EXHIBIT 18¶
| <p>Page 1</p> <p>UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIV-MARRAL [REDACTED]</p> <p>JANE DOE NO. 2,</p> <p>Plaintiff,</p> <p>-vs-</p> <p>JEFFREY EPSTEIN,</p> <p>Defendant.</p> <hr/> <p>Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092</p> <hr/> <p>VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I</p> <p>Tuesday, September 8, 2009 10:12 a.m. - 3:45 p.m.</p> <p>2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401</p> <p>Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office</p> | <p>Page 3</p> <p>1 On behalf of the Defendant: 2 ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER 3 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 4 Phone: 561.842.2820 rcrit@bclclaw.com mpike@bclclaw.com</p> <p>5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25</p> |
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| <p>Page 2</p> <p>1 APPEARANCES: 2 On behalf of the Plaintiffs: 3 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 4 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 5 Phone: 561.582.7600 reelrhw@hotmail.com</p> <p>6 STUART MERMELSTEIN, ESQUIRE 7 MERMELSTEIN & HOROWITZ, P.A. 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 9 Phone: 305.931.2200 ssm@sexabuseattorney.com 10 ahorowitz@sexabuseattorney.com</p> <p>11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 Phone: 954.522.3456 bedwards@rra-law.com</p> <p>14 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 15 25 West Flagler Street, Suite 800 Miami, Florida 33130 16 Phone: 305.358.2800 17 rjosefsberg@podhurst.com 18 kezell@podhurst.com 19 ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 20 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 21 Phone: 561.515.1400 skuvin@leopoldkuvin.com</p> <p>22 23 24 25</p> | <p>Page 4</p> <p>1 - - - 2 EXHIBITS 3 - - - 4 5 6 Exhibit number 1 Photographs 45 7 Exhibit number 2 Transcript 130 8 Exhibit number 3 Incident Report 137 9 Exhibit number 4 Incorporation Papers 149 10 Exhibit number 5 Incorporation Papers 150</p> <p>11 12 13 14 15 16 17 18 19 20 21 22 23 24 25</p> |
PROCEEDINGS 1 Boynton Beach, Florida, 33472. 2 - - - 2 Q. All right, sir. Did you ever work for Jeffrey 25 MR. LANGINO: Adam Langino, on behalf of B.B. 25 A. I had a company at that time used to take care¶
3 Deposition taken before Sandra W. Townsend, Court 3 Epstein? 4 Reporter and Notary Public in and for the State of 4 A. Yes, I did. 5 Florida at Large, in the above cause. 5 Q. In what capacity? 6 - - - 6 A. Everything. I started with Jeffrey Epstein 7 VIDEOGRAPHER: Today is September 8. 2009. 7 around 19 -- please bear with the dates because I 8 The time is 12 minutes after 10:00 in the morning. 8 trying -- 9 This is the videotaped deposition of Juan 9 Q. Sure. 10 Alessi in the matter of Jane Doe number two versus 10 A. -- to remember. 1969 as a part-time 11 Jeffrey Epstein. This deposition is being held at 11 maintenance guy. 12 2139 Palm Beach Lakes Boulevard in West Palm Beach 12 And then I become a full-time employee. I 13 Florida. 13 think it was January 1, 2 -- '91, '92, so '92. Sorry. 14 My name is Stan Sanders. I'm the videographer 14 Q. You said you started in 1969? That would 15 representing Visual Evidence. Incorporated. 15 -- 16 Would the attorneys please announce their 16 A. No. No. No. No. No. 17 appearances for the record. 17 Q. Okay. 18 MR. WILLITS: Richard Willits. representing 18 A. '99. 19 19 Q. 1999? 20 MR. BERGER: William J. Berger, representing 20 A. Yeah. 21 E.W., L.M. and Jane Doe number two. 21 Q. All right. And how did you happen to get that 22 MR. MERMELSTEIN: Stuart Mermelstein of 22 job? Was it through an employment agency -- 23 Mermelstein and Horowitz. representing Jane Does 23 A. No. 24 numbers two through eight. 24 Q. -- or an ad in the paper?¶
