electronically signed by Sandra Townsend (wf1-37749-2881) | Electronically signed by Sandra Townsend (wf1-37749-2881) | | COELEMENT REQUESTED / Fed. R. Ocm. P. Bx) Materia | COELEMENT REQUESTED / Fed. R. Ocm. P. Bx) Materia | COELEMENT REQUESTED / Fed. R. Ocm. P. Bx) Materia | | GI SUBPOENA RESPONSE 00018 | | | 3504-022 Page 15 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00002629 | | :--- | :--- | This is a simple Markdown document with no headings or paragraphs. It contains just one line of text. EFTA00157582 A. No. 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. "The first was over Labor Day weekend, August 30 to September 1, 2003." Do you see that? A. Oh-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? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend [481-317-8768-2898] | | | | Electronically signed by Sandra Townsend [481-317-8768-2898] | | | | FOA Confidential Treatment Requested / Fed. R. Crin. P. Geei Material | | | | QJ S15BP0C9R4.RESPONSIBLE.D001YT | | | ## BY MR. BERGER: ## 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 on August 30 to September 1, 2003? 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? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Bandra Townsend | A91-377-4758-1895 | Bandra Townsend | | Electronically signed by Bandra Townsend | A91-377-4758-1895 | Bandra Townsend | | FOXA Confidential Treatment Requested / Fast, R. Corr, P. 66e Material | | | | GU SUPERPOENA BOOK 8049 | | | 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 my 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, Mr. Alessi. | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (401-317-4978-2895) | | | | Electronically signed by Sandra Townsend (401-317-4978-2895) | P.O.A Confidential Treatment Requested / Pic. R. Crm. P. Koe) Material | Jafk3ca8-c01be-4b88-8b0f-bad2bcaa871de | | GJ SUBSERVICED RESPONSE 000429 | | | 3504-022 Page 16 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002630 EFTA00157583 3504-022 Page 17 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00002631 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157584 3504-022 Page 18 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002632 EFTA00157585 Page 153 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. Page 154 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 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Beverne Townsend | U61-327-0762-2883 | Jafu3ca0-cd8e-bd81-bd81-bd28cac87de | | Electronically signed by Beverne Townsend | U61-327-0762-2883 | Jafu3ca0-cd8e-bd81-bd81-bd28cac87de | | FDA Confidential Treatment Requested / Fed. R. Orn, P. Gee Material | | | | QJU 51L8481_RESPONDING_DOC499 | | | remember saying that? A. Yeah. MR. CRITTON: Form. "Y MR. BERGER: Q. And those were signed by you? A. And Mr. Epstein. Q. And was that signed after the October incident? A. No. This was signed in January 2003. Q. When you left? 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? | (561) 032-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 032-7506 | | :--- | :--- | :--- | | Electrically signed by Sandra Teresasd | 405-377-6876-2818 | | :--- | :--- | | Electrically signed by Sandra Teresasd | 405-377-6876-2818 | | FOIA Confidential Treatment Requested | Fac, R. Crim, P. Bux Material | | SU SUBP06NA RESPORENS 000403 | | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandee Tresmanal (489-377-478-298E) | | | | Electronically signed by Sandee Tresmanal (489-377-478-298E) | | 3a3c3ca8-c08e-a499-b891-b930ca87de | | FOA Confidential Treatment Requested / Fed. R. Crin. P. Gjei Material | | | | GU SUPERVENA RESPONSE 000431 | | | 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. (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. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend | A841-377 476-3885 | | Electronically signed by Sandra Townsend | A841-377 476-3885 | | POA Confidential Treatment Requested / Fac. R. Cim. P. Bix Material | GJ 9U82PROSP2C 000452 | 3504-022 Page 19 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002633 EFTA00157586 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? | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Twemansen | 4801-377-478-2895 | | | Electronically signed by Sandra Twemansen | 4801-377-478-2895 | | [FoA Confidential Treatment Requested / Fed. R. Conn. P. Gee] Material GU 3183BPC018 B.39P0DG5 000323 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, 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 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Tewersenal (831-377-8758, 2980) | | | Electronically signed by Sandra Tewersenal (831-377-8758, 2980) | PDA Confidential Treatment Requested / Fed. R. Crin. P. 6(ii) Material | | GJ SUPERIOR RESPONSE 00435 | |
1the 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.
4Q. Did you talk to him about the confidentiality agreement that you mentioned?
6A. No.
7Q. Or the separation agreement?
8A. No.
9Q. Or the arrest?
10A. No.
11Q. Or the $30,000 that you were paid?
12A. No.
13Q. Did he tell you that this case that we're here about --
15A. $30,000 where? What $30,000?
16Q. You said you were paid $30,000 and your wife was paid $20,000.
18A. Yes. Yes. The separation agreement. No.
19No.
20Q. You didn't talk about that?
21A. No.
22Q. Did he tell you there were young women suing Mr. Epstein? Did he tell you that yesterday?
24A. No. He mentioned to me that it was a lot of lawsuits against Mr. Epstein, criminal and civil suits.
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 -- | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sambra Townsend (405-277-4782-2988) | saf3c2ca8-c88e-4d91-b911-da20xc987de | | Electronically signed by Sambra Townsend (405-277-4782-2988) | POJA Confidential Treatment Requested | Fac. R. Crim. P. Bax) Material | | GI SUBPOENA RESPONSE 000438 | | 3504-022 Page 20 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002634 EFTA00157587
1A.Absolutely.
