EXHIBIT 6¶
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE No.08-CV-80119-CIV-MARRAID¶
JANE DOE NO. 2,¶
Plaintiff,¶
-vs-¶
JEFFREY EPSTEIN,¶
Defendant.¶
Related cases:
08-80232, 08-80380, 98-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092¶
VIDEOTAPED DEPOSITION OF JUAN ALESSI
VOLUME 1¶
Tuesday, September 8, 2009
10:12 a.m. - 3:45 p.m.¶
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33401¶
Reported By:
Sandra W. Townsend, FPR
Notary Public, State of Florida
PROSE COURT REPORTING AGENCY
West Palm Beach Office¶
1 APPEARANCES:
2 On behalf of the Plaintiffs:
3 RICHARD WILLITS, ESQUIRE
4 RICHARD H. WILLITS, P.A.
2 2290 10th Avenue North, Suite 404
Lake Worth, Florida 33461
5 Phone: 561.582.7600
reelrhw@hotmail.com
6
7 STUART MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
8 18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
9 Phone: 305.931.2200
ssm@sexabuseattorney.com
ahorowitz@sexabuseattorney.com
10 WILLIAM J. BERGER, ESQUIRE
11 ROTHSTEIN ROSENFELDT ADLER
12 401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale, Florida 33301
13 Phone: 954.522.3456
bedwards@ma-law.com
14
15 KATHERINE W. EZELL, ESQUIRE
PODHURST ORSECK, P.A.
16 25 West Flagler Street, Suite 800
Miami, Florida 33130
17 Phone: 305.358.2800
rjosefsberg@podhurst.com
18 kezell@podhurst.com
19 ADAM J. LANGINO, ESQUIRE
LEOPOLD KUVIN
20 2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
21 Phone: 561.515.1400
skuvin@leopoldkuvin.com
22
23
24
25¶
1 ---
2 EXHIBITS
3 ---
4¶
| NUMBER | DESCRIPTION | PAGE |
|---|---|---|
| 5 | ||
| 6 Exhibit number 1 | Photographs | 45 |
| 7 Exhibit number 2 | Transcript | 130 |
| 8 Exhibit number 3 | Incident Report | 137 |
| 9 Exhibit number 4 | Incorporation Papers | 149 |
| 10 Exhibit number 5 | Incorporation Papers | 150 |
| 11 | ||
| 12 | ||
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| 14 | ||
| 15 | ||
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| Page | 5 | Page 7 | |||||||
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| 1 | PROCEEDINGS | 1 | Boynton | Beach, Florida, 33472 | |||||
| 2 | 2 | Q | All right, sir Did you ever work for Jeffrey | ||||||
| 3 | Deposition | taken | before | Sandra | W | Townsend Court | 3 | Epstein? | |
| 4 | Reporter | and Notary | Public | in and | for | the State of | 4 | A | Yes, I did |
| 5 | Florida at | Large | in the above | cause | 5 | Q | In what capacity? | ||
| 6 | 6 | A | Everything I started with Jeffrey Epstein | ||||||
| 7 | VIDEOGRAPIIER: | Today | is September | 8 2009 | 7 | around | 19 please bear with the dates because I | ||
| 8 | The time | is 12 | minutes | after 10:00 | in the morning | 8 | trying | ||
| 9 | This | is the | videotaped | deposition | cilium* | 9 | Q | Sure | |
| 10 | Alessi | in the maucr | of | Jane Doe | number | two versus | 10 | A | to remember 1969 as a part -time |
| :1 | Jeffrey | Epstein | This | deposition | is | being held at | 1 1 | maintenance | guy |
| 12 | 2139 Palm | Beach | Lakes | Boulevard | in West Palm | Beach 12 | And then I become a full -time employee, l | ||
| 13 | Florida | 13 | think | it was January I .2 '91 , '92 , so '92 Sorry | |||||
| :4 | My | name is | Stan Sanders | I 'm the | videographer | 14 | Q | You said you started in 1969? That would | |
| 15 | representing | Visual | Evidence | Incorporated | 15 | ||||
| 16 | Would | the | attorneys | please | announce | their | 16 | A | No No No No No |
| 17 | appearances | for | the record | 17 | Q | Okay | |||
| 1 .8 | MR | WILLITS: | Richard | Willits | re presenting | 18 | A | '99 | |
| 19 | 19 | Q | 1999? | ||||||
| 20 | MR | BERGER: | William | J Berger | representing | 20 | A | Yeah | |
| 21 | E .W | 1 .M and | Jane Doe | number | two | 2 I | Q | All right And how did you happen to get that | |
| 22 | MR | MERMEI | .STEIN: | Stuart | Mennelstein of | 22 | job? | Was it through an employment agency | |
| 23 | Memielstein | and | Ilorowitz | representing | Jane Does | 23 | A | No | |
| 24 | numbers | two | through | eight | 24 | Q | or an ad in the paper? | ||
| 25 | MR | LANGINO: | Adam Langino, | on behalf of | BA 25 | A | I had a company at that time used to lake care |
