EFTA00310278.pdf

Page 270 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant. JANE DOE NO. 3, Plaintiff, 9 8 10 CASE NO: 08-CV-80119 CONDENSED CASE NO: 08-CV-80232 Vs. JEFFREY EPSTEIN, Defendant. 13 ,14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. JANE DOE NO. 5, CASE NO: 08-CV-80381 Plaintiff, 11 12 19 20 21 22 23 24 25 Vs JEFFREY EPSTEIN, Defendant. EFTA00310278 Page 271 1 JANE DOE ea 6, USE NO: 08-CV-80994 2 Plaintiff, 3 Vs. JEFFREY tpSie81, Defendant. 6 7 8 WE DOE NO. 7, CASE NO: 08-CV-80993 Plaintiff, vs. 9 JEFFREY EPSIEIN, 10 11 12 C.N.A., 13 Plaintiff, 14 Vs. 15 JEFFREY EPSTEIN, 16 Defendant. 17 JANE DOE, CASE NO: 08.07-80893 18 Plaintiff, 19 Vs. 20 21 Defendant. 22 23 24 25 Defendant. CASE NO: 08.CV-80811 JEFFREY EPSTEIN, 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR 2 PALM BEACH COUNTY, FLORIDA 3 CASE NO. 502008CA0373199000<MB AB 4 B.B., 5 Plaintiff, 6 Vs. 7 JEFFREY EPSTEIN. B Defendant. 9 10 11 12 1031 Ives Dairy Road 13 14 :5 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 of 20 ALFREDO RODRIGUEZ 21. 22 taken on behalf of the Plainbffs pursuant 23 to a Re-Notice of Taking Continued Videotaped 24 Depo9tlon (Duals Tatum) 25 - - - Page 2/3 Page 272 1 JANE DOE NO. Ii, CASE NO: 08-CV.80469 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant. 6 JANE DOE NO. 101 CASE NO: 08-CV-80591 7 Plaintiff, 8 VS. 9 JEFFREY EPSTEIN, 10 Defendant. 11 12 JANE DOE NO. 102, CASE NO: 08-0/-80656 13 Plaintiff, 14 VS. 15 JEFFREY EPSTEIN, 16 Defendant. 17 18 19 20 21 22 23 24 25 1 APPEARANCES: 2 3 TERVELSTEIN & liOROWIT2, P.A. BY: ADAI4HORownt ESQ. 4 6 7 8 9 10 11 12 13 14 15 16 12 18 19 20 21 22 23 24 25 la y , .,„ 6, and 7. ROTHSTEIN ROSENfELOT ADLER BY: BRAD J. EDWARDS, ESQ., and PODHURST ORSECK SQ. Attorney for lane Doe 101 and 102. Palm Bead, Gardens, Florida 33410 Attorney for B.B. Pa4e 274 2 (Pages 271 to 274 Kress Court Reporting, Inc. EFTA00310279 1 APPEARANCES: 2 3 RICHARD WILLITS, ESQ. 2290 10th AVenue North 4 Suite 404 Lake Worth, Florida 33461 S Attorney for C.MA. speared via telephone. 6 7 BURMAN, CRITTON, CURTER 8 COLEMAN, LLP BY: ROBERT CRITTON, ESQ. 9 515 North Rapier Drive Suite 400 10 West Palm Beach, Florida 33401 Attorney for Jeffrey Epstein. 11 12 13 ALSO PRESENT: 14 30E LANGSAM, VIDEOGRAPHER 15 16 17 18 19 20 21 22 23 24 25 Page 275 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 Page 277 Deposition taken before MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is a continuation of the deposition of Alfredo Rodriguez. Today is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in the witness? Thereupon, ALFREDO RODRIGUEZ, having been first duly sworn or affirmed, was examined and testified as follows: MR. CRITTON: Before we get started just with regard to Ms. Ezell represents Jane Doe 101 and 102, the alleged time of her incidents as of least have been plead in the complaint for 101 is '99 -- I'm sorry, '98 through 2002, with Jane Doe 102 the Spring of -- Spring/Summer of 2003. Mr. Rodriguez never even began employment until '04 and '05. I think her questioning I think -- I can't say she doesn't have standing based on the court order, but I would say it's 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 CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ (By Ms. Ezell) 278 441, 467 (By Mr. Willits) 334 453, 469 (By Mr. Crkton) 338 464 (By Mr. Edwards) 419, 454, 468 (By Mr. Langlno) 452 CONTINUED INDEX OF EXHIBITS PLAINTIFFS PAGE 3 Drawing 315 4 Photograph 327 5 Photograph 331 6 Photograph 331 7 Photograph 331 8 Photograph 331 9 Report 446 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. Ezell.) Page 276 Page 278 1 completely irrelevant and immaterial and has 2 no probative value with regard to this 3 particular witness based upon the two 4 clients at least that are in suit at this 5 point in time. 6 MS. EZELL: As Mr. Critton well knows I 7 represent a number of other dients whose 8 cases have not been filed and I believe we 9 do have standing to ask questions, and I do 10 intend to do that today. 11 EXAMINATION 12 BY MS. EZELL: 13 Q. Mr. Rodriguez, you stated last time that 14 there were guests at the house, frequent guests, 15 friends from Harvard. 16 Do you remember that testimony? 17 A. Yes, ma'am. 18 Q. And was there a lawyer from Harvard named 19 Alan Dershowitz? 20 A. Yes, ma'am. 21 Q. And are you familiar with the fact that 22 he's a famous author and famous lawyer? 23 A. Yes, ma'am. 24 Q. How often during the six months or so 25 that you were there was Mr. Dershowitz there? Kress Court Reporting, Inc. I 3 (Pages 275 to 278 EFTA00310280 Page 279 1 A. Two or three times. 2 Q. And did you have any knowledge of why he 3 was visiting there? 4 A. No, ma'am. 5 Q. You don't know whether or not he was a 6 lawyer -- acting as a lawyer or whether he was 7 there as a friend? 8 A. I believe as a friend. 9 Q. Were there also young ladies in the house 10 at the time he was there? 11 MR. CRITTON: Form. 12 THE WITNESS: Yes, ma'am. 13 BY MS. EZELL: 14 Q. av in ded for 15 instan 16 A. Yes, ma'am. 17 Q. Were there other young ladies there when 18 Mr. Dershowitz was there? 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 BY MS. EZELL: 22 Q. Do you have any idea who those young 23 women were? 24 A. No, ma'am. 25 Q. Were any of those the young women that Page 281 1 Q. Can you tell me where those were? 2 A. One in the kitchen, and the one in the 3 formal -- the main entrance. And there was one 4 more added later on, but there is two when I was 5 working there. 6 Q. Could you just give me a rough sketch of 7 the house of where the main entrance was and where 8 the kitchen was? 9 A. I'm not an architect but it's something 10 like this. This is the kitchen, this is the main 11 entrance. 12 Q. Will you mark the kitchen with a K, 13 please, and the main entrance with ME? 14 A. This is the pool. 15 Q. The pool? 16 A. Yes, ma'am. 17 Q. And in the upper left? 18 A. In the terrace, yeah, there was a balcony 19 here. 20 Q. And where were the staircases? 21 A. This is one, the kitchen, one in the 22 foyer, and the pool. 23 Q. Okay. And would you just put an F where 24 the foyer staircase began? And KS where the 25 kitchen staircase began. Page 280 1 you have said came to give massages? 2 A. Yes, ma'am. 3 Q. And do you have any Idea whether or not 4 Mr. Dershowitz was also receiving massages? 5 A. I don't know, Ma'am. 6 Q. I want to ask you to take this piece of 7 paper, please, and a pencil -- 8 MR. WILLITS: Can anybody hear me? 9 MS. EZELL: Yes. Can you hear me? 10 MR. WILLITS: I've heard nothing for 11 about a minute or so. 12 MR. CRITTON: Can you hear me now? 13 MR. WILLITS: Yes. 14 MS. EZELL: I'm asking questions, I'm 15 sorry. 16 MR. CRITTON: Why don't we go off the 17 record for a second. 18 (Thereupon, a discussion was held off the 19 record.) 20 THE VIDEOGRAPHER: We're back on the 21 record 22 BY MS. EZELL: 23 Q. Mr. Rodriguez, you indicated that there 24 were several staircases in the house? 25 A. Yes, ma'am. Page 282 1 And you said that later another staircase 2 was added? 3 A. Yeah, we rehabilitated this, you know, 4 but you asked me how many stairs there were, to 5 answer your question there were three. 6 Q. Three. So where was the third one? 7 A. The pool, this leads to the pool. 8 Through the outside master bedroom you could go 9 downstairs to the pool. 10 Q. Okay. A stairway then from the outside, 11 from outside the master bedroom? 12 A. Yes, ma'am. 13 Q. Down to the pool? 14 A. Yes, ma'am. 15 Q. One of your duties was to answer the 16 door. Is that correct? 17 A. Yes, ma'am. 18 Q. Which door would you answer? 19 A. Mainly the kitchen. 20 Q. And why was that, why would people mainly 21 come to the kitchen? 22 A. I'll say it was for practicable reasons 23 because not to go to the main -- it was shorter 24 because the entrance was here, so this was the 25 driveway and we used to take Into the back door of 4 (Pages 279 to 282 Kress Court Re ortin Inc EFTA00310281 Page 283 1 the kitchen and they will wait there. 2 Q. All right. Would you just put BD where 3 the back door of the kitchen was, please? 4 Now, these young women that came to give 5 Mr. Epstein massages, would they usually come to 6 the kitchen door? 7 A. Yes, ma'am. 8 MR. CRITTON: Form. 9 BY MS. EZELL: 10 Q. Did any ever come to the front door? 11 A. Very rarely. 12 Q. And you would let them in the kitchen? 13 A. Yes, ma'am. 14 A h n how did you then turn them over 15 to 7 16 MR. CRITTON: Form. 17 THE WITNESS: I will call her. 18 BY MS. EZELL: 19 Q. How would you call her? 20 A. On her cell phone and she will know they 21 were waiting in the kitchen. 22 Q. And would you bring them in the kitchen 23 and then just leave? 24 A. Yes, ma'am. 25 Q. And where would you go? Page 285 1 A. You're welcome. 2 Q. Could you see the pool from the staff 3 house? 4 A. No, ma'am. 5 Q. How would you know, or would you know 6 when the young women were brought downstairs after 7 giving the massages? 8 MR. CRITTON: Form. 9 THE WITNESS: I will hear the commotion, 10 some voices, but I was not told they were 11 leaving. 12 BY MS. EZELL: 13 Q. And so did you have any duties that had 14 anything to do with their leaving? 15 A. Check the security and see if the gate 16 was closed, that the cars were locked because the 17 garage were here. 18 Q. Would you put a G where the garage was? 19 I believe you testified that you were 20 required to have on your person $2,000 everyday? 21 A. More or less, Ma'am. 22 Q. And if you open the door and a young 23 there to give a massage you would call 24 and go back to the staff house? 25 . es, ma'am. Page 284 1 A. To my -- to the staff house that was 2 here. 3 Q. Good, I was going to ask you to show me 4 where the staff house is. Just put SH. 5 A. It was just maybe five feet, I used to 6 stay here. 7 Q. Okay. So what you're saying, it's about 8 five feet from the kitchen? 9 A. More or less, yes. 10 Q. Was it connected to the house? 11 A. No, it's detached but it's very dose 12 proximity. 13 Q. Okay. So to get to the staff house would 14 you come out the kitchen door? 15 A. Yes, ma'am. And I came through my -- 16 there was two entrances, one through the laundry 17 here and one to the main entrance to the staff 18 house. 19 Q. All right. And what was your usual 20 pathway if you left the kitchen to enter the staff 21 house, how would you generally do it? 22 A. Normally I will came to the laundry, the 23 laundry was here and my office was next to the 24 laundry. 25 Q. Okay. Thank you. Page 286 1 Q. And then you believ would 2 come In and lead the young woman upstairs. 3 Correct? 4 MR. CRITTON: Form. 5 THE WITNESS: I'm sorry, can you repeat 6 your question? 7 BY MS. EZELL: 8 Q. I'll try to, yes. 9 When you would answer the door and there 10 would be a young lady there to give a massage. 11 A. Yes, ma'am. 12 Q. I believe you testified you would let her 13 in the kitchen. 14 A. Yes, ma'am. 15 Q. And you called a 16 A. Yes, ma'am. 17 Q. And you then left her in the kitchen 18 alone? 19 A. Yes. 20 Q. And went to the staff house? 21 A. Yes, ma'am. 22 Q. And sometimes you heard the commotion 23 when the young woman was leaving -- 24 A. Yes, ma'am. 25 Q. -- but you didn't necessarily see them 5 (Pages 283 to 286 Kress Court Reporting, Inc EFTA00310282 Page 287 1 leave. Is that correct? 2 A. Exactly, yes, ma'am. 3 Q. How did the money that you 4 were keeping t ' to pay those young 5 women? 6 A. =would tell me who to pay and how 7 much, that's the way we work. 8 Q. And when would she tell you that? 9 A. She will call me by phone and say I'll 10 give so much to so on and so forth. 11 Q. Okay. Was that at the condusion of the 12 massage? 13 MR. CRITTON: Form. 14 THE WITNESS: Yes, ma'am. 15 BY MS. EZELL: 16 Q. Okay. Then I'm a little confused because 17 I thought you said that you didn't see them when 18 they left from giving the massage. 19 A. She will call me and she will say pay X, 20 Y, or Z, and that's the way I knew how much and to 21 whom. But sometimes they would leave and I didn't 22 pay those, I don't know who paid them. 23 Q. Okay. So if she calls you and told you 24 to pay X, Y, and Z $200, would you then go back 25 into the kitchen and give X, Y, and Z $200 each? 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 Page 289 A. Yes. le south face of the house, but this was . Q. All rig . nd so did she usually work with her laptop on the dining room table? A. She will have all over the house but she will sit down here to work on the desk. Q. Do you know whether she kept any lists of names of girls to come and give massages? A. She did, Ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. And do you know in what form she kept those? A. She had notes, you know, she always have papers, but I don't know. Q. Do you recall seeing the papers with telephone numbers on them? A. A couple of times. Q. Do you know whether she also kept records on the computer relating to the girls? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And how do you know that? A. Everything was recorded in -- everything Page 288 1 A. Sometimes in the kitchen, sometimes in 2 the driveway I will pay them in an envelope, you 3 know. 4 Q. Okay. And she would tell you how much to 5 pay them? 6 A. Yes, ma'am. 7 Q. Where was Ms. when you would call 8 her to tell her that there was someone at the 9 kitchen door to give a massage? 10 A. She was inside the house so I call her on 11 her cell and say, Alfredo, leave them in the 12 kitchen, but I don't know where she was. 13 Q. Okay. Did she have an office? 14 A. No, ma'am. 15 Q. Did she have a computer In the house? 16 A. Yes. 17 Q. Where was her computer? 18 A. She had a laptop but she usually work in 19 the dining room. 20 Q. And where was the dining room? 21 A. All this area facing the garde 22 north -- I'm sorry, facing south, a 23 was at her desk here. 24 Q. So did the dining room have large 25 windows? Page 291 1 we did as employees we used to record and kept in 2 the internal circuit we used to have among the 3 employees. 4 Q. And so would it be, if I understand you 5 correctly then, was there some sort of a program 6 so could access Information that lil 7 Ms as putting into that program and she 8 co information you put in? 9 A. Yes, ma'am. 10 Q. And did you also send each other e-mails 11 that way or did you use a different program for 12 e-mail`., 13 A. didn't send direct e-malls to me 14 but she will call me on her cell. But I was 15 supposed to send through Citrix to other 16 employees. 17 Q. E-mail them through Citrix? 18 A. Yes, ma'am. 19 Q. Okay. And who would those other 20 employees be, have been, I mean, while you were 21 there? 22 A. Mrs. n New York, mostly 23 them Mind -- 24 Q. 25 A. yes, the secretary, and somebody as -- 6 (Pages 287 to 290) Kress Court Reporting, Inc. EFTA00310283 Page 291 1 else, I don't recall. 2 Q. Was there anyone else that you could 3 e-mail? 4 A. We could e-mail anybody in the 5 organization. 6 Q. On that particular program? 7 A. Yes, ma'am. 8 Q. And so who else would be In that 9 organization? 10 A. Other household managers from Parks or 11 the Island, Manhattan. 12 Q. Do you know whether Ms kept any 13 pictures of the young women whit come to give 14 massages on her laptop? 15 A. Yes, ma'am. 16 Q. You saw those pictures? 17 A. Yes. 18 Q. Were the pictures uniform? And by that I 19 mean, were they all taken, for instance, there at 20 the house so that they would all be fairly 21 standard? 22 MR. CRITTON: Form. 23 THE WITNESS: They will be all over, you 24 know, sometimes out of the country and 25 sometimes in the house. Page 293 "Il .* 1 A. I don't remember ' 2 Q. Did you ever see sing that i 3 small compact camera to a e a pi re of the 4 girls? 5 A. Yes, ma'am. 6 MR. CRITTON: Form. 7 BY MS. EZELL: 8 Q. When you saw her doing that where were 9 they, the girls? 10 A. The dining room, the library, the first 11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 pictures of the girls? 17 A. No, ma'am. 18 Q. Were you ever told by anyone that Mr. 19 Epstein sometimes took pictures of the girls? 20 MR. CRITTON: Form. 21 THE WITNESS: Yes, ma'am. 22 BY MS. EZELL: 23 Q. And do you rtgalleo told you that? 24 A. I think it wasM. 25 Q. Do you recall what she said about that? 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 Page 292 BY MS. EZELL: Q. Were these pictures that were taken by someone for the purpose of keeping them in that program? A. I don't know. MR. CRITTON: Form. BY MS. EZELL: Q. Or opposed to, for instance, one of the nuunc3 ladies bringing a picture to give to A E I don't know. Q. You don't know where the pictures came from? A. No, ma'am. Q. Do you know was there anyone staying in the house who often took pictures of young women? MR. CRITTON: Form. THE WITNESS: There was several cameras in the house and they were used often, but I don't know who used them. BY MS. EZELL: Q. Okay. Do you remember what kind of cameras they were? A. The small compact camera. Q. Any other kind? Page 294 1 A. He likes photography and he likes -- like 2 a hobby. 3 Q. Do you know which camera or what kind of 4 camera he used to take those pictures? 5 A. No, ma'am. 6 Q. And you said I think you never saw him 7 taking them? 8 A. Yes. 9 Q. So -- 10 MR. CRITTON: Yeah meaning correct? 11 THE WITNESS: Yes. 12 BY MS. EZELL: 13 Q. Was it your understanding that he took 14 those pictures upstairs? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 Q. And when you had occasion to go upstairs 19 do you recall seeing camera equipment? 20 A. No, ma'am. 21 Q. Were you ever told that he took pictures 22 of the girls nude? 23 A. No, ma'am. 24 Q. Were you ever told that he liked to have 25 pictures taken of the girls nude? 7 (Pages 291 to 294) EFTA00310284 Page 295 1 MR. CRMON: Form. 2 THE WITNESS: No, ma'am. 3 BY MS. EZELL: 4 Q. I believe you were asked before In the 5 deposition about the stairway leading from the 6 kitchen upstairs and whether or not there were 7 pictures on that stairway. 8 A. Yes, there were pictures. 9 Q. Were those pictures some of them of nude 10 young women? 11 MR. CRITTON: Form. 12 THE WITNESS: Not on the stairway, they 13 were in the foyer in the second -- on the 14 foyer and the foyer leading to the master 15 bedroom. 16 BY MS. EZELL: 17 Q. I see. Were those -- what size generally 18 were those pictures? 19 A. They were, you know, I'll say three by 20 five. 21 Q. So very large -- 22 A. Yes, ma'am. 23 Q. -- pictures? Were there lots of 24 photographs just around the house on top of 25 furniture in the various rooms? Page 297 1 BY MS. EZELL: 2 Q. And was that already installed when you 3 came there? 4 A. Yes, ma'am. 5 Q. Where is it you -- first of all, did they 6 tell you where the equipment was installed? 7 A. No. 8 Q. Did you have any understanding of where 9 the equipment was installed? 10 A. No. 11 Q. Do you know whether or not there was 12 surveillance photography equipment upstairs and 13 downstairs? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 17 Q. And how do you know that? 18 A. I read it through the FBI report after 19 the fact that I -- after I left the job. 20 Q. Before reading through the FBI report did 21 you have any knowledge of the fact that there was 22 surveillance equipment both upstairs and 23 downstairs? 24 A. No, ma'am. 25 Q. While you were there was there ever an Page 296 1 A. Yes, ma'am. 2 Q. And were any of those photographs of 3 young women in the nude? 4 A. Yes, ma'am. 5 Q. Did you recognize any of those young 6 women? 7 A. Yes, a couple. 8 Q. And who was it that you recognized? 9 A. Miland some other girl from Brazil 10 that was house but I don't remember her 11 name. 12 Q. Was this a girl that would come and stay 13 in the house or one of the girls that would come 14 and give massages? 15 A. They will stay at the house. 16 Q. Stay at the house. Do you recall a 17 picture of the girl, of a young women nude in a 18 hammock? 19 MR. CRITTON: Form. 20 THE WITNESS: No, I don't remember. 21 BY MS. EZELL: 22 Q. Was there surveillance equipment 23 installed in the house? 24 A. Yes, ma'am. 25 MR. CRITTON: Form. Page 298 1 occasion when someone came to do any maintenance 2 or repair on the surveillance equipment? 3 A. Yes, ma'am. 4 MR. CRITTON: Object to the form of the 5 last question. 6 MS. EZELL: Pardon? 7 MR. CRITTON: Form of the last question. 8 BY MS. EZELL: 9 Q. Did that happen more than one time? 10 A. I believe so, yes, ma'am. 11 Q. Do you have any recollection of who came 12 there, either the name of the company or the name 13 of the person who would come to repair or do 14 maintenance on the video equipment? 15 A. We used to have a young technician from 16 Ohio who used to maintain all the computers and he 17 would be the only one dealing with those things. 18 Q. So he maintained the computers and the 19 video equipment. 20 A. Yes. 21 Q. Is that correct? 22 MR. CRITTON: Form. 23 BY MS. EZELL: 24 Q. Do you have any recollection of what his 25 name was? 8 (Pages 295 to 298 EFTA00310285 Page 299 1 A. I don't remember, Ma'am. He came from 2 New Albany, Ohio. 3 Q. From New -- 4 A. New Albany, Ohio. 5 Q. New Albany, Ohio. 6 business? 7 A. No, he worked for Mr. Epstein. He will 8 maintain all the computers. 9 Q. Was he there everyday? 