2Q.-- with his secretary?
3A.Yes.
4Q.And did she take notes?
5A.Yes, she did.
6Q.Pardon me?
7A.She did.
8Q.She took notes. Just by pen and paper?
9A.Pen and paper.
10Q.Not a machine like the court reporter?
11A.No.
12Q.Were you taped? Did somebody tape record you?
13A.No.
14Q.Did he show you the notes that she took down?
15A.No.
16Q.Typed up and show you the transcript?
17A.No.
18Q.No? Now, how long was Mr. Critton at your house then?
19A.For about half an hour.
20Q.And did you know that he was coming? Did he call ahead of time?
21A.Yeah.
22Q.And, so, what did you expect was going to happen?
| (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Tawersendl (481-377-8769)(2019) | 3a4c3ca0-c186-4b9d-b991-a820bc9e87de | | Electronically signed by Sandra Tawersendl (481-377-8769)(2019) | FDA Confidential Treatment Requested / Fed. R. Crin, P. Gosal Material | | QU 318P288R RB320G17 DOSKIT | | 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. 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 $4? 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 | [561] 832-7500 | PROSE COURT REPORTING AGENCY, INC. | [561] 832-7506 | | :--- | :--- | :--- | | Electronically signed by Banda Tresmanad | 401-377-4878 (2988) | 5a8f3ca8-c86e-4889-b901-ba20bca8/7de | | Electronically signed by Banda Tresmanad | 401-377-4878 (2988) | POIA Confidential Treatment Requested / Plec. R. Crim. P. Bio. Material | | | GU SUBPOENA RESPORENS 000108 | | 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 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsendi [401-377-6759-8995] | saf:3ce8-698e-40d8-891a-0928c9aa7fde | | Electronically signed by Sandra Townsendi [401-377-6759-8995] | FOA Confidential Treatment Requested / Feat. R. Corr. P. Gee Material | | GU SUPPORA RESPONSE 008490 | 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? (561) 832-7500 PROSE COUNT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (801-877-476-2990) Electronically signed by Sandra Townsend (801-877-476-2990) POA Confidential Treatment Requested | Fac. R. Conn. P. Box Material GJ SUBPOENA RESPONSE 000448 3504-022 Page 21 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002635 EFTA00157588 Page 165
1A.No.
2Q.Where was the list kept?
3A.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.
4Q.Was it the same list that was in all those places?
5A.Basically, yes.
6Q.Was the list updated?
7A.Yes.
8Q.Did you keep a copy of the list?
9A.No, I don't have a copy of the list.
10Q.When you left Mr. Epstein's employment, you didn't take a copy with you?
11A.Not at all.
12Q.And when you worked for Mr. Epstein, you didn't write notes about what you did and what you saw?
13A.No.
14Q.No?
15A.No. I had too much to do.
16Q.You didn't put anything in a computer about
Page 166 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (401-271-4782-2958) | | | | Electronically signed by Sandra Townsend (401-271-4782-2958) | | | | FOA Confidential Treatment (Requested / Fed. R. Crin. P. 66) Material | | | | QUJ5BSP03U4.RESP03D0001 | | | 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 messages. 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 people meet before I left. Had 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. 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. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Towersent (409-371-479-3886) | | 3afc3ca8-c86e-49f9-4891-ba20ce687de | | Electronically signed by Sandra Towersent (409-371-479-3886) | POIA-Confidential Treatment Requested / PICL. R. Crim. P. Kuc) Material | | | | SU SUBPOENA RESOURCES 000412 | | ## picture. Page 167 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. Q. I want you to see page 9. MR. CRITTON: You want the transcript page 9? MR. BERGER: Yeah. BY MR. BERGER: Q. Let me just make sure you're on the right page. Yeah. Look at line 13. It says, answer: "No, sir. Mostly no. We saw one or two young ones in the last year." | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend (489-327-4758-2898) | 3ahe3ca0c-088e-49f9-89d1-aad02b0ae87de | | Electronically signed by Sandra Townsend (489-327-4758-2898) | FOA Confidential Treatment Requested / Fed. R. Grin. P. Gee! Material | | | GJ SUEPOCNA RESPONSE 000445 | Page 168 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 and the another one was 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. Do you see that? A. Yeah. MR. CRITTON: Form. BY MR. BERGER: [561] 832-7500 PROSE COURT REPORTING AGENCY, INC. [561] 832-7506 Electronically signed by Sandra Tewentman [801-777-478-2980] Electronically signed by Sandra Tewentman [801-777-478-2980] POIA Confidential Treatment Required / Fec. R. Corn. P. Rxj Material GI SUBPCENA RESPOWC 000444 3504-022 Page 22 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002636 EFTA00157589 Q. Who were you referring to? A. 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 I remember one girl was young. We never ask her how old she was. I never asked 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. 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 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 Puntanella (phonetics), Puntanella. Joe Joe and Lynn was his wife, Puntanella. 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 his father. Do you remember talking about that? A. Uh-buh. Q. Now do you know that person was her father?
6Q. Now, you said you know -- you knew who Alan Dershowitz or you know who Alan Dershowitz is, right?
7A. Many times.
8Q. And he was at the house?
9A. He's been at the house a lot of times.
10Q. Was he ever at the house when there were naked women at the house?
13A. No.
14Q. No?
15A. They were never naked woman at the house, sir.
16I 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.