1 MS. EZELL: Katherine Ezell from Podhurst 1 of a lot of residents in Palm Beach. And I got to knots 2 Orseck, on behalf of Jane Does 101 and 102. 2 Jeffrey through Lesley Wexner. And I used to work in 4 Jeffrey Epstein. 4 as a maintenance guy. 5 THEREUPON. 5 Q. Okay. 6 JUAN ALESSI, 6 A. And I have basically my own company and I do 7 having been first duly sworn or affirmed, was examined 7 repairs for them. I did home sit in for them. 8 and testified as follows: 8 Q. And what was -- did you work for Jeffrey 9 THE WITNESS: I do. 9 Epstein? What was your position when you started'? 10 DIRECT EXAMINATION 10 A. When I started, he hire me to -- he just 11 BY MR. WILLITS: 11 bought the house. 12 Q. Good morning, sir. 12 Q. I'm sorry? 13 A. Good morning. 13 A. He just had bought the house -- 14 Q. I introduced myself through the videographer. 14 Q. Okay. 15 My name is Richard Willits. 15 A. -- where he live on El Brillo. And he hire me 16 A. Okay. 16 through Mr. Wexner's references to do repair works. :A Id 17 Q. I represent a young lady by the name of 17 basically what I did the most was taking walls apart. 18 18 windows and stuff that he didn't want to have it. -- 19 A. Okay. 19 Q. I see. 20 Q. Is that name familiar to you at all? 20 A. -- fix it. 21 A. Whose name? 21 Q. And when you started working for Mr. Epstein, 22 Q. Do you recognize that name? 22 were you still working for other people in Palm Beach? 23 A. No. 23 A. Yes. I did. 24 Q. What is your residence address, sir? 24 Q. Okay. And about how long a period of time did 25 A. NI) address is 6791 Fairvi a) Lakes Drive. 25 you do this type of work t or Mr. Eimein. the¶
3 MR. CRITTON: Bob Criuon, on behalf of 3 about 20 different. 20.25 different homes in Palm Beach¶
maintenance and taking out walls? 1 about seven months before -- after I become a full-time 3 before. 3 Q. Okay. And how did Ms. Maxwell come into the 6 Q. And how were you paid? 6 Q. Okay. Had you known her before she becam.. -¶
2 A. It was couple months. It was couple months 2 employee. 4 Q. And what was the name of your company? 4 picture? 5 A. Alessi Maintenance. 5 A. It was his girlfriend, his main girlfriend. 7 A. By him? 7 A. No. 8 Q. Yes. 8 Q. -- your -- 9 A. Usually by check or cash sometimes. 9 A. Never know her before. 10 Q. Do you know what company actually paid your 10 Q. I'm sorry. I didn't get a chance to finish my 11 company? 11 question. 12 A. It was Jeffrey Epstein and Company. 12 Would you have referred to her as your 13 Q. So you said you had that position for a couple 13 supervisor or your superior or what would you has e 14 of months. 14 called Mrs. Maxwell? 15 What happened next? 15 A. I used to call her Ghislaine. 16 A. Then Mr. Epstein asked me to. if I wanted to 16 Q. Okay. And how was it explained to you thai 17 be his employee, because I was going from one house tc 17 you were now to deal with Ms. Maxwell. as opposed It, 18 another house to another house, one hour here. I was 18 Jeffrey Epstein? 19 just running around Palm Beach all day. 19 A. She would tell me, I am going to take care of 20 So he asked me if I would just work for him. 20 the house. 21 exclusively for him. 21 Q. Okay. That was explained to you by 22 Q. Okay. 22 Ms. Maxwell? 23 A. And we agreed with the terms and I become a 23 A. Uh-huh. 24 full-time employee as a maintenance guy. And I was 24 Q. Is that a yes? 25 taking care of everything, as far as maintenance. 25 A. Yes.¶
1 Then my job changed little by little to house 1 Q. And when Ms. Maxwell started assuming 2 man, estate manager, and then to a majordomo. 2 responsibility for the house. did your duties change at 3 Q. Okay. When you first agreed to terms with 3 that time? 4 Mr. Epstein and you first started working for him full 4 A. Not much. 5 time, what were those terms, do you remember? 5 Q. Okay. 6 A. The terms is basically was how much -- he 6 A. Not much. 7 asked me how much I was making in all the properties. 7 Q. And at that time when Ms. Maxwell started 8 And I says, well, I make this -- this amount 8 taking responsibility for the house, what were your 9 of money. 9 duties? 