1 JANE DOE NO. 6, CASE NO: 08-CV-80994
2 Plaintiff,
3 Vs.
4 JEFFREY EPSTEIN,
5 Defendant.
6 \_\_\_\_\_
7 JANE DOE NO. 7, CASE NO: 08-CV-80993
8 Plaintiff,
9 Vs.
10 JEFFREY EPSTEIN,
11 Defendant.
12 \_\_\_\_\_
13 C.M.A., CASE NO: 08-CV-80811
14 Plaintiff,
15 Vs.
16 JEFFREY EPSTEIN,
17 Defendant.
18 \_\_\_\_\_
19 JANE DOE, CASE NO: 08-CV-80993
20 Plaintiff,
21 Vs.
22 JEFFREY EPSTEIN,
23 Defendant.
24 \_\_\_\_\_
25 \_\_\_\_\_
|Page 271
1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB
2 B.B.,
3 Plaintiff,
4 Vs.
5 JEFFREY EPSTEIN.
6 Defendant.
7 \_\_\_\_\_
8 1031 Ives Dairy Road Suite 228 North Miami, Florida August 7, 2009 1:15 p.m. to 5:30 p.m.
9 CONTINUED VIDEOTAPED DEPOSITION of ALFREDO RODRIGUEZ
10 taken on behalf of the Plaintiff's pursuant to a Re-Notice of Taking Continued Videotaped Deposition (Duces Tecum)
11 - - -
|Page 273
| | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ----------------- | | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ----------------- | |1 JANE DOE NO. II, CASE NO: 08-CV-80469
2 Plaintiff,
3 Vs.
4 JEFFREY EPSTEIN,
5 Defendant.
6 \_\_\_\_\_
7 JANE DOE NO. 101, CASE NO: 08-CV-80591
8 Plaintiff,
9 Vs.
10 JEFFREY EPSTEIN,
11 Defendant.
12 \_\_\_\_\_
13 JANE DOE NO. 102, CASE NO: 08-CV-80556
14 Plaintiff,
15 Vs.
16 JEFFREY EPSTEIN,
17 Defendant.
18 \_\_\_\_\_
19 \_\_\_\_\_
20 \_\_\_\_\_
21 \_\_\_\_\_
22 \_\_\_\_\_
23 \_\_\_\_\_
24 \_\_\_\_\_
25 \_\_\_\_\_
|Page 272
1 APPEARANCES:
2 MERMELSTEIN & HOROWITZ, P.A.
3 BY: ADAM HOROWITZ, ESQ.
4 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Attorney for Jane Doe 2, 3, 4, 5, 6, and 7.
5 ROTHSTEIN ROSENFELDT ADLER BY: BRAD J. [REDACTED] ESQ., and CARA [REDACTED] ESQ.
6 Las Olas City Centre Suite 1650 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 Attorney for Jane Doe and E.W. And L.M.
7 PODHURST ORSECK BY: KATHERINE W. EZELL, ESQ.
8 25 West Flagler Street Suite 800 Miami, Florida 33130
9 Attorney for Jane Doe 101 and 102.
10 LEOPOLD-KUVIN BY: ADAM J. LANGINO, ESQ.
11 2925 PGA Boulevard Suite 200 Palm Beach Gardens, Florida 33410 Attorney for B.B.
12 \_\_\_\_\_
13 \_\_\_\_\_
14 \_\_\_\_\_
15 \_\_\_\_\_
|Page 274
| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------- | | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------- | 2 (Pages 271 to 274) Kress Court Reporting, Inc. 305-866-7688\ 7115 Rue Notre Dame, Miami Beach, FL 33141 |Page 299
1 A. I don't remember, [REDACTED]. He came from
2 New Albany, Ohio.
3 Q. From New --
4 A. New Albany, Ohio.
5 Q. New Albany, Ohio. Did he have his own
6 business?
7 A. No, he worked for Mr. Epstein. He will
8 maintain all the computers.
9 Q. Was he there everyday?
10 A. No, [REDACTED].
11 Q. Do you know whether at that time Mr.
12 Epstein had an office in Palm Beach?
13 A. Not outside the house, no.
14 Q. Do you have any knowledge of whether or
15 not the video equipment was -- and I don't know
16 the technical term, forgive me, but was it the
17 kind of equipment that would record for a certain
18 amount of time and then record over that film?
19 A. I don't know.
20 MR. CRITTON: Form.
21 BY MS. EZELL:
22 Q. You don't know?
23 A. No, [REDACTED].
24 MR. CRITTON: Just for clarification, I
25 may have misunderstood, but I thought he
|Page 301
1 video, even phones.
2 Q. Would he also repair the televisions if
3 they needed work?
4 A. No.
5 Q. No. Did you have any kind of intercom
6 system in the house?
7 A. Yes, [REDACTED].
8 Q. And what kind of system was that?
9 A. It was standard office equipment, Lucid
10 Technologies maybe, but it was an intercom like we
11 using right now.
12 MS. EZELL: Just let the record reflect
13 that the witness pointed to the telephone on
14 the table that has a speaker phone.
15 THE WITNESS: Yes, [REDACTED].
16 BY MS. EZELL:
17 Q. And did you use that in your work?
18 A. Yes, [REDACTED].
19 Q. And what did you use it for?
20 A. Mr. Epstein used to page me when he
21 needed me.
22 Q. Did you have one of those phones in the
23 kitchen?
24 A. Yes, [REDACTED].
25 Q. And was there one out in the staff house
| | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |Page 300
1 said he didn't even know the video equipment
2 existed until he read the FBI report.
3 MS. EZELL: He said he didn't know that
4 it was upstairs and downstairs, I believe.
5 MR. CRITTON: I thought he said he didn't
6 know that it even existed.
7 [REDACTED] be wrong.
8 BY MS. EZELL:
9 Q. Did you know it existed before you read
10 the FBI report?
11 A. No, [REDACTED].
12 Q. I'm sorry, then I was wrong.
13 How did you know then that the young
14 technician from Ohio maintained the computers and
15 the video equipment?
16 A. Because we used to request -- there were
17 always problems with the computers so he came to
18 the house and he was the programmer. It was very
19 sophisticated.
20 MR. CRITTON: Form to the last question,
21 move to strike the answer as nonresponsive.
22 BY MS. EZELL:
23 Q. How did you know then that he maintained
24 the video equipment as well?
25 A. Because he was in charge of computers,
|Page 302
1 as well?
2 A. Yes, [REDACTED].
3 Q. Do you know where others were in the
4 house?
5 A. Probably have like 15 phones. We used to
6 have three in the staff house, one in the cabana,
7 two in the [REDACTED] bedroom, one in each room,
8 kitchen, dining room, Mrs. Maxwell's office, the
9 garage.
10 Q. Where was Mrs. Maxwell's office?
11 A. Under the stairs next to the kitchen.
12 Q. Can you give me some idea of what size
13 space that was?
14 A. It was probably -- we change the floor.
15 Twelve by five, something like that.
16 Q. And was the computer equipment in that
17 space?
18 A. Yes, [REDACTED].
19 Q. Do you know whether Ms. Maxwell kept the
20 names and telephone numbers of the girls who came
21 to do massages?