| <p>1 MS. EZELL: Katherine Ezell from Podhurst 2 Orseek, on behalf of Jane Does 101 and 102. 3 MR. CRITTON: Bob Critton, on behalf of 4 Jeffrey Epstein. 5 THEREUPON, 6 JUAN ALESSI, 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: I do. 10 DIRECT EXAMINATION 11 BY MR. WILLITS: 12 Q. Good morning, sir. 13 A. Good morning. 14 Q. I introduced myself through the videographer. 15 My name is Richard Willits. 16 A. Okay. 17 Q. I represent a young lady by the name of 18 [REDACTED]. 19 A. Okay. 20 Q. Is that name familiar to you at all? 21 A. Whose name? 22 Q. [REDACTED]. Do you recognize that name? 23 A. No. 24 Q. What is your residence address, sir? 25 A. My address is 6791 Fairway Lakes Drive.</p> | <p>1 of a lot of residents in Palm Beach. And I got to know 2 Jeffrey through Lesley Wexner. And I used to work in 3 about 20 different, 20, 25 different homes in Palm Beach 4 as a maintenance guy. 5 Q. Okay. 6 A. And I have basically my own company and I do 7 repairs for them. I did home sit in for them. 8 Q. And what was -- did you work for Jeffrey 9 Epstein? What was your position when you started? 10 A. When I started, he hire me to -- he just 11 bought the house. 12 Q. I'm sorry? 13 A. He just had bought the house -- 14 Q. Okay. 15 A. -- where he live on El Brillo. And he hire me 16 through Mr. Wexner's references to do repair works. And 17 basically what I did the most was taking walls apart, 18 windows and stuff that he didn't want to have it, -- 19 Q. I see. 20 A. -- fix it. 21 Q. And when you started working for Mr. Epstein, 22 were you still working for other people in Palm Beach? 23 A. Yes, I did. 24 Q. Okay. And about how long a period of time did 25 you do this type of work for Mr. Epstein, the</p> |
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(Pages 5 to 8)¶
| Page 9 | Page 11 | ||
|---|---|---|---|
| maintenance and taking out walls? | 1 | about seven months before -- alter I become a full-time | |
| 2 | A. It was couple months. It was couple months | 2 | employee. |
| 3 | before. | 3 | Q. Okay. And how did Ms. Maxwell come into the |
| 4 | Q. And what was the name of your company? | 4 | picture? |
| 5 | A. Alessi Maintenance. | 5 | A. It was his girlfriend, his main girlfriend. |
| 6 | Q. And how were you paid? | 6 | Q. Okay. I lad you known her before she became -- |
| 7 | A. By him? | 7 | A. No. |
| 8 | Q. Yes. | 8 | Q. -- your -- |
| 9 | A. Usually by check or cash sometimes. | 9 | A. Never know her before. |
| 10 | Q. Do you know what company actually paid your | 10 | Q. I'm sorry. I didn't get a chance to finish my |
| 11 | company? | 11 | question. |
| 12 | A. It was Jeffrey Epstein and Company. | 12 | Would you have referred to her as your |
| 13 | Q. So you said you had that position for a couple | 13 | supervisor or your superior or what would you have |
| 14 | of months. | 14 | called Mrs. Maxwell? |
| 15 | What happened next? | 15 | A. I used to call her Ghislaine. |
| 16 | A. Then Mr. Epstein asked me to. if I wanted to | 16 | Q. Okay. And how was it explained to you that |
| 17 | be his employee, because I was going from one house t | 17 | you were now to deal with Ms. Maxwell. as opposed to |
| 18 | another house to another house, one hour here. I was | 18 | Jeffrey Epstein? |
| 19 | just running around Palm Beach all day. | 19 | A. She would tell me. I am going to take care of |
| 20 | So he asked me ill would just work for him. | 20 | the house. |
| 21 | exclusively for him. | 22 | Q. Okay. That was explained to you by |
| 22 | Q. Okay. | 22 | Ms. Maxwell? |
| 23 | A. And we agreed with the terms and I become a | 23 | A. Llh-huh. |
| 24 | full-time employee as a maintenance guy. And I was | 24 | Q. Is that a yes? |
| 25 | taking care of everything, as far as maintenance. | 25 | A. Yes. |
| taking care of everything, as far | maintenance. | A. Yes. | |
|---|---|---|---|
| Page 10 | Page 12 | ||
| 1 | Then my job changed little by little to house | 1 | Q. And when Ms. Maxwell started assuming |
| 2 | man, estate manager, and then to a majordomo. | 2 | responsibility for the house, did your duties change at |
| 3 | Q. Okay. When you first agreed to terms with | 3 | that time? |
| 4 | Mr. Epstein and you first started working for him full | 4 | A. Not much. |