10 And he says. fine. 10 A. Basically I was still doing the maintenance 11 Q. And how much was that, did he pay you? 11 work. 12 A. Around $45,000. I think I started with 45. 12 Q. Okay. 13 Q. Okay. And when you started to work for him as 13 A. Was doing -- they were trying to remodel the 14 a full-time employee, did you have anybody that you 14 home and they would told me, okay, tear down this wall. 15 reported to or did you deal directly with Mr. Epstein? /5 We want to see how it's going to look. Or put this 16 A. At the beginning with Mr. Epstein. directly to 16 windows and tear down -- we had a fishing tank. We took 17 him. 17 it out -- I took it out. A kitchen on the second floor. 18 Q. Did that change? 18 I took it out. So it was basically dismantling the 19 A. Later on. yes. 19 house. 20 Q. And how did that change? 20 Q. Okay. And about how long a period of time did 21 A. When Ms. Maxwell, Ghislaine Maxwell came to 21 that project last? 22 the picture. 22 A. I would says. six to seven months. 23 Q. Okay. About when was it that she came into 23 Q. Okay. And after the remodeling slacked off or 24 the picture? 24 stopped, did your duties then change? 25 A. Exactly date. I cannel elmmthel Makvvs 25 A. Yeah. Increasingl) the)amige.¶
1 MS. F7Fi 1 • I'm going to ask --I don't know 1 THE WITNESS: Could have been. But, you knits..¶
2 whether you've still been serially designating 2 I am not -- I don't think I am a very good judge of 3 Exhibits or whether we're doing them separately for 3 ages. If you ask me how old you are. I really 4 deposition. 4 couldn't tell you. 5 MR. CRITTON: I think we cannot trust that 5 MR. CRITTON: Kathy thinks she's 25. 6 people will do them serially. I'd do them with 6 MS. EZELL: In my dreams. 7 each one. 7 THE WITNESS: Now, again, I must tell you. I 8 MS. EZELL: Then would you mark this, please, 8 was never told to check any i.d.s on any of the 9 as Exhibit 1 to this deposition. 9 people who work at the house. 10 And I'm just going to state on the record that 10 BY MS. EZELL: 11 I will keep that original. We will not attach it 11 Q. I understand that. And, so, I think I'm just 12 to the deposition. 12 trying to establish that you didn't consider it part of 13 (Exhibit number I was marked for 13 your job description to worry about or consider the 14 identification purposes and retained by Counsel for the 14 ages -- 15 Plaintiffs.) 15 A. No. 16 THE WITNESS: Yes, that's — 16 Q. — of the young women that came there 17 BY MS. EZELL: 17 A. Absolutely not. Absolutely not. 18 Q. Can you identify that -- the young woman in 18 Q. And, so, you never really focused on that or 19 those pictures? 19 particularly thought about it if they seemed young? 20 A. Yes. 20 MR. CRITTON: Form. 21 Q. Who is it? 21 THE WITNESS: I don't -- I didn't see that 22 A. That's V. -- V. Now that you says R.. that 22 many young girls, you know, young, underage girls 23 is V.R. definite, a hundred percent. 23 at the house. I never saw except the two girls 24 MR. CRITTON: Let me just note my objection, 24 that I mentioned that I think it was underage was 25 as I did in A. Rod's deposition or Mr. Rodriguez's 25 N. for sure because she was still in high school.¶
1 deposition. that I know you're going to confiscate 1 And she -- she had dinner with her mother, a couple 2 Exhibit number I. I think it's inappropriate. I 2 times with her mother. And she become an actress. 6 into a pulling match over your Exhibits. 6 because she was going to high school and I pick her¶
