CASE NO: 08-CV-80994\ Plaintiff,\ Vs.\ JEFFREY EPSTEIN,\ Defendant. CASE NO: 08-CV-80993\ Plaintiff,\ Vs.\ JEFFREY EPSTEIN,\ Defendant. C.M.A., CASE NO: 08-CV-80811\ Plaintiff,\ Vs.\ JEFFREY EPSTEIN,\ Defendant. CASE NO: 08-CV-80893\ Plaintiff,\ Vs.\ JEFFREY EPSTEIN,\ Defendant. 1 IN THE CIRCUIT COURT OF THE 15TH\ 2 JUDICIAL CIRCUIT IN AND FOR\ 3 PALM BEACH COUNTY, FLORIDA\ 4 CASE NO. 502008CA037319XXXXMB AB 5 B.B.,\ 6 Plaintiff,\ 7 Vs.\ 8 JEFFREY EPSTEIN.\ 9 Defendant. 10\ 11\ 12 1031 Ives Dairy Road\ 13 Suite 228\ 14 North Miami, Florida\ 15 August 7, 2009\ 16 1:15 p.m. to 5:30 p.m.\ 17 CONTINUED\ 18 VIDEOTAPED\ 19 DEPOSITION\ 20 of\ 21 ALFREDO RODRIGUEZ\ 22 taken on behalf of the Plaintiffs pursuant\ 23 to a Re-Notice of Taking Continued Videotaped\ 24 Deposition (Duces Tecum)\ 25 - - - CASE NO: 08-CV-80469\ Plaintiff,\ Vs.\ JEFFREY EPSTEIN,\ Defendant. CASE NO: 08-CV-80591\ Plaintiff,\ Vs.\ JEFFREY EPSTEIN,\ Defendant. CASE NO: 08-CV-80656\ Plaintiff,\ Vs.\ JEFFREY EPSTEIN,\ Defendant. 1 APPEARANCES:\ 2\ 3 MERMELSTEIN & HOROWITZ, P.A.\ 4 BY: ADAM HOROWITZ, ESQ.\ 5 18205 Biscayne Boulevard\ 6 Miami, Florida 33160\ 7 Attorney for Jane Doe 2, 3, 4, 5,\ 8 6, and 7.\ 9 ROTHSTEIN, ROSENFELDT ADLER\ 10 BY: BRAD 1 [REDACTED], ESQ., and\ 11 CARA [REDACTED], ESQ.\ 12 Las Olas City Centre\ 13 Suite 1650\ 14 401 East Las Olas Boulevard\ 15 Fort Lauderdale, Florida 33301\ 16 Attorney for Jane Doe and E.W.\ 17 And L.M.\ 18\ 19 PODHURST ORSECK\ 20 BY: KATHERINE W. EZELL, ESQ.\ 21 25 West Flagler Street\ 22 Suite 800\ 23 Miami, Florida 33130\ 24 Attorney for Jane Doe 101 and 102.\ 25\ 26 LEOPOLD-KUVIN\ 27 BY: ADAM J. LANGINO, ESQ.\ 28 2925 PGA Boulevard\ 29 Suite 200\ 30 Palm Beach Gardens, Florida 33410\ 31 Attorney for B.B. [REDACTED] bedroom? A. Yes, [REDACTED]. Q. And how would you do that? If you want to turn the page over for the upstairs you could do that. A. Okay. MR. CRITTON: Are you going to mark this as an exhibit? MS. EZELL: Uh-huh. MR. CRITTON: Would that be Exhibit 3? MR. \[REDACTED\]: I think so. (Exhibit No. 3 was marked for Identification.) THE WITNESS: This is the [REDACTED] bedroom, [REDACTED] bath, and there were one, two -- the rest of the bedrooms were here and the [REDACTED] bedroom was here. This is [REDACTED] bath one and [REDACTED] bath two. So the staircase came to the second floor like this and it was between the first and second bedroom. And you could go through here and you enter a foyer with double doors here, double doors here, and you enter the [REDACTED] bath. [REDACTED] EZELL: Q. All right. How would you get to the [REDACTED] bathroom on that end? A. You go through these double doors, go around the bed and you gain access to the [REDACTED] bedroom -- [REDACTED] bathroom, sorry. Q. And then there was another [REDACTED] bathroom on the other side of the room? A. Yes, [REDACTED]. Q. Where generally did the massages take place? A. Right here, [REDACTED]. Q. And is that in the [REDACTED] bathroom? A. [REDACTED] bathroom, yes. Q. Do you recall what color the tile was in that bathroom? A. There was carpet. Q. Was there tile on the walls or marble or -- A. There was a sauna here with marble but outside the sauna everything was carpet, and the walls, they didn't have any tile. [REDACTED] yes, I will say four feet off the floor they will have marble. Q. And do you remember what color marble it was? A. [REDACTED]. 1 pool at the house? 2 A. Yes, [REDACTED]. 