| 5 | time, what were those terms, do you remember? | 5 | Q. Okay. |
| 6 | A. The terms is basically was how much -- he | 6 | A. Not much. |
| 7 | asked me how much I was making in all the properties. | 7 | Q. And at that time when Ms. Maxwell started |
| 8 | And I says. well, I make this -- this amount | 8 | taking responsibility for the house. what were your |
| 9 | of money. | 9 | duties? |
| 10 | And he says. fine. | 10 | A. Basically I was still doing the maintenance |
| 1.1 | Q. And how much was that, did he pay you? | 11 | work. |
| 12 | A. Around 545.000. I think I started with 45. | 12 | Q. Okay. |
| 13 | Q. Okay. And when you started to work for him as | 13 | A. Was doing -- they were trying to remodel the |
| 14 | a full-time employee, did you have anybody that you | 14 | home and they would told me, okay. tear down this wall. |
| 15 | reported to or did you deal directly with Mr. Epstein? | 15 | We want to see how it's going to look. Or put this |
| 16 | A. At the beginning with Mr. Epstein. directly to | 16 | windows and tear down -- we had a fishing tank. We took |
| 17 | him. | 17 | it out -- I took it out. A kitchen on the second floor. |
| 18 | Q. Did that change? | 18 | I took it out. So it was basically dismantling the |
| 19 | A. Later on. yes. | 19 | house. |
| 20 | Q. And how did that change? | 20 | Q. Okay. And about how long a period of time did |
| 21 | A. When Ms. Maxwell, Ghislaine Maxwell came to | 21 | that project last? |
| 22 | the picture. | 22 | A. I would says. six to seven months. |
| 23 | Q. Okay. About when was it that she came into | 23 | Q. Okay. And after the remodeling slacked off or |
| 24 | the picture? | 24 | stopped. did your duties then change? |
| 25 | A. Exactly date. I cannot remember. But it was | 25 | A. Yeah. Increasingly they change. |
3 (Pages 9 to 12)¶
Q. Okay. Who -- 1 living on the property, but outside the house? A. Periodically. It didn't change from one day 2 A. I was living in the property. No. No. No. to another. 3 I was working outside the property. Q. And who would tell you that your duties were 4 Q. Yes. increasing? 5 A. And because it was multiple jobs that I had to A. Either Mr. Epstein or Ms. Maxwell. 6 do. Q. Okay. And how did your duties increase? 7 Q. Okay. A. In — I become more -- more involved in the 8 A. Had to do with the pool. the service, the daily running operation of this home. This home was rur 9 landscaping, taking care of that. I didn't do it like a hotel basically. 10 myself, but I have people working for me. Q. Okay. Were you given any manuals or rules or 11 Q. Okay. Approximately when was it in procedures that you had to follow? 12 relationship to Ms. Maxwell taking over the Q. Okay. At the end. And I'm going to jump to 14 house? the end now and then come back. 15 A. I will says. after it was done. a big your stay; what kind of papers or manuals? 17 after I did the breaking down of this renovation, they A. It was a manual. I can't remember how many 18 hire architects, they hire decorators and engineers, and pages. but it was quite thick manual that was -- that 19 did the -- they did the work. It was abig renovation. was done by estate manager. that she will manage all -- 20 one of the renovations. all the properties. And that was also to be in force in 21 And then they make our quarters. They even Palm Beach. 22 built our -- my quarters in there. Q. I see. Do you still have a copy of that 23 Q. When you said "our: was there someone else manual? 24 who had quarters there, too? A. No, I don't. 25 A. About three years later, after I start¶
A. At the end of my stay, yes. I was. 13 responsibility of the house did you then move inside the What was ii that you were given at the end of 16 renovation, when architects and engineers. And that wa¶