22 A. Yes, [REDACTED].
23 MR. CRITTON: Form.
24 BY MS. EZELL:
25 Q. Do you know that because you saw the
| 9 (Pages 299 to 302) Kress Court Reporting, Inc. 305-866-7688\ 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 303 1 names and phone numbers? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, [REDACTED] 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 6 girls on the computer? 7 A. Yes, she did. 8 Q. And you know that as well because you 9 happen to see them? 10 A. Yes, [REDACTED] 11 MR. CRITTON: Form to the last two 12 questions. 13 BY MS. EZELL: 14 Q. Were they similar to the pictures that 15 [REDACTED] had on her computer? 16 MR. CRITTON: Form. 17 THE WITNESS: Yes, [REDACTED] 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 look like pictures that were posed? 21 A. They were more casual. 22 Q. Did they look as though the person being 23 photographed knew that they were being 24 photographed? 25 MR. CRITTON: Form. Page 304 1 THE WITNESS: No, [REDACTED] 2 EZELL: 3 Q. And what can you tell me about that, what 4 lead you to draw that conclusion? 5 A. They were probably taken in parties in 6 big reception or banquet. 7 MR. CRITTON: Let me offer as a 8 suggestion, not that you have to accept or 9 that you would, you're using the term young 10 girls generically, he has probably seen 11 many, many young girls, there was no -- 12 you've used it interchangeably with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, 16 so that's part of my form objection. 17 MS. EZELL: Okay, thank you. 18 BY MS. EZELL: 19 Q. When I asked you about [REDACTED] whether 20 she had a list of the girls and telephone numbers, 21 I think I asked about those girls that came to 22 give massages, but let me go back and just ask it 23 that way. 24 Did you notice that [REDACTED] had a list 25 of the girls that came to give massages on her Page 305 1 computer? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, [REDACTED] 4 BY MS. EZELL: 5 Q. And did she generally have phone numbers 6 for those girls? 7 A. Yes, [REDACTED] 8 Q. And were they generally pictures of the 9 girls? 10 MR. CRITTON: Form. 11 THE WITNESS: No, [REDACTED] 12 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 girls who came to give massages? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, [REDACTED] 17 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 A. Yes, [REDACTED] 20 MR. CRITTON: Form. 21 BY MS. EZELL: 22 Q. Were there pictures on her computer of 23 the girls who came to give massages? 24 MR. CRITTON: Form. 25 BY MS. EZELL: Page 306 1 Q. Ms. Maxwell I'm talking about. 2 A. Yes, [REDACTED] 3 Q. And were those pictures the more casual 4 ones that you described when I asked whether or 5 not the subject looked as though she knew she was 6 being photographed? 7 MR. CRITTON: Form. 8 THE WITNESS: I'm sorry, can you repeat? 9 BY MS. EZELL: 10 Q. Yeah. The pictures of the young girls 11 who came to the house to give massages that were 12 on Ms. Maxwell's computer, did they appear to have 13 been taken when the girls knew they were being 14 photographed? 15 MR. CRITTON: Form. 16 THE WITNESS: I don't think they knew 17 they were being photographed. 18 BY MS. EZELL: 19 Q. I believe you said they were more casual 20 pictures. 21 A. Yes, [REDACTED] 22 Q. Did you notice any nude photographs in 23 those pictures? 24 A. Yes, [REDACTED] 25 MR. CRITTON: Form for the last question. 10 (Pages 303 to 306) Kress Court Reporting, Inc. 305-866-7688\ 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 335 1 Q. Do you remember whether she came to the\ 2 house on more than one occasion?\ 3 A. I heard her name several times from\ 4 Sarah, sir, but beyond that I cannot say anything\ 5 else.\ 6 Q. Okay. Who have you talked to about your\ 7 knowledge of Mr. Epstein in the last year?\ 8 A. My wife.\ 9 Q. Anyone else?\ 10 A. No, sir.\ 11 Q. Well, you talked to Mr. Critton.\ 12 A. We have a conversation in West Palm\ 13 Beach.\ 14 Q. Yes. So you talked to your wife, you\ 15 talked to Mr. Critton?\ 16 A. Yes.\ 17 Q. Had you talked to anyone else in the last\ 18 year about Epstein?\ 19 A. No.\ 20 Q. Did you talk to Mr. Goldberger?\ 21 A. Yeah, I called Mr. Goldberger first\ 22 before I talked to Mr. Critton.\ 23 Q. Okay. So we have your wife, we have Mr.\ 24 Critton, and we have Mr. Goldberger.\ 25 Do we have anyone else that you talked to Page 336 1 in the last year?\ 2 A. No, sir.\ 3 Q. How about Mr. Epstein of course?\ 4 A. No.\ 5 Q. Where did you usually keep the journal\ 6 with the names of the girls, in what part of the\ 7 house?\ 8 A. In the staff house.\ 9 Q. Sorry?\ 10 A. The staff house, the guest house.\ 11 Q. Right. But you said you had a journal at\ 12 your own residence with the names of the girls.\ 13 A. I give the whole journal and all the\ 14 information regarding this case, sir, to Detective\ 15 Joe Recarey, sir.\ 16 Q. Okay. And the materials that you gave to\ 17 the Detective, were they kept -- were any of them\ 18 kept at your own personal residence?\ 19 A. Yes, they were with me, sir.\ 20 Q. Okay. When you gave the materials to the\ 21 Detective, did all of the materials you gave to\ 22 him come from your residence?\ 23 A. Yes.\ 24 Q. Do you remember exactly what you gave to\ 25 him? Page 337 1 A. I give him a list of notes that I used to\ 2 take from frequent people -- I mean, people who\ 3 used to frequent the house and -- I'm sorry, it's\ 4 been a few years, I don't remember, but it was\ 5 those years, like it was a file with my personal\ 6 notes because he told me it was very important and\ 7 he kind of said can I borrow this from you, and he\ 8 still has those documents, sir.\ 9 Q. So even though they pertain to Mr.\ 10 Epstein you kept those notes at your residence?\ 11 A. Yes, sir.\ 12 Q. Okay. Where in your residence did you\ 13 keep those notes before you gave them to the\ 14 Detective?\ 15 A. In my bedroom.\ 16 Q. Did you have a file cabinet or --\ 17 A. No.\ 18 Q. -- chester drawers or something?\ 19 A. No, they were laying next to some other\ 20 papers that I have.\ 21 Q. Did the other papers pertain to Mr.\ 22 Epstein?\ 23 A. No, no, nothing else related to Mr.\ 24 Epstein.\ 25 Q. I'm just confused as to why you told us Page 338 1 before that you had a journal at home and today\ 2 you say that you gave everything to the Detective.\ 3 MR. CRITTON: Form. You also may have\ 4 missed a portion of his earlier testimony if\ 5 you couldn't hear something, but go ahead.\ 6 MR. WILLITS: Most likely.\ 7 THE WITNESS: What I said was I thought I\ 8 had some information, and then I look with\ 9 my daughter and we couldn't find anything,\ 10 and I remember now that I put everything in\ 11 the file that I give to Detective Recarey.\ 12 BY MR. WILLITS:\ 13 Q. Did anyone help you assemble those papers\ 14 to give to the Detective?\ 15 A. No, sir.\ 16 MR. WILLITS: I don't have any other\ 17 questions.\ 18 CROSS EXAMINATION\ 19 BY MR. CRITTON:\ 20 Q. Mr. Rodriguez, my name is Bob Critton and\ 21 I represent Mr. Epstein as you're aware, I have a\ 22 few questions for you.\ 23 What I would like to remind you at the\ 24 start of this is if you know something, tell us,\ 25 if you don't know something tell us that. 18 (Pages 335 to 338) Kress Court Reporting, Inc. 305-866-7688\ 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 339 You're not required to speculate, you're 2 not required to guess, you're not required to 3 assume because some lawyers ask you a leading 4 question Or suggested in a report or like them 5 police report like Mr. mermeistem and Mr. 6 did, that did you tell the police officers X, Y, 7 or Z without showing you the statement. You're 8 not required to guess, I want personal knowledge, 9 not speculation. Do you understand? 10 A. Yes, I do. 11 Q. All right. Now, when Mr. and -- 12 Mr. Horowitz is here today for Mr. Mermelstein, 13 but you remember a lawyer asked you some questions 14 last time you were here? 15 A. Yes. 16 Q. That is he started and he went on for a 17 few hours. Do you recall that? 18 A. Yes, I remember. 19 Q. He asked you do you remember telling the 20 police officer Y, X, or Z. 21 Do you remember that? Do you remember 22 that's how he phrased his question? 23 A. Yes, yes. 24 Q. He never showed you a statement that you 25 made to the police department; did he? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Page 340 A. I'm sorry? Q. He didn't show you a document that said, question, you know, what is your name; answer, my name is Alfredo Rodriguez -- MR. WILLITS: Object to the form of the question. MR. CRITTON: You need to let me finish it first. MR. WILLITS: I'm sorry, I thought you were. BY MR. CRITTON: Q. He never showed you a statement of what the question was and the answer that you gave. True? MR. WILLITS: Object to the form of the question. 17 18 19 20 21 22 23 24 25 THE WITNESS: I don't exactly understand your question. BY MR. CRITTON: Q. Do you know what a deposition is? A. Yes, I am. Q. That's what you're doing here. MR. CRITTON: Could I borrow your deposition for just a minute? MR. HOROWITZ: The transcript? It's Page 341 1 marked up, no, you can't. 2 MR. CRITTON: I just want to show him. 3 Thank you, Cathy. 4 BY MR. CRITTON: S Q. This is the first what Ms. Ezell was kind 6 enough to provide is the first part of your 7 deposition, it was transcribed by the court 8 reporter and provided by all counsel. 9 Do you understand that? 10 A. Yes, I understand that. 11 Q. And no one has provided that to you yet 12 today; have they? 13 A. No. 14 Q. Now, I think you told us that with the 15 police officers you gave a taped statement. 16 Did I understand you correctly? 17 A. Yes. 18 Q. And the only conversation that you had 19 with the police officers, and it may have been a 20 state attorney, it was somebody named Ms. Weiss 21 who I think was referenced in the questions, the 22 only time that you talked with at least Officer 23 Recarey and the State Attorney's Office from Palm 24 Beach County was in a taped statement. 25 Is that correct? Page 342 1 A. No. 2 Q. Did you talk with them separate and apart 3 from that? 4 A. Yes, I did. 5 Q. Okay. Did they tape that statement? 6 A. No. 7 Q. You told us you also spoke with 8 representatives of the FBI? 9 A. Yes. 10 Q. Okay. And you distinguished between the 11 FBI and between Officer Recarey? 12 A. Yes. 13 Q. So how many times did Officer Recarey, or 14 Detective Recarey, I think he's from the Palm 15 Beach Police Department speak with you? 16 A. Like three or four times. LI 18 19 20 21 22 23 24 25 .4. ULM I IC VI lly LW% VIM; WIA:11 ICI 14 A. One taped. Q. I'm sorry, one taped statement? A. Yes. Q. All right. So as to whether or not if you said something to Officer Recarey or not that you would be able to confirm, that would only have been in a taped statement, one taped statement out of the three, approximately three times he spoke 19 (Pages 339 to 342) 1 with you.\ 2 MR. [REDACTED] Form.\ 3 MR. HOROWITZ: Form.\ 4 BY MR. CRITTON:\ 5 Q. Is that correct?\ 6 A. Yes, correct.\ 7 MR. WILLITS: Object to the form.\ 8 MR. HOROWITZ: Join.\ 9 BY MR. CRITTON:\ 10 Q. And when we were here, I think it was\ 11 last week or the last ten days anyway -- I could\ 12 tell you. On July 29th of this year, and Mr.\ 13 Mermelstein started with your deposition and then\ 14 others asked questions, when Mr. Mermelstein and I\ 15 think Mr. [REDACTED] asked questions about did you\ 16 tell Officer Recarey X, Y, or Z, they didn't show\ 17 you a statement, they didn't give you like a\ 18 transcript like this and say see what the question\ 19 and see what the answer is?\ 20 A. No.\ 21 MR. [REDACTED] Form.\ 22 MR. WILLITS: Object to the form of the\ 23 question.\ 24 BY MR. CRITTON:\ 25 Q. And you haven't had an opportunity to see 1 Q. When Officer Recarey took -- spoke with\ 2 you on those approximately two times when he did\ 3 not take a taped statement, did he ever present\ 4 anything for you, anything in writing that he had\ 5 written to say, Mr. Rodriguez, I would like you to\ 6 review this to make certain that I took down\ 7 correctly what you said?\ 8 A. No, sir.\ 9 Q. If he had offered to do that would you\ 10 have read what he wrote down to determine whether\ 11 or not he took down that which you had said or\ 12 told him?\ 13 MR. [REDACTED] Object to the form.\ 14 THE WITNESS: Probably I will read it\ 15 first.\ 16 BY MR. CRITTON:\ 17 Q. All right. And if in fact he had\ 18 recorded something incorrectly or recorded in a\ 19 particular way that he wanted it phrased and it\ 20 was not accurate, would you have told him that?\ 21 MR. [REDACTED] Object to the form.\ 22 THE WITNESS: No, I never told him that.\ 23 BY MR. CRITTON:\ 24 Q. Listen to my question.\ 25 If he, Officer Recarey, had taken down 1 your taped statement since you gave it many years\ 2 ago?\ 3 A. No, sir.\ 4 Q. Would you agree that your taped statement\ 5 would probably be a little more accurate than your\ 6 testimony today because of the time period that\ 7 has transpired?\ 8 A. That's correct.\ 9 MR. HOROWITZ: Object to the form.\ 10 MR. WILLITS: Object to the form of the\ 11 question.\ 12 BY MR. CRITTON:\ 13 Q. When you spoke with the FBI over at\ 14 Greens -- I think it was Greens Pharmacy?\ 15 A. Yes.\ 16 Q. Did they take a statement from you, that\ 17 is, did they have a tape recorder or did they just\ 18 make notes?\ 19 A. They took notes.\ 20 Q. All right. Did you sign anything?\ 21 A. No, sir.\ 22 Q. That is like did they take notes of what\ 23 you said and then you signed it to say yep, that\ 24 accurately reflects what I said?\ 25 A. No, I didn't sign anything. 1 what you said and it was not accurate, that is, he\ 2 put his interpretation of what you said, would you\ 3 have told him that's not accurate, Officer\ 4 Recarey?\ 5 MR. HOROWITZ: Form.\ 6 MR. [REDACTED] Object to the form.\ 7 THE WITNESS: I will tell him.\ 8 MR. CRITTON: Go ahead and change. We're\ 9 going to change the tape. We do have time.\ 10 Cathy, could I borrow back the\ 11 photographs, please?\ 12 While you're giving me those back, would\ 13 it be correct that you're going to keep --\ 14 you took as you did with photograph\ 15 number four you took back five, six, seven,\ 16 and eight, and you're going to keep those\ 17 and not allow me or anyone else to have a\ 18 copy of them?\ 19 MS. EZELL: Yes.\ 20 MR. CRITTON: You're going to be equally\ 21 restrictive; right?\ 22 MS. EZELL: Right.\ 23 MR. CRITTON: All right. Thank you.\ 24 BY MR. CRITTON:\ 25 Q. You were shown photograph five of a lady, Page 347 1 F.E., and I think you told us that you had seen\ 2 her, you recognized her photograph.\ 3 A. Yes, I did.\ 4 Q. On how many occasions did you ever see\ 5 her at the Epstein home?\ 6 A. More than three times.\ 7 Q. More than three?\ 8 A. Yes, sir.\ 9 Q. That's as accurate as you can be?\ 10 A. Yes.\ 11 Q. More than three?\ 12 A. More than three.\ 13 Q. Whether it was four or five you don't\ 14 know, but more than three?\ 15 A. More than three, sir.\ 16 Q. In terms of F.E.'s age, did you ever ask\ 17 her what her age was?\ 18 A. No, sir.\ 19 Q. Did she appear to you to be someone at\ 20 least from seeing her and recalling her that she\ 21 appeared at least to you to be while a young woman\ 22 appeared to be someone who was 18 or older?\ 23 A. No, sir.\ 24 Q. Okay. Well, did you ever say anything to\ 25 the police or did you ever -- were you ever Page 348 1 concerned about that such that you told someone?\ 2 A. No, sir.\ 3 Q. Haven't you told the police, sir -- let\ 4 me strike that, let me ask it this way.\ 5 In your taped statement that you gave to\ 6 the police did you not tell them that all of the\ 7 girls appeared to you to be 18 or above?\ 8 A. Sir, as far as when all these actions\ 9 that were taking place I was under an environment\ 10 that I thought I was going to be -- in other\ 11 words, I was afraid of any reprisal Mr. Epstein\ 12 and Mrs. Maxwell if I say something that is any\ 13 idea of me because I have this confidentiality\ 14 agreement. What I saw that they were very young,\ 15 but I cannot say that they were 18 and old.\ 16 Q. Right. Let me just take you back to my\ 17 question again and see if you can answer my\ 18 question.\ 19 MR. CRITTON: Could you please read it\ 20 back?\ 21 (Thereupon, a portion of the record was\ 22 read by the reporter.)\ 23 THE WITNESS: I think I told the police\ 24 that.\ 25 BY MR. CRITTON: Page 349 1 Q. I'm sorry?\ 2 A. Yes, I did, I told the police.\ 3 Q. And at the time that you spoke with the\ 4 police and gave them a statement, isn't it true,\ 5 Mr. Rodriguez, that you were no longer employed by\ 6 Mr. Epstein?\ 7 A. Yes.\ 8 Q. And you understood that you were required\ 9 to tell the police officers the truth at that\ 10 time?\ 11 A. Yes.\ 12 Q. And if I understood your testimony I\ 13 believe from July 29th through today, you at no\ 14 time asked any of these girls how old they were.\ 15 True?\ 16 A. No.\ 17 Q. And as to whether the girls were under 18\ 18 or 18 or over 18, you really didn't know one way\ 19 or the other at the time. Would that be a fair\ 20 statement?