25Q. But when Alan Dershowitz was there, were there
| (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend (861)-327-478-2885) | (561) 832-7506 | | Electronically signed by Sandra Townsend (861)-327-478-2885) | 1afc3ca0<88a-46f9-8481-ba20cae687de | | FXA Confidential Treatment Requested / Fast, R. Crin, P. Qiesi Material | GJ SUPERIOR RESPONSE 808447 | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandie Tawersendal (401-377-4768-2898) | Electronically signed by Sandie Tawersendal (401-377-4768-2898) | saf2cad4-0f86-4d98-8b91-ba202cae7/fde | | Electronically signed by Sandie Tawersendal (401-377-4768-2898) | POJA Confidential Treatment (Request) | Fac. R. Conn. P. Bix) Material | | | GI SUBPOENA RESPOWC 00048 | | Page 23 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002637 EFTA00157590 went to his office in the pool house and it was -- I talk to him and says, John, -- 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, John, 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? Page 174 | (561) #32-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) #32-7506 | | :--- | :--- | :--- | | Electrically signed by Bandra Townsend | (861-071-478-2986) | Saf3cab-c86e-4899-bd91-ba30c6ae71de | | Electrically signed by Bandra Townsend | (861-071-478-2986) | Saf3cab-c86e-4899-bd91-ba30c6ae71de | | FOA Confidential Treatment Requested / Fed. R. Crin. P. 6ej Material | | | | GJ SLB3P0UFAK.RESPONDENCE.000699 | | | A. No. That's lawyer stuff. I don't know. MR. BERGER: Okay. That's all I have. CROSS EXAMINATION
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## BY MR. CRITTON: Q. Mr. Alessi, my name is Bob Critton, as you know, and I represent Mr. Epstein. 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? 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? 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. | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Tremanuel | 801-377-678-2988 | 3a4c3ca8-6f8e-499d-6d91-8a20cea87de | | Electronically signed by Sandra Tremanuel | 801-377-678-2988 | POJA Confidential Treatment Requested / Fact. R. Conn. P. No.) Material | | | GU SJB20C9NA RESPOWER 000408 | | Page 175 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? Q. And I'm more interested, not so much in the details, Mr. Alessi, but the color, so to speak, the lawyers have put on this, is, is that as a result of A. And I will have to add something to that. When we talk at the luncheonette, we have coffee, he says, John, 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. | (561) @32-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) @32-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (406-327-8788) | | | | Electronically signed by Sandra Townsend (406-327-8788) | | | *FDA Confidential Treatment Requested / Fed. R. Crin. P. 6(ii)* Material *GU SUPERVISOR RESPONSE 000451* 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. 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? A. Yes. Q. Okay. MR. WILLITS: Object to the form of the question. MR. CRITTON: | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townewood (409-317-476-2885) | | safc3ca8-c89e-4b8d-b89d-b9a12b9cc87de | | Electronically signed by Sandra Townewood (409-317-476-2885) | | | | POA Confidential Treatment Requested | Fax: R. Crem. P. 50x | Material | | GJ SUBOENA RESPOWER2 00042 | | | 3504-022 Page 24 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002638 EFTA00157591 Page 178 | (561) 832-7500 | PROSE COUNT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (481-377-476-2985) | Electronically signed by Sandra Townsend (481-377-476-2985) | Electronically signed by Sandra Townsend (481-377-476-2985) | | Electronic copy of Requested / Fed. R. Crin. P. Gelt Marasen | Electronic copy of Requested / Fed. R. Crin. P. Gelt Marasen | Electronic copy of Requested / Fed. R. Crin. P. Gelt Marasen | | QJ 515BP3024A_RESPONSE (D0581) | QJ 515BP3024A_RESPONSE (D0581) | QJ 515BP3024A_RESPONSE (D0581) | included not only maintenance and repair, but appropriate staffing, laundry, cleaning, shopping, cooking, whatever -- whatever needed to be done at the home? MR. WILLITS: Object to the form of the question. 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? A. Yes. MR. WILLITS: Object to the form of the question. RY MR. CRITTON: Q. And at some point -- let me strike that. The original deal, so to speak, that you cut was with Mr. Epstein; that is, when you became the full-time house manager; is that true? A. That's true. Q. And some point within -- what? -- a year or so, I think Eva -- Eva -- A. Eva. Q. Anderson -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 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Banda Townsend (409-377-478-0895) | Electronically signed by Banda Townsend (409-377-478-0895) | Electronically signed by Banda Townsend (409-377-478-0895) | | FOIA Confirmed by Townsend Registration员 / Fed. R. Cern. P. Buc Material | FOIA Confirmed by Townsend Registration员 / Fed. R. Cern. P. Buc Material | FOIA Confirmed by Townsend Registration员 / Fed. R. Cern. P. Buc Material | | GU SUPERVISOR RESUME 0004H4 | GU SUPERVISOR RESUME 0004H4 | GU SUPERVISOR RESUME 0004H4 | 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, | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | 409-317-476-2895 | Info@court.ibm.com/409-317-476-2895 | | Electronically signed by Sandra Townsend | 409-317-476-2895 | Info@court.ibm.com/409-317-476-2895 | | FOA Confidential Treatment Requested / Fast, R. Crin, P. Koo | Material | GU SUPPODNA RESPONSE 008495 | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Barbara Townsend | 861-371-478-2985 | Safa3x0d-c8b8-4bb8-8b112bx026871de | | Electronically signed by Barbara Townsend | 861-371-478-2985 | FOIA Confidential Treatment Requested | Fact. R. Corn, P. Box) Material | | GJ SUBPOENA RESPOHS2 000458 | | | 3504-022 Page 25 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002639 EFTA00157592
1Mr. Maxwell as not being as good?
