EXHIBIT 4¶
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
JANE DOE NO. 2, Case No: 08-CV-80119¶
Plaintiff,¶
Vs¶
JEFFREY EPSTEIN, Defendant.¶
JANE DOE NO. 3, Case NO: 08-CV-80232¶
Plaintiff,¶
Vs¶
JEFFREY EPSTEIN, Defendant.¶
JANE DOE NO. 4, Case No: 08-CV-80380¶
Plaintiff,¶
Vs.¶
JEFFREY EPSTEIN, Defendant.¶
JANE DOE NO. 5, Case No: 08-CV-80381 PlAinriff,¶
Vs¶
JEFFREY EPSTEIN, Defendant.¶
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| <p>1 JANE DOE NO. 6, Case No: 08-CV-80994</p> <p>2 Plaintiff,</p> <p>3 Vs</p> <p>4 JEFFREY EPSTEIN,</p> <p>5 Defendant.</p> <p>6 _____</p> <p>7 JANE DOE NO. 7, Case No. 08-CV-80993</p> <p>8 Plaintiff,</p> <p>9 Vs</p> <p>10 JEFFREY EPSTEIN,</p> <p>11 Defendant.</p> <p>12 C.M.A., Case No: 08-CV-80811</p> <p>13 Plaintiff,</p> <p>14 Vs</p> <p>15 JEFFREY EPSTEIN,</p> <p>16 Defendant.</p> <p>17 _____</p> <p>18 JANE DOE, Case No: 08-CV-80993</p> <p>19 Plaintiff,</p> <p>20 Vs</p> <p>21 JEFFREY EPSTEIN,</p> <p>22 Defendant.</p> <p>23 _____</p> <p>24 _____</p> <p>25 _____</p> | <p style="text-align: right;">Page 4</p> <p>1 VIDEO TAPED</p> <p>2 DEPOSITION</p> <p>3 of</p> <p>4 ALFREDO RODRIGUEZ</p> <p>5 taken on behalf of the Plaintiffs pursuant</p> <p>6 to a Re-Notice of Taking Deposition (Duces Tecum)</p> <p>7 ---</p> <p>8 APPEARANCES:</p> <p>9 MERMELSTEIN & HOROWITZ, P.A.</p> <p>10 BY: STUART MERMELSTEIN, ESQ.</p> <p>11 18205 Biscayne Boulevard</p> <p>12 Suite 2218</p> <p>13 Miami, Florida 33160</p> <p>14 Attorney for Jane Doe 2, 3, 4, 5,</p> <p>15 6, and 7.</p> <p>16 ROTHSTEIN ROSENFELDT ADLER</p> <p>17 BY: BRAD [REDACTED], ESQ., and</p> <p>18 CARA [REDACTED], ESQ.</p> <p>19 Las Olas City Centre</p> <p>20 Suite 1650</p> <p>21 401 East Las Olas Boulevard</p> <p>22 Fort Lauderdale, Florida 33301</p> <p>23 Attorney for Jane Doe and E.W.</p> <p>24 And L.M.</p> <p>25 PODHURST ORSECK</p> <p>26 BY: KATHERINE W. EZELL</p> <p>27 25 West Flagler Street</p> <p>28 Suite 800</p> <p>29 Miami, Florida 33130</p> <p>30 Attorney for Jane Doe 101 and 102.</p> |
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| <p style="text-align: right;">Page 5</p> <p>1 JANE DOE NO. 11, Case No: 08-CV-80469</p> <p>2 Plaintiff,</p> <p>3 Vs</p> <p>4 JEFFREY EPSTEIN,</p> <p>5 Defendant.</p> <p>6 _____</p> <p>7 JANE DOE NO. 101, Case No: 09-CV-80591</p> <p>8 Plaintiff,</p> <p>9 Vs</p> <p>10 JEFFREY EPSTEIN,</p> <p>11 Defendant.</p> <p>12 _____</p> <p>13 JANE DOE NO. 102, Case No: 09-CV-80656</p> <p>14 Plaintiff,</p> <p>15 Vs</p> <p>16 JEFFREY EPSTEIN,</p> <p>17 Defendant.</p> | <p style="text-align: right;">Page 5</p> <p>1 APPEARANCES:</p> <p>2 LEOPOLD-KUVIN</p> <p>3 ADAM J. LANGINO, ESQ.</p> <p>4 2925 PGA Boulevard</p> <p>5 Suite 200</p> <p>6 Palm Beach Gardens, Florida 33410</p> <p>7 Attorney for B.B.</p> <p>8 RICHARD WILLITS, ESQ.</p> <p>9 2290 10th Avenue North</p> <p>10 Suite 404</p> <p>11 Lake Worth, Florida 33461</p> <p>12 Attorney for C.M.A.</p> <p>13 BURMAN, CRITTON, LUTTIER &</p> <p>14 COLEMAN, LLP</p> <p>15 BY: ROBERT CRITTON, ESQ.</p> <p>16 515 North Flagler Drive</p> <p>17 Suite 400</p> <p>18 West Palm Beach, Florida 33401</p> <p>19 Attorney for Jeffrey Epstein.</p> <p>19 _____</p> <p>20 ALSO PRESENT:</p> <p>21 JOE LANGSAM, VIDEOGRAPHER</p> <p>22 ---</p> <p>23 _____</p> <p>24 _____</p> <p>25 _____</p> |
2 (Pages 2 to 5)¶