\ 21 A. Yes.\ 22 MR. WILLITS: Object to the form of the\ 23 question.\ 24 BY MR. CRITTON:\ 25 Q. On Exhibit 6 there is a person who's Page 350 1 covered, the lady that Ms. Ezell asked you about I\ 2 believe was on the right-hand side of the\ 3 photograph. There is a young lady on the\ 4 left-hand side with a black hat on.\ 5 Do you recognize her at all?\ 6 A. No, I don't recognize her.\ 7 Q. Okay. Thank you. With regard to the\ 8 photograph four that you saw that you think\ 9 possibly might be [REDACTED] I think you told us that\ 10 you recall seeing that woman in the sauna at Mr.\ 11 Epstein's house on one occasion and she was naked.\ 12 A. Yes.\ 13 Q. Was that near the end of your employment\ 14 or the middle or the front end?\ 15 A. I saw her on January 2005, sir, and I was\ 16 terminated in March, so that was two months prior.\ 17 Q. And did you ever tell anyone that you had\ 18 seen her naked in the sauna?\ 19 A. I told Louella.\ 20 Q. Okay. And what did Louella say?\ 21 A. She was surprised.\ 22 Q. Okay. Did you wake the young lady up in\ 23 the sauna?\ 24 A. No.\ 25 Q. And do you know how old the young lady 21 (Pages 347 to 350) Page 351 I was at that time? 2 A. No. 1 didn't crew. 3 Q. If : was to tell you she was born .n 4 December of '86 which would have made her 18 at S the time, and you would say, not surprised? 6 MS. EZELL: Objection, form. 7 MR. WILLITS: Object to the fo-m of the 8 qtreston. 9 MR. HOROWITZ: Join. 10 THE WITNESS: I would say I wouldn't 11 know. 12 BY MR. CRTTTON: 13 Q. Other than telling Louella d d you say 14 anythirg to anyone else when you saw. the 15 lady ycu telieve was. naked in the sauna? 16 A. I believe I mentioned that to my wife. 17 Q. All right. Aryone else? 18 A. No. 19 Q. And dd continue •- assuming it was 20 dd she continue to sleep an tie sauna, that 21 is, she didn't know you were there? 22 A. She never knew that I was there. 23 Q. She didn't at least acknowledge that she 24 knew. Correct? 25 A. Yes, correct. - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 - Q. You were asked by Ms. Eze I -- I'm just going to cover a couple of things as long as I'm staying with Cathy here whether Louel a, you had toll us something about the picture of the Pope near a picture of a naked person, naked woman That's what Louella told you, ycu never saw those photos. Correct? - A. I dd saw the pictures. - Q. You dd see the pictures? yes. - Q. And the photos that you saw of the naked woman that was near the Pope's piotograph, was that someone that you knew or just a piaUre of a naked woman? - A. It was somebody somebody that was a v sitor in the house, but I don't knew her name. - Q. Ana CPC visitors, mac HMO have peen one of :he plane women, you described the women who came In on planes, o' that they came with Mr. tpstcln from Orne to time, - A. They Wire with Mr. Epstein from Untie to time. - Q. All right. And those are women that think you testified at your last deposition all appeared to be in their 2C's or older. Is that Page 352 rage 351 I correct? 2 A. I think so. sir. 3 Q. All right. I assume that in over the 4 course of your life separate and apart from your 5 wife you've seen a naked woman before. 6 A. Yes. 7 Q. And : assume that in your 50 some odd 8 years how old are you, sir? 9 A. 55. 10 Q. In your 55 years you've seen pictures of 11 naked women both photographs, paintings, statutes 12 Would that be a fair statement? 13 A. Yes. 14 Q. And In terms of at least In this 15 particular case there s all sorts of as feu 16 know there is testimony, and you've peen asked a 17 number of questions about sex related issues, that 18 is whether you saw in photographs or whether you 19 saw anyone engaged in any type of sexual activity. 20 Correct? 2: A. Correct. 22 Q. And I assume that you understand that men 23 and women -- we'll start there first, that men and 24 women actually do have sex in this world? 75 A. Yes. Page 35\< 1 Q. That comes as no grand surprise to your 2 A. No. 3 Q. And ycu understand that people actually 4 enjoy sex from time to tine? 5 A. Yes 6 Q. Are you familiar with that concept at 7 least? 8 A. Yes 9 Q. All right. And what may be tygical IC sexual actirity for one man and woman, or whatever 11 the permutation might te, another couple, or 12 another man and woman, cr another man or woman may 13 consider to be unusual a overly aggressive. 14 MS. EZELL: Objection to form. 15 BY MR CRITTON7 16 0. True? 18 Q. That's what 1 mean. Everyone has a 19 differert point of view about sex and what may be 20 COnSiCered typical sexual aCtIVey for someone, 21 sue cum use Mee Ltre1rJer Woe> a bit 22 adventurous' 23 MR. Ohyrt to the form. 24 THE WITNESS Yes. 25 BY NR. CRMON: 22 (Pages 351 to 354 Page 355 1 Q. I'm not trying to make you a sex expert. 2 Also, I assume that when you've been in 3 CVS or Walgreens, for that matter Publix or Winn 4 Dixie I assume that you've -- I don't want to 5 assume anything. 6 Have you ever been in an aisle where 7 you've actually seen condorns being sold? 8 A. Yes. 9 Q. And where lubricants are being sold? 10 A. Yes. 11 Q. And as well as massage oils and other 12 types of oils actually are sold in those kinds of 13 stores? 14 A. Yes. 15 Q. And they're available so that someone 16 walking through Walgreens or Publix or CVS could 17 actually take it off the shelf, put it in their 18 cart, go up and pay for it and take it home? 19 A. Yes. 20 Q. All right. In the photographs that you 21 talked about, and if I understood you correctly, 22 at least during the time that you were there, Mr. 23 Rodriguez, in '04 and '05 there were -- you said 24 that there were -- I think you said downstairs -- 25 and I'm talking about really from the kitchen area Page 356 1 up the back stairway, or what would be the kitchen 2 stairway to the upper floor, there was I think you 3 said, but correct me if I'm wrong, please, that 4 you don't recall seeing there being any pictures 5 or photographs of any nude women. Is that 6 correct? 7 A. They were not nude women in the 8 staircase. 9 Q. That's all I'm talking about right now. 10 In that area you never saw any pictures, or 11 photographs, paintings, any type of depiction of a 12 nude woman on that staircase going upstairs. 13 Correct? 14 A. Correct. 15 Q. All right. And I think you said 16 downstairs you saw a picture of -- the only 17 picture that you saw of I'd say of a younger child 18 that displayed some form of -- I don't want to say 19 nudity because it's probably not that, but of some 20 portion of their body that was exposed, and I 21 think you described it as her cheek. 22 A. Yes, that's upstairs. 23 Q. That's upstairs? 24 A. Upstairs. 25 Q. And that was -- was it Eva; is that how Page 357 1 you say her name? 2 A. Yes, her mother. 3 Q. Okay. It's Eva's daughter, there was a 4 picture where someone it looked like was pulling 5 on their swimsuit? 6 A. Yes. 7 Q. Do you recall ever seeing the old 8 Coppertone -- 9 A. Yes. 10 Q. Let me ask the question. I know you know 11 what this is. 12 Have you ever seen the old Coppertone 13 commercials and billboards that used to be 14 plastered all over certainly Florida and other 15 places where there is a cute little girl who 16 appears to be two, three, four years old and 17 someone is pulling down at least a portion of her 18 swimsuit so she's exposing a small portion of her 19 cheek is exposed? 20 A. Yes. 21 Q. Okay. Is that what the picture of the 22 young girl looked like that is Mr. Epstein's God 23 daughter? 24 A. More or less, yes. 25 Q. All right. And downstairs in the kitchen Page 358 1 were there any pictures of women in any stage of 2 undress? 3 A. No. 4 Q. And then I think you said as you walk 5 upstairs, or as you walked up the stairway from 6 the kitchen at the top of the landing, I think you 7 described -- did you describe it as the foyer? 8 A. Yes. 9 Q. Okay. But it's really the landing, the 10 upstairs landing? 11 A. Yes. 12 Q. I think you said there were -- there was 13 -- were or was a three by five picture or 14 pictures? 15 A. Yes. 16 Q. Of women in some stage of undress? 17 A. Yes. 18 Q. Okay. And when you say three by five, I 19 assume you meant three feet? 20 A. Three feet. 21 Q. By five feet? 22 A. Yes. 23 Q. Were they photographs? 24 A. Yes, they were photographs. 25 Q. And I think you also told us that you 23 (Pages 355 to 358) Kress Court Reporting, Inc. 305-866-7688\ 7115 Rue Notre Dame, Miami Beach, FL 33141 |Page 359
1 didn't recognize who those people were. Is that
2 correct?
