Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE No.08-CV-80119-CIV-MARRA/JOHNSON

Page 3
1
2

JANE DOE NO. 2,

3

Plaintiff,

4

-vsJEFFREY EPSTEIN,
Defendant.
_____________________________________________________
Related cases:
08-80232, 08-80380, 98-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
______________________________________________________
VIDEOTAPED DEPOSITION OF JUAN ALESSI
VOLUME I
Tuesday, September 8, 2009
10:12 a.m. - 3:45 p.m.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33401

Reported By:
Sandra W. Townsend, FPR
Notary Public, State of Florida
PROSE COURT REPORTING AGENCY
West Palm Beach Office

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

On behalf of the Defendant:
ROBERT J. CRITTON, ESQUIRE
BURMAN, CRITTON & LUTTIER
515 North Flagler Drive, Suite 400
West Palm Beach, Florida 33401
Phone: 561.842.2820
rcrit@bclclaw.com
mpike@bclclaw.com

Page 2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21

APPEARANCES:
On behalf of the Plaintiffs:
RICHARD WILLITS, ESQUIRE
RICHARD H. WILLITS, P.A.
2290 10th Avenue North, Suite 404
Lake Worth, Florida 33461
Phone: 561.582.7600
reelrhw@hotmail.com
STUART MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
Phone: 305.931.2200
ssm@sexabuseattorney.com
ahorowitz@sexabuseattorney.com
WILLIAM J. BERGER, ESQUIRE
ROTHSTEIN ROSENFELDT ADLER
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale, Florida 33301
Phone: 954.522.3456
bedwards@rra-law.com
KATHERINE W. EZELL, ESQUIRE
PODHURST ORSECK, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
Phone: 305.358.2800
rjosefsberg@podhurst.com
kezell@podhurst.com
ADAM J. LANGINO, ESQUIRE
LEOPOLD KUVIN
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
Phone: 561.515.1400
skuvin@leopoldkuvin.com

22
23
24
25

Page 4

- - EXHIBITS
- - -

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

NUMBER

DESCRIPTION

PAGE

Exhibit number 1
Exhibit number 2
Exhibit number 3
Exhibit number 4
Exhibit number 5

Photographs
45
Transcript
130
Incident Report
137
Incorporation Papers
149
Incorporation Papers
150

1 (Pages 1 to 4)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 5
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

PROCEEDINGS
--Deposition taken before Sandra W. Townsend, Court
Reporter and Notary Public in and for the State of
Florida at Large, in the above cause.
- - VIDEOGRAPHER: Today is September 8, 2009.
The time is 12 minutes after 10:00 in the morning.
This is the videotaped deposition of Juan
Alessi in the matter of Jane Doe number two versus
Jeffrey Epstein. This deposition is being held at
2139 Palm Beach Lakes Boulevard in West Palm Beach,
Florida.
My name is Stan Sanders. I'm the videographer
representing Visual Evidence, Incorporated.
Would the attorneys please announce their
appearances for the record.
MR. WILLITS: Richard Willits, representing
Carolyn Andriano.
MR. BERGER: William J. Berger, representing
E.W., L.M. and Jane Doe number two.
MR. MERMELSTEIN: Stuart Mermelstein of
Mermelstein and Horowitz, representing Jane Does
numbers two through eight.
MR. LANGINO: Adam Langino, on behalf of B.B.