10 A. No, ma'am. 11 Q. Do you know whether at that time Mr. 12 Epstein had an office in Palm Beach? 13 A. Not outside the house, no. 14 Q. Do you have any knowledge of whether or 15 not the video equipment was -- and I don't know 16 the technical term, forgive me, but was it the 17 kind of equipment that would record for a certain 18 amount of time and then record over that film? 19 A. I don't know. 20 MR. CRITTON: Form. 21 BY MS. EZELL: 22 Q. You don't know? 23 A. No, ma'am. 24 MR. CRITTON: Just for clarification, I 25 may have misunderstood, but I thought he Did he have his own Page 301 1 video, even phones. 2 Q. Would he also repair the televisions if 3 they needed work? 4 A. No. 5 Q. No. Did you have any kind of intercom 6 system in the house? 7 A. Yes, ma'am. 8 Q. And what kind of system was that? 9 A. It was standard office equipment, Lucid 10 Technologies maybe, but it was an intercom like we 11 using right now. 12 MS. EZELL: Just let the record reflect 13 that the witness pointed to the telephone on 14 the table that has a speaker phone. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 17 Q. And did you use that in your work? 18 A. Yes, ma'am. 19 Q. And what did you use it for? 20 A. Mr. Epstein used to page me when he 21 needed me. 22 Q. Did you have one of those phones in the 23 kitchen? 24 A. Yes, ma'am. 25 Q. And was there one out in the staff house Page 300 1 said he didn't even know the video equipment 2 existed until he read the FBI report. 3 MS. EZELL: He said he didn't know that 4 it was upstairs and downstairs, I believe. 5 MR. CRITTON: I thought he said he didn't 6 know that it even existed. 7 MS. EZELL: I may be wrong. 8 BY MS. EZELL: 9 Q. Did you know it existed before you read 10 the FBI report? 11 A. No, ma'am. 12 Q. I'm sorry, then I was wrong. 13 How did you know then that the young 14 technician from Ohio maintained the computers and 15 the video equipment? 16 A. Because we used to request -- there were 17 always problems with the computers so he came to 18 the house and he was the programmer. It was very 19 sophisticated. 20 MR. CRITTON: Form to the last question, 21 move to strike the answer as nonresponsive. 22 BY MS. EZELL: 23 Q. How did you know then that he maintained 24 the video equipment as well? 25 A. Because he was In charge of computers, Page 302 1 as well? 2 A. Yes, ma'am. 3 Q. Do you know where others were in the 4 house? 5 A. Probably have like 15 phones. We used to 6 have three in the staff house, one in the cabana, 7 two in the master bedroom, one in each room, 8 kitchen, dining room, Mrs. Maxwell's office, the 9 garage. 10 Q. Where was Mrs. Maxwell's office? 11 A. Under the stairs next to the kitchen. 12 Q. Can you give me some idea of what size 13 space that was? 14 A. It was probably -- we change the floor. 15 Twelve by five, something like that 16 Q. And was the computer equipment in that 17 space? 18 A. Yes, ma'am. 19 Q. Do you know whether Ms. Maxwell kept the 20 names and telephone numbers of the girls who came 21 to do massages? 22 A. Yes, ma'am. 23 MR. CRITTON: Form. 24 BY MS. EZELL: 25 Q. Do you know that because you saw the 9 (Pages 299 to 302) Reoortino, Inc. EFTA00310286 Page 303 1 names and phone numbers? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 6 girls on the computer? 7 A. Yes, she did. 8 Q. And you know that as well because you 9 happen to see them? 10 A. Yes, ma'am. 11 MR. CRITTON: Form to the last two 12 questions. 13 BY MS. EZELL: 14 re they similar to the pictures that 15 Ms had on her computer? 16 . CRITTON: Form. 17 THE WITNESS: Yes, ma'am. 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 look like pictures that were posed? 21 A. They were more casual. 22 Q. Did they look as though the person being 23 photographed knew that they were being 24 photographed? 25 MR. CRITTON: Form. Page 305 1 computer? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. And did she generally have phone numbers 6 for those girls? 7 A. Yes, ma'am. 8 Q. And were they generally pictures of the 9 girls? 10 MR. CRITTON: Form. 11 THE WITNESS: No, ma'am. 12 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 girls who came to give massages? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 A. Yes, ma'am. 20 MR. CRITTON: Form. 21 BY MS. EZELL: 22 Q. Were there pictures on her computer of 23 the girls who came to give massages? 24 MR. CRITTON: Form. 25 BY MS. EZELL: Page 304 1 THE WITNESS: No, ma'am. 2 BY MS. EZELL: 3 Q. And what can you tell me about that, what 4 lead you to draw that conclusion? 5 A. They were probably taken in parties in 6 big reception or banquet. 7 MR. CRITTON: Let me offer as a 8 suggestion, not that you have to accept or 9 that you would, you're using the term young 10 girls generically, he has probably seen 11 many, many young girls, there was no -- 12 you've used it interchangeably with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, 16 so that's part of my form objection. 17 MS. EZELL: Okay, thank you. 18 BY MS. EZELL: 19 Q. When I asked you about Ma whether 20 she had a list of the girls and teleph mbers, 21 I think I asked about those girls that came to 22 give massages, but let me go back and just ask it 23 that way. 24 Did you notice that Ms. Mad a list 25 of the girls that came to give massages on her Page 306 1 Q. Ms. Maxwell I'm talking about. 2 A. Yes, ma'am. 3 Q. And were those pictures the more casual 4 ones that you described when I asked whether or 5 not the subject looked as though she knew she was 6 being photographed? 7 MR. CRITTON: Form. 8 THE WITNESS: I'm sorry, can you repeat? 9 BY MS. EZELL: 10 Q. Yeah. The pictures of the young girls 11 who came to the house to give massages that were 12 on Ms. Maxwell's computer, did they appear to have 13 been taken when the girls knew they were being 14 photographed? 15 MR. CRITTON: Form. 16 THE WITNESS: I don't think they knew 17 they were being photographed. 18 BY MS. EZELL: 19 Q. I believe you said they were more casual 20 pictures. 21 A. Yes, ma'am. 22 Q. Did you notice any nude photographs in 23 those pictures? 24 A. Yes, ma'am. 25 MR. CRITTON: Form for the last question. 10 (Pages 303 to 306) Kress Court Re• •rtin. EFTA00310287 Page 307 1 BY MS. EZELL: 2 Q. Among those pictures in Ms. Maxwell's 3 computer of the young women who came there to give 4 massages, were the nude photographs in that group 5 taken, did they appear to be taken in the house? 6 MR. CRITTON: Form. 7 THE WITNESS: No, ma'am. 8 BY MS. EZELL: 9 Q. You said before they appeared to be taken 10 at receptions or banquets? 11 A. Yes, ma'am. 12 Q. And Pm a little confused about how they 13 were casual and taken while the girls were nude at 14 receptions and banquets? 15 A. What I saw there were parties in Russia, 16 Eastern Europe, I don't know which country, but 17 there were also pictures of nude girls in a 18 shower, for instance, In a shower stall. 19 Q. You said for instance, so were there 20 other places other than the shower? 21 A. Yes, ma'am. 22 Q. Like what? 23 A. Gatherings, you know, in a party. You 24 could tell everybody is smiling so I believe It 25 was a place where they're having fun. Page 309 1 Q. And was there more than one during the 2 time you were there? 3 A. Yes. 4 Q. Do yougaber their names? 5 A. One w I don't remember the other 6 one name. 7 Q. Did they appear to be American? 8 A. Yes, ma'am. 9 Q. Do you know the name 10 A. Could be, ma'am, but I'm not sure of his 11 last name. 12 Q. Do you have any idea where those chefs 13 had goiiiiieir training? 14 A. was working in San Francisco when 15 he was hired. 16 Q. Was he still there when you left Mr. 17 Epstein's employ? 18 A. Yes, to my knowledge, ma'am. 19 Q. Did the chef interact with the girls who 20 came to give massages? 21 A. In the kitchen, yes. 22 Q. And did he often offer them some food 23 while they were there? 24 A. Yes, ma'am. 25 Q. Were there occasions where a girl came to Page 308 1 Q. Were any of those pictures, if you 2 recall, taken in the cabana? 3 A. I don't remember. 4 Q. Do you recall there being parties and 5 gatherings in the cabana at the house? 6 A. I don't remember. 7 MR. CRITTON: Form. 8 BY MS. EZELL: 9 Q. When Mr. Epstein entertained did you have 10 anything to do with seeing that the bars were 11 stocked and that there was food that was needed 12 and so forth? 13 MR. CRITTON: Form. 14 THE WITNESS: There was no alcohol in the 15 house, only for guests. But, yeah, he will 16 ask sometimes for food. 17 BY MS. EZELL: 18 Q. And do you ever recall him asking for 19 food for parties In the cabana? 20 A. No, ma'am. 21 Q. Was there a chef at the house on El 22 Brillo Way when you were there? 23 A. I'm sorry? 24 Q. A chef. 25 A. Yes, there was. Page 310 1 give a massage accompanied by another girl, or 2 another person, let me say? 3 A. Yes, ma'am. 4 Q. And sometimes was that other person a 5 woman and sometimes a man? 6 A. No, ma'am, always a woman. 7 Q. Always a woman. Usually would it have 8 been a woman about the same age as the young woman 9 coming to give the massage? 10 MR. CRITTON: Form. 11 THE WITNESS: Yes, ma'am. 12 BY MS. EZELL: 13 Q. Were you ever told by Ms to pay 14 the person who came who didn't give a massage? 15 A. Yes, ma'am. 16 Q. Do you recall how much you paid that 17 person? 18 A. Yes, ma'am. 19 MR. CRITTON: 20 BY MS. EZELL_: 21 Q. Now much? 22 A. 300 to 500 dollars. 23 Q. Were some of those young women who 24 brought other young women for massages regulars, I 25 mean, did they regularly bring other young women? Form. 11 (Pages 307 to 310) Court Re ortin Inc EFTA00310288 Page 311 1 MR. CRITTON: Form. 2 THE WITNESS: Yes, ma'am. 3 BY MS. EZELL: 4 Q. And were there some who maybe came just 5 once or twice with other young women? 6 A. That's correct, ma'am. 7 Q. Now, where would the young woman who was 8 bringing another young woman go during the time 9 the person that she brought was upstairs giving 10 the massage? 11 MR. CRITTON: Form. 12 THE WITi v(v)ill take them to the 13 kitchen an uld take them from 14 there. 15 BY MS. EZELL: 16 Q. Do you know where she took them? 17 A. No, ma'am. 18 Q. Were they ever taken to just sit in the 19 living room and wait? 20 MR. CRMON: Form. 21 THE WITNESS: I don't know, ma'am. 22 BY MS. EZELL: 23 Q. These pictures of nude young women taken 24 in gatherings where they were smiling, did they 25 appear to you to be taking part in an orgy? Page 313 1 shower, I don't know whether he ever used 2 plural. 3 BY MS. EZELL: 4 Q. Was there more than one picture of a girl 5 in the shower? 6 A. There were two girls in the shower. 7 Q. Two girls in the shower together? 8 A. Yes, ma'am. 9 Q. And were those two girls engaged in 10 something sexual? 11 A. Yes, ma'am. 12 Q. And I may have asked you this question, 13 forgive me if I did, did you know those two girls? 14 A. No, ma'am. 15 Did Ms. Maxwell have nude pictures of 16 on her computer? 17 MR. CRITTON: Form. 18 THE WITNESS: I don't know, ma'am. 19 BY MS. EZELL: 20 Q. Did you ever meet a young woman named 21 who had an accn iafinn with Ms. Maxwell? 22 MR. CRMO 23 MS. EZELL: 24 THE WITNE on remember, ma'am. 25 BY MS. EZELL: Page 312 1 MR. CRITTON: Form. 2 THE WITNESS: I don't know, ma'am. 3 BY MS. EZELL: 4 Q. Do you know the word cavorting? 5 A. No, ma'am, I don't know. 6 Q. I need my Thesaurus. You said they were 7 smiling, did they appear to be having a good time? 8 A. Yes, ma'am. 9 Q. Did they appear to be doing anything 10 sexual? 11 A. Yes, ma'am. 12 Q. And in these Instances were there girls 13 doing sexual things with other girls? 14 A. Yes, ma'am. 15 Q. And I'm still talking about the pictures 16 on Ms. Maxwell's computer. 17 A. Yes, ma'am. 18 MR. CRITTON: You're talking about the 19 group shots that he's mentioned from Russia 20 and Eastern Europe? 21 MS. EZELL: And girls In the shower. 22 MR. CRITTON: Let me object to the form 23 then the way you just now described that. 24 MS. EZELL: He said for instance. 25 MR. CRITTON: He had said a girl in the Page 314 1 Q. Did you ever have any conversations with 2 Ms. Maxwell about any of the women in those 3 pictures? 4 A. No, ma'am. 5 d you ever have a conversation with 6 about any of the pictures of the 7 mputer? 8 A. No, ma'am. 9 Q. You were asked last time about the creams 10 and lotions that Mr. Epstein typically had 11 available to him and you said you thought there 12 was a favorite one but you couldn't remember it. 13 A. Spa. 14 Q. Spa, you did say Spa. 15 A. Yeah. 16 Q. Thank you. 17 Where did the stairway from the kitchen 18 lead -- to where did it lead? 19 A. To the second floor between the first and 20 second bedrooms. 21 Q. Were either of those bedrooms the master 22 bedroom? 23 A. No, ma'am. 24 Q. Could one go up that stairrace through -- 25 could one go up that staircase and reach the 12 (Pages 311 to 314) EFTA00310289 Page 315 1 master bedroom? 2 A. Yes, ma'am. 3 Q. And how would you do that? If you want 4 to turn the page over for the upstairs you could 5 do that 6 A. Okay. 7 MR. CRITTON: Are you going to mark this 8 as an exhibit? 9 MS. EZELL: Uh-huh. 10 MR. CRITTON: Would that be Exhibit 3? 11 MR. EDWARDS: I think so. 12 (Exhibit No. 3 was marked for 13 Identification.) 14 THE WITNESS: This is the master bedroom, 15 master bath, and there were one, two -- the 16 rest of the bedrooms were here and the 17 master bedroom was here. This is master 18 bath one and master bath two. 19 So the staircase came to the second floor 20 like this and it was between the first and 21 second bedroom. And you could go through 22 here and you enter a foyer with double doors 23 here, double doors here, and you enter the 24 master bedroom. 25 BY MS. EZELL: Page 317 1 Q. White. By the way, I have some more 2 water, would you like some? 3 A. Thank you, ma'am. 4 Q. I figure if I'm a little dry you may be 5 too. 6 I believe one of the items that you 7 mentioned that sometimes had to be picked up after 8 girls were there giving massages was a back 9 massager. 10 A. Yes, ma'am. 11 Q. Could you describe that for me, please? 12 A. It was a piece about this big. 13 Q. Would you say that's about 18 inches? 14 A. Yes, ma'am. And two prongs with the 15 rubber tips and a cord. 16 Q. Okay. 17 A. Or it could be detached too. 18 Q. Do you have any recollection of what make 19 that was? 20 A. No, ma'am. 21 Q. Were there any other massagers that you 22 recall seeing there regularly? 23 A. Those are the ones I remember. I think 24 they are from Sharper Image, but I don't -- 25 Q. Okay. Were there often girls around the Page 316 1 Q. All right. How would you get to the 2 master bathroom on that end? 3 A. You go through these double doors, go 4 around the bed and you gain access to the master 5 bedroom — master bathroom, sorry. 6 Q. And then there was another master 7 bathroom on the other side of the room? 8 A. Yes, ma'am. 9 Q. Where generally did the massages take 10 place? 11 A. Right here, ma'am. 12 Q. And is that in the master bathroom? 13 A. Master bathroom, yes. 14 Q. Do you recall what color the tile was in 15 that bathroom? 16 A. There was carpet. 17 Q. Was there tile on the walls or marble 18 or — 19 A. There was a sauna here with marble but 20 outside the sauna everything was carpet, and the 21 walls, they didn't have any tile. Oh yes, I will 22 say four feet off the floor they will have marble. 23 Q. And do you remember what color marble it 24 was? 25 A. White. Page 318 1 pool at the house? 2 A. Yes, ma'am. 3 Q. And were these sometimes the same girls 4 that came to give massages? 5 A. Yes, ma'am. 6 Q. Were there girls in addition to those who 7 came to give massages who hung around the pool? 8 A. The girls who were staying at the house. 9 Q. Okay. And so they weren't girls who Just 10 regularly came to hangout around the pool? 11 A. No, ma'am. 12 MS. EZELL: Excuse me. Can we go off the 13 record for a minute? 14 (Thereupon, a recess was had.) 15 THE VIDEOGRAPHER: We're back on the 16 record with tape number two. 17 BY MS. EZELL: 18 Q. Mr. Rodriguez, did you receive a subpoena 19 that asked you to bring documents with you to the 20 deposition? 21 A. Yes, ma'am. 22 Q. And did you bring any with you? 23 A. I couldn't find anything at my house. 24 Q. Okay. I believe we talked about a 25 Journal that you kept, and you looked for that? I= ,. K.ress rn_ Reporting, Coidui l a 2.; 13 (Pages 315 to 318) EFTA00310290 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Q. Do you know if she was married to 21 MI Do you know Mr... 22 MR. CRITTON: Form. 23 THE WITNESS: I believe, yeah, I'm not 24 sure, ma'am. 25 BY MS. EZELL: Page 319 A. Yes, ma'am. Q. And you couldn't find it? A. I give it to Detective Joe. Q. Recarey? A. Yes, ma'am. Q. You mentioned that you called Mr. Jean-Luc Bernell about a recommendation when you were looking for a job. A. Yes, ma'am. Q. And did you know him from his visits in the home? A. Yes, ma'am. Q. Did you say that his wife's name w. MR. CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. A. years u know what his wife's name was? was a model, a former model from ho was friend of Mr. Epstein. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 321 BY MS. EZELL: Q. Did they ever visit Mr. Epstein at the home when you were there? A. Yes, ma'am. Q. How old was the little girl at that time? A. Eight years old. Q. Did the girl's father come to visit as well? A. Yes, ma'am. Q. And do you remember his name? A. No, ma'am. Q. Do you remember hearing anything about what he does for a living? A. No, ma'am. Q. Can you describe him? A. Tall, American born, I will say 50 years old. Q. What color hair did he have? A. At that time it was black with a few white hairs. Q. Were there drawings of nude women in the house? A. No, ma'am. Q. Were there paintings of nude women in the house? Page 320 1 Q. Is she now a doctor? 2 A. No, she was a model, her husband could be 3 a doctor but I don't think she Is. 4 Q. Okay. So is Jean-Luc Bernell married; to 5 your knowledge? 6 A. I don't know, ma'am. 7 Q. I think I must have gotten confused 8 because we were talking about the picture in the 9 house of the little girl who is lifting up her 10 skirt or her underpants, I'd forgotten what it 11 was. 12 A. Yes, ma'am. 13 MR. CRITTON: Form. 14 BY MS. EZELL: 15 Q. And I thought you said that that was 16 Jean-Luesill. 17 A. No, . , she is Mrs 18 Q. Eva'srr IIM? 19 A. Yes, ma'am. 20 Q. And she is Jeffrey 21 A. Yes, ma'am. 22 Q. Do you know where she and her mother 23 live? 24 A. They live in Manhattan. 25 MR. CRITTON: Form. Page 322 1 A. Yes, ma'am. 2 Q. Did any of those appear to be 3 Ms. Maxwell? 4 A. Yes, ma'am. 5 Q. You mentioned that who was still 6 working there when you left -- 7 A. Yes, ma'am. 8 Q. -- was a very religious woman -- 9 A. Yes, ma'am. 10 Q. -- and would sometimes be upset about 11 seeing pictures of nude girls or having to pick up 12 sex toys, et cetera. 13 MR. CRITTON: Form. 14 THE WITNESS: Yes, ma'am. 15 BY MS. EZELL: 16 Q. And you said that you remembered her 17 crying because there was a picture of the Pope 18 next to a picture of a naked girl. 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 BY MS. EZELL: 22 Q. Do you know who that naked girl was? 23 A. I don't remember, ma'am. 24 Q. I believe David Copperfield's name came 25 up in the last deposition as someone who would 14 (Pages 319 to 322) Kress Court Renortino, Inc EFTA00310291 Page 323 1 call or visit. 2 A. Yes, ma'am. 3 Q. Were you ever there when he visited? 4 A. Yes, ma'am. 5 Q. And do you remember did he spend the 6 night? 7 A. No, ma'am. 8 Q. Did he come for dinner? 9 A. Yes, ma'am. 10 Q. Did that happen more than one time when 11 you were there? 12 A. Yes, ma'am. 13 Q. Do you remember whether or not any of the 14 young ladles who came to perform massages also 15 stayed for dinner? 16 A. No, ma'am. 17 MR. CRITTON: Just so It's clear, no, you 18 don't remember? 19 THE WITNESS: No, they were not there. 20 BY MS. EZELL: 21 Q. Did any of them ever stay for dinner? 22 Just any dinner, not the dinner with David 23 Copperfield. 24 A. You said they, the girls? 25 Q. The girls who came to give massages. Page 325 1 we are start with It and then you can use 2 the initials after that for all I care. 3 BY MS. EZELL: 4 Q. Do you remember a girl nameclill? 5 A. I heard that name. 6 Q. So I will refer to her as Mom now 7 on. 8 I'm going to show you a document, we can 9 mark it but I'm not going to leave it. I'm going 10 to take the exhibit. 11 MR. CRITTON: Wait a minute. Are you 12 going to make a copy of it? 13 MS. EZELL: No, I'm not going to leave a 14 copy. 15 MR. CRITTON: All right. Then I object 16 to you showing him a document that is not 17 part of this record. 18 MS. EZELL: Then object and the Judge can 19 rule, but I'm going to ask him to look at 20 this document. We can mark it as Exhibit 4. 21 THE WITNESS: Oh yeah. 22 BY MS. EZELL: 23 Q. Do you remember this young woman? 24 A. Yes. 25 MR. CRITTON: Let's see. Page 324 1 A. No, ma'am. 2 Q. In the earlier part of the deposition you 3 stated that you didn't drive the girls but then 4 later you remembered that you did sometimes have 5 to drive them. 6 A. Yes, ma'am. 7 Q. Do you remember a young woman named A. 8 who came there? 9 A. Yes, I do remember. 10 MS. EZELL: And again, we're going to 11 have the same agreement, if we use a girl's 12 name it will be shown on the transcript as 13 the initials only. 14 MR. EDWARDS: Agreed. 