3 MR. \[REDACTED\]: Object to the form.
4 THE WITNESS: I knew this particular girl
5 because it was the daughter of Mrs. Eva.
6 BY MR. CRITTON:
7 Q. Okay. And is that the picture you're
8 talking about?
9 A. This is the picture I'm talking about.
10 Q. Okay. And that was a three by five?
11 A. Yes.
12 Q. All right. And the only thing that you
13 could see was a portion, that is of her other than
14 say her waist or her shoulders or her arms or
15 something, that's one where you could see kind of
16 like the Coppertone commercial, a picture of her
17 cheek?
18 A. Yes. Part of her buttocks.
19 MR. LANGINO: Object to the form.
20 BY MR. CRITTON:
21 Q. Okay. And was there another picture at
22 the top of the foyer, large one, or is that the
23 only one that you can recall?
24 A. There were two of the same girl in
25 different poses.
|Page 361
1 A. Inside his closet, the walk-in closet.
2 Q. And those pictures, I think you called it
3 a mosaic?
4 A. Yes.
5 Q. And of the mosaic, approximately how many
6 pictures were in the mosaic?
7 A. 16 or 20.
8 Q. Okay. And of those pictures how many did
9 you recognize?
10 A. About three or four.
11 Q. All right. Were they -- as to who those
12 people were, you don't know, you just recognized
13 three or four of them?
14 A. Mr. Epstein when he was younger, and then
15 different girlfriends, but I didn't recognize
16 except the ones --
17 Q. Okay. You said three or four of those
18 were pictures of the girls who came over to give a
19 massage?
20 A. Yes.
21 Q. Okay. But as to who those girls were you
22 don't know as you sit here today?
23 A. No, sir.
24 Q. And as to what their ages were you don't
25 know?
| | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |Page 360
1 Q. But showed the same thing?
2 A. Yes.
3 Q. Okay. As you walked through into -- then
4 if I understood it correctly, you go to the pretty
5 much to the end of the hallway, then you go
6 through another small vestibule, double doors, two
7 sets of double doors, and as you go straight ahead
8 then you make a left around the bed and then you
9 end up in the bathroom.
10 A. Yes.
11 Q. In the bathroom -- in the bathroom or in
12 that location were there any pictures of any women
13 in any stage of undress?
14 A. Yes.
15 Q. All right. And were any of those
16 pictures, did they involve -- or were they of any
17 of the girls that have been described as women who
18 came over to give Mr. -- purportedly to give Mr.
19 Epstein a massage?
20 A. Yes.
21 Q. And do you remember who any of the names
22 of any of those people were?
23 A. No.
24 Q. And the pictures you saw, where were they
25 located?
|Page 362
1 A. No, sir.
2 Q. That's correct?
3 A. That's correct.
4 Q. And as to what they depicted in the
5 photographs of the girls were they in different
6 stages of undress?
7 A. Yes.
8 Q. Was everyone undressed to some degree,
9 that is, they were described as nude, or at least
10 the questions asked were these people nude? Were
11 they actually nude or someone may have had their
12 top off?
13 A. There were two girls completely naked in
14 a shower in a sexual act.
15 Q. Is that the one when Ms. Ezell asked you
16 questions, that's one of the photographs that you
17 were talking about?
18 A. No, sir.
19 Q. That was a different --
20 A. Different one.
21 Q. Okay. And the mosaic that you saw where
22 you saw two girls involved in a sexual act, do you
23 know where that photograph was taken?
24 A. I think it was taken in one of the rooms
25 in the house because there is an oval bathtub, but
| 24 (Pages 359 to 362) Kress Court Reporting, Inc. 305-866-7688\ 7115 Rue Notre Dame, Miami Beach, FL 33141 1 I don't know which room, sir.\ 2 Q. Okay. Did you recognize both the girls\ 3 or just one of the girls?\ 4 A. The two girls.\ 5 Q. Then there were -- there was one or two\ 6 other photographs of girls that you recognized?\ 7 A. Yes.\ 8 Q. Okay. And were they fully unclothed or\ 9 did they have some degree of clothes on and/or\ 10 off?\ 11 A. They were naked.\ 12 Q. All right. And all of the remaining\ 13 pictures at least within that mosaic were of\ 14 individuals that you did not know?\ 15 A. No, sir.\ 16 Q. And that you did not recognize as having\ 17 been at the house. Is that correct?\ 18 A. Yes, that's correct.\ 19 Q. You were also asked about some -- let me\ 20 switch for just a minute.\ 21 You were asked about a vibrator that you\ 22 saw, and I think you described it as a back\ 23 massager that was approximately 18 inches long\ 24 that had a couple of rotating heads on it.\ 25 A. Yes. 1 Q. And I think you ultimately came up with\ 2 the idea as it was something you had seen at like\ 3 a Sharper Image store.\ 4 A. Yes, sir.\ 5 Q. Have you ever seen one of those types of\ 6 devices, that is a back massager with the rotating\ 7 heads also sold -- well, let me ask you this.\ 8 Strike that last question.\ 9 Have you ever been to Brookstone?\ 10 A. Yes.\ 11 Q. Okay. Have you ever seen a massager like\ 12 that at Brookstone?\ 13 A. Yes.\ 14 Q. Okay. You were asked whether Ms. Maxwell\ 15 kept the names of any of the girls who came to\ 16 give massages on -- let me ask it this way.\ 17 I think you were asked whether\ 18 Ms. Maxwell ever kept the names of any of the\ 19 girls who came to give massages and I think your\ 20 response was yes.\ 21 A. Yes.\ 22 Q. Okay. Did she keep them on a pad of\ 23 paper, did she keep them in a notebook, did she\ 24 keep them in a computer?\ 25 A. We used to have internal books for 1 pilots, masseuses, chefs, so she have a copy of\ 2 the black book with herself and as well as the\ 3 computer.\ 4 Q. Did you ever go on Ms. Maxwell's computer\ 5 to see what she had in it?\ 6 A. Yes.\ 7 Q. And was that something you were allowed\ 8 to do?\ 9 A. No.\ 10 Q. Okay. You actually went in her office?\ 11 A. Yes.\ 12 Q. And was her computer on so that you\ 13 didn't need to access the password?\ 14 A. It was off.\ 15 Q. Okay. So you just turned it on?\ 16 A. Yes, sir.\ 17 Q. And then you were able to access her\ 18 computer?\ 19 A. Exactly.\ 20 Q. And what possessed you to go in and to\ 21 access her personal computer?\ 22 A. I needed to send some documents to the\ 23 New York office and it was the only computer\ 24 working in the house.\ 25 Q. Okay. And how many occasions did you use 1 her computer?\ 2 A. Several times.\ 3 Q. Was she ever aware that you used her\ 4 computer?\ 5 MR. LANGINO: Form.\ 6 THE WITNESS: I don't think so.\ 7 BY MR. CRITTON:\ 8 Q. Did you ever ask Ms. Maxwell for\ 9 permission to use her computer?\ 10 A. I was the house manager, I believe I was\ 11 supposed to use everything in the house to\ 12 accomplish my duties, in that case sending\ 13 financial reports or e-mails.\ 14 Q. So would you have been -- did you ever\ 15 use Mr. Epstein's computer?\ 16 A. No.\ 17 Q. Okay. But you used Ms. Maxwell's\ 18 computer?\ 19 A. Yes.\ 20 Q. Did you ever use [REDACTED] computer?\ 21 A. Yes.\ 22 Q. In looking at Ms. Maxwell still, you went\ 23 into Ms. Maxwell's computer with at least the idea\ 24 of sending some documents?\ 25 A. Yes. 25 (Pages 363 to 366) |Page 367
1 Q. Up to New York?
2 A. Yes.
3 Q. Were you going to pdf them?
4 A. Yes.
5 Q. And did she have a fax machine -- not a
6 fax machine, a copy machine in her office as well?
