EFTA00105921.pdf

Lase 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 2 of 6 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, a aL, Plaintiffs I Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. AFFIDAVIT O REGARDING KNOWLEDGE OF ALAN M. DERSHOWITZ A. Introduction 1. My name is I make this declaration voluntarily and without compensation on personal knowledge concerning Alan Dershowitz and his visits at my former employer Jeffrey Epstein's home in Palm Beach, Florida. 2. I worked for Mr. Epstein from January 1991 to December 2002 as a full-time employee performing maintenance services and then also became the manager for the home on 358 El Brillo Way in Palm Beach, Florida. 3. Since Mr. Epstein was investigated and arrested, I have spoken with police, investigators, and attorneys concerning my time working for Mr. Epstein. 4. On September 8, 2009, I gave a deposition in the case captioned Jane Doe No. 2 v. Jeffrey Epstein, Case No. 08-CV-80119 in which I truthfully answered the questions posed by the attorneys. I also gave a sworn statement on November 21, 2005 to 1 GM 01197 EFTA00105921 Case 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 3 of 6 Detectivaaf the Palm Beach P.D. during their investigation of Mr. Epstein. 5. I have reviewed the statements that Bradley Edwards and Paul Cassell attribute to me in their papers in the cases against the Government and against Mr. Dershowitz. Because I do not believe they accurately reflect the statements 1 previously made, I submit this affidavit to have my statements accurately reflected and made clear on the record. B. Summary of My Knowledge of Massages at Mr. Epstein's Palm Beach Home 6. As I stated in my deposition, a massage was like a treat for all the guests at Mr. Epstein's home. Mr. Epstein usually received his massages in his private suite, but guests would also be given massages in their respective rooms or by the pool area. 7. There were between fifty (50) to one hundred (100) masseuses — mostly women but also some men - who would come to give massages during this time. I provided names of masseuses in my deposition. 8. As I stated in my deposition, I was unaware of any masseuses being under the age of 18. I believed that the females' age ranged from overage to maybe mid-forties. As I stated in my deposition, I received as a gift a massage from a male masseuse at Mr. Epstein's home in Palm Beach. 9. In my deposition, I was asked about cleaning up after massages. I stated that when I cleaned Mr. Epstein's bedroom suite, which included the bathroom of Ms. Maxwell, after massages, I would, on occasion, find vibrators and sex toys. I have specific recollection of finding these items in the sink of Ms. Maxwell's bathroom. I did not state or imply that vibrators or sex toys were found after massages in other rooms used by guests because that was not the case. Guests having massages did not have 2 GM_01198 EFTA00105922 Case 1:15-cv-07433-RWS Document 435.3 Filed 09/15/16 Page 4 of 6 massages in Mr. Epstein's private bedroom suite. This area was private and off-limits to guests, which I explained to the lawyers during my deposition. As I said in my deposition, massage tables were located in almost every room, including guest rooms and by the pool. I never found, and never heard anyone in the house finding, a vibrator or a sex toy in the same room where any guest, including Alan Dershowitz, had a massage. 10. The following statement made la attorneys in a filing on January 21, 2015 is not accurate and is a misrepresentation of what I said in my deposition: "The private, upstairs room where Dershowitz got his 'massages' was one that contained a lot of vibrators — Maxwell had 'a laundry basket . . . full of those toys' in that room." C. Summary of My Interaction with Alan M. Dershowitz 11. During the approximate thirteen years I worked for Mr. Epstein, I believe I saw Mr. Dershowitz visit Mr. Epstein's Palm Beach home approximately four or five times a year. I recall driving him to the airport on multiple occasions. 12. At the time, I understood that Mr. Dershowitz was a famous lawyer. His visits to the house would typically involve a group of intellectuals or business men in social, but professional type gatherings. 13. I can recall that Mr. Dershowitz had a massage on at least one occasion during a visit to Mr. Epstein's home in Palm Beach (although I cannot recall that Mr. Dershowitz received a massage on more than one occasion). I do not recall Mr. Dershowitz being massaged by anyone who I thought was less than 18 years old. I have no reason to doubt Mr. Dershowitz's statement that this massage was done by a woman named who was in her forties. In fact, I do remember a masseuse namedMhat 3 GM_01199 EFTA00105923 Case 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 5 of 6 lived in Palm Beach, though I do not know her last name. As I have said, I never saw Mr. Dershowitz around young girls. I have also explained that there were masseuses, both male and female, that were in their mid-forties. 14. I never saw Mr. Dershowitz do anything improper or be present while anyone else was being improper. 15. Before asking me about Jeffrey Epstein speaking to celebrities at the house, the attorney for "Jane Doe 102" asked me about Jean Luc Brunel, Mark Epstein, Daniel Estes, Matt Groening, and Leslie Wexner. I then listed Senator Mitchell, Prince Andrew, Princess Sarah Ferguson, Miss Yugoslavia, Miss Germany, Alan Dershowitz, Princess Diana's secretary with her children, Mr. Trump, Mr. Robert Kennedy, Jr., Frederik Fekkai, and a couple Noble prize winners as celebrities that I had seen while working for Mr. Epstein. I also mentioned a reunion of Nobel prize winners that was held at the house, and that I met President Clinton at Mr. Epstein's plane the last month that I was working for Mr. Epstein. C. Summary of My Interaction with 16. The first time I saw vas at Mar-a-Lago where I believed she worked in the spa. I only recall seeinfl ome to Mr. Epstein's house during the last year that I worked for Mr. Epstein. During this time, I believe she visited Mr. Epstein's home in Palm Beach two or three times a week. 17. I never saw any photographs of in Mr. Epstein's house. I was shown a photo of luring my deposition, and I recognized the woman in the photo 18. As I stated in my deposition, 1 am not sure whether house when Prince Andrew was there. 4 ame to the GM 01200 EFTA00105924 Case 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 6 of 6 19. I was never asked by any attorneys it came to the house when Mr. Dershowitz was there. If I had been asked, I would have answered that I never saw i ltt the house when Mr. Dershowitz was there. 20. The following statement made b attorneys and their own attorney in a filing on December 4, 2015 is not accurate and is a misrepresentation of what I said in my deposition: es able to identify a photograph ofM as someone who was at the mansion as the same time as Dershowitz." 21. As far as I can recall, since I gave my deposition in 2009, [have never been asked by Brad Edwards or Paul Cassell about my knowledge regarding or Alan Dershowitz or about my 2009 deposition testimony. I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this affidavit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. Dated: January 13, 2016 STATE OF EC-40 et—% 0A- COUNTY OF taln—ki 6 c Sworn by on .1/7"tvv...tvl 1 3a 2- O / 1/4-i " ravii.1 Ass eiris•Co• TARY PUBLIC or DEPUTY CLERK /- rr A- S . C-A c-L-c-r7 [Print, type, or stamp commissioned name of notary or clerk.] 5 GM_01201 EFTA00105925