Page 7

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

Boynton Beach, Florida, 33472.
Q. All right, sir. Did you ever work for Jeffrey
Epstein?
A. Yes, I did.
Q. In what capacity?
A. Everything. I started with Jeffrey Epstein
around 19 -- please bear with the dates because I
trying -Q. Sure.
A. -- to remember. 1969 as a part-time
maintenance guy.
And then I become a full-time employee, I
think it was January 1, 2 -- '91, '92, so '92. Sorry.
Q. You said you started in 1969? That would
be -A. No. No. No. No. No.
Q. Okay.
A. '99.
Q. 1999?
A. Yeah.
Q. All right. And how did you happen to get that
job? Was it through an employment agency -A. No.
Q. -- or an ad in the paper?
A. I had a company at that time used to take care

Page 6
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

MS. EZELL: Katherine Ezell from Podhurst
Orseck, on behalf of Jane Does 101 and 102.
MR. CRITTON: Bob Critton, on behalf of
Jeffrey Epstein.
THEREUPON,
JUAN ALESSI,
having been first duly sworn or affirmed, was examined
and testified as follows:
THE WITNESS: I do.
DIRECT EXAMINATION
BY MR. WILLITS:
Q. Good morning, sir.
A. Good morning.
Q. I introduced myself through the videographer.
My name is Richard Willits.
A. Okay.
Q. I represent a young lady by the name of
Carolyn Andriano.
A. Okay.
Q. Is that name familiar to you at all?
A. Whose name?
Q. Carolyn Andriano. Do you recognize that name?
A. No.
Q. What is your residence address, sir?
A. My address is 6791 Fairway Lakes Drive,

Page 8
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

of a lot of residents in Palm Beach. And I got to know
Jeffrey through Lesley Wexner. And I used to work in
about 20 different, 20, 25 different homes in Palm Beach
as a maintenance guy.
Q. Okay.
A. And I have basically my own company and I do
repairs for them. I did home sit in for them.
Q. And what was -- did you work for Jeffrey
Epstein? What was your position when you started?
A. When I started, he hire me to -- he just
bought the house.
Q. I'm sorry?
A. He just had bought the house -Q. Okay.
A. -- where he live on El Brillo. And he hire me
through Mr. Wexner's references to do repair works. And
basically what I did the most was taking walls apart,
windows and stuff that he didn't want to have it, -Q. I see.
A. -- fix it.
Q. And when you started working for Mr. Epstein,
were you still working for other people in Palm Beach?
A. Yes, I did.
Q. Okay. And about how long a period of time did
you do this type of work for Mr. Epstein, the

2 (Pages 5 to 8)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 9
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

maintenance and taking out walls?
A. It was couple months. It was couple months
before.
Q. And what was the name of your company?
A. Alessi Maintenance.
Q. And how were you paid?
A. By him?
Q. Yes.
A. Usually by check or cash sometimes.
Q. Do you know what company actually paid your
company?
A. It was Jeffrey Epstein and Company.
Q. So you said you had that position for a couple
of months.
What happened next?
A. Then Mr. Epstein asked me to, if I wanted to
be his employee, because I was going from one house to
another house to another house, one hour here. I was
just running around Palm Beach all day.
So he asked me if I would just work for him,
exclusively for him.
Q. Okay.
A. And we agreed with the terms and I become a
full-time employee as a maintenance guy. And I was
taking care of everything, as far as maintenance.

Page 11
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

about seven months before -- after I become a full-time
employee.
Q. Okay. And how did Ms. Maxwell come into the
picture?
A. It was his girlfriend, his main girlfriend.
Q. Okay. Had you known her before she became -A. No.
Q. -- your -A. Never know her before.
Q. I'm sorry. I didn't get a chance to finish my
question.
Would you have referred to her as your
supervisor or your superior or what would you have
called Mrs. Maxwell?
A. I used to call her Ghislaine.
Q. Okay. And how was it explained to you that
you were now to deal with Ms. Maxwell, as opposed to
Jeffrey Epstein?
A. She would tell me, I am going to take care of
the house.
Q. Okay. That was explained to you by
Ms. Maxwell?
A. Uh-huh.
Q. Is that a yes?
A. Yes.