15 MR. CRITTON: Why don't you give him the 16 initials? Because in reading the transcript 17 we could end up with 25 Cs or E's or Ts, 18 in looking at it by just using the first, I 19 am just offering a suggestion because none 20 of us will remember who in the heck these 21 people are. 22 MS. EZELL: So you're asking me to give 23 both names so we would have two initials? 24 MR. CRITTON: lie may not recognize either 25 the first or the second name but as long as Page 326 1 BY MS. EZELL: 2 Q. And was she one of the ones who came to 3 the house to give massages? 4 A. Yes, ma'am. 5 Q. Do you remember her name? 6 A. No, ma'am. 7 Q. Is it possible she waM 8 MR. CRITTON: Form. 9 THE WITNESS: I hear that name but I 10 cannot say for sure. 11 BY MS. EZELL: 12 Q. Okay. Did she come often to the house? 13 A. Yes, ma'am. 14 Q. Were you ever aware of her being 15 photographed? 16 A. No, ma'am. 17 Q. I asked you about David Copperfield 18 before and let me ask you again. In thinking 19 about it is it possible that you remember that she 20 was there for dinner with David Copperfield? 21 MR. CRITTON: Form, asked and answered. 22 THE WITNESS: Possible, yes, ma'am. 23 BY MS. EZELL: 24 Q. Did you ever meet her parents? 25 A. No, ma'am. 15 (Pages 323 to 326) EFTA00310292 Page 327 1 Q. I'll take the pictures back. 2 MR. CRITTON: Just put on the record that 3 my client obviously could be here at the 4 deposition, or anyone's clients could be 5 here at the deposition and have full access 6 to the information that's being provided, by 7 taking the photograph back I'm not going to 8 be able to provide to that dient, nor will 9 I have possession of it so I could discuss 10 that photograph, it's now been explored with 11 this witness. 12 (Exhibit No. 4 was marked for 13 Identification.) 14 BY MS. EZELL: 15 Q. Do you recall that on occasion you drove 16 this young woman to or from Mr. Epstein's house? 17 MR. CRITTON: Form. 18 THE WITNESS: I don't remember, ma'am. 19 BY MS. EZELL: 20 Q. Do you ever recall driving her by the 21 airport and showing her Jeffrey Epstein's plane? 22 MR. CRITTON: Form. 23 THE WITNESS: Yes, ma'am. 24 BY MS. EZELL: 25 Q. Do you ever recall one time perhaps by Page 329 1 BY MS. EZELL: 2 Q. You mentioned last time that Mr. Epstein 3 asked you to go and rent a car for one of the 4 girls who gave him massages. 5 A. Right. 6 Q. Do you know if that waO 7 A. I'm not hundred percent sure, ma'am. 8 Q. Do you know how long that girl kept the 9 car? 10 A. A couple of months. 11 Q. Did she bring it back to you or did she 12 turn it in at the agency? 13 A. She brought it back to me. 14 Q. Did you ever have any knowledge of Mr. 15 Epstein helping this girl with her college 16 applications? 17 MR. CRITTON: Form. 18 THE WITNESS: I believe Mr. Epstein was 19 giving her money for good grades, that's 20 what I -- she told me, I understood that. 21 BY MS. EZELL: 22 Q. Was this the girl that you were 23 instructed by Mr. Epstein to take roses to at the 24 completion of her graduation? 25 A. I don't remember exactly, ma'am, but Page 328 1 accident seeing her naked? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. How happen? 6 A. I told to go upstairs because I 7 saw Mr. Epstein leave, so we rushed upstairs to 8 clean and this girl was sleeping naked in the 9 sauna, she fall asleep there, there was nobody 10 else there. 11 MR. CRITTON: Can I ask just for 12 darification, Is he talking now about the 13 person he thought was A. but he wasn't sure 14 or the person that's in photo four? 15 MS. EZELL: The person that's in 16 photo four. 17 THE WITNESS: Yes. 18 MR. CRITTON: Okay, thank you. 19 BY MS. EZELL: 20 Q. just so we're clear, do you think 21 this i but you're not sure? 22 . CRITTON: Form. 23 THE WITNESS: I heard the name so many 24 times but I know I took her, you know, in 25 the Suburban, so it was her. Page 330 1 there were so many faces, you know, but I cannot 2 say a hundred percent. 3 Q. But it's possible that this is the same 4 girl? 5 A. Yes, ma'am. 6 MR. CRITTON: Form. 7 BY MS. EZELL: 8 Q. And thinking about it carefully you still 9 believe she kept that car for two months? 10 A. Yes, ma'am. 11 Q. Do you recall an encounter with this same 12 girl when you saw a strange vehicle in the 13 driveway one day? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 17 Q. And what happened then? 18 A. I saw, you know, an old car that didn't 19 belong to the house so I went to the police 20 department, so the police department follow me and 21 they with flashlight they went into the driver and 22 ask her because she was -- I forgot I was suppose 23 to pay her but it was late at night, 8:00 p.m., 24 something like that, 8:30, so I recognize her and 25 I said to the police department I know this girl, 16 (Pages 327 to 330) Re ortin Inc EFTA00310293 Page 3M 1 so I paid her and she went off. 2 Q. Do you recall how much you paid her? 3 A. Between two and 300 dollars, I believe. 4 Q. How often was Mr. Epstein in Palm Beach 5 during the period you were there? 6 A. He will stay two months — I mean, two 7 weeks out of the month. 8 MS. EZELL: If I could please have these 9 marked as Exhibits 5 through 8. 10 (Exhibit No's. 5, 6, 7, and 8 were 11 marked for Identification.) 12 MR. CRITTON: Do you want them in the 13 order you gave them? 14 MS. EZELL: It doesn't matter. 15 BY MS. EZELL: 16 Q. Would you look, please, at the exhibit 17 that has been marked as number -- what Is it; 18 five? 19 A. Five. 20 Q. Five. Do you recall seeing this young 21. woman at the house when you were there? 22 A. Yes, ma'am. 23 Q. And do you recall her name? 24 A. No, ma'am. 25 MR. CRITTON: Let the record reflect it's Page 333 1 Q. Possibly but you're not sure? 2 A. Yes, ma'am. 3 Q. Okay. Would you look, please, at the two 4 photographs that have been marked as Composite 5 Exhibit 7? 6 Do you recall seeing this girl come to 7 the house to give massages? 8 A. I don't remember, ma'am. 9 Q. Okay. That's perfectly all right. 10 MR. CRITTON: Who does that purport to 11 be; number 12 MS. EZELL 13 BY MS. EZELL: 14 Q. The last one is exhibit what? 15 A. Eight. 16 Q. Eight. Do you recall seeing this girl 17 come to the house to give massages? 18 A. No, ma'am. 19 Q. Okay. 20 MS. EZELL: I don't have any other 21 questions right now. If anybody else wants 22 to go, if I could just reserve that if I 23 find something. 24 MR. WILUTS: I don't know who's next, 25 this is Richard Willits, I have a couple of Page 332 1 written on the photographs is a name, so 2 it's already being suggested to him, I think 3 that's Inappropriate. 4 MS. EZELL: It shouldn't be there, Pm 5 sorry. If I can erase it I will, I didn't 6 realize It was on there. 7 MR. CRITTON: It's on all of them, Cathy. 8 MS. EZELL: You're right, sorry. 9 BY MS. EZELL: 10 Q. Looking at the girl in number five, if I 11 told you that her name was F.E., would that 12 refresh your recollection as to who she was? 13 A. No, ma'am. 14 Q. Would you look, please, at the girl in 15 the picture that's been marked as Exhibit 6? 16 Do you ever recall seeing that girl come 17 to the house to give massages? 18 A. I cannot guarantee that, Ma'am. 19 Q. I understand, It's not the best picture 20 In the world either, you can't see. 21 MR. EDWARDS: I don't know that I 22 understood the answer. You can't guarantee 23 It? 24 THE WITNESS: I cannot guarantee it, sir. 25 BY MS. EZELL: Page 334 1 questions. 2 MR. CRITTON: All right, you're up. 3 MR. EDWARDS: Hold on one second, 4 Richard, they're going to put a microphone 5 by the phone. 6 MR. WILUTS: I only have a couple of 7 questions. 8 (Thereupon, an interruption was had.) 9 THE VIDEOGRAPHER: We're back on the 10 record. 11 EXAMINATION 12 BY MR. WILLITS: 13 Q. Back on the record. Sir, my name is 14 Richard Willits and I just have a couple of 15 questions for you. 16 Do you remember a young girl coming to 17 the house by the name IMMO 18 A. I hear that name, sir. 19 Q. You know the name, does that ring a bell 20 at all? 21 A. I hear the name in the house. 22 Q. Can you associate that name with a girl? 23 A. Yes, sir. 24 Q. I'm sorry? 25 A. Yes, sir, yes, I do. 17 (Pages 331 to 334) Kress Court Reporting, Inc. EFTA00310294 Page 335 1 Q. Do you remember whether she came to the 2 house on more than one occasion? 3 I heard her name several times from 4 u, sir, but beyond that I cannot say anything 5 6 Q. Okay. Who have you talked to about your 7 knowledge of Mr. Epstein in the last year? 8 A. My wife. 9 Q. Anyone else? 10 A. No, sir. 11 Q. Well, you talked to Mr. Critton. 12 A. We have a conversation in West Palm 13 Beach. 14 Q. Yes. So you talked to your wife, you 15 talked to Mr. Critton? 16 A. Yes. 17 Q. Had you talked to anyone else in the last 18 year about Epstein? 19 A. No. 20 Q. Did you talk to Mr. Goldberger? 21 A. Yeah, I called Mr. Goldberger first 22 before I talked to Mr. Critton. 23 Q. Okay. So we have your wife, we have Mr. 24 Critton, and we have Mr. Goldberger. 25 Do we have anyone else that you talked to Page 337 1 A. I give him a list of notes that I used to 2 take from frequent people -- I mean, people who 3 used to frequent the house and -- I'm sorry, it's 4 been a few years, I don't remember, but it was 5 those years, like it was a file with my personal 6 notes because he told me it was very important and 7 he kind of said can I borrow this from you, and he 8 still has those documents, sir. 9 Q. So even though they pertain to Mr. 10 Epstein you kept those notes at your residence? 11 A. Yes, sir. 12 Q. Okay. Where in your residence did you 13 keep those notes before you gave them to the 14 Detective? 15 A. In my bedroom. 16 Q. Did you have a file cabinet or -- 17 A. No. 18 Q. -- chester drawers or something? 19 A. No, they were laying next to some other 20 papers that I have. 21 Q. Did the other papers pertain to Mr. 22 Epstein? 23 A. No, no, nothing else related to Mr. 24 Epstein. 25 Q. I'm just confused as to why you told us Page 336 1 in the last year? 2 A. No, sir. 3 Q. How about Mr. Epstein of course? 4 A. No. 5 Q. Where did you usually keep the journal 6 with the names of the girls, in what part of the 7 house? 8 A. In the staff house. 9 Q. Sorry? 10 A. The staff house, the guest house. 11 Q. Right. But you said you had a journal at 12 your own residence with the names of the girls. 13 A. I give the whole journal and all the 14 information regarding this case, sir, to Detective 15 Joe Recarey, sir. 16 Q. Okay. And the materials that you gave to 17 the Detective, were they kept -- were any of them 18 kept at your own personal residence? 19 A. Yes, they were with me, sir. 20 Q. Okay. When you gave the materials to the 21 Detective, did all of the materials you gave to 22 him come from your residence? 23 A. Yes. 24 Q. Do you remember exactly what you gave to 25 him? Page 338 1 before that you had a journal at home and today 2 you say that you gave everything to the Detective. 3 MR. CRITTON: Form. You also may have 4 missed a portion of his earlier testimony if 5 you couldn't hear something, but go ahead. 6 MR. WILLITS: Most likely. 7 THE WITNESS: What I said was I thought I 8 had some information, and then I look with 9 my daughter and we couldn't find anything, 10 and I remember now that I put everything in 11 the file that I give to Detective Recarey. 12 BY MR. WILLITS: 13 Q. Did anyone help you assemble those papers 14 to give to the Detective? 15 A. No, sir. 16 MR. WILLITS: I don't have any other 17 questions. 18 CROSS EXAMINATION 19 BY MR. CRITTON: 20 Q. Mr. Rodriguez, my name is Bob Critton and 21 I represent Mr. Epstein as you're aware, I have a 22 few questions for you. 23 What I would like to remind you at the 24 start of this is if you know something, tell us, 25 if you don't know something tell us that 18 (Pages 335 to 338) Kress Court Reporting, Inc. EFTA00310295 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 Page 339 You're not required to speculate, you're not required to guess, you're not required to assume because some lawyers ask you a leading question or suggested in a report or like the police report like Mr. Mermelsteln and Mr. Edwards did, that did you tell the police officers X, Y, or Z without showing you the statement. You're not required to guess, I want personal knowledge, not speculation. Do you understand? A. Yes, I do. Q. All right. Now, when Mr. Edwards and -- Mr. Horowitz is here today for Mr. Mermeistein, but you remember a lawyer asked you some questions last time you were here? A. Yes. Q. That is he started and he went on for a few hours. Do you recall that? A. Yes, I remember. Q. He asked you do you remember telling the police officer Y, X, or Z. Do you remember that? Do you remember that's how he phrased his question? A. Yes, yes. Q. He never showed you a statement that you made to the police department; did he? 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 Page 341 marked up, no, you can't. MR. CRITTON: I just want to show him. Thank you, Cathy. BY MR. CRITTON: Q. This is the first what Ms. Ezell was kind enough to provide is the first part of your deposition, it was transcribed by the court reporter and provided by all counsel. Do you understand that? A. Yes, I understand that. Q. And no one has provided that to you yet today; have they? A. No. Q. Now, I think you told us that with the police officers you gave a taped statement. Did I understand you correctly? A. Yes. Q. And the only conversation that you had with the police officers, and it may have been a state attorney, it was somebody named Ms. Weiss who I think was referenced in the questions, the only time that you talked with at least Officer Recarey and the State Attorney's Office from Palm Beach County was in a taped statement. Is that correct? Page 340 1 A. I'm sorry? 2 Q. He didn't show you a document that said, 3 question, you know, what Is your name; answer, my 4 name is Alfredo Rodriguez -- 5 MR. WILLITS: Object to the form of the 6 question. 7 MR. CRITTON: You need to let me finish 8 it first. 9 MR. WILLITS: I'm sorry, I thought you 10 were. 11 BY MR. CRITTON: 12 Q. He never showed you a statement of what 13 the question was and the answer that you gave. 14 True? 15 MR. WILLITS: Object to the form of the 16 question. 17 THE WITNESS: I don't exactly understand 18 your question. 19 BY MR. CRITTON: 20 Q. Do you know what a deposition is? 21 A. Yes, I am. 22 Q. That's what you're doing here. 23 MR. CRITTON: Could I borrow your 24 deposition for just a minute? 25 MR. HOROWITZ: The transcript? It's Page 342 1 A. No. 2 Q. Did you talk with them separate and apart 3 from that? 4 A. Yes, I did. 5 Q. Okay. Did they tape that statement? 6 A. No. 7 Q. You told us you also spoke with 8 representatives of the FBI? 9 A. Yes. 10 Q. Okay. And you distinguished between the 11 FBI and between Officer Recarey? 12 A. Yes. 13 Q. So how many times did Officer Recarey, or 14 Detective Recarey, I think he's from the Palm 15 Beach Police Department speak with you? 16 A. Like three or four times. 17 Q. But he only took one statement? 18 A. One taped. 19 Q. I'm sorry, one taped statement? 20 A. Yes. 21 Q. All right So as to whether or not if 22 you said something to Officer Recarey or not that 23 you would be able to confirm, that would only have 24 been in a taped statement, one taped statement out 25 of the three, approximately three times he spoke 19 (Pages 339 to 342) Kress Court RIII EFTA00310296 Page 343 1 with you. 2 MR. EDWARDS: Form. 3 MR. HOROWITZ: Form. 4 BY MR. CRITTON: 5 Q. Is that correct? 6 A. Yes, correct. 7 MR. WILLITS: Object to the form. 8 MR. HOROWITZ: Join. 9 BY MR. CRITTON: 10 Q. And when we were here, I think it was 11 last week or the last ten days anyway -- I could 12 tell you. On July 29th of this year, and Mr. 13 Mermelstein started with your deposition and then 14 others asked questions, when Mr. Mermelsteln and I 15 think Mr. Edwards asked questions about did you 16 tell Officer Recarey X, Y, or Z, they didn't show 17 you a statement, they didn't give you like a 18 transcript like this and say see what the question 19 and see what the answer is? 20 A. No. 21 MR. EDWARDS: Form. 22 MR. WILLITS: Object to the form of the 23 question. 24 BY MR. CRITTON: 25 Q. And you haven't had an opportunity to see Page 345 1 Q. When Officer Recarey took -- spoke with 2 you on those approximately two times when he did 3 not take a taped statement, did he ever present 4 anything for you, anything In writing that he had 5 written to say, Mr. Rodriguez, I would like you to 6 review this to make certain that I took down 7 correctly what you said? 8 A. No, sir. 9 Q. If he had offered to do that would you 10 have read what he wrote down to determine whether 11 or not he took down that which you had said or 12 told him? 13 MR. EDWARDS: Object to the form. 14 THE WITNESS: Probably I will read it 15 first 16 BY MR. CRITTON: 17 Q. All right. And if in fact he had 18 recorded something incorrectly or recorded in a 19 particular way that he wanted it phrased and it 20 was not accurate, would you have told him that? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: No, I never told him that. 23 BY MR. CRITTON: 24 Q. Listen to my question. 25 If he, Officer Recarey, had taken down Page 344 1 your taped statement since you gave it many years 2 ago? 3 A. No, sir. 4 Q. Would you agree that your taped statement 5 would probably be a little more accurate than your 6 testimony today because of the time period that 7 has transpired? 8 A. That's correct. 9 MR. HOROWITZ: Object to the form. 10 MR. WILLITS: Object to the form of the 11 question. 12 BY MR. CRITTON: 13 Q. When you spoke with the FBI over at 14 Greens -- I think it was Greens Pharmacy? 15 A. Yes. 16 Q. Did they take a statement from you, that 17 is, did they have a tape recorder or did they just 18 make notes? 19 A. They took notes. 20 Q. All right. Did you sign anything? 21 A. No, sir. 22 Q. That is like did they take notes of what 23 you said and then you signed it to say yep, that 24 accurately reflects what I said? 25 A. No, I didn't sign anything. Page 346 1 what you said and it was not accurate, that is, he 2 put his interpretation of what you said, would you 3 have told him that's not accurate, Officer 4 Recarey? 5 MR. HOROWITZ: Form. 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: I will tell him. 8 MR. CRITTON: Go ahead and change. We're 9 going to change the tape. We do have time. 10 Cathy, could I borrow back the 11 photographs, please? 12 While you're giving me those back, would 13 it be correct that you're going to keep -- 14 you took as you did with photograph 15 number four you took back five, six, seven, 16 and eight, and you're going to keep those 17 and not allow me or anyone else to have a 18 copy of them? 19 MS. EZELL: Yes. 20 MR. CRITTON: You're going to be equally 21 restrictive; right? 22 MS. EZELL: Right. 23 MR. CRITTON: All right. Thank you. 24 BY MR. CRITTON: 25 Q. You were shown photograph five of a lady, 20 (Pages 343 to 346 Kress Court Reporting, Inc. EFTA00310297 Page 347 1 M, and I think you told us that you had seen 2 her, you recognized her photograph. 3 A. Yes, I did. 4 Q. On how many occasions did you ever see 5 her at the Epstein home? 6 A. More than three times. 7 Q. More than three? 8 A. Yes, sir. 9 Q. That's as accurate as you can be? 10 A. Yes. 11 Q. More than three? 12 A. More than three. 13 Q. Whether it was four or five you don't 14 know, but more than three? 15 A. More than three, sir. 16 Q. In terms o 's age, did you ever ask 17 her what her age 18 A. No, sir. 19 Q. Did she appear to you to be someone at 20 least from seeing her and recalling her that she 21 appeared at least to you to be while a young woman 22 appeared to be someone who was 18 or older? 23 A. No, sir. 24 Q. Okay. Well, did you ever say anything to 25 the police or did you ever -- were you ever Page 349 1 Q. I'm sorry? 2 A. Yes, I did, I told the police. 3 Q. And at the time that you spoke with the 4 police and gave them a statement, isn't it true, 5 Mr. Rodriguez, that you were no longer employed by 6 Mr. Epstein? 7 A. Yes. 8 Q. And you understood that you were required 9 to tell the police officers the truth at that 10 time? 11 A. Yes. 12 Q. And if I understood your testimony I 13 believe from July 29th through today, you at no 14 time asked any of these girls how old they were. 15 True? 16 A. No. 17 Q. And as to whether the girls were under 18 18 or 18 or over 18, you really didn't know one way 19 or the other at the time. Would that be a fair 20 statement? 21 A. Yes. 22 MR. WILLITS: Object to the form of the 23 question. 24 BY MR. CRITTON: 25 Q. On Exhibit 6 there is a person who's Page 348 1 concerned about that such that you told someone? 2 A. No, sir. 3 Q. Haven't you told the police, sir -- let 4 me strike that, let me ask it this way. 5 In your taped statement that you gave to 6 the police did you not tell them that all of the 7 girls appeared to you to be 18 or above? 8 A. Sir, as far as when all these actions 9 that were taking place I was under an environment 10 that I thought I was going to be -- in other 11 words, I was afraid of any reprisal Mr. Epstein 12 and Mrs. Maxwell if I say something that is any 13 idea of me because I have this confidentiality 14 agreement. What I saw that they were very young, 15 but I cannot say that they were 18 and old. 16 Q. Right. Let me just take you back to my 17 question again and see if you can answer my 18 question. 