7 A. Yes.
8 Q. Okay. So how would you generally do
9 that? Would you do that through a Microsoft
10 program?
11 A. Through Citrix.
12 Q. Through Citrix. All right. With Citrix,
13 and that is, if you said you saw some names of
14 individuals on her computer if you were just going
15 to pdf some documents up to New York why would you
16 of -- what would of caused you to have seen any
17 names on her computer?
18 MS. EZELL: Objection to form.
19 THE WITNESS: All the calls that came to
20 358 El Brillo, they came through the
21 telephone, they have a transcript somehow
22 that they connect to the computer, so you
23 can pull it and you register the time, who
24 called, who didn't call, and you can pull
25 this at your request. So I used to use that
|Page 369
1 record with tape number three.
2 BY MR. CRITTON:
3 Q. Mr. Rodriguez, I was asking you about
4 Ms. Maxwell's computer and you told me how you
5 went on the computer.
6 If she was out of town would she take her
7 computer with her?
8 A. No.
9 Q. It was something she left there?
10 A. Yes.
11 Q. All right. And when you went on to pdf,
12 I think you said it was really one time that you
13 saw the names of some of these girls?
14 A. Yes.
15 Q. And if I understand it correctly, it was
16 -- did it have the name and then a phone number?
17 A. Yes.
18 Q. And was that something that was
19 automatically downloaded from the system?
20 A. Yeah, from the phone system to the
21 computer so we have a transcript.
22 Q. When you say a transcript, the fact that
23 Sally [REDACTED] phone number 561, whatever it was,
24 called.
25 A. It was a transcript of the phone calls of
| | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | |Page 368
1 to go back to some calls that they were
2 requesting, especially when the hurricane
3 season happened.
4 BY MR. CRITTON:
5 Q. Okay. So if I understand, even the
6 computer you used would have had that same
7 feature?
8 A. No, no, it was totally different. Mine
9 was slower and all the time was breaking down
10 that's why we have the guy from Ohio came and
11 fixed the computers.
12 Q. Okay. Were there other computers that
13 you used that had that feature, that is that --
14 A. Only Sarah, Mrs. Maxwell, and the staff
15 house.
16 Q. Staff house being yours?
17 A. The guest house, yes, my office.
18 Q. So you could go out to your guest house
19 then and look for the same information?
20 A. No.
21 Q. All right. I don't understand but why
22 don't we take a break because we're almost out of
23 tape.
24 (Thereupon, a recess was had.)
25 THE VIDEOGRAPHER: We're back on the
|Page 370
1 the house, we can get it from the computer.
2 Q. Okay. And I'm distinguishing,
3 transcript, it would tell you the name and phone
4 number, it wouldn't tell you what was said?
5 A. It was the message also.
6 Q. Okay. Now I understand. And so
7 Ms. Maxwell when you said she had the names of
8 some of these girls who may have given massages,
9 or at least were what you called earlier girls
10 that gave massages, or females that gave massages,
11 she would have had it because that was information
12 that was downloaded from the Citrix system into
13 her computer?
14 A. Yes.
15 MS. EZELL: Objection, form.
16 BY MR. CRITTON:
17 Q. Okay, I understand. Now, you said she
18 also had some pictures. Is that that one time you
19 also saw pictures?
20 A. Yes.
21 Q. And were you going through her computer
22 at that time?
23 A. No.
24 Q. The question is, if all you were going to
25 do was try to pdf some financial information to
| 26 (Pages 367 to 370) Kress Court Reporting, Inc. 305-866-7688\ 7115 Rue Notre Dame, Miami Beach, FL 33141 |Page 371
1 New York what were you doing getting to names and
2 phone numbers and then pictures of girls?
3 A. I was trying to get some information. I
4 was working the computer and I just happen -- they
5 have the icon of the file and I open and it was
6 right there, so I was not looking but, you know,
7 it was already accessible to me.
8 Q. And how many photographs did you then
9 scroll through to look at?
10 A. Probably 30.
11 Q. Okay. And why?
12 A. Just curiosity, sir.
13 Q. So again, you never told anyone other
14 than your wife?
15 A. No.
16 Q. Correct?
17 A. Yes, correct.
18 Q. Of the pictures that you saw, if I
19 understood it correctly, some of those were
20 pictures of -- well, I think you said some of them
21 reflected parties or banquets?
22 A. Yes.
23 Q. I think you described some of the
24 pictures gatherings that appeared to be either in
25 Russia or Eastern Europe?
Page 373
1 Q. Okay. Were any of the photographs that
2 were in -- again, I'm talking about Ms. Maxwell's
3 computer now, were those photographs of
4 individuals who were any of the girls or ladies
5 that came over to give massages?
6 A. No. They stay at the house.
7 Q. Okay. So the photographs that you saw on
8 Ms. Maxwell's computer of females in any state of
9 undress or at parties or at banquets, those were
10 all of individuals who would fly in with Mr.
11 Epstein at various periods of time that had
12 traveled with him?
13 A. That's correct.
14 Q. Okay. Those are the girls that you told
15 us I think at your last deposition and reaffirmed
16 here today, those girls all appeared to be in
17 their 20's?
18 A. Yes, sir.
19 Q. All right. Now, you were also asked some
20 questions, a lot of questions about surveillance.
21 And if I understood your testimony, and this is
22 where it goes back to what do you know, what don't
23 you know, what were you speculating on, what did
24 you know at the time, what do you know now, at
25 least I need you to distinguish that for me so
Page 372
1 A. Yes.
2 Q. All right. And then you talked about a
3 picture of two girls in the shower that you didn't
4 know the girls. Correct?
5 A. Yes.
6 Q. That's correct?
7 A. That's correct.
8 Q. All right. And that in all of the
9 photographs that you saw the individuals seemed to
10 be having a good time?
11 A. Yes.
12 Q. All right. Would it be a correct
13 statement that in none of the photographs did
14 anyone seem to be distressed or disturbed or show
15 any type of negative emotion, at least from what
16 you observed?
17 A. That's correct.
18 MS. EZELL: Objection, form.
19 BY MR. CRITTON:
20 Q. And in terms of the photographs that you
21 did see, were any of the photographs that you saw,
22 did they appear -- did they appear to have been of
23 women that you had seen fly in with Mr. Epstein on
24 his plane?
25 A. Yes.
Page 374
1 that I know what you knew at the time, and as
2 distinct from what you may have read in the
3 newspaper or been told by some lawyer or someone
4 else that may not be accurate. Okay?
5 A. Yes, sir.
6 Q. With regard to the -- with regard to
7 surveillance equipment, if I understood your
8 testimony today is you were completely unaware of
9 the existence of any surveillance equipment in the
10 house during the 2004/2005 time period that you
11 worked there. Is that correct?
12 A. Yes.
13 Q. And therefore, where it was, what may
14 have existed, whether it in fact actually did
15 exist, whether anyone maintained it, you have no
16 personal knowledge whatsoever. Is that true?
17 A. That's true.
18 MR. WILLITS: Object to the form.
19 BY MR. CRITTON:
20 Q. You talked about pictures of two women
21 who you saw in the house who were nude, one was
22 Nadia?
23 A. Yes.
24 Q. And you knew Nadia was someone who was in
25 her 20's?
Page 403
1 A. No.
2 MR. \[REDACTED\]: Form.
3 BY MR. CRITTON:
4 Q. For those women -- I think I need -- let
5 me strike that.
6 On some occasions you'd see the women
7 come down from upstairs because you would either
8 let them out of the house or you might give them
9 an envelope that had money in it. Is that
10 correct?
11 A. Yes.
12 Q. Did any of those -- Mr. [REDACTED] asked you
13 some questions -- I think it was Mr. [REDACTED]
14 whether they had sat down and had anything to eat,
15 whether they had cereal or anything like that.
16 A. Yes.
17 Q. Did you ever observe any of those women
18 before they went upstairs eating anything at the
19 house?
20 A. Sometimes.
21 Q. And I think he used -- he meaning Mr.
22 [REDACTED] used cereal and ice cream.