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Page 94 A. I don't remember, sir. Q. The next page is a message in the upper left dated January 13, 2005, from C.W. Correct? A. Yes. Q. That's the same C. that we've been talking about. Correct? A. Yes. Q. That was at 7:30 p.m. Correct? A. Yes. Q. And you don't recall what that particular call was about. Right? A. NO, sir. Q. The message dated January 20, 2005, from Maria. Do you see that on the bottom right? A. Yes. Q. Do you know who that is? A. I think I have a different page. Q. You're a little ahead of me. January 20, 2005. MR. CRITTON: I think that's page 31. THE WITNESS: I don't remember who she was, sir. BY MR. MERMELSTEIN: Q. You don't recall what that message was about?¶
Page 95 I. A. No, sir. Q. What about the next page there is a message that Eva called? A. Yes. Q. Dated January 21, 2005? A. Yes. Q. Do you know who Eva is? A. Yes. Q. Who is Eva? A. The assistant comptroller from the New York office. Q. Do you remember her last name? A. Polish last name I guess. She was Russian. She is Russian actually. Q. Did you ever travel to any other residences that Mr. Epstein had? 1/ A. NO. Q. Are you aware he had a residence in the Virgin Islands? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. MERMELSTEIN: Q. And would he sometimes travel to that residence from Palm Beach? A. Yes.¶
Page 96 Q. Okay. Do you recall on any occasion whO would travel with him to the Virgin Islands? MR. CRITTON: Form. THE WITNESS: No, sir. BY MR. MERMELSTEIN: Q. I think we were talking about the money before, the household account, sometimes you gave gifts? A. Yes, I was told to buy some gifts. Q. For whom? A. For the guests. Q. Okay. And what kind of gifts? A. Shoes, sweaters, clothes. Q. So were you instructed to buy something in particular at a particular store? A. They would go to the store, if they like something I will go after and pay them and retrieve it. Q. Okay. So would this be a girl who was staying at the house? A. Yes. Q. Okay. This was one of the girls who travelled with Mr. Epstein to Palm Beach. Correct? A. Yes.¶
Page 97 Q. And so Mr. Epstein would Instruct you to go shopping with this girl? A. Yes. Q. And instructed you to pay for whatever it S is she wanted to buy? A. Yes. Q. Was there a price limit or anything of that nature? A. No, sir. Q. So when the girl decided what she wanted you would -- A. I would write them a check. Q. In that instance you would pay by check? A. Yes. Q. Any other instances where you gave gifts to girls at the instruction of Mr. Epstein? told me I will buy the item. Q. I'm sorry? A. You know, when I was told to purchase this item for them, you know, I will do that, but not on any other occasions. Q. What do you mean not in any locations? A. Any other occasions. Q. Not any other occasions. Okay. Did you¶
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| <p>Page 98</p> <p>1 ever buy flowers for a girl? 2 A. Yes, sir. 3 Q. Tell me about that. 4 A. I was told to buy flowers and roses for a 5 girl performing in high school. 6 Q. Which girl was that? 7 A. I don't remember the name, sir. 8 Q. What was Mr. Epstein's relationship to 9 this girl? 10 MR. CRITTON: Form. 11 THE WITNESS: I think she was an 12 acquaintance, friend. 13 BY MR. MERMELSTEIN: 14 Q. She was a friend? 15 A. Yes, sir. 16 Q. Now, she was performing at the high 17 school in what capacity? 18 A. There was like a -- like a play in the 19 graduation for high school. 20 Q. A play for graduation? 21 A. Yes, in the high school theatre there was 22 some kind of performance. 23 Q. Was it like a theatre production? 24 A. Yeah, something like that. I didn't go 25 inside so I didn't know what was going on inside.</p> | <p>Page 101</p> <p>1 Q. Now, you said you never went inside the 2 theatre? 