19 MR. CRITTON: Could you please read it 20 back? 21 (Thereupon, a portion of the record was 22 read by the reporter.) 23 THE WITNESS: I think I told the police 24 that. 25 BY MR. CRITTON: Page 350 1 covered, the lady that Ms. Ezell asked you about I 2 believe was on the right-hand side of the 3 photograph. There Is a young lady on the 4 left-hand side with a black hat on. 5 Do you recognize her at all? 6 A. No, I don't recognize her. 7 Q. Okay. Thank you. With regard to the 8 photograph four that you saw that you think 9 possibly might be I think you told us that 10 you recall seeing MEIwoman in the sauna at Mr. 11 Epstein's house on one occasion and she was naked. 12 A. Yes. 13 Q. Was that near the end of your employment 14 or the middle or the front end? 15 A. I saw her on January 2005, sir, and I was 16 terminated in March, so that was two months prior. 17 Q. And did you ever tell anyone that you had 18 seen her nak te sauna? 19 A. I told 20 Q. Okay. And what did say? 21 A. She was surprised. 22 Q. Okay. Did you wake the young lady up in 23 the sauna? 24 A. No. 25 Q. And do you know how old the young lady 21 (Pages 347 to 350) EFTA00310298 Page 351 1 was at that time? 2 A. No, I didn't know. 3 Q. If I was to tell you she was bom in 4 December of '86 which would have made her 18 at 5 the time, and you would say, not surprised? 6 MS. EZELL: Objection, form. 7 MR. WILLITS: Object to the form of the 8 question. 9 MR. HOROWITZ: Join. 10 THE WITNESS: I would say I wouldn't 11 know. 12 BY MR. CRITTON: 13 Q. Other than telling did you sa 14 anything to anyone else when you saw the 15 lady you believe waM naked in the sauna? 16 A. I believe I mentioned that to my wife. 17 Q. All right. Anyone else? 18 A. No.. 19 Q. And did . continue -- assuming it was 20 A.H., did she continue to sleep in the sauna, that 21 is, she didn't know you were there? 22 A. She never knew that I was there. 23 Q. She didn't at least acknowledge that she 24 knew. Correct? 25 A. Yes, correct. Page 353 1 correct? 2 A. I think so, sir. 3 Q. All right. I assume that in over the 4 course of your life separate and apart from your 5 wife you've seen a naked woman before. 6 A. Yes. 7 Q. And I assume that in your 50 some odd 8 years -- how old are you, sir? 9 A. 55. 10 Q. In your 55 years you've seen pictures of 11 naked women both photographs, paintings, statutes. 12 Would that be a fair statement? 13 A. Yes. 14 Q. And in terms of at least In this 15 particular case there is all sorts of -- as you 16 know there is testimony, and you've been asked a 17 number of questions about sex related issues, that 18 is whether you saw in photographs or whether you 19 saw anyone engaged in any type of sexual activity. 20 Correct? 21 A. Correct. 22 Q. And I assume that you understand that men 23 and women -- we'll start there first, that men and 24 women actually do have sex In this world? 25 A. Yes. Page 352 1 Q. You were asked by Ms. Ezell -- I'm just 2 going to cover a couple of things a I'm 3 staying with Cathy here -- whetherilt you 4 had told us something about the picture of the 5 Pope near a picture okLualied person, naked 6 woman. That's what told you, you never 7 saw those photos. Correct? 8 A. I did saw the pictures. 9 Q. You did see the pictures? 10 A. Yes. 11 Q. And the photos that you saw of the naked 12 woman that was near the Pope's photograph, was 13 that someone that you knew or just a picture of a 14 naked woman? 15 A. It was somebody -- somebody that was a 16 visitor in the house, but I don't know her name. 17 Q. And the visitors, that would have been 18 one of the plane women, you described the women 19 who came in on planes, or that they came with Mr. 20 Epstein from time to time? 21 A. They came with Mr. Epstein from time to 22 time. 23 Q. All right. And those are women that I 24 think you testified at your last deposition all 25 appeared to be In their 20's or older. Is that Page 354 1 Q. That comes as no grand surprise to you? 2 A. No. 3 Q. And you understand that people actually 4 enjoy sex from time to time? 5 A. Yes. 6 Q. Are you familiar with that concept at 7 least? 8 A. Yes. 9 Q. All right. And what may be typical 10 sexual activity for one man and woman, or whatever 11 the permutation might be, another couple, or 12 another man and woman, or another man or woman may 13 consider to be unusual or overly aggressive. 14 MS. EZELL: Objection to form. 15 BY MR. CRITTON: 16 Q. True? 17 A. It depends on your point of view. 18 Q. That's what I mean. Everyone has a 19 different point of view about sex and what may be 20 considered typical sexual activity for someone, 21 someone else may consider that's a bit 22 adventurous? 23 MR. EDWARDS: Object to the form. 24 THE WITNESS: Yes. 25 BY MR. CRITTON: 22 (Pages 351 to 354) lir sCm c. 305-866-7688 EFTA00310299 Page 355 1 Q. I'm not trying to make you a sex expert. 2 Also, I assume that when you've been in 3 CVS or Walgreens, for that matter Publix or Winn 4 Dixie I assume that you've -- I don't want to 5 assume anything. 6 Have you ever been in an aisle where 7 you've actually seen condoms being sold? 8 A. Yes. 9 Q. And where lubricants are being sold? 10 A. Yes. 11 Q. And as well as massage oils and other 12 types of oils actually are sold in those kinds of 13 stores? 14 A. Yes. 15 Q. And they're available so that someone 16 walking through Walgreens or Publix or CVS could 17 actually take it off the shelf, put it in their 18 cart, go up and pay for it and take it home? 19 A. Yes. 20 Q. All right. In the photographs that you 21 talked about, and if I understood you correctly, 22 at least during the time that you were there, Mr. 23 Rodriguez, in '04 and '05 there were -- you said 24 that there were -- I think you said downstairs -- 25 and I'm talking about really from the kitchen area 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 Page 357 you say her name? A. Yes, her Q. Okay. It's aughter, there was a picture where so looked like was pulling on their swimsuit? A. Yes. Q. Do you recall ever seeing the old Coppertone -- A. Yes. Q. Let me ask the question. I know you know what this is. Have you ever seen the old Coppertone commercials and billboards that used to be plastered all over certainly Florida and other places where there is a cute little girl who appears to be two, three, four years old and someone Is pulling down at least a portion of her swimsuit so she's exposing a small portion of her cheek is exposed? A. Yes. Q. Okay. Is that what the picture of the young girl looked like that is Mr. Epstein's God daughter? A. More or less, yes. Q. All right. And downstairs in the kitchen Page 356 1 up the back stairway, or what would be the kitchen 2 stairway to the upper floor, there was I think you 3 said, but correct me if I'm wrong, please, that 4 you don't recall seeing there being any pictures 5 or photographs of any nude women. Is that 6 correct? 7 A. They were not nude women in the 8 staircase. 9 Q. That's all I'm talking about right now. 10 In that area you never saw any pictures, or 11 photographs, paintings, any type of depiction of a 12 nude woman on that staircase going upstairs. 13 Correct? 14 A. Correct. 15 Q. All right. And I think you said 16 downstairs you saw a picture of -- the only 17 picture that you saw of I'd say of a younger MI 18 that displayed some form of -- I don't want to say 19 nudity because it's probably not that, but of some 20 portion of their body that was exposed, and I 21 think you described it as her cheek. 22 A. Yes, that's upstairs. 23 Q. That's upstairs? 24 A. Upstairs. 25 Q. And that was -- was RE is that how Page 358 1 were there any pictures of women in any stage of 2 undress? 3 A. No. 4 Q. And then I think you said as you walk 5 upstairs, or as you walked up the stairway from 6 the kitchen at the top of the landing, I think you 7 described -- did you describe it as the foyer? 8 A. Yes. 9 Q. Okay. But it's really the landing, the 10 upstairs landing? 11 A. Yes. 12 Q. I think you said there were -- there was 13 -- were or was a three by five picture or 14 pictures? 15 A. Yes. 16 Q. Of women in some stage of undress? 17 A. Yes. 18 Q. Okay. And when you say three by five, I 19 assume you meant three feet? 20 A. Three feet. 21 Q. By five feet? 22 A. Yes. 23 Q. Were they photographs? 24 A. Yes, they were photographs. 25 Q. And I think you also told us that you 23 (Pages 355 to 358) Kress Court Reporting, Inc. EFTA00310300 Page 359 1 didn't recognize who those people were. Is that 2 correct? 3 MR. EDWARDS: Object to the form. 4 THE WITNESS: I knew this pallgirl 5 because It was the daughter of Mrs 6 BY MR. CRITTON: 7 Q. Okay. And is that the picture you're 8 talking about? 9 A. This is the picture I'm talking about. 10 Q. Okay. And that was a three by five? 11 A. Yes. 12 Q. All right. And the only thing that you 13 could see was a portion, that is of her other than 14 say her waist or her shoulders or her arms or 15 something, that's one where you could see kind of 16 like the Coppertone commercial, a picture of her 17 cheek? 18 A. Yes. Part of her buttocks. 19 MR. LANGINO: Object to the form. 20 BY MR. CRITTON: 21 Q. Okay. And was there another picture at 22 the top of the foyer, large one, or is that the 23 only one that you can recall? 24 A. There were two of the same girl in 25 different poses. Page 361 1 A. Inside his closet, the walk-in closet. 2 Q. And those pictures, I think you called it 3 a mosaic? 4 A. Yes. 5 Q. And of the mosaic, approximately how many 6 pictures were in the mosaic? 7 A. 16 or 20. 8 Q. Okay. And of those pictures how many did 9 you recognize? 10 A. About three or four. 11 Q. All right. Were they -- as to who those 12 people were, you don't know, you just recognized 13 three or four of them? 14 A. Mr. Epstein when he was younger, and then 15 different girlfriends, but I didn't recognize 16 except the ones -- 17 Q. Okay. You said three or four of those 18 were pictures of the girls who came over to give a 19 massage? 20 A. Yes. 21 Q. Okay. But as to who those girls were you 22 don't know as you sit here today? 23 A. No, sir. 24 Q. And as to what their ages were you don't 25 know? Page 360 1 Q. But showed the same thing? 2 A. Yes. 3 Q. Okay. As you walked through into -- then 4 if I understood it correctly, you go to the pretty 5 much to the end of the hallway, then you go 6 through another small vestibule, double doors, two 7 sets of double doors, and as you go straight ahead 8 then you make a left around the bed and then you 9 end up in the bathroom. 10 A. Yes. 11 Q. In the bathroom -- in the bathroom or in 12 that location were there any pictures of any women 13 in any stage of undress? 14 A. Yes. 15 Q. All right. And were any of those 16 pictures, did they involve -- or were they of any 17 of the girls that have been described as women who 18 came over to give Mr. -- purportedly to give Mr. 19 Epstein a massage? 20 A. Yes. 21 Q. And do you remember who any of the names 22 of any of those people were? 23 A. No. 24 Q. And the pictures you saw, where were they 25 located? Page 362 1 A. No, sir. 2 Q. That's correct? 3 A. That's correct. 4 Q. And as to what they depicted in the 5 photographs of the girls were they in different 6 stages of undress? 7 A. Yes. 8 Q. Was everyone undressed to some degree, 9 that is, they were described as nude, or at least 10 the questions asked were these people nude? Were 11 they actually nude or someone may have had their 12 top off? 13 A. There were two girls completely naked in 14 a shower in a sexual act. 15 Q. is that the one when Ms. Ezell asked you 16 questions, that's one of the photographs that you 17 were talking about? 18 A. No, sir. 19 Q. That was a different -- 20 A. Different one. 21 Q. Okay. And the mosaic that you saw where 22 you saw two girls involved in a sexual act, do you 23 know where that photograph was taken? 24 A. I think it was taken in one of the rooms 25 In the house because there is an oval bathtub, but 24 (Pages 359 to 362) EFTA00310301 Page 363 1 I don't know which room, sir. 2 Q. Okay. Did you recognize both the girls 3 or just one of the girls? 4 A. The two girls. 5 Q. Then there were -- there was one or two 6 other photographs of girls that you recognized? 7 A. Yes. 8 Q. Okay. And were they fully unclothed or 9 did they have some degree of clothes on and/or 10 off? 11 A. They were naked. 12 Q. All right. And all of the remaining 13 pictures at least within that mosaic were of 14 Individuals that you did not know? 15 A. No, sir. 16 Q. And that you did not recognize as having 17 been at the house. Is that correct? 18 A. Yes, that's correct. 19 Q. You were also asked about some -- let me 20 switch for just a minute. 21 You were asked about a vibrator that you 22 saw, and I think you described it as a back 23 massager that was approximately 18 inches long 24 that had a couple of rotating heads on it. 25 A. Yes. Page 365 1 pilots, masseuses, chefs, so she have a copy of 2 the black book with herself and as well as the 3 computer. 4 Q. Did you ever go on Ms. Maxwell's computer 5 to see what she had in it? 6 A. Yes. 7 Q. And was that something you were allowed 8 to do? 9 A. No. 10 Q. Okay. 11 A. Yes. 12 Q. And was her computer on so that you 13 didn't need to access the password? 14 A. It was off. 15 Q. Okay. So you just turned it on? 16 A. Yes, sir. 17 Q. And then you were able to access her 18 computer? 19 A. Exactly. 20 Q. And what possessed you to go in and to 21 access her personal computer? 22 A. I needed to send some documents to the 23 New York office and it was the only computer 24 working in the house. 25 Q. Okay. And how many occasions did you use You actually went in her office? Page 364 1 Q. And I think you ultimately came up with 2 the idea as it was something you had seen at like 3 a Sharper Image store. 4 A. Yes, sir. 5 Q. Have you ever seen one of those types of 6 devices, that is a back massager with the rotating 7 heads also sold -- well, let me ask you this. 8 Strike that last question. 9 Have you ever been to Brookstone? 10 A. Yes. 11 Q. Okay. Have you ever seen a massager like 12 that at Brookstone? 13 A. Yes. 14 Q. Okay. You were asked whether Ms. Maxwell 15 kept the names of any of the girls who came to 16 give massages on -- let me ask it this way. 17 I think you were asked whether 18 Ms. Maxwell ever kept the names of any of the 19 girls who came to give massages and I think your 20 response was yes. 21 A. Yes. 22 Q. Okay. Did she keep them on a pad of 23 paper, did she keep them in a notebook, did she 24 keep them in a computer? 25 A. We used to have Internal books for Page 366 1 her computer? 2 A. Several times. 3 Q. Was she ever aware that you used her 4 computer? 5 MR. LANGINO: Form. 6 THE WITNESS: I don't think so. 7 BY MR. CRITTON: 8 Q. Did you ever ask Ms. Maxwell for 9 permission to use her computer? 10 A. I was the house manager, I believe I was 11 supposed to use everything in the house to 12 accomplish my duties, in that case sending 13 financial reports or e-mails. 14 Q. So would you have been -- did you ever 15 use Mr. Epstein's computer? 16 A. No. 17 Q. Okay. But you used Ms. Maxwell's 18 computer? 19 A. Yes. 20 Q. Did you ever use Ms. computer? 21 A. Yes. 22 Q. In looking at Ms. Maxwell still, you went 23 into Ms. Maxwell's computer with at least the idea 24 of sending some documents? 25 A. Yes. 25 (Pages 363 to 366) Kress Court Reporting, Inc. EFTA00310302 Page 367 1 Q. Up to New York? 2 A. Yes. 3 Q. Were you going to pdf them? 4 A. Yes. 5 Q. And did she have a fax machine -- not a 6 fax machine, a copy machine in her office as well? 7 A. Yes. 8 Q. Okay. So how would you generally do 9 that? Would you do that through a Microsoft 10 program? 11 A. Through Citrix. 12 Q. Through Citrix. An right. With Citrix, 13 and that is, if you said you saw some names of 14 individuals on her computer if you were just going 15 to pdf some documents up to New York why would you 16 of — what would of caused you to have seen any 17 names on her computer? 18 MS. EZELL: Objection to form. 19 THE WITNESS: All the calls that came to 20 358 El Bak), they came through the 21 telephone, they have a transcript somehow 22 that they connect to the computer, so you 23 can pull it and you register the time, who 24 called, who didn't call, and you can pull 25 this at your request. So I used to use that 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 Page 369 record with tape number three. BY MR. CRITTON: Q. Mr. Rodriguez, I was asking you about Ms. Maxwell's computer and you told me how you went on the computer. If she was out of town would she take her computer with her? A. No. Q. It was something she left there? A. Yes. Q. All right. And when you went on to pdf, I think you said it was really one time that you saw the names of some of these girls? A. Yes. Q. And if I understand it correctly, it was -- did it have the name and then a phone number? A. Yes. Q. And was that something that was automatically downloaded from the system? A. Yeah, from the phone system to the computer so we have a transcript. Q. When you say a transcript, the fact that hone number 561, whatever it was, A. It was a transcript of the phone calls of Page 368 1 to go back to some calls that they were 2 requesting, especially when the hurricane 3 season happened. 4 BY MR. CRITTON: 5 Q. Okay. So if I understand, even the 6 computer you used would have had that same 7 feature? 8 A. No, no, it was totally different. Mine 9 was slower and all the time was breaking down 10 that's why we have the guy from Ohio came and 11 fixed the computers. 12 Q. Okay. Were there other computers that 13 you used taiihat feature, that Is that -- 14 A. On rs. Maxwell, and the staff 15 house. 16 Q. Staff house being yours? 17 A. The guest house, yes, my office. 18 Q. So you could go out to your guest house 19 then and look for the same Information? 20 A. No. 21 Q. All right. I don't understand but why 22 don't we take a break because we're almost out of 23 tape. 24 (Thereupon, a recess was had.) 25 THE VIDEOGRAPHER: We're back on the Page 370 1 the house, we can get it from the computer. 2 Q. Okay. And I'm distinguishing, 3 transcript, it would tell you the name and phone 4 number, it wouldn't tell you what was said? 5 A. It was the message also. 6 Q. Okay. Now I understand. And so 7 Ms. Maxwell when you said she had the names of 8 some of these girls who may have given massages, 9 or at least were what you called earlier girls 10 that gave massages, or females that gave massages, 11 she would have had it because that was information 12 that was downloaded from the Citrix system Into 13 her computer? 14 A. Yes. 15 MS. EZELL: Objection, form. 16 BY MR. CRITTON: 17 Q. Okay, I understand. Now, you said she 18 also had some pictures. Is that that one time you 19 also saw pictures? 20 A. Yes. 21 Q. And were you going through her computer 22 at that time? 23 A. No. 24 Q. The question is, if all you were going to 25 do was try to pdf some financial Information to 26 (Pages 367 to 370) Kress Court Reporting, Inc. EFTA00310303 Page 371 1 New York what were you doing getting to names and 2 phone numbers and then pictures of girls? 3 A. I was trying to get some information. I 4 was working the computer and I just happen -- they 5 have the icon of the file and I open and it was 6 right there, so I was not looking but, you know, 7 it was already accessible to me. 8 Q. And how many photographs did you then 9 scroll through to look at? 10 A. Probably 30. 11 Q. Okay. And why? 12 A. Just curiosity, sir. 13 Q. So again, you never told anyone other 14 than your wife? 15 A. No. 16 Q. Correct? 17 A. Yes, correct. 18 Q. Of the pictures that you saw, if I 19 understood it correctly, some of those were 20 pictures of -- well, I think you said some of them 21 reflected parties or banquets? 22 A. Yes. 23 Q. I think you described some of the 24 pictures gatherings that appeared to be either in 25 Russia or Eastern Europe? Page 373 1 Q. Okay. Were any of the photographs that 2 were in -- again, I'm talking about Ms. Maxwell's 3 computer now, were those photographs of 4 individuals who were any of the girls or ladies 5 that came over to give massages? 6 A. No. They stay at the house. 7 Q. Okay. So the photographs that you saw on 8 Ms. Maxwell's computer of females in any state of 9 undress or at parties or at banquets, those were 10 all of Individuals who would fly in with Mr. 11 Epstein at various periods of time that had 12 traveled with him? 13 A. That's correct. 14 Q. Okay. Those are the girls that you told 15 us I think at your last deposition and reaffirmed 16 here today, those girls all appeared to be in 17 their 20's? 18 A. Yes, sir. 19 Q. All right. Now, you were also asked some 20 questions, a lot of questions about surveillance. 21 And if I understood your testimony, and this is 22 where It goes back to what do you know, what don't 23 you know, what were you speculating on, what did 24 you know at the time, what do you know now, at 25 least I need you to distinguish that for me so Page 372 1 A. Yes. 2 Q. All right. And then you talked about a 3 picture of two girls in the shower that you didn't 4 know the girls. Correct? 