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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 20 of 27 Page 391 Page 393 1 Q. Allright. In terms of these wealthy 1 about what they do? 2 people that you've worked for, these individuals, 2 MR. HOROWITZ; Object to the form. 3 do they all have, that is at least in terms of Mr. 3 THE WITNESS: Yes. 4 Epstein, the way that his household was managed, 4 BY MR. CRITTON: 5 was it similar to other set of circumstances that 5 Q. And have you worked at other locations, 6 you've been involved with? 6 thatis, in the other houses that you've worked 7 MR. HOROWITZ: Object to form. 7 where they have massage tables? 8 THE WITNESS: They have a common ground,| 8 A. Yes. 9 yes. 9 Q. And in those other locations where they 10 BY MR. CRITTON: 10 hada massage table, were they similar to the 11 Q. Allright. And in terms of you talked 11 massage table that was in Mr. Epstein's home? 12 about Mr. Epstein that there was some sort of a 12 A. Yes, sir. 13 manual or a procedure book with regard to his 13 Q. All right. Almost same make and model? 14 house. 14 A. Same type, yes. 15 A. House manual, yes. 15 Q. And did other individuals in houses that 16 Q. A house manual. Did other houses have 16 you worked at and other places where you helped 17 house manuals as well? Is that reasonably -- I 17 out other estate managers, would those individuals 18 mean not common but it's something that you've 18 have massages from time to time? 19 seen before? 19 A. Yes. 20 MR. EDWARDS: Form. 20 Q. So having a massage or a massage table in 21 THE WITNESS: I know a lot of houses do 21 someone's house that you might -- that lives in 22 but that was the only estate that we have a 22 Palm Beach or Montauk or New York or something, 23 house manual. 23 would you consider that unusual? 24 BY MR. CRITTON: 24 MR. HOROWITZ: Form. 25 Q. And other individuals like where you've 25 THE WITNESS: No. Page 392 Page 394 1 worked similar to Mr. Epstein -- now, Mr. Epstein 1 BY MR. CRITTON: 2 was single? 2 Q._ I think you told me at least in Mr. 3 A. Yes. 3. Epstein's home other than for one guest he didn't 4 Q. Allright. And him having a lot of -- or 4 have any type of alcohol in the house. Is that 5 bringing a lot of attractive women and other 5 correct? 6 people to his house, I assume that didn’t offend 6 A. That's correct. 7 you in any way? 7 Q. Was that basically you understood that 8 MR. EDWARDS: Object to the form. 8 that was one of the policies and procedure, no 9 THE WITNESS: No, sir. 9 alcohol in the house? 10 BY MR. CRITTON: 10 A. Yes. 11 Q. At least based upon your experience in 11 Q. And did you ever see any type of illegal 12 dealing with other individuals either of some 12 or inappropriate drugs? 13 notoriety like Ms. Helmsley or when you said the 13 A. No, sir. 14 club that you worked up is in Montauk -- 14 Q. And was that another policy or procedure, 15 A. Montauk Lake Club and Marina. 15 absolutely no drugs of any kind? 16 Q. Right. You ran into separate and apart 16 A. No smoking in the house. 18 corporate people, business people? 18 alcohol? 19 A. Yes. 19 A. Yes. 20 Q. People of substantial resources and 20 Q. Was that pretty typical for other Palm 21 wealth? 21 Beach places that you were familiar with? 22 A. Yes. 22 A. No. 23 Q. Have you found at least in your 23 Q. Allright. And other places you'd always 24 experience that most of those people are pretty 24 find alcohol? 25 25 A. Yes. discreet about -- when I say discreet, private Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 i i } H | Hi t F i iH iH | : | | 32 (Pages 391 to 394) NON PARTY (VR) 000346 GIUFFRE001036