3 think I should be allowed to have a copy of 3 She's an actress and she has done movies. And he 4 Exhibits that are being used in deposition. But 4 help her in her career. 5 I'll file a motion with the Court so we don't get 5 That's the only girl that I knew she was young 7 MR. BERGER: I would ask that the court 7 up from high school sometimes. But she was not a 8 reporter initial that. 8 massage therapist. She will go for dinner. And 9 MS. EZELL: Sure. 9 they will go for the movies and she sang sometini,., 10 IM, you did? 10 because she was a . So she sung at the 11 MR. WILLITS: She marked it. 11 house. Beautiful girl. Very talented. 12 MR. BERGER: Did she put her initials or did 12 That's the only girl that I know that it 13 she just put a number or a letter? 13 was -- I would says. underage. 14 MR. CRITTON: She's nodding that she did 14 BY MS. EZELL: 15 everything that she usually does, which means. 15 Q. Okay. Did -- who told you that V.R. was a 16 initials, date and number. 16 massage therapist? 17 MR. MERMELSTEIN: You can talk. 17 A. Nobody. 18 MR. WILLITS: But when you talk, use your 18 Q. Did you assume that she was a massage 19 initials. 19 therapist because you were told she was coming to gi' a 20 BY MS. EZELL: 20 massage? 21 Q. How old did you think V.R. was at the time she 21 A. No. I assumed she was a massage therapy 22 began coming to Mr. Epstein's home? 22 because I was -- I drove Ms. Maxwell to Mar-a-lago. 23 A. She could have been 17, 18. 19. 23 Donald Trump's residence. And I wait in the car while 24 Q. Could she have also been 15? 24 Ms. Maxwell got a -- I think it was a facial or massage. 25 MR. CRITTON: Form. 25 I don't kilos,. But that da' I lemeinher this girl. V..¶
1 MR. CRITFON: Form. 1 Diane's secretary, she stay there for a week with her 2 THE WITNESS: No, not that I can remember. 2 kids and we took care of her. 3 BY MS. EZELL: 3 Who else? Mr. Trump. That's a celebrity. 4 Q. Do you know if he and Mr. Epstein were 4 Mr. Robert Kennedy. Junior. Mr. Frederick Fekkai. 5 involved in any businesses together? 5 Q. Who is that? 6 A. Mr. Epstein. I never knew what businesses he 6 A. Fekkai, Frederick Fekkai, the famous 7 was involved. He will -- I was completely shut off of 7 hairstylist. Who else? I don't think I can remember 8 all of the business, except for the office, transfer of 8 anymore. 9 communications or faxes. But I have no idea of the 9 Q. David Copperfield, the magician? 10 relationship with other business partners. 10 A. No, I never saw him. 11 Q. Did you ever have to deal with his -- the 11 Q. You never saw him. 12 office in New York with someone named Lesley in New 12 Now, would these -- the people that you named 13 York? 13 were all people that you saw visiting in the home? 14 A. The secretary? 14 A. Yes. Also was a Noble Prize winners, the -- I 16 A. Yeah. I would call -- I would call Lesley 16 was a Noble Prize, chemistry. I think, or mathematics 17 almost every day or other secretaries, they live in Ncw 17 There was a couple -- a couple of those, very -- also. 18 York. Basically it came a point when Mr. Epstein will 18 we had at one time at the house, it was a reunion of 19 call New York and New York call me to do things for 19 very Noble Prize winners. But I don't know. They're 20 Mr. Epstein. But he was on the phone or busy or 20 not famous, I guess. I can't remember their names. 21 something and he would call the office and the office 21 Very important people. 22 will send me an e-mail or call me or -- it was a 22 Q. Was that a dinner or a reception? 23 constant report with the office in New York. 23 A. I think it was a lunch. 24 Q. And did you in turn sometimes call New York to 24 Q. A lunch. 25 get a message to Mr. Epstein? 25 President Clinton, did you ever --¶
15 Q. Yes. 15 can't remember his name. It was an old gentleman. He¶
A. Yes. 1 A. I met President Clinton on Mr. Epstein's plane couple limes. And he slept there. Ile -- Princess 25 Hut Prince Andrew. yes. Prince Andrew spellt weeks with¶