3 Q. And were these sometimes the same girls that came to give massages? 4 A. Yes, [REDACTED]. 5 Q. Were there girls in addition to those who came to give massages who hung around the pool? 6 A. The girls who were staying at the house. 7 Q. Okay. And so they weren't girls who just regularly came to hangout around the pool? 8 A. No, [REDACTED]. 9 [REDACTED] EZELL: Excuse me. Can we go off the record for a minute? 10 (Thereupon, a recess was had.) 11 THE VIDEOGRAPHER: We're back on the record with tape number two. 12 BY MS. EZELL: 13 Q. Mr. Rodriguez, did you receive a subpoena that asked you to bring documents with you to the deposition? 14 A. Yes, [REDACTED]. 15 Q. And did you bring any with you? 16 A. I couldn't find anything at my house. 17 Q. Okay. I believe we talked about a journal that you kept, and you looked for that? Page 319 A. Yes, Q. And you couldn't find it? A. I give it to Detective Joe. Q. Recall. A. Yes, Q. You mentioned that you called Mr. can-Luc Bernell about a recommendation when you re lookin b. A. Yes, Q. And did you know him from his visits in e home? A. Yes, Q. Did you say that his wife's name was Eva? MR. CRITTON: Form. THE WITNESS: No, al EZELL: Q. Do you know what his wife's name was? A. Eva was amodel, a former model from years past who was friend of Mr. Epstein. Do you know if she was married to Glenn Do you know Mr. la MR. CRITTON: Form. THE WITNESS: I believe, yeah, I'm not ure, EZELL: 1 Page 321 1 BY MS. EZELL: 2Q. Did they ever visit Mr. Epstein at the 3 home when ere there? 4 A. Yes, 5Q. How old was the little girl at that time? 6 A. Eight years old. 7Q. Did the girl's father come to visit as 8 well? 10Q. And \*remember his name? 9 A. Yes, 11 A. No, 12Q. Do you remember hearing anything about 13 what he does for aliving? 14 A. No, 15Q. Can,describe him? 16A. Tall, American born, I will say 50 years 17 old. 18Q. What color hair did he have? 19 A. At that time it was black with a few 20 -hairs. 21Q. Were there drawings of nude women in the 22 house? 23 A. No, 24Q. Well paintings of nude women in the 25 house? Page 320 Q. Is she now adoctor? A. No, she was amodel, her husband could be a doctor but I don't think she is. Q. Okay. So is Jean-Luc Bernell married; to your knowledge? A. I don't know, lilt Q. I think I must have gotten confused because we were talking about the picture in the house of the little girl who is lifting up her skirt or her underpants, I'd forgotten what it was. A. Yes, MR. ON: Form. BY MS. EZELL: Q. And I thought you said that that was Jean-Luc's child. Q. Eva.? A. No, she is Mrs. Eva. Q. And !II leffrey Epstein's Goddaughter? A. Yes, A. Yes, Q. Do you now where she and her mother live? A. They live in Manhattan. MR. CRITTON: Form. 1 A. Yes, Q. Did any ihose appear to be 3 Ms. Maxwell? 4A. Yes, Q. You mentioned that Louella who was still 6 working there when you left -- A. Yes, lin Q. -- was a very religious woman -- 9 A. Yes, Q. -- all sometimes be upset about 11 seeing pictures of nude girls or having to pick up 12 sex toys, et cetera. MR. CRITTON: Form. THE WITNESS: Yes, BY MS. EZELL: Q. And you said that you remembered her 17 crying because there was apicture of the Pope 18 next to apicture of a naked girl. MR. CRITTON: Form. THE WITNESS: BY MS. EZELL: Q. Do you know who that naked girl was? 23 A. I don't remember, Q. I believe David Copplld's name came 25 up in the last deposition as someone who would Page 322