3 A. No, sir. 4 Q. Okay. How did you get to the flower 5 store? 6 A. I called the girl to her cell and she 7 will come to the back door and I give her the 8 flowers. 9 Q. Was anyone else around at the time? 10 A. No, sir. 11 Q. And you mentioned this was a girl you had 12 seen before? 13 A. Yes. 14 Q. Was this girl who had come to give 15 massages to Mr. Epstein? 16 MR. CRITTON: Form. 17 THE WITNESS: I don't know if she was 18 doing massages but she was at the house. 19 BY MR. MERMELSTEIN: 20 Q. What would she have been there for? 21 A. To visit him. 22 Q. This was a high school girl who was 23 coming to visit Mr. Epstein at the house? 24 A. She came to the house, I open the door 25 and I left, you know.</p> |
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| <p>Page 99</p> <p>1 Q. Why do you say it was for graduation? 2 A. Because everybody was the graduation 3 outside, there were parents, there were a lot of 4 people at the school. 5 Q. Okay. A lot of high schools have theatre 6 production companies and they put on plays. 7 Correct? 8 MR. CRITTON: Form. 9 THE WITNESS: It was towards the end of 10 the year. Well, I think I overheard that 11 there was a graduation performance of some 12 kind. 13 BY MR. MERMELSTEIN: 14 Q. But you didn't go in so you don't know? 15 A. No, sir. 16 Q. But this was a high school student you 17 were bringing the flowers to. Is that correct? 18 A. Yes. 19 Q. Had you seen this girl before at the El 20 Brillo Way property? 21 A. Yes, sir. 22 Q. You had seen her a number of times? 23 A. Yes, sir. 24 Q. Do you recall her name? 25 A. I don't remember her name, sir.</p> | <p>Page 101</p> <p>1 Q. Did you take her to the kitchen like you 2 did -- 3 A. Yes. 4 Q. So you brought her to the kitchen just 5 like you did for the girls who gave him massages. 6 Correct? 7 A. Yes, sir. 8 Q. Did you ever pay her? 9 A. I don't remember, sir, but probably I 10 did. 11 MR. CRITTON: Form, move to strike, 12 speculation. 13 BY MR. MERMELSTEIN: 14 Q. Why do you say you probably did? 15 A. Because I was the only one paying -- 16 well, not the only one but, you know, but chances 17 are I paid her but I don't remember that 18 particular instance that I gave her money. 19 Q. Is it fair to say th</p> |
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| <p>Page 166</p> <p>1 written down anywhere?</p> <p>2 A. No.</p> <p>3 Q. It's my understanding that C. and T.</p> <p>4 either came to his house alone to visit with Mr.</p> <p>5 Epstein or brought other girls in their age group</p> <p>6 to Mr. Epstein.</p> <p>7 Were you familiar with that type of</p> <p>8 recruitment process of girls bringing other girls?</p> <p>9 MR. CRITTON: Form.</p> <p>10 THE WITNESS: Yes.</p> <p>11 BY MR. [REDACTED]</p> <p>12 Q. Can you tell me more about what you know</p> <p>13 about girls bringing other girls that are</p> <p>14 relatively the same age to come to Jeffrey</p> <p>15 Epstein's house and to use your words, have a good</p> <p>16 time?</p> <p>17 MR. CRITTON: Form.</p> <p>18 THE WITNESS: It's hard to know who they</p> <p>19 knew. But I think that was -- they feel</p> <p>20 better themselves when they're in a group</p> <p>21 than going by themselves, but I don't know</p> <p>22 somebody recruiting.</p> <p>23 BY MR. [REDACTED]</p> <p>24 Q. Okay. And you've talked about, at least</p> <p>25 referred to yourself I believe to the police and</p> | <p>Page 168</p> <p>1 for now we'll call it a massage -- as well as</p> <p>2 anybody who brought that person over to the house,</p> <p>3 they would both get paid cash. Are you familiar</p> <p>4 with that?