Page 10
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

Then my job changed little by little to house
man, estate manager, and then to a majordomo.
Q. Okay. When you first agreed to terms with
Mr. Epstein and you first started working for him full
time, what were those terms, do you remember?
A. The terms is basically was how much -- he
asked me how much I was making in all the properties.
And I says, well, I make this -- this amount
of money.
And he says, fine.
Q. And how much was that, did he pay you?
A. Around $45,000. I think I started with 45.
Q. Okay. And when you started to work for him as
a full-time employee, did you have anybody that you
reported to or did you deal directly with Mr. Epstein?
A. At the beginning with Mr. Epstein, directly to
him.
Q. Did that change?
A. Later on, yes.
Q. And how did that change?
A. When Ms. Maxwell, Ghislaine Maxwell came to
the picture.
Q. Okay. About when was it that she came into
the picture?
A. Exactly date, I cannot remember. But it was

Page 12
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

Q. And when Ms. Maxwell started assuming
responsibility for the house, did your duties change at
that time?
A. Not much.
Q. Okay.
A. Not much.
Q. And at that time when Ms. Maxwell started
taking responsibility for the house, what were your
duties?
A. Basically I was still doing the maintenance
work.
Q. Okay.
A. Was doing -- they were trying to remodel the
home and they would told me, okay, tear down this wall.
We want to see how it's going to look. Or put this
windows and tear down -- we had a fishing tank. We took
it out -- I took it out. A kitchen on the second floor.
I took it out. So it was basically dismantling the
house.
Q. Okay. And about how long a period of time did
that project last?
A. I would says, six to seven months.
Q. Okay. And after the remodeling slacked off or
stopped, did your duties then change?
A. Yeah. Increasingly they change.

3 (Pages 9 to 12)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 13
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

Q. Okay. Who -A. Periodically. It didn't change from one day
to another.
Q. And who would tell you that your duties were
increasing?
A. Either Mr. Epstein or Ms. Maxwell.
Q. Okay. And how did your duties increase?
A. In -- I become more -- more involved in the
daily running operation of this home. This home was run
like a hotel basically.
Q. Okay. Were you given any manuals or rules or
procedures that you had to follow?
A. At the end of my stay, yes, I was.
Q. Okay. At the end. And I'm going to jump to
the end now and then come back.
What was it that you were given at the end of
your stay; what kind of papers or manuals?
A. It was a manual. I can't remember how many
pages, but it was quite thick manual that was -- that
was done by estate manager, that she will manage all -all the properties. And that was also to be in force in
Palm Beach.
Q. I see. Do you still have a copy of that
manual?
A. No, I don't.

Page 15
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

living on the property, but outside the house?
A. I was living in the property. No. No. No.
I was working outside the property.
Q. Yes.
A. And because it was multiple jobs that I had to
do.
Q. Okay.
A. Had to do with the pool, the service, the
landscaping, taking care of that. I didn't do it
myself, but I have people working for me.
Q. Okay. Approximately when was it in
relationship to Ms. Maxwell taking over the
responsibility of the house did you then move inside the
house?
A. I will says, after it was done, a big
renovation, when architects and engineers. And that was
after I did the breaking down of this renovation, they
hire architects, they hire decorators and engineers, and
did the -- they did the work. It was a big renovation,
one of the renovations.
And then they make our quarters. They even
built our -- my quarters in there.
Q. When you said "our," was there someone else
who had quarters there, too?
A. About three years later, after I start

Page 14
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

Q. Do you have any papers whatsoever that were
prepared while you were working -A. No.
Q. -- for Mr. Epstein?
A. I left everything in there.
Q. Did you make any diary notes yourself or any
notes for your own private use while you worked for
Mr. Epstein?
A. No, sir. The only thing I have is my
separation agreement. That's it.
Q. Okay. Did you bring that with you today?
A. No, I didn't.
Q. Okay. Did your duties ever include taking
telephone messages?
A. Yes, sometimes.
Q. And when did that start approximately?
A. When I move from the outside to the inside of
the house.
Q. All right.
A. I -- when I start the position, I never had an
apartment in the house. And when I definite they want
me inside to run the house, I had an apartment. I have
a small service quarters in the house, inside the house.
Q. Okay. And when you say, outside the house, do
you mean outside the property or were you -- or were you