2 Q. Did you ever overhear Mr. Epstein talking to 2 in the last. I think it was the last month or just 3 any people that you would consider celebrities? 3 before I left -- I left I met President Clinton in 4 A. Yes. I knew some -- many celebrities. 4 Miami at his plane. We drove him to Miami. 5 Q. Who -- what celebrities did you understand 5 Q. And do you know, was that a trip -- were they 6 that he spoke with? 6 going on a trip to Africa? 7 A. He spoke to it? 7 A. I hear about it, but it was not when I was 8 Q. Yes. 8 there. 9 A. I don't know who he spoke to because I never 9 Q. So that was not the time that you drove 10 listen to his conversations. But I saw guests at the 10 A. No, I was already out. 11 house that were celebrities. 11 Q. And Kevin Spacey, did you ever meet him! 12 Q. Who did you see at house? 12 A. No. I hear about it on the news, but I never 13 A. Many. It was senators. It was Senator 13 met him. 14 Mitchell, Mitchell. It was Prince Andrew. It 14 Q. Were Prince Andrew and Princess Sarah friend\ 15 was Princess Sarah. 15 of Ms. Maxwell? 16 Q. Princess? 16 A. Both of them. 17 A. Sarah. the wife of Andrew. 17 Q. Both Ms. Maxwell and Mr. Epstein? 18 Q. Sarah 18 A. Yeah. 19 A. 19 Q. Did -- did they ever have massages when the) 20 And it was a couple Misses, Misses Yugoslavia, 20 were there? 21 Miss Germany that I don't even know the names. But they 21 A. Prince Andrew did. I think Sarah was there 22 were a lot of queens and other famous people that I 22 only once and for a short time. I don't think she slept 23 can't remember. It was a very famous lawyers that I'm 23 in there. I cannot remember. I think she was visiting 74 sure you know, Alan Dershowitz, who spend at the house I 24 Wellington and she came to the house and we met her.¶
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 us. Q. Where would he sleep? A. In the main room, the main guest bedroom. That was the blue room. Q. And, so, when he would come and stay, during that time would he frequently have massages? MR. CRITTON: Form. THE WITNESS: I would says, daily massages. They have a daily massage. BY MS. EZELL: Q. Was it sometimes more than one a day? A. I can't remember if he had more than one, but I think it was just a massage for him. We set up the tables and -- Q. Do you have any recollection of V.R. coming to the house when Prince Andrew was there? A. It could have been, but I'm not sure. Q. Not sure. When Mr. Dershowitz was visiting, -- A. Uh-huh. Q. -- how often did he come? A. He came pretty -- pretty often. I would says, at least four or five times a year. Q. And how long would he stay typically? A. Two, three days.¶
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 MR. LANGINO: Go ahead. Sure. BY MS. EZELL: Q. You said that you set up the massage tables. And would you also set up the oils and the towels? A. Yes, Q. And I think I read one time you said they used 40 or 50 towels a day? MR. CRITTON: Form. THE WITNESS: That's correct. There was a tremendous amount of work in the house, especial') laundry towels, because they were -- we have towels, piles of towels. And they use in the pool. There was a lot of people in the pool and there were a towel that went in the floor, we have to go and pick it up, wash it. So it was -- it was a lot of towels, yes. BY MS. EZELL: Q. And did you ever have occasion to go upstairs and clean up after the massages? A. Yeah, uh-huh. Q. Did you ever find any vibrators in that area? A. Yes. I told him, yes. MS. EZELL: And did you ask that? I'm sorry. MR. CRITTON: Yes. MS. F7FI 1 • I don't know how I missed that.¶
Page 74 Page 76¶
1 Q. Did he have massages sometimes when he was 1 BY MS. EZELL: 2 there? 2 Q. Since I did miss it, if you don't mind, let me 3 A. Yes. A massage was like a treat for 3 just ask you again. 4 everybody. If they want it, we call the massage and 4 Would you describe for me what kinds of 5 they have a massage. 5 vibrators you found? 6 Q. Now, Mr. Trump had a home in Palm Beach, 6 A. I'm not familiar -- not too familiar with the 8 A. Uh-huh. 8 rubber things like that (indicating). And I used to go 10 A. No, never. 10 sink, rinse it off and put it in Ms. Maxwell -- 11 Q. He would come for a meal? 11 Ms. Maxwell had in her closet, she had, like, a laundry 13 the table. He eat with me in the kitchen. 13 in. She have full of those toys. And that was — and 14 Q. Did he ever have massages while he was there? 