5 A. Yes. 6 Q. That's correct? 7 A. That's correct. 8 Q. All right. And that in all of the 9 photographs that you saw the individuals seemed to 10 be having a good time? 11 A. Yes. 12 Q. All right. Would It be a correct 13 statement that in none of the photographs did 14 anyone seem to be distressed or disturbed or show 15 any type of negative emotion, at least from what 16 you observed? 17 A. That's correct. 18 MS. EZELL: Objection, form. 19 BY MR. CRITTON: 20 Q. And in terms of the photographs that you 21 did see, were any of the photographs that you saw, 22 did they appear -- did they appear to have been of 23 women that you had seen fly in with Mr. Epstein on 24 his plane? 25 A. Yes. Page 374 1 that I know what you knew at the time, and as 2 distinct from what you may have read in the 3 newspaper or been told by some lawyer or someone 4 else that may not be accurate. Okay? 5 A. Yes, sir. 6 Q. With regard to the -- with regard to 7 surveillance equipment, if I understood your 8 testimony today is you were completely unaware of 9 the existence of any surveillance equipment In the 10 house during the 2004/2005 time period that you 11 worked there. Is that correct? 12 A. Yes. 13 Q. And therefore, where it was, what may 14 have existed, whether It in fact actually did 15 exist, whether anyone maintained it, you have no 16 personal knowledge whatsoever. Is that true? 17 A. That's true. 18 MR. VVILUTS: Object to the form. 19 BY MR. CRITTON: 20 Q. You talked about pictures of two women 21 who you saw in the house who were nude, one was 22 Nadia? 23 A. Yes. 24 Q. And you knew Nadia was someone who was in 25 her 20's? 27 (Pages 371 to 374 Kress Court Reporting, Inc. EFTA00310304 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 Page 375 A. Yes. Q. All right. And then you saw another picture of a Brazilian woman who had traveled or flown on the plane before? A. Yes. Q. All right. And she also appeared to be a woman to you not only in the photograph but from your having seen her who appeared to be in her 20's? A. Yes. Ex e me. Thank you. You talked about computer. Was she hooked into your main rm A. Not to my office in the staff house but she was hooked into the main house. Q. Okay. The same Citrix system? A. Yes. Q. And you said thehad pictures of women on her computer that you saw. Is that correct? A. Yes. Q. Okay. And were those the same types of pictures that Ms. Maxwell had, that Is, females, pictures of females who had traveled in with Mr. Epstein from his plane? 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 Page 377 names and addresses of -- let me start over. Strike that. erstood your testimony, you said thaisaid tha the names and i pict ttaz it again. ou phone numbers of sorH m it17e massage girls. A. Yes. Q. Or at least of the people that you thought may have been called to give massages. A. Yes. MS. EZELL: Form. MR. EDWARDS: Form. BY MR. CRITTON: Q. And was that in the same format that you saw on Ms. Maxwell's computer? A. No. Q. Okay. Wh -- have had to use A. She will ins uld you have been computer? some information from her desk or telephone numbers, so I will. Q. A. Yes. Q. I think you testified at your last deposition, or the start of your deposition that And that's where you would have seen it? Page 376 1 A. This were different pictures. 2 Q. Okay. Were any of hers of any of the 3 girls who came in on the plane, or the ladies or 4 women? 5 A. No. 6 Q. What were her pictures of? 7 A. They were young women rib you know. 8 I don't remember seeing nudity on 9 computer. 10 Q. All right. wh n I say hers, the 11 photographs that had on her computer 12 were all of individuals who appeared -- or not 13 appeared, but were dressed and appeared to be 14 modeling? 15 A. Yes. 16 Q. Would it be a correct statement that none 17 of the women that you saw, the pictures of 18 the women that you saw on computer were 19 any of the girls, women, whoever came to give 20 massages? Is that correct? 21 MR. EDWARDS: Object to the form. 22 MS. EZELL: Form. 23 THE WITNESS: That's correct. 24 BY MR. CRITTON: 25 Q. You said that you thought also had Page 378 1 the number of women that you remember came over to 2 give massages was something eight to ten, twelve, 3 I don't remember, what's your best recollection? 4 A. Can you repeat that, please? 5 Q. Of the women, of different women that you 6 knew came over to give massages during the time 7 that you worked for Mr. Epstein, '04 to '05, 8 during that time period, approximately how many 9 women were there? 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: To give massages? 12 BY MR. CRITTON: 13 Q. Yes, sir. 14 A. Fifteen, yeah. 15 Q. So something between one and lid 16 the names you would have seen on Ms. 17 computer along with a phone number? 18 MR. EDWARDS: Form. 19 THE WITNESS: Yes. 20 BY MR. CRITTON: 21 Q. Do you remember how many you would have 22 seen? 23 A. Fifteen. 24 Q. Okay. d us earlier today 25 that you saw from time to time taking 28 (Pages 375 to 378) EFTA00310305 Page 379 1 pictures in the dining room and the library. 2 A. Yes. 3 Q. Photographs. 4 A. Yes. 5 Q. Okay. Was she taking -- the pictures she 6 took were people who were clothed? 7 A. Yes. 8 Q. And were any of the pictures that she 9 took of any of the girls that you ever -- let me 10 strike that. 11. If I understood your original testimony 12 -- I don't want to say original. If I understood 13 your testimony from July 29th to what you told us 14 today as to the women who did come to give 15 massages they'd knock or somehow you would be 16 aware that they were at the back door, you would 17 punch the security code and lead them into the 18 kitchen. 19 A. Yes. 20 Q. Okay. When you brought them into the 21 kitchen you would say, hi, they would say hi back 22 to you, or something to that, short greeting, 23 you'd offer them water, there was never any 24 alcohol in the whole house other than I think you 25 said for one person at one time. Is that a fair Page 381 1 Q. Regular conversation? 2 A. Yes. 3 Q. And, therefore, you might interject 4 yourself back In because you've been asked to pay 5 someone or to let them out? 6 MR. LANGINO: Form. 7 THE WITNESS: Yes, I was called to pay 8 them. 9 BY MR. CRITTON: 10 Q. All right. And when you hear that 11 conversation that would be another way that you 12 would know that the women were leaving? 13 A. Yes. 14 Q. And sometimes they'd leave without you 15 even being involved, if I understood it correctly? 16 A. That's correct. 17 Q. So, the only places that you ever saw the 18 women who came to give massages would be -- of the 19 some fifteen women during the time you were there 20 would be either when you let them Into the house 21 and escorted them into the kitchen or as they were 22 leaving? 23 A. Yes. 24 Q. And I think you described one jpgtapce 25 earlier today is that you may have ham in the Page 380 1 statement? 2 A. Yes. 3 Q. All ri I the kitchen, you 4 understoo came down, and what 5 happened thereafter you don't have any personal 6 knowledge whatsoever? 7 A. That's correct. 8 MR. EDWARDS: Form. 9 BY MR. CRAYON: 10 Q. At some point in time Might 11 contact you and say pay such and such X amount of 12 dollars, she is now getting ready to leave. 13 A. Yes. 14 Q. That maybe one. Another set of 15 circumstances might be you use the word commotion, 16 you might hear a commotion, I assume you don't 17 mean -- well, let me ask you, when you say 18 commotion, do you mean a disturbance, something 19 that was seriously like raised voices or merely 20 you just heard some people talking? 21 A. Conversation of people leaving. 22 Q. Okay. Not a commotion In the form of a 23 disturbance but a commotion in the sense that you 24 heard people talking? 25 A. Yes. Page 382 1 car, in the Suburban? 2 A. Yes. 3 Q. And that's the only person that you can 4 remember having driven any place, that is, of the 5 women who were described as having given massages? 6 MR. EDWARDS: Objection. 7 MS. EZELL: Objection, form. 8 THE WITNESS: Sir, I have to darify 9 that. I drove a lot of girls, but I don't 10 remember the names associated with the 11 faces. But this particular girl A., or 12 others, C., whatever, I remember driving In 13 the Suburban, but I cannot say this was -- 14 BY MR. CRITTON: 15 Q. Let me clarify because what I want to be 16 dear Is, is I do remember you testifying that 17 when some of the 20 plus year old models or 18 females would fly In with Mr. Epstein they might 19 want to go shopping, they might want to go to the 20 store, they may want to go to the dnig store, they 21 may want to go to the beach, wherever they wanted 22 to go and you would drive them. 23 A. Yes. 24 Q. All righ I remember in 25 response to Mtsill Iceprilestions today she asked 29 (Pages 379 to 382) EFTA00310306 Page 383 1 you about having drNer■ and you recalled 2 having had her in the Suburban specifically. 3 A. Yes. 4 Q. Do you remember any of the other girls, 5 women vie to give massages ever having driven 6 them, or nne only one that you remember? 7 MR. EDWARDS: Form. 8 THE WITNESS: I only remembe= right 9 now for the fact that I was driving by the 10 airport and I showed her Mr. Epsteln's 11 plane. 12 BY MR. CRITTON: 13 Q. All right. Which really takes me back to 14 really where I started with this series of 15 questions. 16 You saw the girls, the women who came in 17 to give the massages, when they came in If you 18 were advised or if you heard conversation and you 19 saw them you would see them when they left? 20 A. Yes. 21 Q. And you saw ■. because she was in the 22 Suburban on at least one occasion? 23 A. Yes. 24 Q. And, therefore, you never saw these 25 girls, these women who gave the massages in the Page 385 1 Q. All right. Ms. Ezell asked you about Mr. 2 Dershowitz being present in Mr. Epstein's home, 3 and I think she asked -- and I think that you said 4 Mr. Epstein was a -- and he and Mr. Dershowitz 5 were friends? 6 A. Yes. 7 Q. She also I think asked was Mr. Dershowitz 8 ever there when one of the women who gave a 9 massage was present in the home? 10 A. I don't remember that. 11 Q. That's what I want to dear up. Is it 12 your testimony that Mr. Dershowitz was there when 13 any of the women came to Mr. Epstein's home to 14 give a massage? 15 A. Yes. 16 MR. EDWARDS: 17 BY MR. CRTTTON: 18 Q. As to whether any of those women were 19 ever accociated with Mr. Dershowitz would it be a 20 correct statement that you have absolutely no 21 knowledge? 22 A. I don't know, sir. 23 Q. You don't know? 24 A. I don't know, sir. 25 MS. EZELL: Form. Form. Page 384 1 dining room or the library. Would that be a fair 2 statement? 3 A. That's correct. 4 MR. EDWARDS: Form. 5 BY MR. CRITTON: 6 Q. All rig fore, the pictures 7 that you saw taking of girls, women, 8 either in the dining room or library, those were 9 other individuals other than those who may have 10 given or who came for massages. Is that correct? 11 MS. EZELL: Form. 12 MR. EDWARDS: Form. 13 THE WITNESS: It's confusing, sir, 14 because there were a bunch of girls. I 15 don't know which one they were but I saw her 16 taking pictures of the groups. 17 BY MR. CRITTON: 18 Q. As to whether they were people who came 19 In on the planes or there may have been a massage 20 girl or more than one woman who gave a massage, 21 you just don't know as you sit here, you'd just be 22 speculating. Is that cored? 23 MR. EDWARDS: Form. 24 THE WITNESS: I don't know. 25 BY MR. CRITTON: Page 386 1 BY MR. CRITTON: 2 Q. Okay. Were you in any way attempting in 3 your response to Ms. Ezell to Imply that Mr. 4 Dershowitz had a massage by one of these young 5 ladies? 6 A. I don't know, sir. 7 Q. You have no knowledge? 8 A. No, sir. 9 Q. And you certainly weren't Implying that 10 that occurred, you just have no knowledge. 11 Correct? 12 MR. EDWARDS: Form. 13 THE WITNESS: I don't know. 14 BY MR. CRITTON: 15 Q. Sorry? 16 A. I don't know. 17 Q. I think in response to one of Ms. Ezell's 18 questions you responded that — let me ask it this 19 way. 20 You never saw Mr. Epstein ever take 21 photographs of anyone. Would that be a correct 22 statement? 23 A. Yes. 24 Q. Would it be a correct statement you never 25 saw Mr. Epstein Initiate a phone call to anyone? 30 (Pages 383 to 386) Kress Court Reporting, Inc. EFTA00310307 Page 387 1 A. To place a phone call? 2 Q. Yeah. Did you ever see him place a phone 3 call? 4 A. Yes. 5 Q. If in fact, maybe it was this way, is 6 that you never saw him call someone to schedule a 7 massage appointment. Correct? 8 A. That's correct. 9 Q. I think you said that Ms. told you 10 that Mr. Epstein would take photograp s. Did I 11 understand you correctly? ist 12 A. I'm so ou repeat that? 13 Q. Did M ver tell you that Mr. 14 Epstein took a p o ograph of anyone? 15 A. No, she said to me Mr. Epstein is like 16 he's an amateur photographer. 17 Q. Okay. I may have misunderstood you then. 18 Let me clarify that testimony. 19 It's your testimony that Ms. EN told 20 you that Mr. Epstein Is an amateur photographer? 21 A. Yes. 22 Q. She never told you that -- or let me 23 strike that. 24 Is it correct that she never told you 25 that Mr. Epstein took photographs of any of the Page 389 1 Q. Of the time that you've done that 2 approximately how many years does that include in 3 your working life? 4 A. Eight years, ten years. 5 Q. All right. And have you worked for -- 6 have you been in other circumstances where you 7 have worked around -- well, let me step back. 8 With all of the Individuals that you 9 mentioned, estate manager, house manager, has this 10 been for individuals who have or at least appear 11 to have substantial wealth? 12 A. Yes. 13 Q. And as part of your duties, or not duties 14 but as part of being a house manager or general 15 manager for an estate do you interact with other 16 estate managers? 17 A. Yes. 18 Q. And do you assist each other from time to 19 time if someone needs help? 20 A. That's correct. 21 Q. And I assume that you've been in other 22 estates in Palm Beach and probably in Fort 23 Lauderdale and other locations? 24 A. Yes. 25 Q. As part of during your working career did Page 388 1 girls, women, who came over to give him a massage? 2 A. That's correct. 3 Q. All right. Mr. Rodriguez, other than Mr. 4 Epstein I think you told us you had worked for a 5 lady named Ms. Hammond? 6 A. Yes. 7 Q. And you had worked for a gentleman -- 8 A. Sidney Bowman. 9 Q. Is he the gentleman from Fisher Island? 10 A. No, Arturo Torres. 11 Q. All right. In addition to Ms. Hammond up 12 In Palm Beach you worked for other individuals as 13 well? 14 A. I did it part-time but I don't have her 15 name right now, sir. 16 Q. During your career as a -- let me strike 17 that. 18 Had you worked other than those places, 19 Mr. Arturo -- 20 A. Arturo Torres, yes. 21 Q. Arturo Torres, Ms. Hammond, the other 22 individual you can't remember, and Mr. Epstein, 23 have you worked for other individuals as an estate 24 manager or general house manager? 25 A. No, sir. Page 390 1 you ever work in restaurant or a personal services 2 type business where you would provide like 3 catering or something like that to other wealthy 4 individuals? 5 A. I did. 6 Q. Give us a little of your background if 7 you could then, Mr. Rodriguez. 8 A. I work in Long Island, Montauk Lake Club 9 and Marina, a very exclusive country club where 10 Mr. Nixon used to spend his summers, Richard 11 Nixon. I worked for Leona Helmsley in New York. 12 Very demanding lady. And then Mr. Torres in Texas 13 in his ranch and as well as Fisher Island. And I 14 was a general manager of one of his restaurants in 15 San Antonio, Texas. This is the most high profile 16 people that I worked for. 17 Q. Okay. When you worked for Ms. Helmsley, 18 Leona Helmsley, she used to have the Helmsley 19 Palace and she with her husband, Harry Helmsley, I 20 think they owned a number of real estate in 21 addition to hotel properties. 22 A. That's correct. 23 Q. When you would -- I think you described 24 her as a demanding person? 25 A. Yes. 31 (Pages 387 to 390) EFTA00310308 Page 391 1 Q. All right. In terms of these wealthy 2 people that you've worked for, these individuals, 3 do they all have, that is at least in terms of Mr. 4 Epstein, the way that his household was managed, 5 was it similar to other set of circumstances that 6 you've been involved with? 7 MR. HOROWITZ: Object to form. 8 THE WITNESS: They have a common ground, 9 yes. 10 BY MR. CRITTON: 11 Q. All right. And In terms of you talked 12 about Mr. Epstein that there was some sort of a 13 manual or a procedure book with regard to his 14 house. 15 A. House manual, yes. 16 Q. A house manual. Did other houses have 17 house manuals as well? Is that reasonably -- 1 18 mean not common but it's something that you've 19 seen before? 20 MR. EDWARDS: Form. 21 THE WITNESS: I know a lot of houses do 22 but that was the only estate that we have a 23 house manual. 24 BY MR. CRITTON: 25 Q. And other individuals like where you've Page 393 1 about what they do? 2 MR. HOROWITZ: Object to the form. 3 THE WITNESS: Yes. 4 BY MR. CRITTON: 5 Q. And have you worked at other locations, 6 that is, in the other houses that you've worked 7 where they have massage tables? 8 A. Yes. 9 Q. And in those other locations where they 10 had a massage table, were they similar to the 11 massage table that was in Mr. Epstein's home? 12 A. Yes, sir. 13 Q. All right. Almost same make and model? 14 A. Same type, yes. 15 Q. And did other individuals in houses that 16 you worked at and other places where you helped 17 out other estate managers, would those individuals 18 have massages from time to time? 19 A. Yes. 20 Q. So having a massage or a massage table in 21 someone's house that you might -- that lives in 22 Palm Beach or Montauk or New York or something, 23 would you consider that unusual? 24 MR. HOROWITZ: Form. 25 THE WITNESS: No. Page 392 1 worked similar to Mr. Epstein -- now, Mr. Epstein 2 was single? 3 A. Yes. 4 Q. All right. And him having a lot of -- or 5 bringing a lot of attractive women and other 6 people to his house, I assume that didn't offend 7 you in any way? 8 MR. EDWARDS: Object to the form. 9 THE WITNESS: No, sir. 10 BY MR. CRITTON: 11 Q. At least based upon your experience in 12 dealing with other individuals either of some 13 notoriety like Ms. Helmsley or when you said the 14 club that you worked up is in Montauk -- 15 A. Montauk Lake Club and Marina. 16 Q. Right. You ran into separate and apart 17 from Richard Nixon were there a lot of people, 18 corporate people, business people? 19 A. Yes. 20 Q. People of substantial resources and 21 wealth? 22 A. Yes. 23 Q. Have you found at least in your 24 experience that most of those people are pretty 25 discreet about -- when I say discreet, private Page 394 1 BY MR. CRITTON: 2 Q. I think you told me at least in Mr. 3 Epstein's home other than for one guest he didn't 4 have any type of alcohol In the house. Is that S correct? 6 A. That's correct. 7 Q. Was that basically you understood that 8 that was one of the policies and procedure, no 9 alcohol in the house? 10 A. Yes. 11 Q. And did you ever see any type of illegal 12 or inappropriate drugs? 13 A. No, sir. 14 Q. And was that another policy or procedure, 15 absolutely no drugs of any kind? 16 A. No smoking in the house. 17 Q. All right. So no drugs, no smoking, no 18 alcohol? 19 A. Yes. 20 Q. Was that pretty typical for other Palm 21 Beach places that you were familiar with? 22 A. No. 23 Q. All right. And other places you'd always 24 find alcohol? 25 A. Yes. 32 (Pages 391 to 394) Re ortin Inc. EFTA00310309 Page 395 1 Q. All right. And you might find drugs? 2 A. Yes. 3 Q. And some pretty wild parties? 4 A. Yes. 5 Q. Now, with regard to the women who came to 6 give massages, of those women, of those 7 approximately fifteen that you described, how many 8 of them came more than one -- more than one 9 occasion? 10 MR. HOROWITZ: Form. 11 THE WITNESS: I'd say more than half. 12 BY MR. CRITTON: 13 Q. So maybe seven, eight, nine, ten? 14 A. Yes. 15 Q. Of those people that came on -- of those 16 seven to ten that came on more than one occasion, 17 did those individuals come on many occasions? 18 A. Yes. 19 Q. And as to the women who were — who you 20 understood were coming to give the massages -- 21 MR. EDWARDS: Form. 22 MR. CRITTON: I'm not done yet 23 THE V1DEOGRAPHER: I need to go off the 24 record for a second. 25 (Thereupon, an interruption was had.) Page 397 1 MR. EDWARDS: Object to the form. 2 BY MR. CRITTON: 3 Q. And I don't know whether he asked, do you 4 remember a person named= 5 A. Yes. 6 Q. And would she call from time to time 7 aski she could come to give a massage just 8 like GIN? 9 MR. EDWARDS: Object to the form. 10 THE WITNESS: Yes. 11 BY MR. CRITTON: 12 Q. So at least those two individuals, they 13 were overtly, that is, they were asking whether 14 they could come to give Mr. Epstein a massage. 15 Correct? 16 A. Th-tyial call aggitjapy will say I need 17 to talk to and MINfifteen minutes later 18 will tell, Alfredo, we're going to have a massage 19 with so and so. 20 Q. So either oall would call to ask 21 if they could come and then a massage would be set 22 then they would show up? 23 A. That's correct, sir. 24 Q. Okay. And from time to time they would 25 bring other people as well? Page 396 1 THE VIDEOGRAPHER: We're back on the 2 record. 