Page 16
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

working, my wife came to help me.
Q. I see. And are you able to describe for me
where the quarters were, like, what floor?
A. Yes. It was in the second floor and the -let me trying to remember -- northeast corner of the
property. Northeast corner, yes.
Q. Did anyone else work for Mr. Epstein while you
were working for him there at the house?
A. During the whole time?
Q. Yes, sir.
A. Yes.
Q. All right. When you first started there,
there was no one else?
A. When I started there, was a -- it was a
Jamaican girl that she was doing the cooking.
Q. Okay. Do you happen to remember her name?
A. No.
Q. All right.
A. She worked for couple months.
Q. I see. All right. When did any other
employees begin to work for Mr. Epstein while you were
there?
A. They hire chefs. There was mostly European
chefs. It was an English chef, but I cannot -- Rupert.
I know his name was Rupert. A french chef that was

4 (Pages 13 to 16)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 17
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

Didier. A kid from New York who was a chef, also. But
they were one after another one. They were hiring chefs
when I doing -- sometimes I did most of the cooking.
When they wanted to bring their chef, they bring their
chef in their plane. And the chef will stay, will work
there and then will travel with them.
Q. Were there any other employees that worked for
Mr. Epstein while you were worked for him, that you know
of?
A. No, except my wife.
Q. Did you know a lady by the name of Sarah
Kellen?
A. Sarah, yes, I do. Sarah Kellen came at the
end of my stay there, probably two or three months
before I left.
Q. Okay. Did she do any work for Mr. Epstein,
that you know of?
A. Yes. She was a -- I don't know her deterrent,
but she was an assistant to him or to her. I don't
know.
Q. All right. There is a -- I've seen a
reference in -- and the spelling has changed in my
various references -- is there a N. or N.? Do you
recognize that name?
A. N.

Page 19
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

Q. Were there any photographs of nude females in
the house while you were there?
MR. CRITTON: Form.
MR. WILLITS: What's the matter with that
form?
MR. CRITTON: Overly broad. Nude? You mean,
completely naked?
MR. WILLITS: However you want to interpret
it.
THE WITNESS: Excuse me. Can you repeat that
again?
MR. CRITTON: Form.
BY MR. WILLITS:
Q. Yes. Were there any photographs of nude
females in the house while you worked for Mr. Epstein?
A. Yes. Sometimes I saw nude photographs.
Q. Are you able to describe where you saw those,
where in the house?
A. Most of the times those photographs were taken
by Ms. Maxwell. And they usually are her desk. And she
kept a big album.
Q. Do you remember any pictures of nude or
partially unclothed females on the walls at
Mr. Epstein's house?
MR. CRITTON: Form.

Page 18
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

Q. N.
A. N. Yes, I know N.B.
Q. Want to take a chance at spelling that last
name?
A. I think it was B. But she was not an
employee. She was a guest.
Q. Was she a full-time guest?
A. No.
Q. When would she visit?
A. She was a girl that was very, very talented.
Mr. Epstein help her become an actress. Now she's a
movie actress and she's in a soap opera. She came with
her mother to the house. And she -- he help her come up
with her career.
Q. Okay. Do you -- are you familiar with any
other individuals by the name of N. or N. who worked for
Mr. Epstein?
A. No.
Q. After the renovations were complete, did you
have access to the entire house while you worked for
Mr. Epstein?
A. Absolutely, yeah.
Q. Was there any particular portion of the house
that was denied access by -- to you?
A. No.