</p> <p>5 MR. CRITTON: Form.</p> <p>6 THE WITNESS: No.</p> <p>7 BY MR. [REDACTED]</p> <p>8 Q. If C. brought another girl over to the</p> <p>9 house and C. stayed downstairs but this other girl</p> <p>10 went upstairs with Mr. Epstein, which one would</p> <p>11 you pay?</p> <p>12 A. I don't know because I was told who to</p> <p>13 pay.</p> <p>14 Q. And [REDACTED] always told you?</p> <p>15 A. Sarah told me pay so and so.</p> <p>16 Q. So if we were going to ask anybody else</p> <p>17 about the exact method in terms of who would get</p> <p>18 paid and for what, who would the people be? I</p> <p>19 mean, other than Mr. Epstein who else could we ask</p> <p>20 these questions?</p> <p>21 A. Sarah.</p> <p>22 Q. [REDACTED]</p> <p>23 A. Yes.</p> <p>24 Q. She would know this?</p> <p>25 A. Yes.</p> |
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| <p>Page 167</p> <p>1 as well today as a human ATM machine. Right?</p> <p>2 MR. CRITTON: Form.</p> <p>3 THE WITNESS: Something like that. I was</p> <p>4 supposed to carry cash at all times.</p> <p>5 BY MR. [REDACTED]</p> <p>6 Q. One of the primary reasons why you</p> <p>7 carried cash was to pay the girls in this age</p> <p>8 group of C. and T. for whatever happened at the</p> <p>9 house. Right?</p> <p>10 MR. CRITTON: Form.</p> <p>11 THE WITNESS: Yes.</p> <p>12 BY MR. [REDACTED]</p> <p>13 Q. That's a fair statement. Right?</p> <p>14 MR. CRITTON: Form.</p> <p>15 THE WITNESS: Yes.</p> <p>16 BY MR. [REDACTED]</p> <p>17 Q. Okay. And when C., let's use her for</p> <p>18 example, would bring somebody else to the house,</p> <p>19 did you pay C. as well as whomever she brought to</p> <p>20 the house, pay them both?</p> <p>21 A. No, I pay only one person.</p> <p>22 Q. Okay. My understanding, and tell me if</p> <p>23 this is wrong or you can corroborate this, is that</p> <p>24 Mr. Epstein would pay the girl that was actually</p> <p>25 performing whatever was happening in the room --</p> | <p>Page 169</p> <p>1 Q. What about Ghislaine Maxwell?</p> <p>2 MR. CRITTON: Form.</p> <p>3 THE WITNESS: You're talking about the</p> <p>4 boss. I don't know.</p> <p>5 BY MR. [REDACTED]</p> <p>6 Q. To your knowledge was Ghislaine Maxwell</p> <p>7 aware of these girls that are in the age group of</p> <p>8 C. and T. coming to Jeffrey Epstein's house to</p> <p>9 have a good time?</p> <p>10 MR. CRITTON: Form.</p> <p>11 THE WITNESS: I have to say something.</p> <p>12 Mrs. Maxwell called me and told me not to</p> <p>13 ever discuss or contact her again in a</p> <p>14 threaten way.</p> <p>15 BY MR. [REDACTED]</p> <p>16 Q. When was this?</p> <p>17 A. Right after I left because I call one of</p> <p>18 the friends for a job and she told me this, but,</p> <p>19 you know, I feel intimidated and so I want to keep</p> <p>20 her out.</p> <p>21 Q. What exactly did she say? First of all,</p> <p>22 was this a telephone call?</p> <p>23 A. Yes, she was in New York.</p> <p>24 Q. She called you on your cell phone?</p> <p>25 A. Yes.</p> |
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1 Q. Is this the cell phone that was issued to
2 you by Mr. Epstein?
3 A. No, it was my personal phone. I was
4 already --
5 Q. Gone?
6 A. Yeah, this is three, four months down the
7 road.
8 Q. So if you left in --
9 A. February, March -- it was May or June.
10 Q. Of 2005?
11 A. Yes.
12 Q. And you got a call from Ghislaine Maxwell
13 out of the blue?
14 A. Yes.
15 Q. And do you know what prompted that
16 telephone call?