Q. Do you have any papers whatsoever that wcrc 1 working, my wife came to help me. prepared while you were working -- 2 Q. I see. And are you able to describe for me A. No. 3 where the quarters were, like, what floor? Q. — for Mr. Epstein? 4A. Yes. It was in the second floor and the -- A. I tell everything in there. 5 let me trying to remember — northeast corner of the Q. Did you make any diary notes yourself or any 6 property. Northeast corner. yes. Mr. Epstein? B were working for hint there at the house? A. No. sir. The only thing I have is my 9 A. During the whole time? separation agreement. That's it. 10 Q. Yes. sir. Q. Okay. Did you bring that with you today? 11 A. Yes. A. No, I didn't. 12 Q. All right. When you first started there, Q. Okay. Did your duties ever include taking 13 there was no one else? telephone messages? 14 A. When I started there, was a -- it was a A. Yes. sometimes. 15 Jamaican girl that she was doing the cooking. Q. And when did that start approximately? 16 Q. Okay. Do you happen to remember her name! A. When I move from the outside to the inside of 17 A. No. the house. 18 Q. All right. 9 Q. All right. 19 A. She worked for couple months. A. I -- when I start the position. I never had an 20 Q. I see. All right. When did any other me inside to run the house. I had an apartment. I have 22 there? a small service quavers in the house. inside the house. 23 A. 'I'hey hire chefs. There was mostly European Q. Okay. And when you say. outside the house, do 24 chefs. It was an English chef, but I cannot -- Rupert. you mean outside the property or were you — or wcrc you 25 I know his name was Rupert. A chef that was¶
notes for your own private use while you worked for 7 Q. Did anyone else work for Mr. Epstein while you apartment in the house. And when I definite they want 21 employees begin to work for Mr. Epstein while you were¶
(Pages 13 to 16)¶
1 Didier. A kid from New York who was a chef, also. But
2 they were one after another one. They were hiring chefs
3 when I doing -- sometimes I did most of the cooking.
4 When they wanted to bring their chef, they bring their
5 chef in their plane. And the chef will stay, will work
6 there and then will travel with them.
7 Q. Were there any other employees that worked for
8 Mr. Epstein while you were worked for him, that you know
9 of?
10 A. No, except my wife.
11 Q. Did you know a lady by the name of [REDACTED]
12 [REDACTED]
13 [REDACTED] yes, I do. [REDACTED] came at the
14 end of my stay there, probably two or three months
15 before I left.
16 Q. Okay. Did she do any work for Mr. Epstein,
17 that you know of?
18 A. Yes. She was a -- I don't know her deterrent,
19 but she was an assistant to him or to her. I don't
20 know.
21 Q. All right. There is a -- I've seen a
22 reference in -- and the spelling has changed in my
23 various references -- is there a N. or N.? Do you
24 recognize that name?
25 A. N.¶
1 Q. Were there any photographs of nude females in
2 the house while you were there?
3 MR. CRITTON: Form.
4 MR. WILLITS: What's the matter with that
5 form?
6 MR. CRITTON: Overly broad. Nude? You mean
7 completely naked?
8 MR. WILLITS: However you want to interpret
9 it.
10 THE WITNESS: Excuse me. Can you repeat that
11 again?
12 MR. CRITTON: Form.
13 BY MR. WILLITS:
14 Q. Yes. Were there any photographs of nude
15 females in the house while you worked for Mr. Epstein?
16 A. Yes. Sometimes I saw nude photographs.
17 Q. Are you able to describe where you saw those,
18 where in the house?
19 A. Most of the times those photographs were taken
20 by Ms. Maxwell. And they usually are her desk. And she
21 kept a big album.
22 Q. Do you remember any pictures of nude or
23 partially unclothed females on the walls at
24 Mr. Epstein's house?
25 MR. CRITTON: Form.¶
1 Q. N.
2 A. N. Yes, I know N.B.
3 Q. Want to take a chance at spelling that last
4 name?
5 A. I think it was B. But she was not an
6 employee. She was a guest.
7 Q. Was she a full-time guest?
8 A. No.
9 Q. When would she visit?
10 A. She was a girl that was very, very talented.
11 Mr. Epstein help her become an actress. Now she's a
12 movie actress and she's in a soap opera. She came with
13 her mother to the house. And she -- he help her come up
14 with her career.
15 Q. Okay. Do you -- are you familiar with any
16 other individuals by the name of N. or N. who worked for
17 Mr. Epstein?
18 A. No.
19 Q. After the renovations were complete, did you
20 have access to the entire house while you worked for
21 Mr. Epstein?
22 A. Absolutely, yeah.
23 Q. Was there any particular portion of the house
24 that was denied access by -- to you?