Page 20
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

BY MR. WILLITS:
Q. He's just making objections for the record
that he can take -- he will take it up with the Judge
later on.
A. Okay.
Q. You don't need to worry about -A. Yes, it was. It was pictures of partially
nude.
Q. And where were they?
A. Most of the times they were in the pool.
Q. How about on the stairway?
A. No. On the stairway there were no pictures
when I was there.
Q. How many stairways were there?
A. It was the service stairway that is very
narrow coming from the service quarters to the kitchen.
And the main stairway, that it was quite wide
and to the second floor.
Just those two.
And also there was a stairway outside through
the pool to the balcony upstairs.
Q. And do you have a recollection of pictures of
any females whatsoever on either of the inside
stairways?
A. No, I don't.

5 (Pages 17 to 20)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 21
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

Q. What is your understanding, sir, of the -- a
reference to a girl, as opposed to a woman? Are you
familiar with the term, girl?
A. Of course.
Q. Are you familiar with the term, woman?
A. I interpret most a woman, a married woman, a
married person.
Q. Are you -- how would you describe a 14 year
old, a woman or a girl?
A. A girl, of course.
Q. How would you describe a 16 year old, a woman
or a girl?
A. Again, I don't know. I am not -- I don't
think I can tell you exactly she is 14 or 16.
Q. But if you knew -A. Sixteen, I would think is a girl, of course.
Q. Were there ever any visitors to the Epstein
house that you considered to be girls, as opposed to
women?
A. Yes. Yes. I think I would says, I never
check her i.d.
Q. Right.
A. Or I was not told to check i.d.s. -Q. Of course.
A. -- on these girls. But one, I would says,

Page 23
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

Q. Okay. Do you remember any other females being
present at the house, other than the females that you've
mentioned, which were N., her mother, Sarah Kellen, V.
Were there any others that you -A. Many, many, many, many, many.
Q. When did you first -MR. CRITTON: Can I just have the last
question read back?
MR. WILLITS: Of course you can.
MR. CRITTON: Please.
MR. WILLITS: But only once.
MR. CRITTON: That's all I need.
MR. WILLITS: You sure.
Go ahead.
(Previous question was read.)
MR. CRITTON: And can I just ask for a
clarification from you? Are you going to use -- if
you use the word woman, are you -MR. WILLITS: I said, females.
MR. CRITTON: No, no, I understand. But in
the future if you use woman, does that mean, at
least to Mr. Alessi, that that's married, and if
it's a girl she has to be 14 or 16? Because that's
how you asked the question.
MR. WILLITS: All I'm going to talk about is

Page 22
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

N.B. was very young because she was in high school. And
sometimes either I pick her mother and herself from her
house or I pick her from The School of the Arts or the
ballet place, ballet in West Palm Beach. I can't
remember exactly what that place is, the name of the
place.
Q. Did you give -- provide transportation for any
other females while you worked for Mr. Epstein?
A. Occasionally, yes, I did.
Q. Do you happen to remember the names of any of
those females?
A. I remember one, specifically one. It was V.
Her name was V. I can't remember her last name, but I
think it was P. I'm not sure. I can be wrong on that.
Q. And how many times did you provide
transportation services for this female?
A. Whenever I had -- I been told. Whenever I was
told to go get them or bring them back to their house.
Q. Did you consider V. to be a girl or a woman?
A. Again, I think it was a woman, from myself,
her dressing and her -- I think it was -- again, I don't
know if she was 16, 17 or 18 or 19, could have been.
But she was not -- I never pick her up from a school or
anything like that. The only girl that I picked up from
the school was N.