17 A. Because I contact somebody in New York to
18 get a job.
19 Q. Who was that person?
20 A. I contact Jean-Luc and I contact Eva, the
21 Swedish girl, she used to be very good friends
22 with Mr. Epstein because she asked me she need
23 somebody in New York.
24 Q. What does Eva do?
25 A. Eva was a model many years ago and he¶
1 married -- Eva is the mother of the girl who was
2 on the wall.
3 Q. Who is on the wall of Mr. Epstein's
4 house?
5 A. Yeah.
6 Q. All right. There is a younger girl model
7 that's on the wall of Mr. Epstein's house and this
8 lady Eva is her mother?
9 A. Yes.
10 Q. And at some point in time you called her
11 in New York to get a job?
12 A. That's right.
13 Q. And you also called Jean-Luc Bernell?
14 That's his name. Right?
15 A. Jean-Luc, yeah, I don't remember his last
16 name.
17 Q. Does that sound familiar to you, Jean-Luc
18 Bernell?
19 A. Yeah.
20 Q. What did Eva and/or Jean-Luc say about
21 employing you?
22 A. No, they said they're going to find out
23 and obviously the first thing they did was talk to
24 Mrs. Maxwell.
25 Q. She made a telephone call to you and what¶
1 precisely did she say?
2 A. She said I forbid you that you're going
3 to be -- that I will be sorry if I contact any of
4 her friends again.
5 Q. Okay. Other than you will be sorry if
6 you contact any of my friends again did she say
7 anything else about what you know about Mr.
8 Epstein and/or what goes on at his house?
9 A. She said something like don't open your
10 mouth or something like that. But you have to
11 understand, I'm a civil humble, I came as an
12 immigrant to service people, and right now you
13 feel a little -- I'm 55 and I'm afraid. First of
14 all, I don't have a job, but I'm glad this is on
15 tape because I don't want nothing to happen to me.
16 This is the way they treat you, better do this and
17 you shut up and don't talk to nobody and --
18 Q. When you say this is the way they treat,
19 who specifically are you talking about when you
20 say the word they?
21 A. Maxwell.
22 Q. And usually when you say the word they,
23 you're not only talking about one person --
24 A. Wealthy people.
25 Q. Are you also putting Jeffrey Epstein in¶
1 that category?
2 MR. CRITTON: Form.
3 THE WITNESS: I didn't talk to him
4 directly most of the time.
5 BY MR. [REDACTED]
6 Q. What's the reason why if you were his
7 head of security that you wouldn't have more
8 direct contact with him? Why is that?
9 MR. CRITTON: Form.
10 THE WITNESS: He wanted that way, you
11 know, so, yeah, I have to talk to Sarah,
12 Sarah is not available talk to Lesley in New
13 York. He didn't want to be disturbed.
14 BY MR. [REDACTED]
15 Q. Even while you were in the same house
16 with him he still had other people you could talk
17 to directly but he was not one of them?
18 A. Yeah.
19 Q. When you were fired you were not fired
20 directly by him?