2A. Yes.
3Q. 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,
4Exhibit --
8MR. CRITTON: What did we mark it as, 2?
9THE WITNESS: At what page?
10MR. WILLITS: Yes. It was 2.
11MR. CRITTON: Thank you.
12BY MR. CRITTON:
13Q. No, just statement, the whole statement.
14You had an opportunity to look at it over lunch?
16A. Yes.
17Q. And that's a statement you gave back on November 21st of 2005?
19A. Ub-huh.
20Q. Is that correct?
21A. That's correct.
22Q. 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?
| (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Townsend | 801-571-479-2888 | | Electronically signed by Sandra Townsend | GJ 318-001-4834 Requested / Fed. P. Crim. P. Gies] Interim | | GJ 318-001-4834 | GJ 318-001-4834 | 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? said -- 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 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 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 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (481-377-4784-2985) | | | | Electronically signed by Sandra Townsend (481-377-4784-2985) | | | | FDA Confidential Treatment Requested / Fed. R. Grin, P. Geil Material | | | | GJ SUPERCONA RESPONSE 000459 | | | 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? A. Yes. Q. You saw more women? A. More woman. Q. And all of the women, at least from your viewpoint, were 18, 19 or older? A. Yes. 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 2:55. BY MR. CRITTON: 3504-022 Page 26 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002640 EFTA00157593 Q. Mr. Alessi, 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 Page 186 | (561) 832-7500 | PHOSSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | [491] 777-475-2895 | | | Electronically signed by Sandra Townsend | [491] 777-475-2895 | | | OMA Confidential Telegram Requested / Fast, R. Cron, P. Koej International | | | | GJ SJBPCONPA.DE | D00481 | | ## them afterward? 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? | (561) 832-7500 | PROGE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Banda Trenewed (801-071-478-2888) | | | | Electronically signed by Banda Trenewed (801-071-478-2888) | | Zafi3caal0818e-4899-8011bd30caa87de | | POJA Confidential Treatment (Requested / Fact, R. Crim. P. Bai) Material | | | | SU JUBBORNA RESPORESE 0008Q2 | | | 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. If I understood your testimony, you helped set up -- either you set up the room or you helped set up the massage room? A. Uh-huh. Q. And you might be the person or it might be someone else who would lead the massage therapists or the female up to the room, the male or the female up to the room? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7500 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | sord71-977-459-2884 | | | Electronically signed by Sandra Townsend | sandrastownsend@proseco.com Requested / Fat. R. Crin. P. Oje] Internet | | GJ SUBPOENA RESPONSE 009483 | A. Yes, sir. Q. Once that person was upstairs, you then would come back down and resume your multiple duties downstairs? A. Absolutely. Q. As to what occurred during the course of a massage, do you have any personal knowledge during the 11 years you were there? A. There was absolutely no way to know or to get into the room. The windows were what they have, those automatic electric shutters. They were completely dark, completely a hundred percent dark, the rooms. And it was -- nobody saw it. I knew it when I was at the house that I never saw anything was going on inside. Q. So you have no personal knowledge what occurred during any particular massage? A. Nothing. Q. And I think you said -- well, let me strike that. In other individuals whom you have done work for at big houses in Palm Beach, did those people from time to time have massages, too? A. I never work in a house inside as I did work for Mr. Epstein. Q. Yours was outside maintenance work? Page 188 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7500 | | :--- | :--- | :--- | | Electronically signed by Sandra Treinenman (481-377-478-2898) | Electronically signed by Sandra Treinenman (481-377-478-2898) | 3af3cfa0 c-088a-44d8-b0d1 aa3046e87de | | POJA Confidential Treatment Requested | Fac. R. Conn. P. Bax Material | | | GJ SUBPOENA FRESHWORK 00064 | | | 3504-022 Page 27 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00002641 | | :--- | :--- | This is a simple Markdown representation of the provided image, preserving the original layout with headings, paragraphs, and formulas as they appear. No additional content has been added or removed. EFTA00157594 1. A. I was the maintenance guy outside. 2. Q. All right. And if -- well, let me strike that. 3. You're aware that there's all sorts of spas. 4. The Breakers? PGA? Trump? 5. A. Absolutely. 6. Q. The Ritz Carlton? The Four Seasons? And probably a thousand other places in Palm Beach County? 7. MR. WILLITS: Object to the form of the question. 8. BY MR. CRITTON: 9. Q. Well, let me strike that. 10. Are you aware that there's more than ten places that someone can get a massage in Palm Beach County? 11. A. Of course. 12. Q. Are you aware that there's probably more than a hundred places, maybe a thousand places in Palm Beach County from Boca Raton up through Jupiter and all the way out west where people can get a therapeutic or a massage? 13. A. Yes. 14. Q. And I assume you were aware that -- or were you aware of that during the time period that you worked for Mr. Epstein? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (981-377-476-099) | Electronically signed by Sandra Townsend (981-377-476-099) Requested / Fed. R. Conn. P. 6e1 Material | Jafh3c0d-c8e4-4kM-801-ba20kras61de | | GJ SL5BP02NA RESPONSE (D0068) | | | A. Yes. Q. And I think you told us that you were aware that there were massage schools? A. Yes. Q. And is it your understanding that generally massages are given in a -- in a room with a table where the lights are generally turned down? A. And music on, yeah. Q. All right. You were asked a question about vibrators or I think that the word was sex toys. If you'll turn to page 20 of your statement, sir. If you look at page -- if you just glance at line 9 -- A. Okay. Q. -- through line 22. Take a chance. If you'll just look at that, then I'll ask you a couple questions. Read to yourself, please. Otherwise, the court reporter will have to take down everything you say. A. Yeah. Q. And at least the statement that you gave back in -- on November 21st of 2005, almost -- almost four years ago now, you describe that there were -- that you saw two types of massagers or vibrators; is that | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | @Electronically signed by Sandra Timmersandl (891-377-4785 2898) | saf3ca8-c86e-486f-b991-ba1b8ca87de | | @Electronically signed by Sandra Timmersandl (891-377-4785 2898) | POIA Confidential Treatment Requested / Plec. R. Crim. P. 60j Material | | | SU SUBPOENA RESOURCES 000018 | (561) 832-7506 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | 832-757-495-8881 | 2afc2a8-c0fbe-4b0h-8d4t-b0d1bcaa7fde | | Electronically signed by Sandra Townsend | 832-757-495-8881 | Fet. R. Conn. P. 65e] Marina GU SUPERMEDIA RESPONSE 000487 |
1correct?