23 A. Yes.
24 Q. And he said, if I recall from the last
25 deposition, kids like ice cream.
|Page 405
1 them stop and have anything to eat or did you
2 always see them at the end, that is they're ready
3 to go?
4 A. I didn't know, they came from downstairs,
5 they went to the kitchen, but I didn't know they
6 were there because I was in the guest house.
7 Q. Okay, that's my question. You only
8 observed them either if you heard conversation or
9 Sarah had called you and said would you pay such
10 and such?
11 A. Yes.
12 Q. At which time you would give them the
13 envelope with money?
14 A. Yes.
15 Q. In that set of circumstances they were on
16 their way basically to leave?
17 A. Yes.
18 Q. When you saw them leave did any of them
19 at any time, any of the ones that you saw during
20 August of '04 through March of '05 appear to you
21 to be scared?
22 A. No, sir.
23 Q. Did any girls, women ever appear to have
24 been injured in any way?
25 MR. \[REDACTED\]: Form.
| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |Page 404
1 A. Yes.
2 Q. Do you remember him asking you that?
3 A. Yes.
4 Q. Are you familiar that teenagers like ice
5 cream?
6 A. Yes.
7 Q. Are you familiar that people who are 20
8 and 30 years old like ice cream?
9 A. Yes.
10 Q. Are you familiar that older people, even
11 our age, Mr. Rodriguez, like ice cream too?
12 A. Yes.
13 Q. Okay. And when the individuals would sit
14 there, and that is these women who would come over
15 to give a massage and they would -- you would
16 observe them eating, did they appear to be
17 comfortable?
18 A. Yes.
19 MR. HOROWITZ: Form.
20 BY MR. CRITTON:
21 Q. Did they appear to be interacting with
22 either you or the chef?
23 A. Yes.
24 Q. When any of those women would come over
25 to give massage came downstairs, did you ever see
|Page 406
1 THE WITNESS: No, sir.
2 BY MR. CRITTON:
3 Q. Did anyone appear to be in shock?
4 A. No, sir.
5 Q. Was anyone ever crying?
6 A. No, sir.
7 Q. Was anyone disheveled or appeared to be
8 unhappy?
9 A. No, sir.
10 Q. Did all of them appear, that is the ones
11 that you saw leave the house that you had an
12 opportunity to observe during that time period,
13 did they appear to be approximately the same
14 personality, same demeanor that they had had when
15 they came into the house?
16 MR. HOROWITZ: Form.
17 THE WITNESS: Yes.
18 BY MR. CRITTON:
19 Q. Did anyone ever tell you when they came
20 down the stairs that they had been injured?
21 A. No.
22 Q. I'm talking about the young lady, the
23 women who had given the massages that you saw
24 actually leave the house, that is you had some
25 interaction with, either some interaction as they
| 35 (Pages 403 to 406) Page 407 1 were leaving the house, did anyone ever tell you 2 that they had been injured? 3 A. No, sir. 4 Q. Did they ever tell you that they had been 5 forced to do something against thet will? 6 A. No. 7 Q. Did they ever tell you that they had been B forced :o do something inappropriate? 9 A. No. 10 Q. Did they ever tell you that they had been 11 assaulted in any way? 17 A. No. 13 Q. Did they ever tell you that they had been 14 inappropriately touched? 15 A. No. 16 MR. HOROWITZ: Form. This Is a 17 cumulative. lies already tod you the 18 limted contact he had. This is totally 19 inappropriate line of questions. 20 MR. CRITTON: Is that a form objection? 21 MR. HOROWITZ: You're exceeding the scope 22 of the direct because nobody asked him -- 23 MR. CR1 TION: Form, you get form in 24 federal court, that's what you get. Give me 25 your form. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 408 MR. HOROWITZ: Form, cumulative. MR. CRITTON: Great. Why don't you let me finish the question and ther you can obpct to it. Could you give me back what my last question was, please? (Thereupon, a portion of the record was read by the repo-ter.) THE WITNESS: No. BY MR. CRITTON: Q. Did they eve- tell you that they had been sexually assaulted In any way? MR. Form. NR. HOROWITZ: Form. ThIF WITNESS: No. BY MR. CRITTON: Q. so,ir A. No. Q. At any time did you hear anyone -- strike that. AC to the women who Carr to give a massage, did you ever hear anyone scream? A. No, sir. Q. Did you tier hear anyone cry out what sounded like to you bob? 1 2 3 4 5 6 7 8 9 10 11 17 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. Firm. THE W. NE : No. EMI BY MR. CRITTON: Q. Did you ever hear anyone yell rape or assault or battery? MR. HCROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. Did you ever hear anyone yell out in anger? A. No. Q. You've gone onFne It. Rodriguez, and looked at carious articles cr postings that have been made regarding these cases. Is that a 'air statement? sorry? Q. :f I understood your testimony from July 29th and a little bit today, is that you've gone online and read some articles and/or what the police report may have sad, that is, you've read information that you've — about these lawsuits alter the time that you left Mr. Epstein's empoyment. A. ves Q. Corect.? Page 409 Par 410 1 A. Yes. 2 Q. And, therefore, you have at least seen 3 certain allegations and what people say occurred, 4 or at least their recitation of what may have S occurred at Mr. Epstein's home. 6 A. err.. 7 Q. You have no personal knowledge one way o• 8 the other. 9 MR. HOROWITZ: Object to the form. 10 MR. Form. 11 BY MR. CICTION: 12 Q. Correa? 13 A. That's correct. 14 Q. Are you also aware that the individuals 15 who have filed lawsuits want n some instance 16 millions of dol'ars? 18 Q. Okay. Are you aware that some of them 19 are now claim ng that they were sexuaey 20 assaulted? 21 A. Yec 22 Q. And battered? 23 A. Yes. 24 Q. And you have no information, no personal 25 knowledge In that regard. Is that true? Pace 4:1 1 A. Yes. 2 MR. form. 3 MR. HOROWITZ: Form. 4 BY NR. CRITTON. 5 Q All right. Were YOu aware of the 6 backgrounds of any Cf these women who came over to 7 gve massages? 8 MR. HOROW1 IL: Form. 9 THE WITNESS, Nu, sir. 10 BY NR. CRITTON: 11 Q wen, have you -- d c any one of tne 12 femaes who ever came :o give massage;, did they 13 ever tell you that they were prostitutes? 14 A. No, sir. 15 Q. Did they ever ten you that they had teen 1G lead into a iife of prostitution? 17 MR. HOROWITZ: Form. 18 THE WITNESS: No. 19 BY M.R. CRITTON: 20 Q. Did they ever tell you about their family 21 life, whether it irnolved prostitution, atom. 22 prior posttraumatc stress syndrome, dru?s, 23 alcohol, abuse by end vlduals, physical aWse as 24 well as verbal abase? 25 A. No, they dirsn't tell me. Pose 412 1 Q. And, obviously, you have no personal 2 knowledge one way or the other -- 3 A. No, sir 4 Q. -- with regard to what their backgrounds 5 were before they ever met or came in :ontact with 6 Mr. Epstein? 7 A. No, sir 8 Q. DA any person, female, who came to give 9 a massage at the Epstein home, did aryone eve 10 come downstairs and say, Mr. Rodriguez, or sir, II call the poi 7 12 MR. Fo.m. 13 MR. HOROWITZ: Form. 14 THE WITNESS. No, sir 15 BY MR. CRITTON: 16 Q. : think you said on one occasion you saw 18 you didn't -ecogrize. 19 A. Exactly. 20 Q. You called the police? 21 A Yes. 1 did 22 Q. Did YOU (20 to the police or you cal ed 23 the police and they came? 24 A. 1 went to the police department 25 Q. 5o now dd you -- did you actually leave ?age 412 1 the property In your car? 2 A. 1 was puling over from Publik so 1 3 turned around and I went to the pat and say — 4 Q. Okay. You were coming back to the home 5 when you saw that car there? 6 A. Exactly. 7 Q. And they sent they, the police, sent a tl police car with you to come there> 9 A. yes. 10 Q. Did you and the prarce office- walk up to 11 the car? 12 A. The police went first. 13 Q. All right. And if I understand that, 14that was in January of '05? 