14 that was me being professional, leaving the room ready 15 A. No. Because he's got his own spa. 15 for bed when he would come back to the room again. 16 Q. Sure. 16 Q. Okay. 17 MS. EZELL: I don't have any other questions 17 A. That happened a few times, few times. 18 right now. I'd just like to reserve if something 18 Q. Were there other sex toys that you found in 19 comes up to ask. But, otherwise, you may go ahead. 19 the area -- 20 MR. LANGINO: It is noon, so I don't know what 20 A. No. 22 you're feeling. 22 a basket in her closet? 23 THE WITNESS: I am fine. 23 A. She kept them in her basket. She had some 25 ask it? 25 she bought ii. that .he brought it v. ith her.¶
7 correct? 7 names, but they were big dildos, what they call the big 9 Q. So he didn't come and stay there, did he? 9 and put my gloves on and pick them up. put them in the 12 A. He would come, have dinner. He never sat at 12 basket. one of those laundry basket that you put laundry 21 everybody else's schedule is. I don't know how 21 Q. -- sometimes? You mentioned she kept them in 24 MS. EZELL: I do have another question. May I 24 videos there and she have a costume there. I know that¶
1 Q. What kind of costume?
2 A. I don't know. It was a black, shiny costume.
3 I never saw it on her.¶
4 Q. Was it leather?
5 A. No. I think it was like a vinyl. But we were
6 very fussy about touching any of that stuff. We just...
7¶
8 MS. EZELL: No other questions. Thank you,
9 sir.¶
10 THE WITNESS: You're welcome.
11 MR. LANGINO: I shouldn't have more than a
12 half hour's worth of questions, if everybody is
13 okay to power through.¶
14 MR. BERGER: I probably have a half hour to an
15 hour.¶
16 MR. LANGINO: Okay.
17 MR. BERGER: Unless you cover what I cover.¶
18 MR. MERMELSTEIN: I could say the same thing,
19 so probably less than that.¶
20 MR. LANGINO: So I guess my question is --
21 MR. BERGER: I think we ought to take a break.¶
22 MR. LANGINO: That was my question.
23 MR. BERGER: We're going to take a break.
24 Do you have any problem with that?¶
25 THE WITNESS: No. Whatever you guys want to
do.¶
1 (Lunch recess.)
2 (Continued to Volume II.)
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1 CERTIFICATE OF OATH
2 STATE OF FLORIDA
3 COUNTY OF PALM BEACH
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5 I, the undersigned authority, certify that
6 JUAN ALESSI personally appeared before me and was duly
7 sworn on the 8th day of September, 2009.
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15 Dated this 19th day of September, 2009.¶
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Sandra W. Townsend, Court Reporter
Notary Public - State of Florida
My Commission Expires: 6/26/12
My Commission No.: DD 793913¶
1 CERTIFICATE
2 STATE OF FLORIDA
3 COUNTY OF PALM BEACH
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5 I, Sandra W. Townsend, Court Reporter and
6 Notary Public in and for the State of Florida at Large,
7 do hereby certify that the aforementioned witness was by
8 me first duly sworn to testify the whole truth; that I
9 was authorized to and did report said deposition in
10 stenotype; and that the foregoing pages numbered 1 to
11 78, inclusive, are a true and correct transcription of
12 my shorthand notes of said deposition.¶
13 I further certify that said deposition was
14 taken at the time and place hereinabove set forth and
15 that the taking of said deposition was commenced and
16 completed as hereinabove set out.¶
17 I further certify that I am not attorney or
18 counsel of any of the parties, nor am I a relative or
19 employee of any attorney or counsel of party connected
20 with the action, nor am I financially interested in the
21 action.¶
22 The foregoing certification of this transcript
23 does not apply to any reproduction of the same by any
24 means unless under the direct control and/or direction
25 of the certifying reporter.¶
26 Dated this 19th day of September, 2009.¶
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Sandra W. Townsend, Court Reporter¶