2A. That's correct.
3Q. And is that your best recollection, as you sit here today?
4A. That's the best recollection.
5Q. And one of the vibrators, you said was, as you described earlier, looked like a dildo?
6A. Right.
9Q. And --MR. WILLITS: Object to the form of the question.
12BY MR. CRITTON:
13Q. Well, let me ask you this: Was the item that you described, that's described at lines 12, 13 and 14,and 15--12, 13 and 14 on page 20, is that what you described, is that what you were talking about as the dildo?
18A. Yes.
19Q. And I assume you're familiar with what a dildo is?
21A. I know that it's one of those --
22Q. You don't have to describe it. Just are you familiar with what one is?
23A. No, I don't. I'm not really familiar with that type of instruments. But what did I saw it and is
it true now, is it true when I make this statement, it was a big rubber man's -- Q. Penis? A. -- looking penis, with double head, two heads. Q. And -- A. And I don't know how is it even called. And I am sorry. It's a little unpleasant. Q. That's all right. The second item that you described was a neck and back vibrator; is that correct? A. Yeah. They have this vibrators, they have the cordless and they have these balls and they have different types of those vibrators, too. Q. Like you can get them at Brookstone or something like that? A. Yeah. Yeah. Yes, sir. Q. So at least when you were at Mr. Epstein's, and I think as you described in response to lawyer's questions today, is during the last couple of months that you worked at Mr. Epstein's you saw these two vibrators? A. Yes. Q. And on those two occasions you'd take those vibrators, if you went up to clean afterwards, you'd put on your gloves, pick them up with a towel and you'd (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 3504-022 Page 28 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002642 EFTA00157595 clean them off and you’d put them back in Mrs. Maxwell's -- A. Closet. Q. -- closet in her bathroom? MR. WILLITS: Object to the form of the question. THE WITNESS: I put it back in the closet and inside the closet there was a laundry basket that is where she had those. BY MR. CRITTON: Q. And as to whether or not someone actually used those items or how they were used, all you know is you found them -- A. I find it in the sink. MR. BERGER: Objection. Mr. Critton is testifying. Leading. MR. WILLITS: Objection, also, to the form. BY MR. CRITTON: Q. Let me ask you this: Do you know, if I understand it correctly, you found the two vibrators, one for the neck and back and the other one that you described as a dildo, you found them in the sink on those few occasions near the end of your employment? A. Yes. MR. BERGER: Objection. Testifying. Leading. | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (561)-377-476-299G | Electronically signed by Sandra Townsend (561)-377-476-299G | Electronically signed by Sandra Townsend (561)-377-476-299G | | Requested / Fact. R. Crim. P. Gee) Marina | Requested / Fact. R. Crim. P. Gee) Marina | Requested / Fact. R. Crim. P. Gee) Marina | GU SUPPORA RESPONSE CODE: 00099 THE WITNESS: I find it in the sink. BY MR. CRITTON: Q. And then you would clean up and put it back in Ms. -- A. I will put my rubber gloves, get a towel, put them under the sink, run the water and put them in the closet. Q. And you put them back in Ms. Maxwell's closet? A. Closet. Q. Why? Why into her closet? A. Because they were always kept there. Q. All right. You testified earlier, is that if you were going to call someone for a massage, it would either be you or Ms. Maxwell, if I understood you correctly? A. Yeah. Q. Okay. A. At the end -- at the end of my stay was also another girl, that came. And then she was handling everything, as far as calls to these girls. Q. Did Mr. Epstein ever make these calls? A. I never heard. Q. If Mr. Epstein was not in residence, that is, if he was in New York or some place else other than Palm Beach, did you and your wife still stay at the home or | [561] 832-7500 | PROSE COURT REPORTING AGENCY, INC. | [561] 832-7506 | | :--- | :--- | :--- | | Electronically signed by Banda Trowerawan | A81-177-478-2896 | | | Electronically signed by Banda Trowerawan | P11-177-478-2896 | Requested | Pec. R. Cem. P. Exx. Material | | GJ SUBPCNA RESPONSES DEPTS | | | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | 409-317-878-2895 | 3aefc3caf-4c8e-49d9-89d1-1b918bcce87de | | Electronically signed by Sandra Townsend | 409-317-878-2895 | FOA Confidential Treatment Requested / Fed. R. Crin, P. Gaji Material | | Gu SUPROENA RESPONSE 600471 | | | would you go to one of your apartment? A. No. We went to our apartment. Q. And then when he wasn't there, would you have pretty more regular hours around the house? A. Pretty much. Pretty much, yeah. That was the days that we had to have the cleaning crew, I still had to go to the house and oversee the cleaning operation, oversee the gardener because there was not, when they were there the gardener weren't supposed to make noise, so we have to take care of the pool, the chlorine and all that stuff. Q. So you would still do your regular but you could finish pretty much 9:00 to 5:00? A. Yes. That was