25 A. No.¶
1 BY MR. WILLITS:
2 Q. He's just making objections for the record
3 that he can take -- he will take it up with the Judge
4 later on.
5 A. Okay.
6 Q. You don't need to worry about --
7 A. Yes, it was. It was pictures of partially
8 nude.
9 Q. And where were they?
10 A. Most of the times they were in the pool.
11 Q. How about on the stairway?
12 A. No. On the stairway there were no pictures
13 when I was there.
14 Q. How many stairways were there?
15 A. It was the service stairway that is very
16 narrow coming from the service quarters to the kitchen
17 And the main stairway, that it was quite wide
18 and to the second floor.
19 Just those two.
20 And also there was a stairway outside through
21 the pool to the balcony upstairs.
22 Q. And do you have a recollection of pictures of
23 any females whatsoever on either of the inside
24 stairways?
25 A. No, I don't.¶
5 (Pages 17 to 20)¶
Q. What is your understanding, sir, of the — a reference to a girl, as opposed to a woman? Arc you familiar with the term. girl? A. Of course. Q. Arc you familiar with the term. woman? A. I interpret most a woman, a married woman, a married person. Q. Are you -- how would you describe a 14 year old. a woman or agirl? A. A girl. of course. Q. How would you describe a 16 year old, awoman or agirl? A. Again. I don't know. I am not I don't think I can tell you exactly she is 14 or 16. Q. But if you knew -- A. Sixteen. I would think is a girl, of course. Q. Were there ever any visitors to the Epstein house that you considered to be girls, as opposed to women? A. Yes. Yes. I think I would says. I never check her i.d. Q. Right. A. Or I was not told to check i.d.s. -- Q. Of course. A. -- on these girls. But one. I would says,¶
Q. Okay. Do you remember any other females beim present at the house, other than the females t • ) 've mentioned, which were N.. her mother V. Were there any others that you -- A. Many. many, many, many. many. Q. When did you first -- MR. CRITION: Can 1 just have the last question read back? MR. WILLITS: Of course you can. MR. CRITTON: Please. MR. WILLITS: But only once. MR. CRITTON: That's all I need. MR. WILLITS: You sure. Go ahead. (Previous question was read.) MR. CRITION: And can I just ask for a clarification from you? Are you going to use -- if you use the word woman. arc you -- MR. WII.I.ITS: I said. females. MR. CRITION: No. no. I understand. But in the future if you use woman, does that mean, at least to Mr. Alessi. that that's married. and if it's a girl she has to be 14 or 16? Because that's how you asked the question. MR. WII.LITS: All I'm going to talk about is¶
Page 22 N.B. was very young because she was in high school. And sometimes either I pick her mother and herself from her house or I pick her from The School of the Arts or the ballet place, ballet in West Palm Beach. I can't remember exactly what that place is. the name of the place. Q. Did you give -- provide transportation for any other females while you worked for Mr. Epstein? A. Occasionally. yes, I did. Q. Do you happen to remember the names of any of those females? A. I remember one. specifically one. It was V. I ler name was V. I can't remember her last name, but I think it was P. I'm not sure. I can be wrong on that. Q. And how many times did you provide transponation services for this female? 1'7 A. Whenever I had — I been told. Whenever I was told to go get them or bring them back to their house. Q. Did you consider V. to be a girl or a woman? A. Again. I think it was a woman. from myself. her dressing and her I think it was again. I don't know if she was 16, 17 or 18 or 19. could have been. But she was not -- I never pick her up from a school or anything like that. The only girl that I picked up from the school was N.¶
Page 24 females. MR. CRITTON: Okay. MR. WII.LITS: And ask -- MR. CRITTON: I'll be alert to the questions then. MR. WILLITS: All right. So you don't need u sleep through the next few questions. MR. CRITTON: I don't sleep at all. MR. WILLITS: All right. Now I'm totally confused. BY MR. WILLITS: Q. When did you first become aware of females visiting the Epstein house? A. Since I know him. Q. During the renovations? A. Yeah. Q. Were there -- A. Before the -- before Ms. Maxwell. Q. Okay. All right. Let's use that as a milepost. Before Ms. Maxwell -- A. Before it was Ms. Maxwell, it was only one woman that it was Mr. Epstein's girlfriend. And her name was Dr. she was a doctor of medicine -- Eva And I really liked this girl. She was very¶
(Pages 21 to 24)¶