15 A. Yes. 16 Q. And when you did that then did you fclIove 17 behind the police office to see who was in the 18 car? 19 A ves. 20 Q. And then you recognized that as IM? 21 A. yes. 22 Q. AN:1M said she had come back or was 23 there to get some money? 24 A. ves. 25 Q. And did you in fact give her money' Odce 414 1 A. Yes, I did. 2 Q. Arse 1 think you said you told the police 3 o'ficer you recognized her? 4 A. Yes. 5 Q. Did you have to get pernYssion to pay her 6 or" did you just pay her? 7 A No, because Sarah told me already but I 8 forgot she was going tc be that late, so that was 9 my concern In ca'ling the police. 10 Q. Okay. And that person who cane, do you 11 have any idea what her age was at that time? 12 A That night? 13 Q. Right, January of '08. 14 A No, no IS Q e'm s sorry, January of '05. 16 A No. l8 had had with ..ouella . who was 1 think she was ore 19 of the house -- the main housekeeper. 20 A Yes. 21 Q. Anc touella told yo!' a number of thoughts 22 that she had. Is that correct? 23 A Yes 24 Q. Anc as to Louella what she told you about 25 let me strike that. aoge 415 1 1 think you toed us, you were asked 2 questions about sex toys, : think you certainly 3 descnbcd the back massagers. Correct? 4 A. Yes. Q. I think you said the only sex toys that 6 you ever saw were in the armoire at the end of Mr 7 Epstein's bed. 8 A. Yes. 9 Q. Ckay. And whatever other sex toys that 10 to which there was a reference, that's something 11 that louella told you. Is that correct? 12 A. Ihat's correct. 13 Q. You were asked at the last deposition, I 14 don't remember who asked the question, but whether 15 you had ever seen pornography on any computer. 1 16 think one of your responses was you saw some 17 photos of a naked woman who appeared to you to be 18 a model. 19 A. Yes. 20 Q. Ckay. Do you consider ever/ photograph, 21 picture, paIntirg of a naked njde woman to be 22 pornography? 23 MR. HOROWITZ: Form. 29 MS. EZELL: Objection, form. 25 THE WITNESS: I consider -- wel, it it's Paye 416 a frontal picture it's pornography, I will 2 look at my way. 3 BY MR. CRITTON: 4 Q. In your views 5 A. Yes. 6 Q. So if you looked at -- I don': remember 7 whether Playboy ail has -- say a Playboy that 8 has a frontal rudty shot of a woman, yoj would in 9 essence say that Playboy is selling pornography? 10 A. Yes. 11 Q. Therefore, every person who buys a 12 Playboy that has over the last umpteen tens of 13 years that has a frontal picture of a woman in the 14 nude would be purchasing pornography whether it's 15 frcm CVS, or Walgreens, or Eckerd as they existed, dny g utery store that sells diCi 17 A. Yes. 18 MS. EZELL: Objection, form. 19 MR. Form. 21) MK. HuitoWli Z: term. 21 BY MR. CRITIDN: 22 Q. The photographs I'm sorry, :he 23 pictures that you saw in the computer, I think you 24 were able to draw those up or bring those up from 75 your own computer. Par 417 1 A. To tring the pictures from my computer? 2 Q. Let me rephrase the question. I thought 3 what you said est tine was that os to tie 4 pictures that you did see of naked women -- of a 5 naked woman or naked women on the computer, that 6 you've looked at hose photographs through your 7 Computer. 8 A. No. 9 Q. Okay. Then I may have misunderstood you. 10 Was your reference to Ms. Maxwell's computer that 11 you made at the last deposition? 12 A. Yes. 13 Q. Okay. your computer that you tad either 14 in the staff house or that you •• 15 A. D•dn t access. 16 Q. You caldn't access these files' 17 A. That's correct. 18 Q. All right, now I'm with you. So the 19 photographs you've talked of the nude individuals, 20 or the naked women, were the photographs that 21 we've already talked about with both, i.e., in 22 Ms. Maxwel's (Waiter) 23 A. Yes. 24 Q. Thank you for clearing that up. 25 I'm going to ask you to assume that C.W. Per 418 I who you've descrioed as having come to Mr. 2 Epsten's house on three or four t mes a week for 3 a period of time, one of her claims in this case 4 is :ha: she has been emotionally traumatized by 5 her contact with Mr. Epstein. Just assume that to 6 be true for purposes of this queston. 7 Did you ever observe any what you would 8 have seen as emotional trauma or any type of 9 disturoance with C.W. on the many times she came 10 to your house? 11 MR. Form. 12 THE WITNESS: I didn't see any. 13 BY MR. CRITTON: 14 Q Does it make sense to you that a person 15 who daims emotiona trauma would continie to come .r a Anne th at rh alai! 17 sir? 18 19 ZU 21 22 23 24 25 MR. Form. MR. HOROWITZ: Form. MR. WILLITS: QDJeCI to the form 01 the question. THE WITNESS: I'm not a psychologist. MR. Can you state your Onawer, cliclit hear it, THE WITNESS! Yeah, I .11 not a Page 419 1 psychologist, I don't know. 2 MR. CRITTON: I have no further 3 questions. 4 REDIRECT EXAMINATION 5 BY MR..= 6 Q. Mr. Rodriguez, I don't know if we covered 7 this last time, I think that we did not, but can 8 you tell us during the period of time when you 9 worked at that house at E Brilb, tor. Epstein's, 10 what cars did he own or were in the driveway? 1: A. We have two Suburbans, two Mercedes 600, 12 and a Cobra, and a motorcyce. 13 Q. And which, if any, did he drive? 14 A. preferred the Mercedes or any of the 15 Suburbans. 16 Q. All right. Do you know where he owns 17 homes? 18 A. Yes. 19 Q. V/herel 20 MR. CRITTON: Form. 21 THE WITNESS: Pads, New York City, El 22 Brillo, Saint James Island -• I'm sorry, an 23 Island in tie Caribbean, and a ranch in New 24 Mexco. 25 BY MR. 1 2 3 4 S 6 7 9 10 11 12 13 14 15 17 18 19 20 21 22 23 24 25 Page 420 Q. Have you been to any of the °theproperties? A. No. Q. Co you know the house managers at any cf the other properties? A. Yes. Q. And who are they? A. Balsone in Pals, good friend of mine fro•n Brazil. And the people la New York give me the brief ng when I came aboard. There is a couple from the Philippines. And I talked to the couple that used to own the Island -• I mean who used to manage the Island, a couple from South African. f3a:sone was cbser to me. Q. Have you talked to Basone about whether iut tti. Coster hem maasegco wher he at that place? A. Q. A. too. MR. CRITTON: Mr. Babone was which one? THE WITNESS: Baslone was the house manager of Paris, 22 Foch Avenue. BY MR. EDWARDS: Yes, I dd. And what did he say about that? That he had a lot or massages over there Page 421 1 Q. What's the address? 2 A. 22 Foch Avenue, Paris. F-O-C.H. 3 Q. Okay. Do you know a telephone number for 4 Balsone? 5 A. No, I don't remember, sir. 6 Q. All right. How did it come up that you 7 to ked to him about whetter or not Mr. Epstein had 8 massages at Oat house? 9 A. He came on two occasions and stay with me 10 for a week because Mr. Epstein wanted me to get 11 into his stye of running the house, and he was 12 good enough to give me some inside information, 13 what he likes and doesn't like, so he told me the 14 came thing was in Paris. 15 Q. And I think that you described Mr. 16 Epstein usually had about two massages a day. or 17 at least we were calling them massages. 18 A. Yes, sir. 19 MR. CRITTON: Form. 20 BY MR. Ma 21 Q. And did Mr. Baisone describe it in a 22 similar fashion -- 23 A. Yes. 24 Q. in Paris? 25 And did he also tell you that the girls Page 422 1 were very young in age that he was receiving these 2 massages from? 3 MR. CRITTON: Form. 4 THE WITNESS: Yes. 5 BY MR. 6 Q. Did he indicate whether or not -- or how 7 old these girls were? 8 A. No, ne didn't told me. 9 Q. Just that the age group was similar to 10 the age group that he was interested :n in Palm It Beach? 12 MR. a Form. 13 THE WITNESS: Yes. 14 BY MR. a 15 Q. And did you talk to any of the louse Ars.\_\_ertanesae sr. Vralel 17 A. No. 18 Q. Who was the house manager in New York at 19 the tune when you were the house manager at El 20 BOW? 21 A. His nickname was lo-.1o, but I don't 22 remember. JoJo and his wife, but I don't 23 remember his name, sir. 74 Q Do you know whether Mr. Epstein would 25 have massages when he was in New vor< at his New