3 BY MR. CRITTON: 4 Q. Mr. Rodriguez, I want to turn to the -- 5 stay with the women who came to give or at least 6 were called to give the massages. 7 You were shown a number of message pads, 8 I think Mr. Mermelstein who represents a number of 9 -- or at least certainly Jane Doe 2 and some 10 others, you were identified or shown a bunch of 11 message pads that had I think in most instances 12 your Initials, Do you recall that? 13 A. Yes, o. 14 Q. I think one of the indiv• that you 15 identified that called often wa 16 A. Yes. 17 Q. Which is one of Mr. Edwards' clients. 18 This lady called on a regular basis, or 19 at least from looking at your pad she would call 20 on a pretty regular basis. Is that true? 21 A. Yes. 22 Q. And she and others who are reflected on 23 those message pads, they were calling to come to 24 give massages. Correct? 25 A. Yes. Page 398 1 A. That 2 Q. Both 3 A. Yes. 4 Q. Of the females that -- the women that 5 came to the house, did you ever see anyone force 6 any of these women onto the property? 7 A. No, sir. 8 Q. Did you ever see anyone force them into 9 the house? 10 A. No. 11 Q. Did you ever see anyone force them into 12 the kitchen? 13 A. No, sir. 14 Q. Did you ever use any force, any type of 15 intimidation or coercion to bring them into the 16 house and get them into the kitchen? 17 A. No, sir. 18 Q. Did you ever observe Ms. using any 19 force or intimidation or coercion -- 20 A. No, I did not. 21 Q. -- with any of these individuals? 22 A. I did not. 23 MR. EDWARDS: Object to the form. 24 BY MR. EDWARDS: 25 Q. Did Ms. M. -- let me use the initials 33 (Pages 395 to 398) Kress Court Reporting, Inc EFTA00310310 1 that way it will show up correctly. 2 Did Meyer use from what you saw, di:: 399 3 she ever use any force or coercion or intimidation 4 with any of the women that she brought to the 5 house? 6 MR. HOROWITZ: Form. 7 MR. EDWARDS: Object to the form. 8 THE WITNESS: No, sir. 9 BY MR. CRITTON: 10 Q. Okay. I'm just talking about what you 11 observed during the time. And you know what I 12 mean by force? 13 A. Yes. 14 Q. You know what I mean by intimidation? 15 A. Yes. 16 Q. Could to be verbal intimidation or 17 coercion, either verbally or using some form of 18 her body, or their bodies. 19 A. Yeah, I understand that 20 MR. EDWARDS: Form. 21 MR. HOROWITZ: Form. 22 MS. EZELL: Objection, form. 23 BY MR. CRITLQW: 24 Q. When brought individuals to the 25 house, did you ever see her use any force or Page 401 1 Q. Did any of them ever appear to be 2 frightened? 3 MR. HOROWITZ: Form. 4 THE WITNESS: No. 5 BY MR. CRITTON: 6 Q. Did any of the women appear to be 7 fearful? 8 A. No. 9 Q. Did any of them appear to be 10 uncomfortable in coming into the house? 11. MR. EDWARDS: Form. 12 THE WITNESS: No. 13 BY MR. CRITTON: 14 Q. At any time did any of them express to 15 you verbally that they were in fear when they came 16 into the house? 17 A. No, sir. 18 Q. Did any one of the fifteen girls that 19 came to the back door, then into the kitchen, and 20 prior to your leaving them in the kitchen say, Mr. 21 Rodriguez, or Alfredo, or sir, could you get me 22 out of here? 23 A. No, sir. 24 Q. Did any of them tell you verbally that 25 they were uncomfortable? Page 400 1 intimidation or coercion from what you could 2 observe with those women who had come to give a 3 massage? 4 A. No. 5 MR. EDWARDS: Form. 6 MR. HOROWITZ: Form. 7 MS. EZELL: Form. 8 BY MR. CRITTON: 9 Q. With any of the fifteen women that you 10 observed who came to the home to give massages 11 during the time period '04 through I think you 12 said February of '05, the time period I think was 13 it August, Mr. Rodriguez -- 14 A. August. 15 Q. -- August of '04 through February of '05? 16 A. March of '05. 17 Q. Through the beginning of March '05? 18 A. Yes. 19 Q. Okay. mars the time period I'm 20 focussing on. 21 Of the approximately fifteen women that 22 you came to see to give massages that you let in 23 the back door after punching the security code, 24 did any of them ever appear to be scared? 25 A. No. Page 402 1 A. No. 2 Q. Did anyone say help me or I'm scared? 3 A. No. 4 Q. Did all of them appear to be at least 5 when they came to the back door in a reasonably 6 good mood? 7 A. Yes. 8 Q. They all appeared to be happy? 9 A. Yes. 10 Q. Smile, I'd say interact with you verbally 11 in your greetings? 12 A. That's correct. 13 Q. Did any one of the fifteen girls that you 14 observed during the August '04 through March 2005 15 time period from your personal observation appear 16 to be there -- appear to be at the Epstein home 17 not voluntarily? 18 MR. EDWARDS: Object to the form. 19 MR. HOROWITZ: Object to the form. 20 THE WITNESS: No. 21 BY MR. CRITTON: 22 Q. Did any one of the fifteen women who came 23 to give the massage ever tell you that they had 24 been forced to come to the house or coerced into 25 coming to the house? 34 (Pages 399 to 402) EFTA00310311 Page 403 1 A. No. 2 MR. EDWARDS: Form. 3 BY MR. CRITTON: 4 Q. For those women -- I think I need -- let 5 me strike that. 6 On some occasions you'd see the women 7 come down from upstairs because you would either 8 let them out of the house or you might give them 9 an envelope that had money in it. Is that 10 correct? 11 A. Yes. 12 Q. Did any of those -- Mr. Edwards asked you 13 some questions -- I think it was Mr. Edwards, 14 whether they had sat down and had anything to eat, 15 whether they had cereal or anything like that. 16 A. Yes. 17 Q. Did you ever observe any of those women 18 before they went upstairs eating anything at the 19 house? 20 A. Sometimes. 21 Q. And I think he used -- he meaning Mr. 22 Edwards, used cereal and ice cream. 23 A. Yes. 24 Q. And he said, if I recall from the last 25 deposition, kids like ice cream. Page 405 1 them stop and have anything to eat or did you 2 always see them at the end, that is they're ready 3 to go? 4 A. I didn't know, they came from downstairs, 5 they went to the kitchen, but I didn't know they 6 were there because I was in the guest house. 7 Q. Okay, that's my question. You only 8 e)c/ them either if you heard conversation or 9 ad called you and said would you pay such 10 and such? 11 A. Yes. 12 Q. At which time you would give them the 13 envelope with money? 14 A. Yes. 15 Q. In that set of circumstances they were on 16 their way basically to leave? 17 A. Yes. 18 Q. When you saw them leave did any of them 19 at any time, any of the ones that you saw during 20 August of '04 through March of '05 appear to you 21 to be scared? 22 A. No, sir. 23 Q. Did any girls, women ever appear to have 24 been injured in any way? 25 MR. EDWARDS: Form. Page 404 1 A. Yes. 2 Q. Do you remember him asking you that? 3 A. Yes. 4 Q. Are you familiar that teenagers like ice 5 cream? 6 A. Yes. 7 Q. Are you familiar that people who are 20 8 and 30 years old like ice cream? 9 A. Yes. 10 Q. Are you familiar that older people, even 11 our age, Mr. Rodriguez, like ice cream too? 12 A. Yes. 13 Q. Okay. And when the Individuals would sit 14 there, and that is these women who would come over 15 to give a massage and they would — you would 16 observe them eating, did they appear to be 17 comfortable? 18 A. Yes. 19 MR. HOROWITZ: Form. 20 BY MR. CRITTON: 21 Q. Did they appear to be Interacting with 22 either you or the chef? 23 A. Yes. 24 Q. When any of those women would come over 25 to give massage came downstairs, did you ever see Page 406 1 THE WITNESS: No, sir. 2 BY MR. CRITTON: 3 Q. Did anyone appear to be In shock? 4 A. No, sir. 5 Q. Was anyone ever crying? 6 A. No, sir. 7 Q. Was anyone disheveled or appeared to be 8 unhappy? 9 A. No, sir. 10 Q. Did all of them appear, that is the ones 11 that you saw leave the house that you had an 12 opportunity to observe during that time period, 13 did they appear to be approximately the same 14 personality, same demeanor that they had had when 15 they came into the house? 16 MR. HOROWITZ: Form. 17 THE WITNESS: Yes. 18 BY MR. CRITTON: 19 Q. Cold anyone ever tell you when they came 20 down the stairs that they had been injured? 21 A. No. 22 Q. I'm talking about the young lady, the 23 women who had given the massages that you saw 24 actually leave the house, that is you had some 25 interaction with, either some Interaction as they 35 (Pages 403 to 406 EFTA00310312 Page 407 1 were leaving the house, did anyone ever tell you 2 that they had been injured? 3 A. No, sir. 4 Q. Did they ever tell you that they had been 5 forced to do something against their will? 6 A. No. 7 Q. Did they ever tell you that they had been 8 forced to do something Inappropriate? 9 A. No. 10 Q. Did they ever tell you that they had been 11 assaulted in any way? 12 A. No. 13 Q. Did they ever tell you that they had been 14 inappropriately touched? 15 A. No. 16 MR. HOROWITZ: Form. This is a 17 cumulative. He's already told you the 18 limited contact he had. This is totally 19 inappropriate line of questions. 20 MR. CRITTON: Is that a form objection? 21 MR. HOROWITZ: You're exceeding the scope 22 of the direct because nobody asked him -- 23 MR. CRITTON: Form, you get form In 24 federal court, that's what you get. Give me 25 your form. Page 409 1 MR. EDWARDS: Form. 2 THE WITNESS: No. 3 BY MR. CRITTON: 4 Q. Did you ever hear anyone yell rape or 5 assault or battery? 6 MR. HOROWITZ: Form. 7 THE WITNESS: No. BY MR. CRITTON: 9 Q. Did you ever hear anyone yell out in 10 anger? 11 A. No. 12 Q. You've gone online, Mr. Rodriguez, and 13 looked at various articles or postings that have 14 been made regarding these cases. Is that a fair 15 statement? 16 A. I'm sorry? 17 Q. If I understood your testimony from July 18 29th and a little bit today, is that you've gone 19 online and read some articles and/or what the 20 poke report may have said, that is, you've read 21 information that you've -- about these lawsuits 22 after the time that you left Mr. Epstein's 23 employment. 24 A. Yes. 25 Q. Correct? I 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 Page 408 MR. HOROWITZ: Form, cumulative. MR. CRITTON: Great. Why don't you let me finish the question and then you can object to it. Could you give me back what my last question was, please? (Thereupon, a portion of the record was read by the reporter.) THE WITNESS: No. BY MR. CRITTON: Q. Did they ever tell you that they had been sexually assaulted in any way? MR. EDWARDS: Form. MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. I'm sorry? A. No. Q. At any time did you hear anyone -- strike that. As to the women who came to give a massage, did you ever hear anyone scream? A. No, sir. Q. Did you ever hear anyone cry out what sounded like to you help? Page 410 1 A. Yes. 2 Q. And, therefore, you have at least seen 3 certain allegations and what people say occurred, 4 or at least their recitation of what may have 5 occurred at Mr. Epstein's home. 6 A. Yes. 7 Q. You have no personal knowledge one way or 8 the other. 9 MR. HOROWITZ: Object to the form. 10 MR. EDWARDS: Form. 11 BY MR. CRITTON: 12 Q. Correct? 13 A. That's correct. 14 Q. Are you also aware that the individuals 15 who have filed lawsuits want In some Instance 16 millions of dollars? 17 A. Yes. 18 Q. Okay. Are you aware that some of them 19 are now claiming that they were sexually 20 assaulted? 21 A. Yes. 22 Q. And battered? 23 A. Yes. 24 Q. And you have no information, no personal 25 knowledge in that regard. Is that true? 36 (Pages 407 to 410) Kress Court Reporting, Inc. EFTA00310313 Page 411 A. Yes. 2 MR. EDWARDS: Form. 3 MR. HOROWITZ: Form. 4 BY MR. CRITTON: 5 Q. All right. Were you aware of the 6 backgrounds of any of these women who came over to 7 give massages? 8 MR. HOROWITZ: Form. 9 THE WITNESS: No, sir. 10 BY MR. CRITTON: 11 Q. Well, have you -- did any one of the 12 females who ever came to give massages, did they 13 ever tell you that they were prostitutes? 14 A. No, sir. 15 Q. Did they ever tell you that they had been 16 lead into a life of prostitution? 17 MR. HOROWITZ: Form. 18 THE WITNESS: No. 19 BY MR. CRITTON: 20 Q. Did they ever tell you about their family 21 life, whether it involved prostitution, abuse, 22 prior posttraumatic stress syndrome, drugs, 23 alcohol, abuse by individuals, physical abuse as 24 well as verbal abuse? 25 A. No, they didn't tell me. Page 413 1 the property In your car? 2 A. I was pulling over from Publix so I 3 turned around and I went to the police and say -- 4 Q. Okay. You were coming back to the home 5 when you saw that car there? 6 A. Exactly. 7 Q. And they sent -- they, the police, sent a 8 police car with you to come there? 9 A. Yes. 10 Q. Did you and the police officer walk up to 11 the car? 12 A. The police went first. 13 Q. All right. And if I understand that, 14 that was In January of '05? 15 A. Yes. 16 Q. And when you did that then did you follow 17 behind the police officer to see who was In the 18 car? 19 A. Yes. 20 Q. And then you recognized that MI.? 21 A. Yes. 22 Q. And • said she had come back or was 23 there to get some money? 24 A. Yes. 25 Q. And did you in fact give her money? Page 412 1 Q. And, obviously, you have no personal 2 knowledge one way or the other -- 3 A. No, sir. 4 Q. -- with regard to what their backgrounds 5 were before they ever met or came in contact with 6 Mr. Epstein? 7 A. No, sir. 8 Q. Did any person, female, who came to give 9 a massage at the Epstein home, did anyone ever 10 come downstairs and say, Mr. Rodriguez, or sir, 11 call the police? 12 MR. EDWARDS: Form. 13 MR. HOROWITZ: Form. 14 THE WITNESS: No, sir. 15 BY MR. CRITTON: 16 Q. I think you said on one occasion you saw 17 someone parked in a vehicle inside the gate that 18 you didn't recognize. 19 A. Exactly. 20 Q. You called the police? 21 A. Yes, I did. 22 Q. Did you go to the police or you called 23 the police and they came? 24 A. I went to the police department. 25 Q. So how did you -- did you actually leave Page 414 1. A. Yes, I did. 2 Q. And I think you said you told the police 3 officer you recognized her? 4 A. Yes. 5 Q. Did you have to get permission to pay her I to 6 or dld you Just pay 7 7 A. No, beaus Id me already but I 8 forgot she was going to e that late, so that was 9 my concern in calling the police. 10 Q. Okay. And that person who came, do you 11 have any idea what her age was at that time? 12 A. That night? 13 Q. Right, January of '08. 14 A. No, no. 15 Q. I'm sorry, January of '05. 16 A. No. 17 Q. You nuke some conversations that you 18 had had with who was I think she was one 19 of the house -- the main housekeeper. 20 A. Yes 21 Q. Anc told you a number of thoughts 22 that she h . s that correct? 23 A. Yes. 24 Q. And as tclIM what she told you about 25 -- let me strike that. 37 (Pages 411 to 414 EFTA00310314 Page 415 1 I think you told us, you were asked 2 questions about sex toys, I think you certainly 3 described the back massagers. Correct? 4 A. Yes. 5 Q. I think you said the only sex toys that 6 you ever saw were in the armoire at the end of Mr. 7 Epstein's bed. 8 A. Yes. 9 Q. Okay. And whatever other sex toys that 10 to • was a reference, that's something 11 tha told you. Is that correct? 12 A. That's correct. 13 Q. You were asked at the last deposition, I 14 don't remember who asked the question, but whether 15 you had ever seen pornography on any computer. I 16 think one of your responses was you saw some 17 photos of a naked woman who appeared to you to be 18 a model. 19 A. Yes. 20 Q. Okay. Do you consider every photograph, 21 picture, painting of a naked nude woman to be 22 pornography? 23 MR. HOROWITZ: Form. 24 MS. EZELL: Objection, form. 25 THE WITNESS: I consider -- well, if Page 417 1 A. To bring the pictures from my computer? 2 Q. Let me rephrase the question. I thought 3 what you said last time was that as to the 4 pictures that you did see of naked women -- of a 5 naked woman or naked women on the computer, that 6 you've looked at those photographs through your 7 computer. 8 A. No. 9 Q. Okay. Then I may have misunderstood you. 10 Was your reference to Ms. Maxwell's computer that 11 you made at the last deposition? 12 A. Yes. 13 Q. Okay. Your computer that you had either 14 in the staff house or that you -- 15 A. Didn't access. 16 Q. You couldn't access those files? 17 A. That's correct. 18 Q. All right, now I'm with you. So the 19 photographs you've talked of the nude individuals, 20 or the naked women, were the photographs that 21 we've already talked about with both, i.e., in 22 Ms. Maxwell's computer? 23 A. Yes. 24 Q. Thank you for clearing that up. 25 I'm going to ask you to assume that Page 416 1 a frontal picture it's pornography, I will 2 look at my way. 3 BY MR. CRITTON: 4 Q. In your view? 5 A. Yes. 6 Q. So if you looked at -- I don't remember 7 whether Playboy still has -- say a Playboy that 8 has a frontal nudity shot of a woman, you would in 9 essence say that Playboy Is selling pornography? 10 A. Yes. 11 Q. Therefore, every person who buys a 12 Playboy that has over the last umpteen tens of 13 years that has a frontal picture of a woman In the 14 nude would be purchasing pornography whether it's 15 from CVS, or Walgreens, or Eckerd as they existed, 16 or any grocery store that sells them? 17 A. Yes. 18 MS. EZELL: Objection, form. 19 MR. EDWARDS: Form. 20 MR. HOROWITZ: Form. 21 BY MR. CRITTON: 22 Q. The photographs -- I'm sorry, the 23 pictures that you saw in the computer, I think you 24 were able to draw those up or bring those up from 25 your own computer. Page 418 1 who you've described as having come to Mr. 2 Epstein's house on three or four times a week for 3 a period of time, one of her claims In this case 4 is that she has been emotionally traumatized by 5 her contact with Mr. Epstein. Just assume that to 6 be true for purposes of this question. 7 Did you ever observe any what you would 8 have seen as enitisal trauma or any type of 9 disturbance wit= on the many times she came 10 to your house? 11 MR. EDWARDS: Form. 12 THE WITNESS: I didn't see any. 13 BY MR. CRITTON: 14 Q. Does it make sense to you that a person 15 who daims emotional trauma would continue to come 16 back to the house, does that make sense to you, 17 sir? 18 MR. EDWARDS: Form. 19 MR. HOROWITZ: Form. 20 MR. WILLITS: Object to the form of the 21 question. 22 THE WITNESS: I'm not a psychologist. 23 MR. EDWARDS: Can you state your answer, 24 I didn't hear it? 25 THE WITNESS: Yeah, I'm not a 38 (Pages 415 to 418) Kress Court Re•orti • Inc. EFTA00310315 Page 419 1 psychologist, I don't know. 2 MR. CRITTON: I have no further 3 questions. 4 REDIRECT EXAMINATION 5 BY MR. EDWARDS: 6 Q. Mr. Rodriguez, I don't know if we covered 7 this last time, I think that we did not, but can 8 you tell us during the period of time when you 9 worked at that house at El Brillo, Mr. Epstein's, 10 what cars did he own or were in the driveway? 11 A. We have two Suburbans, two Mercedes 600, 12 and a Cobra, and a motorcycle. 13 Q. And which, if any, did he drive? 14 A. He preferred the Mercedes or any of the 15 Suburbans. 16 Q. All right. Do you know where he owns 17 homes? 18 A. Yes. 19 Q. Where? 20 MR. CRITTON: Form. 21 THE WITNESS: Paris, New York City, El 22 Grillo, Saint James Island -- I'm sorry, an 2.3 Island in the Caribbean, and a ranch in New 24 Mexico. 25 BY MR. EDWARDS: Page 421 1 Q. What's the address? 2 A. 22 Foch Avenue, Paris. F-O-C-H. 3 Q. Okay. Do you know a telephone number for 4 Balsone? 5 A. No, I don't remember, sir. 6 Q. All right. How did it come up that you 7 talked to him about whether or not Mr. Epstein had 8 massages at that house? 9 A. He came on two occasions and stay with me 10 for a week because Mr. Epstein wanted me to get 11 into his style of running the house, and he was 12 good enough to give me some inside information, 13 what he likes and doesn't like, so he told me the 14 same thing was in Paris. 15 Q. And I think that you described Mr. 16 Epstein usually had about two massages a day, or 17 at least we were calling them massages. 18 A. Yes, sir. 19 MR. CRITTON: Form. 20 BY MR. EDWARDS: 21 Q. And did Mr. Balsone describe it in a 22 similar fashion -- 23 A. Yes. 24 Q. -- in Paris? 25 And did he also tell you that the girls Page 420 1 Q. Have you been to any of the other 2 properties? 3 A. No. 4 Q. Do you know the house managers at any of 5 the other properties? 6 A. Yes. 7 Q. And who are they? 8 A. Balsone in Paris, good friend of mine 9 from Brazil. And the people in New York give me 10 the briefing when I came aboard. There is a 11 couple from the Philippines. And I talked to the 12 couple that used to own the Island -- I mean who 13 used to manage the Island, a couple from South 14 African. Balsone was closer to me. 15 Q. Have you talked to Balsone about whether 16 or not Mr. Epstein has massages when he is at that 17 place? 18 A. Yes, I did. 19 Q. And what did he say about that? 20 A. That he had a bt of massages over there 21 too. 22 MR. CRITTON: Mr. Balsone was which one? 23 THE WITNESS: Basbne was the house 24 manager of Paris, 22 Foch Avenue. 