much easier. Q. And when he was -- how often would he generally be in Palm Beach? A. Too much. Q. All right. But if -- would he be here at least a couple -- A. I would says, at least three times a year -- a month, three weeks a month, three weekends a month. Usually they come in on a Thursday. Either they left a Monday or Tuesday. Q. And then they go wherever else they were going and then things would get back to more of a 9:00 to 5:00 type routine? A. That's right. Q. And if he was in residence, that's when your job became much more all encompassing? A. Exhausting. Q. Okay. You were asked about a female named I think you originally thought it was but ? A. Yeah. Q. You recall now; is that correct? A. Yes. Yes. Q. And I think you described her, I think your recollection was, is that you remember her being at the house the last few months that you worked for Mr. Epstein? A. Yeah. The last few months. Q. And that's the only time that you remember her actually being there? A. Yeah. Q. Because you actually recall when she used to work at Mar-a-lago, and then you recall her starting to come to -- A. To the house. Q. -- Mr. Epstein's home? A. Right. | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend | 409-371-8258-3886 | Jafk5ca8-4188e-4d091-8401-6a20c8aed7de | | Electronically signed by Sandra Townsend | 409-371-8258-3886 | PORA Confidential Treatment Requested | Fact. R. Crim. P. B.) Material | | GJ SUBPORE RESPOWSC 000472 | | | 3504-022 Page 29 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002643 EFTA00157596 3504-022 Page 30 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002644 EFTA00157597 1. Q. With regard to , did it ever appear to you that she was forced to come to Mr. Epstein's home? 2. A. I don't think so. I don't know if it was forced between them, but I never saw force. I never saw -- I was there the first time Ms. Maxwell met her immediately that she went into the spa, when she was walking into the spa. And I was surprised to see that afternoon she was at the house. 3. Q. Did you ever see anyone forcing onto the Epstein's premises; that is, either by grabbing her by the arm or by the hand and dragging her in? 4. A. No. Either her or nobody else. 5. Q. Did you ever see when she came to the home where she appeared to be -- that is, when she arrived at the home to be upset or angry or distraught? 6. A. No. 7. Q. And specifically with regard to when she left on those occasions where you saw her in person leave the house, did she appear to be in the same, I'd say, overall demeanor and mood when she left as she had been when she came? 8. A. Yeah, normal. She was normal. 9. Q. Did she smile? 10. A. Yeah. 11. Q. Say hello to you? | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Trowman (A61-327-478-298E) | Electronically signed by Sandra Trowman (A61-327-478-298E) | Jafu3ca0+b6e+a8fN+b011ba29ca0&de | | Electronically signed by Sandra Trowman (A61-327-478-298E) | FDA Confidential Treatment Requested / Fed. R. Crin. P. Ket Material | GJ SU3BP3004RESPONDENCE0047Y | Q. Did she ever complain to you or seem disturbed by what she thought was going on there? A. No. She never saw anything. Q. Was there ever a guest there by the name of Tommy Matola? A. Tommy Matola? No. Not when I was there. Q. You mentioned this morning that there were some visitors who were very important men, Noble Prize winners? A. Yes, ma'am. 1. Q. Are you -- do you recall a Martin Nowak? 2. A. I think that sounds familiar. If he is an old guy, old man? 3. Q. I think so. Mathematician? 4. A. Yes. 5. Q. Biologist? 6. A. Yes. His name Martin. I recall that, yes. 7. Q. And do you recall a guest, Murray Gell-Mann? 8. A. Mary Gell-Mann? 9. MR. WILLITS: I think you said -- 10. MS. EZELL: Murray. 11. MR. WILLITS: -- Murray and he said Mary. 12. BY MS. EZELL: 13. Q. Murray, Murray Gell-Mann. And, again, I'm speaking of these -- these -- 14. A. Is that a man or a woman? 15. Q. I believe it's a man. 16. A. Murray Gell-Mann. Could be, but I don't recall. 17. Q. Do you recall the name Jerry Edelman? 18. A. No. 19. Q. What about -- can't read my own writing here -- Henry Risorski (phonetics)? 20. A. Henry Risorski, yes. Yes. 21. Q. Was he a frequent visitor or -- 22. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Barbrie Townsend (405) 377-476-3888) Electronically signed by Barbrie Townsend (405) 377-476-3888) PCIA Confidential Treatment (Requested / Pac. R. Clem. P. Box) Material GJ SUBPOENA RESPONSEC 000408 Page 31 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002645 EFTA00157598 A. Not too frequent. But, also, he was a science -- I think so, he was into the science. Q. And Larry Summers? A. Larry Summers. Yes. Larry Summers was a lawyer? Q. I think perhaps he was the president of a college? A. I don't know. Q. No? A. No. Q. Well, then among those that you recall, Mr. Nowak, the biologist and Mr. Risorski, did they ever have massages that you can recall? A. I cannot recall, mo. Q. Was it your impression that Mr. Epstein liked to surround himself with extraordinarily bright people? A. Yes. MR. CRITTON: Form. BY MS. EZELL: Q. And is it your impression, also, that he's rather bright and brilliant himself? A. Yes. MR. WILLITS: Form. BY MS. EZELL: Q. Did -- did you ever gain the impression that | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronicly signed by Sandra Tewnsenl | 1481-377-6782 (298) | 3a4c3caad-cb8e-4d9f-b001-a820ccae7dde | | Electronicly signed by Sandra Tewnsenl | 1481-377-6782 (298) | 3a4c3caad-cb8e-4d9f-b001-a820ccae7dde | | FOA Confidential Treatment Requested / Fed. R. Crin. P. Geei Material | | | | CUJ SBUP303UA RESPONDENCE 000681 | | | he was some sort of brain scientist? MR. CRITTON: Form. THE WITNESS: No. No. No. I know his background. And I -- over the years I learn how he come up and into the business and how he make his fortune. And I don't think he was a brain scientist. BY MS. EZELL: Q. Nobody ever told you that? A. No. Q. If you take a look again at page 9 of the transcript, Exhibit 2? A. Okay. Q. Let me call your attention to line 2, which begins with the question: "Did he have girls come over to give massages?" A. Yes. Q. And you said: "Yes." A. Yes. Q. The next question is: "How many massages would he have in one day?" And I think you said earlier, maybe -- sometimes they'd have three a week? A. No. No. That was not the question. Sometimes he had one, two or three a day. | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Teemann [481-277-6758-2898] | 3a2cbca8-4081-4081-8041-8a20cac8d7fe | | | Electronically signed by Sandra Teemann [481-277-6758-2898] | FOIA Confidential Treatment (Requested) I Fed, R. Conn, P. Ex) Material | | | GU 832BPC61A RP520FN8B 00082 | | | | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sanda Tewresenil (401-371-878-1888) | Safe bsaab-cdbaa-d891-ba01-ba20cc0047e | | Electronically signed by Sanda Tewresenil (401-371-878-1888) | FDA Confidential Treatment Requested / Fed. R. Grin, P. Guej Material | | Gu SUPEPOENA 600485 | | Q. That's what I wanted to ask you. Up to three a day sometimes? A. Up to three a day. Q. And did that happen often? A. Very often. Or he had yoga in the morning or in the afternoon it was a massage. I don't know that again. When it was yoga, it was in the pool house. When it was massage, it was upstairs. So I don't what they did when closed doors, you know. But it was a couple of these girls that were yoga experts and they were massage therapists at the same time, so I don't know. But there were -- many times there were two, three massages a day. Also, she had a massage just about every day. Q. Meaning, Ghislaine? A. Yes. Q. Then on line 12, the question was: "Did the massage therapists seem young to you?" And you said: "Mostly, no. You saw one or two young ones in the last year." A. Yeah. Q. Then, again, still -- MR. CRITTON: Object to form. BY MS. EZELL: Q. -- still talking about the massage therapist, they asked you: "What do you mean, when they looked young?" On line 17. Do you see that? MR. CRITTON: Form. THE WITNESS: Yeah. BY MS. EZELL: Q. Then you go on to say: "I remember one girl was young. We never asked how old she was. It was not my job." And the questioner said: "Right. I understand." And you said: "I imagine she was 16 or 17," -- A. That's correct. Q. -- "in my judgment." A. Yes. MR. CRITTON: Form, I think. BY MS. EZELL: Q. There was -- the only people being discussed in all of this conversation were the massage therapists, right? MR. CRITTON: Form. THE WITNESS: Well, we discuss about this girl that I mention in here. I thinking about her because -- what's her name? 3504-022 Page 32 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002646 EFTA00157599 3504-022 Page 33 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002647 EFTA00157600 Page 213 most of this jobs that she created. Q. And one of those things you also had to do with her was to take her to different spas? A. Yes. Q. And there she would recruit young women to come and do massages? Page 214 A. Because she was English. And she didn't know the area too much as well as I knew. So she -- she says, John, make a list of all the massage -- the spas in the area from Jupiter to Boca Raton. And we went to all the main spas. And then we went to the schools for massage therapists, and all the massage parlors, and massage, the small massage. So I make a list from the telephone book and we would go from one to the another one. I would wait in the car and she goes in. And sometime she took a couple minutes and walk out with cards, business cards. And that -- she did the recruiting. And from then, she pick up the girls and that was the end of it. I never did any recruiting and I never really saw him doing it. Q. You really never saw? A. Never saw Mr. Epstein recruiting anybody. MS. EZELL: All right. I have no other | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandie Tewnsmanal (409) 337-6706-38989 | Electronically signed by Sandie Tewnsmanal (409) 337-6706-38989 | 8a2b2a8c8-eb8e-d89b-bd41-ba202cae87fde | | Electronically signed by Sandie Tewnsmanal (409) 337-6706-38989 | FDA Confidential Treatment Requested / Fed. R. Crin. P. 601 Material | | | | GU 515BP03PUR RESPONDENCE 000899 | | ## RECROSS EXAMINATION questions. Thank you, sir. MR. MERMELSTEIN: I just have a couple follow up. ## BY MR. MERMELSTEIN: Q. Mr. Alessi, I'll be very brief. You testified