21 A. No.
22 Q. It was through somebody else?
23 A. Ms. Maxwell.
24 Q. Okay. But it was for upsetting him for
25 taking the wrong car?¶
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| <p>Page 174</p> <p>1 A. Yes.</p> <p>2 Q. Okay. Ever since this communication that</p> <p>3 Ms. Maxwell made to you where she called you</p> <p>4 sometime in May or June of 2005, and have you felt</p> <p>5 threatened?</p> <p>6 A. Yes.</p> <p>7 MR. CRITTON: Form.</p> <p>8 BY MR. [REDACTED]</p> <p>9 Q. Have you felt reluctant to come forward</p> <p>10 and give truthful, honest, and full disclosure of</p> <p>11 all information that you know about this case?</p> <p>12 MR. CRITTON: Form.</p> <p>13 THE WITNESS: I said this off the record</p> <p>14 but I will say it on the record, being in</p> <p>15 the Epstein case for me resulted in two</p> <p>16 years I have -- I won't bring the names but</p> <p>17 I was in the third interview to get hired as</p> <p>18 a household manager in Palm Beach and they</p> <p>19 told me you are the Jeffrey Epstein guy.</p> <p>20 Not in the sense I did something wrong</p> <p>21 because of the scandal, so they shun the job</p> <p>22 away from me. And so I was afraid that --</p> <p>23 this is very powerful people and one phone</p> <p>24 call and you finish, so I'm the little guy.</p> <p>25 Even I'm wearing a tie I'm a -- I'm talking</p> | <p>Page 176</p> <p>1 this. Because I went through -- the first</p> <p>2 time I went to the deposition I was in Palm</p> <p>3 Beach and I did my duty, I mean, I tell what</p> <p>4 I know, but now I know there is more</p> <p>5 digging, all I want is this to be to get on</p> <p>6 with my normal life and stuff.</p> <p>7 BY MR. [REDACTED]</p> <p>8 Q. So when you come here today to testify,</p> <p>9 your main objective is to get back to your normal</p> <p>10 life and get out of the spotlight of this case.</p> <p>11 Yes?</p> <p>12 A. Yes.</p> <p>13 Q. And in doing so have you held back some</p> <p>14 of the details that you know about that happened</p> <p>15 in this case to remove yourself from the</p> <p>16 spotlight?</p> <p>17 MR. CRITTON: Form.</p> <p>18 THE WITNESS: No, sir.</p> <p>19 BY MR. [REDACTED]</p> <p>20 Q. Okay. Have you ever talked to Ghislaine</p> <p>21 Maxwell after that telephone call where she called</p> <p>22 you and you felt threatened?</p> <p>23 A. No.</p> <p>24 Q. Okay. So going back to where we started</p> <p>25 here was, does Ghislaine Maxwell have knowledge of</p> |
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| <p>Page 175</p> <p>1 from my heart. This is the way it is.</p> <p>2 BY MR. [REDACTED]</p> <p>3 Q. I feel for you, I'm sorry that you have</p> <p>4 to be in this position.</p> <p>5 MR. CRITTON: Move to strike this.</p> <p>6 BY MR. [REDACTED]</p> <p>7 Q. Well, when you applied for these jobs and</p> <p>8 they turned you down and gave you the reason that</p> <p>9 you're the person involved in the Jeffrey Epstein</p> <p>10 scandal, was it that they are associated or</p> <p>11 friends with Jeffrey Epstein or is it that you</p> <p>12 have information and you have this confidentiality</p> <p>13 but you're revealing some certain information that</p> <p>14 Mr. Epstein would not like?</p> <p>15 MR. CRITTON: Form.</p> <p>16 THE WITNESS: Both.</p> | <p>Page 177</p> <p>1 the girls that would come over to Jeffrey</p> <p>2 Epstein's house that are in roughly the same age</p> <p>3 group as C. and T. and to have a good time as you</p> <p>4 put it?</p> <p>5 MR. CRITTON: Form.</p> <p>6 THE WITNESS: Yes.</p> <p>7 BY MR. [REDACTED]</p> <p>8 Q. And what was her involvement and/or</p> <p>9 knowledge about that?</p> <p>10 MR. CRITTON: Form.</p> <p>11 THE WITNESS: She knew what was going on.</p> <p>12 BY MR. [REDACTED]</p> <p>13 Q. You referred to her at one point in time</p> <p>14 as Jeffrey Epstein's companion. But then later on</p> <p>15 you said that if she flew she flew on a different</p> <p>16 airplane and oftentimes or sometimes she slept in</p> <p>17 a different bed from Mr. Epstein. Did that seem</p> <p>18 unusual to you?</p> <p>19 MR. CRITTON: Form.</p> <p>20 THE WITNESS: It was odd but, I mean, and</p> <p>21 again, everything is odd in Palm Beach.</p> <p>22 BY MR. [REDACTED]</p> <p>23 Q. Okay, I don't mean to laugh.</p> <p>24 A. Mr. Epstein fly to Jet Aviation, she fly</p> <p>25 to Galaxy Aviation, but they never flew the same</p> |
