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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 15 of 27
to have been inside the mansion, to imply that I had received a sexual “massage” at the mansion,
and to suggest that the appearance of my name, circled, in Jeffrey Epstein’s address book was
inculpatory—all by reference to the testimony of two of Jeffrey Epstein’s “household
employees,” Juan Alessi and Alfredo Rodriguez. Cassell Decl., { 21(k)-(m). This effort fails
under even cursory scrutiny.
34. First, Mr. Cassell asserts that “Juan Alessi said that [Alan] Dershowitz
visited Epstein’s Palm Beach mansion four or five times a year, staying two or three days when
he went there.” Cassell Decl., § 21(k). He then asserts that “Alessi was able to identify a
photograph of Ms. Giuffre as someone who was at the mansion as [sic] the same time as
Dershowitz.” Jd. Mr. Cassell’s characterization of the Alessi testimony is simply false. Juan
Alessi never testified that Ms. Giuffre was at Epstein’s home in Florida at the same time as me.
35. Mr. Cassell’s assertion is apparently based on the following portion of
Juan Alessi’s deposition:
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.
McCawley Decl., Ex. 6 at 73.
36. But, as the audio recording of this testimony makes clear (and I am happy
to provide it), Mr. Alessi’s “uh-huh” was simply an acknowledgment that he was about to
respond to a question about how often I came to the home during the many years he worked
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Document Details
| Filename | Giuffre_Maxwell_Batch5_p00095.png |
| File Size | 263.9 KB |
| OCR Confidence | 94.5% |
| Has Readable Text | Yes |
| Text Length | 1,662 characters |
| Indexed | 2026-02-04 12:44:08.769734 |