25 BY MR. EDWARDS: Page 422 1 were very young in age that he was receiving these 2 massages from? 3 MR. CRITTON: Form. 4 THE WITNESS: Yes. 5 BY MR. EDWARDS: 6 Q. Did he indicate whether or not -- or how 7 old these girls were? 8 A. No, he didn't told me. 9 Q. Just that the age group was similar to 10 the age group that he was interested in in Palm 11 Beach? 12 MR. EDWARDS: Form. 13 THE WITNESS: Yes. 14 BY MR. EDWARDS: 15 Q. And did you talk to any of the house 16 managers in New York? 17 A. No. 18 Q. Who was the house manager in New York at 19 the time when you were the house manager at El 20 Brillo? 21 A. His nickname was Jo-Jo, but I don't 22 remember. Jo-Jo and his wife, but I don't 23 remember his name, sir. 24 Q. Do you know whether Mr. Epstein would 25 have massages when he was in New York at his New 39 (Pages 419 to 422) Kress Court Re ortin Inc. EFTA00310316 Page 423 1 York house? 2 A. He will have massages. 3 MR. CRMON: Form. 4 BY MR. EDWARDS: 5 Q. And are we still talking about a habit of 6 two a day? 7 MR. CRITTON: Form. 8 THE WITNESS: I don't know that. 9 BY MR. EDWARDS: 10 Q. Okay. So for the time period when you 11 have been familiar with Mr. Epstein and known his 12 habits, is it fair to say that he would have 13 roughly two girls a day in that same age group 14 wherever he was? 15 A. Yes. 16 MR. CRITTON: Form. 17 BY MR. EDWARDS: 18 Q. All right. And have you talked to 19 anybody that has given you similar information 20 from his Island home? 21 A. No. 22 Q. Do you know any of the girls that have 23 been over to his Island? 24 A. Yes. 25 Q. And who are they? Page 425 1 Q. And is your understanding that Mr. 2 Epstein was intimate with any of those girls? 3 MR. CRI1TON: Form. 4 THE WITNESS: Yes. 5 BY MR. EDWARDS: 6 Q. With all of them? 7 MR. CRITTON: Form. 8 THE WITNESS: Yes. 9 BY MR. ED I. 10 Q. Wit as well? 11 A. Yes. 12 MR. CRITTON: 13 BY MR. EDW 14 Q. With 15 A. Yes. 16 MR. CRITTON: 17 BY MR. EDWARDS: 18 Q. And the girls who would come over on the 19 airplane? 20 MR. CRITTON: Form. 21 THE WITNESS: Yes. 22 BY MR. EDWARDS: 23 Q. Did you ever have occasion to go into the 24 bedroom and find the vibrators or back massagers 25 out after Mr. Epstein was in the room with any of Form. Form. Page 424 1 A. Nadia, the girls who used to stay at the 2 home in El Brilb used to go over there to the 3 Island. 4 Q. When he would have these girls -- I guess 5 we've kind of categorized them as the girls who 6 would come over with him on an airplane and stay 7 at the house. 8 A. Yes. 9 Q. When they would be staying at the house 10 would he also have the local Palm Beach girls 11 coming over that you were told to call masseuses? 12 A. Yes. 13 Q. So these girls that came on the airplane 14 with him, were they also -- did they also have 15 knowledge that these young girls were coming over 16 to give massages? 17 MR. CRITTON: Form. 18 THE WITNESS: Yes, sir. 19 BY MR. EDWARDS: 20 Q. Okay. W girls from the 21 airplaniiiiir that you remember? 22 A. There many, sir, I don't 23 recall right now. But s for sure,M 24 was one of the main gir s, but I &FE 25 remember that. Page 426 1 the girls that came over on the plane? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes. 4 BY MR. EDWARDS: 5 Q. So that's something that would be out 6 after the girls that came over on the plane or the 7 girls that came over for the massages? 8 A. Yes. 9 MR. CRITTON: Form. 10 BY MR. EDWARDS: 11 Q. And at the time when you were house 12 manager you had a 15-year old daughter? 13 A. Yes. 14 Q. Did she live down here? 15 A. In New Jersey. 16 Q. Okay. When Alan Dershowitz was at the 17 house I understood you to say that these local 18 Palm Beach girls would come over to the house 19 while he was there but you're not sure if he had a 20 massage from any of those girls. 21 A. Exactly. 22 Q. And what would he do while those girls 23 were at the house? 24 MR. CRITTON: Form. 25 THE WITNESS: He will read a book with a 40 (Pages 423 to 426) EFTA00310317 Page 427 1 glass of wine by the pool, stay inside. 2 BY MR. EDWARDS: 3 Q. Did he ever talk to any of the girls? 4 A. I don't know, sir. 5 Q. Certainly he knew that they were there? 6 MR. CRITTON: Form. 7 THE WITNESS: I don't know, sir. 8 BY MR. EDWARDS: 9 Q. Do you know how Snows Mr. 10 Epstein? 11 A. No, sir. 12 Q. Or how long she's known him? 13 MR. CRITTON: Form. 14 THE WITNESS: She was on board two years 15 or a year and a half before I came on board. 16 BY MR. EDWARDS: 17 Q. Okay. 18 A. So it's probably 2003 or 2. 19 Q. All right. You mentioned this Otrix 20 system. 21 A. Yes. 22 Q. Is that a system that was used to operate 23 the phones and the computers? 24 A. The computers mainly. 25 Q. All right. But you then also described 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 Page 429 usually it's Yahoo dot corn or at Bellsouth dot net. A. It was very uncommon. I don't remember, sir. Q. Did everybody in the -- I think you called it the organization, did everybody have e-malls? A. Yes. Q. Okay. Would that include A. Yes. Q. All right. And did Mr. Epstein have an e-mail? A. Yes. Q. Did you ever correspond with Mr. Epstein by e-mail? A. Yes. MR. EDWARDS: You can go ahead. THE WITNESS: That's the only one that I remember. THE VIDEOGRAPHER: Okay, we're off the record. (Thereupon, a recess was had.) THE VIDEOGRAPHER: We're back on the record with tape number four. BY MR. EDWARDS: Page 428 1 some system where someone would call on the 2 telephone and that would be automatically 3 downloaded to the computer? 4 A. Yeah, you can retrieve who called in a 5 transcript written who called, what's the message, 6 the time so you have it on a piece of paper, you 7 can print it out. 8 Q. Is it your understanding that is also 9 part of the Citrix system? 10 A. Yes. 11 Q. All right. Did you have an e-mail? 12 A. Right now, yes. 13 Q. No, when you were working at — 14 A. Yes, I did. 15 Q. 16 An- dhldridlinhave an e-mail? 17 A. Yes. 18 Q. And did all of the e-mails end the same 19 way such as Epstein's house dot com or something? 20 A. Yes. 21 Q. Okay. What wa e-mail? 22 A. I don't remem 23 Q. What was your e-mail? 24 A. Staff house -- I don't remember, sir. 25 Q. Do you recall how it ended? I mean Page 430 1 Q. Mr. Rodriguez, what was Mr. Epstein's 2 e-mail? 3 A. Jeep project at something -- Jeep 4 project -- I can't remember it right now. 5 Q. Okay. In the course of this next 10 or 6 15 minutes -- 7 A. I can recall. 8 Q. -- if it comes to you just tell me. So 9 it was Jeep project -- 10 A. Like Jeep, the brand name Jeep, Jeep 11 project at — I can't remember. 12 Q. Okay. Was that his only e-mail to your 13 knowledge? 14 A. No. 15 Q. He had other e-mail addresses? 16 A. Yes. 17 Q. Do you know what any of his other e-mail 18 addresses were? 19 A. No, I don't remember. 20 Q. Do you know who the carriers were for the 21 other e-mail addresses owned by Jeffrey Epstein? 22 A. No, sir. 23 Q. Whether it was Yahoo or hot mail or -- 24 A. No, none of those. 25 Q. Okay. Was this Jeep project e-mail run 41 (Pages 427 to 430) Kress Court Reporting, Inc. EFTA00310318 Page 431 1 through the Citrix system? 2 A. Yes. 3 Q. Okay. And was there a certain company 4 that came out and fixed the actual Citrix system? 5 A. Yes. 6 Q. And who was that? 7 A. We used to have our own in-house 8 technician from Ohio. 9 Q. The same guy you were telling us about 10 before? 11 A. Yes. 12 Q. All right. He would fix the video 13 equipment or the -- 14 A. Computers mainly. 15 Q. And if the Citrix system broke down too 16 then he would be in charge of it? 17 A. He was the only one dealing with this, we 18 couldn't hire anybody else. 19 Q. Do you know why that is? 20 A. No. It was too many lines into the house 21 from many properties. 22 Q. And do you know who that person is, 23 remember his name now? 24 A. I don't remember, sir. 25 Q. I understood you to say at some point in Page 433 1 at the house did any of these girls, these local 2 Palm Beach girls come over to the house as well? 3 A. They were earlier, sometimes they will 4 leave and he will stay for dinner. 5 Q. All right. And you remember there was 6 one time where maybe= stayed for dinner with 7 David Copperfield? 8 A. That's correct. 9 Q. Was there ever a time where . and 10 David Copperfield were In a bedroom ether? 11 A. I don't think Mr. Copperfield went 12 upstairs. 13 When the police came to the driveway with 14 =in the car, what did yoe tell the police, if 15 anything, that you were paying El for? 16 A. They asked me whose this people, and I 17 said they're a masseuse. 18 Q. Okay. Why would you tell them that 19 they're a masseuse, that's the name you were 20 supposed to call them? 21 MR. CRITTON: Form. 22 THE WITNESS: Yes. 23 BY MR. EDWARDS: 24 Q. And for these massages you were paying 25 between 300 and 500 dollars each time? Page 432 1 time that you saw photographs of some of the girls 2 that were at the house to give massages on 3 Ms. Maxwell's computer. 4 A. Yes. 5 Q. And -- 6 MR. CRITTON: Form to the last question. 7 BY MR. EDWARDS: 8 Q. And do you know which of the girls? 9 A. No, sir. 10 Q. Was In one of them? 11 MR. CRITTON: Form. 12 THE WITNESS: I cannot guarantee that, I 13 cannot say hundred percent, sir. 14 BY MR. EDWARDS: 15 Q. Was. one of them? 16 A. Could be, s= 17 Q. How about 18 A. It's the same thing, I cannot say a 19 hundred percent, sir. 20 Q. I think that you used the phrase there 21 were so many girls. 22 A. Yes, sir. 23 Q. That you're not sure which ones you saw? 24 A. No, sir, so many names. 25 Q. Okay. While David Copperfield was ever Page 434 1 A. Yes, sir. 2 Q. And that's usually for an hour up in the 3 bedroom with Mr. Epstein? 4 A. More or less, yes. 5 Q. You never told your 15-year old daughter 6 at the time that she could come over to Mr. 7 Epstein's for $500 an hour? 8 A. No, sir. 9 MR. CRITTON: Form. 10 BY MR. EDWARDS: 11 Q. Why is it that you never asked your 12 daughter to come over if it's just a massage? 13 MR. CRITTON: Form. 14 THE WITNESS: My daughters are too clean 15 for that, sir. 16 BY MR. EDWARDS: 17 Q. Too dean to give a massage? 18 MR. CRITTON: Form. 19 THE WITNESS: They are good students, 20 they are in another type of environment, 21 sir, we are poor but you know, they're good 22 students. 23 BY MR. EDWARDS: 24 Q. It's because you knew there was more than 25 a massage going on in the bedroom? 42 (Pages 431 to 434) EFTA00310319 Page 435 1 MR. CRITTON: Form. 2 THE WITNESS: Yes, sir. 3 BY MR. EDWARDS: 4 Q. What are some of Mr. Epstein's companies, 5 if you know the names? 6 A. Well, he was the Price -- Price Corn, it 7 was one of his companies, he had a phone company 8 in Palm Beach. A lot of offshore companies that 9 I don't recall, sir. 10 Q. When you say Price Com -- 11 A. Price dot Com, he owned that for awhile. 12 And the local phone company in Palm Beach was his 13 but then he sold it again. But there is too many. 14 Q. As house manager you're obviously at his 15 house every single day, did you inquire as to what 16 he did in terms of making money? 17 A. No, sir, I only got through the Internet 18 because I put his name on Google and then I find 19 out the rest of his companies. 20 Q. So during the day when he would go to the 21 cabana I think that you described last time that 22 he would work there? 23 A. He would work there. 24 Q. Do you know what he would do in terms of 25 working? Page 437 1 telephone numbers of various girls that were 2 referred to as masseuses, did that also give you 3 access to the girls that were coming over to Mr. 4 Epstein's house in Paris and New York and New 5 Mexico? 6 MR. CRITTON: Form. 7 THE WITNESS: We used to have a book in 8 every car, in every plane, in every boat 9 that Mr. Epstein with all the names of all 10 these people so it was not necessarily a 11 secret. 12 BY MR. EDWARDS: 13 Q. When we're talking all these people, are 14 we talking about -- 15 A. Masseuses and, you know, chefs, the 16 important people in the life of Mr. Epstein, you 17 know, used to have a black book with all the 18 names. 19 Q. So there were many black books? 20 A. Yes. 21 Q. And do you know where those black books 22 are now? 23 A. There were tons of those in the house 24 but, you know, I don't know. 25 Q. Okay. And did each one of them have 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 Page 436 A. No, that was very private. I would put his coffee • uld shut the door. Q. An. had a work station or work comer - TT house? A. Yes. Q. What did she do in terms of work? A. She will set appointments for comedy shops, movies. I will get the tickets but, you know, she was appointments for the masseuse, or travel arrangements with the pilots, that type of thing. Q. And would she keep track of all of the girls who were coming to his house in Palm Beach or at the other houses as well? MR. CRITTON: Form. THE WITNESS: All of the houses. BY MR. EDWARDS: Q. All right. So if he was going to be in Paris and he wanted girls over in that house she would keep track of that as well? MR. CRITTON: Form. THE WITNESS: Exactly. BY MR. EDWARDS: air nd when you talked about seeing computer and seeing the names and 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 Page 438 handwritten names and numbers or were these computer printouts so they were the same? A. They were very organized. Once In awhile they used to be updated, so we used to have these books with obsolete dates, you know, so we discard them and have the new ones. Q. By obsolete dates are you saying that there were girls that came over and then they no longer came over anymore? A. That's correct. MR. CRITTON: Form. BY MR. EDWARDS: Q. Okay. So if a girl that was coming over for a period of time got too old and was no longer able to come over and somebody else took her place then her page would disappear from that book? MR. CRITTON: Form. THE WITNESS: I believe so, sir. BY MR. EDWARDS: Q. You were asked about other homes that you worked at for other wealthy people and asked if these other homes had a massage table. A. Yes. Q. And you said that they did? A. Yes. 43 (Pages 435 to 438) EFTA00310320 Page 439 1 Q. And you said that that was -- the massage 2 table was similar in kind to that used by Mr. 3 Epstein? 4 A. That's correct. 5 Q. And others had massage oils and that was 6 similar in kind to Mr. Epstein's as well? 7 A. Yes. 8 Q. And you didn't think that the massage 9 table at a home was unusual? 10 A. No. 11 Q. All right. Did any of the other houses 12 where you worked have masseuses that were 14, 15, 13 and 16 years old? 14 MR. CRITTON: Form. 15 THE WITNESS: No, sir. 16 BY MR. EDWARDS: 17 Q. And did any of the other homes where you 18 worked have different girls of that age coming 19 every single day? 20 A. Yes. 21 MR. CRITTON: Form. 22 BY MR. EDWARDS: 23 Q. They had different girls? 24 A. Yes. 25 Q. Okay. And how old were the girls that Page 441 1 MR. EDWARDS: I don't have anything else. 2 MS. EZELL: I have a few. 3 EXAMINATION 4 BY MS. EZELL: 5 Q. Mr. Rodriguez, I may have missed 6 something. Did you say that there weren't any 7 wild parties ever at El Brillo Way? 8 A. I never saw what was going on inside the 9 house, Ma'am. 10 Q. So you don't know wether there were or 11 were not? 12 A. No, ma'am. 13 Q. There wasn't just one massage table 14 there; was there? 15 A. We used to have two and we have an extra 16 reserve, I think there were three In the house. 17 Excuse me, I'll take that back. All the bedrooms 18 used to have one. 19 Q. Okay. Ihanl u. 20 about a girl name 21 A. No, no, ma 22 Q. And those pictures on Ms. Maxwell's 23 computer, did you ever see one of a girl naked in 24 a hammock? 25 MR. CRITTON: Form. Asked and answered. Did you ever hear Page 440 1 would come to these other homes? 2 A. They seem older. 3 Q. Older than the ones that would come to 4 Mr. Epstein's home? 5 A. Yes. 6 Q. And did you ever work at a place where 7 there would be girls calling up on the phone to 8 say I have girls to bring him and -- 9 A. No, sir. 10 Q. -- coming over in teams -- 11 A. No. 12 Q. -- or pairs? 13 A. No. 14 Q. So there were a lot of things about Mr. 15 Epstein's house and his arrangement that were very 16 unusual compared to the other places where you 17 worked? 18 MR. CRITTON: Form. 19 THE WITNESS: Yes. 20 BY MR. EDWARDS: 21 Q. And there were no drugs and alcohol or no 22 wild parties at Mr. Epstein's house, that is 23 somewhat different from some of the other places 24 where you worked? 25 A. Yes. Page 442 1 THE WITNESS: I saw on a book not on a 2 computer. 3 BY MS. EZELL: 4 Q. You saw a picture of a girl naked in a 5 book or on a book? 6 A. The book was done for Nadia and she was 7 on the hammock, that's the only one I saw. 8 Q. I'm sorry, the book was done for Nadia? 9 A. She was on the cover. 10 Q. Then there were other people inside the 11 book? 12 A. Yes, ma'am. 13 Q. And in that book there was a picture of a 14 girl naked in a hammock? 15 A. Yes. 16 Q. Where did Nadia keep that book? 17 A. There were a few of those examples but I 18 don't know where she kept it. 19 Q. Was it laying around the house somewhere? 20 A. Yes. 21 Q. Downstairs? 22 A. Downstairs, yes, ma'am. 23 Q. Did Nadia keep scrapbooks or photograph 24 books -- 25 A. Yes. 44 (Pages 439 to 442) EFTA00310321 Page 443 1 Q. -- of friends, girls? 2 A. Yes, ma'am. 3 MR. CRITTON: Form. 4 BY MS. EZELL: 5 Q. Do you remember there being a young man 6 ,who would bring girls to the house named Tony 7 Figueroa? 8 A. No, ma'am. The only person that I saw 9 that night A. was at the house, she was driving 10 the car, but I didn't see any males. 11 MR. CRITTON: You said he, he being whom? 12 BY MS. EZELL: 13 Q. I didn't quite understand that either. 14 Tony Figueroa was driving. 15 A. She was with this girl that night, A. I 16 think that's the only time I saw a male at the 17 house, ma'am. 18 Q. And you're talking about the night when 19 you came and found the old car in the driveway? 20 A. Exactly, yes, with the police, yes. 21 Q. How did you remember that it was Tony 22 Figueroa? 23 A. It's the only person, male that I 24 remember. 25 Q. But you don't know his name? 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 Page 445 eras like.", she was and me, I guess. She was to hell, Q. And is that what your understanding was as to whatiMa did? A. I'm sorry? Q. Was it there to he A. Q. understanding that with her duties? was. was. Okay. ve you spoken to any lawyers or investigators about this case since you were deposed last? A. No, ma'am. Q. I believe Mr. Critton was askin questions relating to the incident when was in a car in the driveway and you went t the police and he was speaking of that time as being in January of '05. Do you remember when it was? A. I will put that in that month, ma'am, but I cannot guarantee. Q. Let me just show you something that we can mark as the next exhibit. I would just ask that if -- yes, the name is in here that we redact it to show just the was Page 444 1 A. No, no, no, Ma'am. 2 Q. Got you. Thank you. 3 MR. CRITTON: Can I ask one quick? 4 There was a man with. you don't know 5 who It was? 6 THE WITNESS: That's the only male that's 7 been to the house, so when she asked me the 8 question I assume, you know. 9 MR. CRITTON: Do you know who Tony 10 Figueroa is? 11 THE WITNESS: No, sir. 12 MR. CRITTON: Okay. Now I think I 13 understand. Thank you. Sorry, Cathy. 14 MS. EZELL: That's okay. 15 BY MS. EZELL: 16 Q. I asked y chefs name 17 could have been nd I was wrong, I 18 wanted to ask you a different name. 19 Could it have been 7 20 A. I don't remember his last name. 21 Q. Do you remember an assistant of some sort 22 who worked there for awhile when you were there 23 named 24 A. Yes. 25 Q. What did she do? Page 446 1 initials. 2 MR. EDWARDS: We're going to attach this; 3 right? 4 MS. EZELL: Yes. 5 MR. CRITTON: You're going to let us have 6 this one? 7 MS. EZELL: Yes. With initials. 8 (Exhibit No. 9 was marked for 9 Identifkation.) 10 BY MS. EZELL: 11 Q. Have you ever seen this report? 12 A. I saw it typed, not handwritten like 13 this. 14 Q. Did the police bring you one that was 15 typed? 16 A. No, the only time I saw my own report was 17 on the Internet because my daughter told me do you 18 know that you're in Palm Beach and this and that, 19 so I was in New York on vacation and that's why I 20 read it but this is the first time I'm looking at 21 this. 22 Q. Okay. 23 MR. HOROWITZ: Do you have extra copies? 24 MS. EZELL: I do, I don't want to give 25 them out, I'd rather -- I don't mind them 45 (Pages 443 to 446) EFTA00310322 Page 447 1 attaching it to the deposition as long as it 2 has just the initials. 3 THE WITNESS: This is the report when I 4 called to the police to the house? 5 BY MS. EZELL: 6 Q. Let me let you look at it, I'd rather you 7 tell us if it is. 8 A. This is why I was fired. This is the 9 reason I was let go. 10 MR. CRITTON: There is no question right 11 now. I'm sure there will be. 12 MR. EDWARDS: I'll ask it if you want. 13 THE WITNESS: I'm thinking out bud. 14 BY MS. EZELL: 15 Q. Did you notice the date on this report? 16 A. November 28th, yes, ma'am. 17 Q. And do you have any reason to believe 18 that that's not accurate? 19 A. No, that's it, yeah. 20 Q. And as you look at other information on 21 the report do you see anything else that's not 22 accurate? 23 A. Let me finish reading this, please. 