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| <p>Page 266</p> <p>1 BY MR. LANGINO:</p> <p>2 Q. Are you currently in fear of Mr. Epstein?</p> <p>3 A. Not at this particular moment but it's</p> <p>4 something I have to be worry about, yes.</p> <p>5 Q. Are you personally afraid of criminal</p> <p>6 prosecution?</p> <p>7 A. No.</p> <p>8 Q. Do you believe that you did anything</p> <p>9 illegal?</p> <p>10 A. Illegal, no.</p> <p>11 MR. LANGINO: I have no further</p> <p>12 questions. Thank you.</p> <p>13 MR. CRITTON: We're going to break in</p> <p>14 about 15 minutes. Do you want to start and</p> <p>15 go for 15 minutes or do you want to -- it's</p> <p>16 up to you.</p> <p>17 MS. EZELL: I'll start.</p> <p>18 MR. WILLITS: When are we going to quit,</p> <p>19 folks?</p> <p>20 MR. CRITTON: In 15 minutes.</p> <p>21 THE VIDEOGRAPHER: Might as well change</p> <p>22 tapes.</p> <p>23 MR. [REDACTED] Bob has to get back so</p> <p>24 we've agreed we're going to come back some</p> <p>25 other time.</p> | <p>Page 268</p> <p>1 THE STATE OF FLORIDA, )</p> <p>2 COUNTY OF DADE. )</p> <p>3</p> <p>4</p> <p>5 I, the undersigned authority, certify</p> <p>6 that ALFREDO RODRIGUEZ personally appeared before</p> <p>7 me on the 29th day of July, 2009 and was duly</p> <p>8 sworn.</p> <p>9</p> <p>10 WITNESS my hand and official seal this</p> <p>11 31st day of July, 2009.</p> <p>12</p> <p>13</p> <p>14</p> <p>15</p> <p>16 [REDACTED] PAYNE, Court Reporter</p> <p>17 Notary Public - State of Florida</p> <p>18</p> <p>19</p> <p>20</p> <p>21</p> <p>22</p> <p>23</p> <p>24</p> <p>25</p> |
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| <p>Page 267</p> <p>1 MR. WILLITS: Why don't we just stop now?</p> <p>2 MS. EZELL: Okay.</p> <p>3 MR. [REDACTED] Rather than you start.</p> <p>4 MS. EZELL: Yeah, I won't get very far.</p> <p>5 MR. [REDACTED] Sorry to do this with you,</p> <p>6 we didn't finish.</p> <p>7 MR. CRITTON: So we're stopped?</p> <p>8 MR. [REDACTED] We're stopped.</p> <p>9 THE VIDEOGRAPHER: Off the record.</p> <p>10 (Thereupon, the videotaped deposition was</p> <p>11 adjourned at 5:30 p.m.)</p> <p>12 - - -</p> <p>13</p> <p>14</p> <p>15</p> <p>16</p> <p>17</p> <p>18</p> <p>19</p> <p>20</p> <p>21</p> <p>22</p> <p>23</p> <p>24</p> <p>25</p> | <p>Page 269</p> <p>1 CERTIFICATE</p> <p>2 The State Of Florida, )</p> <p>3 County Of Dade. )</p> <p>4</p> <p>5 1, [REDACTED] PAYNE, Court Reporter and</p> <p>6 Notary Public in and for the State of Florida at</p> <p>7 large, do hereby certify that I was authorized to</p> <p>8 and did stenographically report the videotaped</p> <p>9 deposition of ALFREDO RODRIGUEZ; that a review of</p> <p>10 the transcript was requested; and that the</p> <p>11 foregoing pages, numbered from 1 to 269,</p> <p>12 inclusive, are a true and correct transcription of</p> <p>13 my stenographic notes of said deposition.</p> <p>14 I further certify that said videotaped</p> <p>15 deposition was taken at the time and place</p> <p>16 hereinabove set forth and that the taking of said</p> <p>17 videotaped deposition was commenced and completed</p> <p>18 as hereinabove set out.</p> <p>19 I further certify that I am not an</p> <p>20 attorney or counsel of any of the parties, nor am</p> <p>21 I a relative or employee of any attorney or</p> <p>22 counsel of party connected with the action, nor am</p> <p>23 I financially interested in the action.</p> <p>14 The foregoing certification of this</p> <p>15 transcript does not apply to any reproduction of</p> <p>16 the same by any means unless under the direct</p> <p>17 control and/or direction of the certifying</p> <p>18 reporter.</p> <p>19 DATED this 31st day of July, 2009.</p> <p>20</p> <p>21</p> <p>22 [REDACTED] PAYNE, Court Reporter</p> <p>23</p> <p>24</p> <p>25</p> |
68 (Pages 266 to 269)¶
Kress Court Reporting, Inc. 305-866-7688
7115 Rue Notre Dame, Miami Beach, FL 33141¶