that a process server came and gave you the subpoena to appear here today, correct? A. Yes. Q. For your deposition? A. Yes. Q. Did you call anyone after you received the subpoena to talk to them about this? A. No. Q. You didn't call anyone? A. No. Q. Did you -- how did you come in contact with Mr. Critton's office to set up the meeting that you discussed? A. His -- his secretary left me a messages on my -- in my machine. Q. And then you called back? A. Then I called back. Q. And you set up the meeting that you mentioned! A. And we set up a meeting for the Labor Day, | (561) 832-7500 | PROBE COURT REPORTING AGENCY, INC. | | :--- | :--- | | Electronically signed by Sandra Transparent (491-377-487-2985) | (561) 832-7506 | | Electronically signed by Sandra Transparent (491-377-487-2985) | 3afc3ca0-c8fe-4b88-801a205ce87de | | FOA Confidential Treatment Requested / Fast, R. Cran, P. Geil Material | | GU SUEPONA RESPONSE 005481 | | | [561] 832-7500 | PROSE COURT REPORTING AGENCY, INC. | [561] 832-7500 | | :--- | :--- | :--- | | Electronically signed by Banda Trowenga (801-771-478-2880) | Electronically signed by Banda Trowenga (801-771-478-2880) | 3afh3ca0-c8ea-489e-b8d1 ba20cac874e | | Electronically signed by Banda Trowenga (801-771-478-2880) | POA Confidential Notification Requested / Fec. R. Cohn. P. Bai Material | SU JUJUBPCNA RESPOWER 000001 |
1Labor Day, Monday.
2Q. What about -- but you said a month and a half ago -- oh, this was before you were subpoenaed, is when you had the meeting at your house with Mr. --
3A. Yes, before I was subpoenaed.
4Q. How did that meeting come about? Now did that get set up? Who called who?
5A. Okay. Before -- I am stuck on this question.
6I don't know. I think it was Mr. Critton office. I think it was Mr. Critton office. They call me. And they left me a message that I must discuss -- call Mr. -- yeah. I had a message in my phone that to call Mr. Critton because he would like to speak to me about Jeffrey Epstein. That was the message.
7And I call it. Then I spoke to him. We set up an appointment. I was sick at that time. And he came to my house and we discussed it.
8Q. Other than Mr. Critton, --
9A. Yes.
10Q. -- in the last few months have you spoken to anyone about the civil cases or your testimony?
11A. No, not even my kids.
12Q. Did you discuss this with your wife?
13A. My wife, yes. My kids, no.
14Q. What did you and your wife talk about?
A. Same thing, what's going on. How bad the situation was. Q. What do you mean, "how bad the situation was?" A. How -- I guess how he got into this mess. Q. How Mr. Epstein got into this mess? A. (Nods head.) Q. Can you be more specific as to what you and your wife said? A. No. It was just the publicity, you know, that his name was on the -- on the magazines and the paper and tv. And I thought that that would never happen. Q. And you and your wife felt bad for Mr. Epstein because of that? A. You know, after you know somebody and he becomes a friend of yours for ten years, I think you feel bad, no matter how bad he has made. And I don't know what he has done or what -- what the final results of this will be. I still will feel bad about it, just because the person that he was and how generous he was with me and other people. Q. Just to be clear, other than Mr. Critton and your wife, you haven't spoken to anyone else about the civil cases or your deposition testimony? A. No, sir. MR. MEHMELSTEIN: All right. That's all I | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (481-371-478-2988) | | 2aaf3caad-cf8ea-bd9f-bd91-aa20cac6e7de | | Electronically signed by Sandra Townsend (481-371-478-2988) | POJA Confidential Treatment Requested | Fact, R. Crim. P. Exx. Material | | GU JIOCENA RESPONSIBLE (6002) | | | 3504-022 Page 34 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002648 EFTA00157601 have. MR. CRITTON: I have one last question. RECROSS EXAMINATION BY MR. CRITTON: Q. I want to just clear up one thing, Mr. Alessi. Go to page 9. A. Page 9, looks like the one that is important. Q. That's right. We've belabored this one to death. MR. WILLITS: I think the ink has worn off the page by now. BY MR. CRITTON: Q. It's Exhibit 2. This is the statement that you gave to the State Attorney's Office on November 21st of '05. Mr. Berger asked you questions about the young girl. Ms. Ezell just asked you some questions about that. So what I want to do is clarify, so that I know what -- so there's no confusion, at least in the record. On page 9, line 16, it says: "During the last year when you were working with him, what do you mean they looked young? Did they look like they were still in high school?" Page 219 | (561) 832-7500 | PROSE COURT REPORTING AGENCY, INC. | (561) 832-7506 | | :--- | :--- | :--- | | Electronically signed by Sandra Townsend (405-571-891-2883) | Electronically signed by Sandra Townsend (405-571-891-2883) | | | Electronically signed by Sandra Townsend (405-571-891-2883) | POP COMMUNICATIONS Requested | Fac. R. Cep. P. Bix Material | | | SU BUSPOENA RESPONSE 0009N | | think I need to see. (Witness excused.) (!eposition was concluded.) 3504-022 Page 35 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00002649 EFTA00157602