24 Q. Sure. 25 MR. CRITTON: Let me just object to the Page 449 1 Q. Can you tell me what you mean by that? 2 A. Mr. Epstein used to give a lot of gifts 3 to the police department, so we used to have 4 certain leeway in terms of speeding or some other S things. So he used to put a baseball cap Palm 6 Beach Police Department on the dashboard. 7 So when he saw I called the police for my 8 own safety because I was carrying cash, I 9 explained that to him, and he say why you called 10 the police, and I said because I saw a dunker in 11 the driveway and it's dark. In Palm Beach there 12 is no nights. So I called for my own safety. I 13 was coming from Publix buying my groceries and I 14 had cash in my pocket. And I said I called the 15 police because I was concerned about my own 16 safety. 17 And I recognized the girl and I figured 18 because I remember told me earlier that day 19 -- it was a hectic day, he just left Palm Beach 20 and I was catching up with my breath, you know, I 21 went to buy my groceries, and I explained that. 22 So he was upset that this will spill, you know, to 23 the public or the street. But I didn't realize 24 this was written or something, you know. 25 Q. You were not fired though until sometime Page 44e 1 form. Can I look at your copy, please? 2 THE WITNESS: This is the first time I 3 saw this. 4 BY MS. EZELL: 5 Q. Have you had a chance now to read it? 6 A. Yes, ma'am. 7 Q. Okay. Does this report accurately 8 describe what occurred that evening? 9 A. Yes, ma'am. 10 MR. CRITTON: Form. 11 BY MS. EZELL: 12 Q. Did you overhear the conversation between 13 A.H. and the policeman? 14 A. Yes, ma'am. 15 Q. And is that part accurate as well? 16 A. Yes. 17 Q. And then your conversation with Mr. -- 18 with Officer Munyan -- 19 A. Yes, ma'am. 20 Q. -- is that accurately reported here as 21 well? 22 A. Yes, ma'am. 23 Q. Now you stated that this is why you got 24 fired. 25 A. Yes, ma'am. Page 450 1 in March? 2 A. Exactly, yes. But he gave me -- Mr. 3 Epstein used the word I'm going to give you -- he 4 make fun of my Spanish and he said (speaking in 5 Spanish). 6 And I said, yes, Mr. Epstein. Okay, I'll 7 give you one more chance. And I said what's going 8 on. But, you know, it meant a few words, I 9 couldn't talk to him too much, but this was it. 10 Because, you know, I have to say this for 11 myself, you know, I never did something illegal, I 12 was working hard to please him and sometimes more 13 than I was supposed to, many hours beyond my 14 duties, and so — but he was concerned about this. 15 And I say, Mr. Epstein, you told me 16 safety is the paramount of this house, in this 17 case it was me, but obviously he didn't care about 18 me, it was his safety. 19 MR. CRITTON: Form. Move to strike. 20 BY MS. EZELL: 21 Q. Can you translate for me what you said a 22 moment ago in -- I don't know -- 23 A. In Spanish he said "conose" amnesty, but 24 he used the word "conose amnistia", I'll give you 25 amnesty so you have a chance to continue working 46 (Pages 447 to 450) Kress Court Re•.rtin• Inc. 305-866-7688 EFTA00310323 Page 451 1 with me. 2 But I didn't ask him why. He just came 3 fast. You're always in the run, you have to be on 4 your toes, and the next thing he said I took the 5 wrong Suburban and they let me go. 6 But I never find out what happened 7 because I have to say this. Being so many people 8 in the house I didn't know if I displease one of 9 the girls, or something I said or I did, I don't 10 think so. So they let me go very mysteriously. 11 But this is it. 12 Q. I understood you to say that Mr. Epstein 13 gave lots of gifts to the police department. 14 A. Yes, ma'am. 15 Q. And you said something about a baseball 16 cap. 17 A. Well, the police department used to give 18 us in retribution dozens of baseball caps with the 19 Palm Beach Police Department, you put one of those 20 on the dashboard you don't get a ticket 21 Q. Oh. 22 A. Stuff like that. Key rings and so on and 23 so forth. There Is -- everybody knows this, I 24 don't think it's a secret. Mr. Epstein give 25 $85,000 simulator for the police to shoot, you Page 453 1 her do you believe under the influence of drugs? 2 A. No. 3 Q. Did you ever see steroids in the house? 4 A. No. S MR. LANGINO: Thank you. 6 MR. EDWARDS: Do you have anything, 7 Richard? 8 MR. WILLITS: Yes. 9 MR. EDWARDS: Okay, shoot. 10 EXAMINATION 11 BY MR. WILLITS: 12 Q. Mr. Critton asked you several questions 13 about the females who you were told to refer to as 14 masseuses. And when he asked you those questions 15 he referred to them often as women. 16 Did you think of those masseuses as 17 women? 18 MR. CRITTON: Form. 19 THE WITNESS: Yes. 20 BY MR. WILLITS: 21 Q. Why? 22 A. Because I saw them, they were females. 23 Q. What is your definition of a woman? 24 A. Person of the opposite sex, I'm a male. 25 Q. Is a three-year old a woman? Page 452 1 know, and it was returned after the scandal broke 2 out. 3 MR. CRITTON: Move as nonresponsive to 4 any question. Move to strike. 5 MS. EZELL: I don't have any other 6 questions. 7 EXAMINATION 8 BY MR. LANGINO: 9 Q. Mr. Rodriguez, do you know where the main 10 server, the main computer server was located 11 inside the house? 12 A. In the garage. 13 Q. Do you know the names of any of the 14 programs — computer programs -- 15 MR. WILLITS: I am missing something. 16 Whose questioning now? 17 MR. LANGINO: Adam Langino. 18 BY MR. LANGINO: 19 Q. Do you know the names of some of the main 20 computer programs that are used as part of your 21 routine as the house manager of the house? 22 A. The main computers? 23 Q. Programs. 24 A. Besides Ci ' • 25 Q. Regarding did you ever see Page 454 1 A. Yes. 2 Q. Okay. 3 MR. WILLITS: I don't have any other 4 questions. 5 MR. EDWARDS: I do but only just to 6 follow-up with this police report that we've 7 just been provided which I'm not sure if it 8 has a designation. 9 MR. CRITTON: Exhibit 9. 10 MR. EDWARDS: Okay. 11 EXAMINATION 12 BY MR. EDWARDS: 13 Q. You were asked by 1ton aboutM 14 who we were referring to a in this 15 deposition, and her date of s 12/30/86. 16 And Mr. Critton was indicating to you earlier that 17 at the time that you had this dealing with her in 18 the driveway that she was 18 years old. It 19 appears that this occurred November 28, 2004, 20 which would indicate that she is 17 years old. 21 I think the question that was asked of 22 you is, are you surprised by that, so I'll ask you 23 the same question? 24 A. No, sir. 25 Q. All right. This report that you have 47 (Pages 451 to 454) EFTA00310324 Page 455 1 indicated Is accurate or accurately reflects the 2 events of that night, I want to make sure that Mr. 3 Willits hears and that we go through it and you 4 can elaborate on any part of It. Okay. 5 On Sunday, 11/28/2004, at approximate!), 6 19:00 hours, so we're talking about 7:00 at night, 7 the property manager of 358 El Brillo Way, Alfredo 8 Rodriguez, came to the station to complain there 9 was a strange vehide parked in the driveway. 10 A. Yes. 11 Q. That's true? 12 A. Yes. 13 Q. When Officer Koemer and I, this is 14 Officer Munyan talking, arrived at 358 El Brillo, 15 we located a white female later identified as 16 A.H., date of birth 12/30/86 waiting in the 17 driveway. 18 A. That's correct. 19 Q. Okay. 20 MR. CRITTON: Form. Are you asking him 21 whether the statement is correct or that 22 you're reading it correctly? 23 BY MR. EDWARDS: 24 Q. No, the statement is correct. 25 A. Yes. Page 457 1 Did you get that impression that H. was 2 very nervous in her car when the police showed up? 3 A. Yes. 4 Q. Was that an indication to you that she 5 realized that there were police there and that 6 there was some form of illegal activity that she 7 was involved in at Jeffrey Epstein's house? 8 MR. CRITTON: Form. 9 THE WITNESS: Yes. 10 BY MR. EDWARDS: 11 Q. H.'s cell phone rang, she answered it 12 quickly, said, in quotes, "I can't talk, I can't 13 talk, I'm at school, I got to go." 14 Did you hear that part of it? 15 A. Yeah. 16 Q. Okay. That's obviously a lie. Right? 17 MR. CRITTON: Form. 18 BY MR. EDWARDS: 19 Q. She's saying she's at school when really 20 she's right in front of Jeffrey Epstein's house? 21 A. Yes. 22 Q. And again, another indication that she's 23 doing something she shouldn't be doing. Right? 24 MR. CRITTON: Form. 25 MS. EZELL: Object to the form. Page 456 1 Q. That's what you understood me to ask you? 2 A. Yes. 3 Q. Okay. Rodriguez arrived at that time and 4 stated he did remember vas there to pick up -- 5 was coming there to pi an envelope the 6 homeowner, Jeffrey Epstein, left for her. 7 And that's correct as well. Right? 8 A. Yes. 9 MR. CRITTON: Form. 10 BY MR. EDWARDS: 11 Q. This document right here, is it 12 refreshing your recollection as to that night? 13 A. Yes. 14 MR. CRITTON: Form. 15 BY MRJDWARDS: 16 Q. Rodriguez quickly entered the house then 17 returned with a sealed envelope wit= first 18 name on It. 19 A. Yes. 20 Q. Do you remember who wrote her first name 21 on that envelope? 22 A. I did. 23 Q. Okay. The envelope peared to have nervous " 24 money in it, in my opinion, was very 25 with us standing there. Page 458 1 BY MR. EDWARDS: 2 Q. If she was a masseuse and was at 3 someone's house in relation to pick up money from 4 a massage she had given, that's not the typical 5 answer that you would expect. Right? 6 MR. CRITTON: Form. 7 THE WITNESS: That's right. 8 BY MR. EDWARDS: 9 Q. Okay. It didn't shock you or surprise 10 you as Mr. Critton asked you earlier that she 11 would make up a tale or a lie about her 12 whereabouts considering what she was doing. 13 Right? 14 A. No. 15 MR. CRITTON: Form. 16 BY MR. EDWARDS: 17 Q. Then hung up, talking about Ms.• I 18 asked her who it was on the phone, she stated it 19 was her mom. I asked her how she knows Epstein, 20 H. stated the s at Abercrombie 21 & Fitchin the Mall, she met 22 Epstein through a female friend at work, Epstein 23 allows them to come over any time and use the 24 house and pool. Then she quickly left. 25 Did you hear that conversation? 48 (Pages 455 to 458) Kress Court R- •ortin• Inc. 305-866-7688 EFTA00310325 Page 459 1 A. Yes, they were next to me. 2 Q. Okay. Is that the entire substance of 3 that conversation between Ms. Nand the police 4 officer? 5 A. Yes. 6 Q. She didn't mention that she comes over to 7 his house and goes Into a bedroom with Mr. 8 Epstein. Right? 9 MR. CRITTON: Form. 10 THE WITNESS: No. 11 BY MR. EDWARDS: 12 Q. And she didn't tell the police officer 13 that she is a masseuse; did she? 14 A. No. 15 Q. And that didn't surprise you either; did 16 It? 17 A. No. 18 MR. CRITTON: Form. 19 BY MR. EDWARDS: 20 Q. I then asked Rodriguez what was in the 21 envelope, Rodriguez was hesitant but -- what is 22 that word? 23 A. But then. 24 Q. But then I said it was drugs and he 25 quickly said it was money. Is that accurate? Page 461 1 Q. I asked what kind of job H. performs, 2 Rodriguez smiled and says she is a massage 3 therapist. 4 A. Yeah. 5 Q. Why did you tell him that? 6 MR. CRITTON: Form. 7 THE WITNESS: Because I understood she 8 came to give massage. 9 BY MR. EDWARDS: 10 Q. Well, that's what somebody had told you? 11 A. Yes. 12 Q. At this point in time though you knew 13 that more was going on than a massage? 14 MR. CRITTON: Form. 15 BY MR. EDWARDS: 16 Q. Right? 17 MR. CRITTON: Form. 18 THE WITNESS: That's right. 19 BY MR. EDWARDS: 20 Q. I asked -- this is the police officer 21 talking, I asked which muscle she rubbed. 22 Do you remember the police officer asking 23 that? 24 A. Yes. 25 Q. And you knew what he was implying. Page 460 1 A. That's correct. 2 Q. When he first asked you what was in the 3 envelope were you nervous? 4 A. No, because I was trying to — I didn't 5 want to disclose these private things with the 6 police so that's why I was concerned about that. 7 Q. When you're talking about private things, 8 the fact that there are young girls coming over? 9 MR. CRITTON: Form. 10 THE WITNESS: It was late, you know, 11 exactly. 12 BY MR. EDWARDS: 13 Q. I'll let you answer. What are the 14 private things that you were nervous to tell the 15 police? 16 A. This was inside the compound, the 17 property itself, so you have to keep 18 confidentiality, and the police was there, that's 19 why. Not that I was doing something wrong but I 20 was trying to keep them -- 21 Q. I'm not suggesting that you were doing 22 something wrong. 23 A. Exactly. So he asked me is there any 24 drugs there, and I said, no, it's just money. 25 That's all I said. Page 462 1 Right? 2 MR. CM-17ON: Form. 3 THE WITNESS: Yeah. 4 BY MR. EDWARDS: S Q. That it was obvious to him that she was 6 over there to sexually please Mr. Epstein. Right? 7 MR. CRITTON: Form. 8 THE WITNESS: That's correct. 9 BY MR. EDWARDS: 10 Q. And that's coming from a police officer 11 who's not the house manager. Right? 12 MR. CRITTON: Form. 13 THE WITNESS: That's right. 14 BY MR. EDWARDS: 15 Q. You knew right away what he was asking 16 and you say, Rodriguez laughed said, in quotes, 17 "off the record, he, Epstein, has many young girls 18 come over for that," end quote. 19 Do you remember telling him that? 20 MR. CRITTON: Form. 21 THE WITNESS: Yes. 22 BY MR. EDWARDS: 23 Q. And when you were saying come over for 24 that, it was -- 25 A. Massage or something. 49 (Pages 459 to 462) Kress Court Re r•rtin• Inc. 305-866-7688 EFTA00310326 Page 463 1 Q. -- to sexually please Mr. Epstein. 2 Right? 3 MR. CRITTON: Form. 4 THE WITNESS: Yes. 5 BY MR. EDWARDS: 6 Q. I mean, that's what you were telling the 7 police officer. 8 MR. CRITTON: Form. 9 THE WITNESS: Yes. 10 BY MR. EDWARDS: 11 Q. Okay. There's always a different girl at 12 the pool or inside with him when he's here. 13 MR. CRITTON: Form. 14 THE WITNESS: Yes. 15 MS. EZELL: You left out a word, young. 16 BY MR. EDWARDS: 17 Q. Sorry, I'll read the last sentence again. 18 There's always a different young girl at 19 the pool or inside with him when he's here. 20 Do you remember telling the police 21 officer that? 22 A. Yes. 23 MR. CRITTON: Form. 24 BY MR. EDWARDS: 25 Q. And that's true. Right? Page 465 1 Q. And as to -- it was read to you by Mr. 2 Edwards and he then asked you a number of 3 questions whether you remembered something. 4 Correct? 5 A. Yes. 6 Q. Okay. Just so I'm clear, he's asking you 7 to speculate on what may or may not have occurred 8 upstairs in the bedroom. I want to be very dear. 9 Mr. Rodriguez, were you ever up in the 10 bedroom to observe whatever went on between a 11 masseuse and Mr. Epstein or anyone else for that 12 matter at any time? 13 MR. HOROWITZ: Form. 14 THE WITNESS: No, sir. 15 BY MR. CRITTON: 16 Q. And so when Mr. Edwards asked you, you 17 were aware that sexual activity or may have been 18 sexual activity occurring upstairs, you have no 19 personal knowledge, you're just speculating; 20 aren't you, sir? 21 MR. HOROWITZ: Form. 22 MR. EDWARDS: Object to the form. 23 THE WITNESS: I never saw them. 24 BY MR. WILLITS: 25 Q. And therefore you can only speculate -- Page 464 1 A. Yes. 2 Q. When he's at the house there is always a 3 young girl inside with him. 4 MR. CRITTON: Form. 5 BY MR. EDWARDS: 6 Q. Right? 7 A. That's right. 8 Q. Okay. And whether the company line is to 9 call them a masseuse, you knew that these girls 10 were young and were up in the bedroom with Mr. 11 Epstein to sexually please Mr. Epstein. 12 MR. CRITTON: Form. 13 THE WITNESS: That's right. 14 MR. EDWARDS: I don't have anything else. 15 We've already attached this; right? Here is 16 the one that can be attached. 17 MR. WILLITS: Who is next? 18 MR. CRITTON: Me. 19 RECROSS EXAMINATION 20 BY MR. CRITTON: 21 Q. Mr. Rodriguez, looking at Exhibit 9 which 22 is the police report that was prepared on November 23 28, 2004, this is the first time you've seen it. 24 Correct? 25 A. That's correct. Page 466 1 MR. WILLITS: Object to the form. 2 MR. CRITTON: I need to ask the question 3 first. 4 MR. WILLITS: It was the earlier 5 question. 6 BY MR. CRITTON: 7 Q. All right. If you did not see what was 8 going on you can have no personal knowledge. 9 True? 10 MR. HOROWITZ: Object to the form. 11 MR. EDWARDS: Object to the form. 12 THE WITNESS: Yes. 13 BY MR. CRITTON: 14 Q. And, therefore, what you're doing is 15 speculating or guessing what may have been 16 occurring. True? 17 MR. HOROWITZ: Form. 18 MR. EDWARDS: Form. 19 MR. WILLITS: Form. 20 THE WITNESS: I use my age together. 21 BY MR. CRITTON: 22 Q. I'm not saying that you don't, but 23 without having personal knowledge you're best 24 guessing what may have occurred up there between 25 Mr. Epstein and one of the massage women, or for 50 (Pages 463 to 466) Kress Court Reporting, Inc. 305-866-7688 EFTA00310327 Page 467 1 that matter anyone else who was upstairs? 2 A. Yes. 3 MR. HOROWITZ: Form. 4 MR. EDWARDS: Form. 5 MR. WILLITS: Object to the form. 6 MR. CRITTON: Thank you. 7 MS. EZELL: I just have a couple of 8 questions. 9 EXAMINATION 10 BY MS. EZELL: 11 Q. Following up on that, you did however see 12 this same young woman asleep naked in the sauna? 13 A. Yes, ma'am. 14 Q. And you did along withand and 15 -- and you did also find sex toys and massagers of 16 various kinds and creams scattered around on 17 several occasions after these young women had been 18 upstairs with Mr. Epstein? 19 MR. CRITTON: Object to form, asked and 20 answered about six times. 21 THE WITNESS: Yes. 22 MS. EZELL: No other questions. 23 MR. EDWARDS: Sorry, last one. It has 24 nothing to do with this report. 25 EXAMINATION 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 Page 469 A. Yes. MR. EDWARDS: Nothing else. MR. WILLITS: Is It my tum? MR. EDWARDS: Yes. EXAMINATION BY MR. WILLITS: Q. Mr. Rodriguez, you mentioned the last time about a lady who watus professional masseuse by the name of Do you remember that? A. Q. A. Q. A. Yes, I do remember. Did you ever pay her? Yes, sir. Okay. How much did you pay her? It was between 200 and 500, sir, but somew -- between those two amounts. Q. A. Yes, sir. MR. WILLITS: Okay. I don't have any other questions. MR. CRITTON: You have a right to read this deposition when the other part is typed and make any changes that you want. Would you like to do that? It's your right a hundred percent. The court reporter can Page 468 1 BY MR. EDWARDS: 2 Q. During Mr. Critton's questioning he asked 3 you about whether or not we had ever shown you a 4 previous taped statement that you had given to a 5 police officer, and we did not do that; did we? 6 A. No. 7 Q. We can represent to you that we don't 8 have It to show It to you otherwise we would like 9 to do that. 10 However, he asked you did you tell the 11 police officers at that time that the girls 12 appeared to be 18 years or older, and I believe 13 that you said when you gave the statement to the 14 police that you did; right, say that? 15 A. Yes. 16 Q. And I wrote, I put it in quotes, you said 17 that because you were fearful of reprise from 18 Ms. Maxwell and Mr. Epstein. 19 A. That's correct. 20 MR. CRITTON: Form. 21 BY MR. EDWARDS: 22 Q. Okay. Is everything that you've said 23 today and told us today, is it true? 24 A. Yes. 25 Q. To the best of your knowledge? 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 Page 470 provide you or whoever set your deposition -- THE WITNESS: I tried to be truthful. MR. CRITTON: All you have to do is tell her you would like to waive. Do you waive the reading and signing? MR. EDWARDS: You can either read or you can waive reading? THE WITNESS: I don't understand what I have to do. MR. CRITTON: Why don't we go off the record and you can explain it to him. MR. EDWARDS: We can go off the record. THE VIDEOGRAPHER: Off the record. (Thereupon, a discussion was held off the record.) THE WITNESS: Waive. (Thereupon, the deposition was concluded at 5:30 p.m.) 51 (Pages 467 to 470) EFTA00310328 Page 471 1 THE STATE OF FLORIDA, ) 2 COUNTY OF DADE. 3 4 5 I, the undersigned authority, certify 6 that ALFREDO RODRIGUEZ personally appeared before 7 me on the 7th day of August, 2009 and was duly 8 sworn. 9 10 WITNESS my hand and official seal this 11 18th day of August, 2009. 12 13 14 15 MICHELLE PAYNE, Court Reporter 16 Notary Public - State of Florida 17 18 19 20 21 22 23 24 25 Page 472 1 2 The Stara Of Hada, ) 3 Canty Of Dade. 5 4 1, MICHEUE PAYNE, Cart Reporter and Wary Public el and for tho Rats ce Florida at 6 large, do hereby any that I was trot/wetted W end dd stenographimly react the deposticro of AuRED0 R0DRIGun; that a review of the transott was not raised; and that the foregoing pages, 8 ninibenxt from 270 b 472, Wise?, are a true and owed trtrectice4M of my sten:cradle notes 9 ce said deposittn. 10 Metter catty that sad deposition was taken at the time and place hereinaboyo set forth and Mat the taking of mid deposten wee =moved and completed as heminatme set out. 12 Lithe, notify that 1 am not an 13 attorney or coussel of any d the parttea, rear am a relative or employee of any ateciney 14 cctnsel ce petty corrected with the anion, nor am I linencbly Int/meted al the adka. 15 the foregoing ontifiegeon d this 16 Utniatt does not apply to any rcatelUdion of the sane by any means unless under the drod 17 anted and/or drecticei of the certifying reporter. IS DATED des 18th day of August, 2009. 19 20 CERTIFICATE 21 14O1E112 PAYNE, tart Reporter 22 23 24 25 52 (Pages 471 to 472) Kress Court Reporting, Inc EFTA00310329