Giuffre_Maxwell_Batch5_p00098.png

Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 18 of 27 any sex toys in any room I ever stayed in, nor were there any visible pictures of naked young women. My children and grandchildren stayed in the rooms in question at Mr. Epstein’s home during Christmas of 2005. I would never have allowed my family to stay in a home with such items, nor would I have stayed in such a home. 42. Mr. Cassell also seeks to rely upon the deposition of Alfredo Rodriguez, an employee of Jeffrey Epstein for the proposition that I was present in Mr. Epstein’s home in 2005 at the same time as some young women—including Ms. Kellen and Ms. Marcinkova’—and “local girls” who gave massages. See Cassell Decl., § 21(1). But Mr. Rodriguez was clear that he did not know whether I received a massage, and did not know if I was aware that there were young girls present in the house: “Q: Okay. When Alan Dershowitz was at the house I understood you to say that these local Palm Beach girls would come over to the house while he was there but you’re not sure if he had a massage from any of those girls. A: Exactly. Q: And what would he do while those girls were at the house? A: He will read a book with a glass of wine by the pool, stay inside. Q: Did he ever talk to any of the girls? A: I don’t know, sir. Q: Certainly he knew that they were there? prostitute. I never denied having one professional massage. | did truthfully state that it was a lie to claim that I had sexual massages in a room full of sex toys. 7 Ms. Kellen was in her late 20s and to my knowledge, was a legitimate employee of Mr. Epstein. Ms. Marcinkova was, to my knowledge, an adult friend of Mr. Epstein. 18