Page 24

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

females.
MR. CRITTON: Okay.
MR. WILLITS: And ask -MR. CRITTON: I'll be alert to the questions
then.
MR. WILLITS: All right. So you don't need to
sleep through the next few questions.
MR. CRITTON: I don't sleep at all.
MR. WILLITS: All right. Now I'm totally
confused.
BY MR. WILLITS:
Q. When did you first become aware of females
visiting the Epstein house?
A. Since I know him.
Q. During the renovations?
A. Yeah.
Q. Were there -A. Before the -- before Ms. Maxwell.
Q. Okay. All right. Let's use that as a
milepost.
Before Ms. Maxwell -A. Before it was Ms. Maxwell, it was only one
woman that it was Mr. Epstein's girlfriend. And her
name was Dr. -- she was a doctor of medicine -- Eva
Anderson. And I really liked this girl. She was very

6 (Pages 21 to 24)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 25

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

nice, nice person.
Q. Did you say Anderson or Underson?
A. Anderson, A-N.
Q. A-N-D-E-R-S-O-N?
A. Yeah.
MR. BERGER: What was her first name?
THE WITNESS: Eva.
BY MR. WILLITS
Q. Before Ms. Maxwell assumed responsibilities
for the house, were there any other female visitors to
the house, except for Dr. Eva Anderson?
A. No, not that I remember. She was one.
Q. All right. After Ms. Maxwell assumed
responsibility for the house, do you recall any female
visitors?
A. Many.
Q. When did that start in relationship to when
Ms. Maxwell assumed responsibilities?
A. Immediately.
Q. Were there visitors who came back more than
once?
A. Yes.
Q. And when I say, "visitors," I mean, female?
A. And males.
Q. I'm only interested in females. Mr. Critton

Page 27
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

A. Because they were local. Some people, they
live in Palm Beach. Some of these girls, they live in
Palm Beach.
Q. How did you know that?
A. They become friends.
Q. Okay. Do you happen to remember the names of
any of those friends?
A. I remember there were some girls that come
multiple times and they're usually there for dinners or
lunches. One was G.B., G.B.
Q. Okay.
A. I think she was a -- she used to work for
Stanley, Morgan Stanley. My son work at that time same
person.
Q. Okay.
A. Try to remember names, but there were a lot of
visitors in the house, a lot of female visitors.
Q. Are you aware of female visitors to the house
who were there to perform massage services?
A. Yes.
Q. Do you recall the first time that you observed
a female come into the Epstein house for the purposes of
massage?
A. I don't recall that.
Q. How many different individuals came to the

Page 26
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

may be interested in the males. I'm not sure.
Did you have any information as to where these
visitors came from?
A. They were mostly European girls.
Q. And when you say, "girls," do you mean 14 to
16, -A. No.
Q. -- or do you mean females?
A. They all were, I would says, under -- over 20
years old.
Q. Okay. And it has been explained to us in
another deposition that sometimes females travelled with
Mr. Epstein.
A. Yes, they did.
Q. Are these females that you are referring to,
did they travel with Mr. Epstein or did they get to the
house in other ways?
MR. CRITTON: Form.
THE WITNESS: Both.
BY MR. WILLITS:
Q. Both. Okay. Were you aware of any female
visitors to the Epstein house from the local area of
Palm Beach County?
A. Yes.
Q. How -- and why did you become aware of that?

Page 28
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

Epstein house for the purpose of massage, as far as you
understood it?
A. In the -- I would says, between 50 and a
hundred different persons.
Q. Do you happen to know any of those names?
A. I remember couple names.
Q. Okay.
A. And the last name I asked -- I going to tell
you there were girls that come multiple times and there
are girls who come one times and that was it.
Of the multiple time the girl -- the girls
come to the house -- "girls," again, mean -- I'm going
to refer everybody as girls.
Q. Okay. But you don't necessarily mean under
the age of 18 when you say -A. None of these girls were under the age of 18.
Then again, I don't know. They could have been 18 or 19
or 20 or 25. I don't know. But they were all masseuses
and they came to the house.
One of the names that I remember was D.D.
Q. That's D.?
A. Uh-huh. D. I think it was.
So many. J., A., C., J.
There were also massage therapists from
Europe. They sometimes travel with him in the plane.

7 (Pages 25 to 28)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 29
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

And some just names that I cannot -- I cannot go on.
Q. Sure. How did you know that D. or J. were
there for purposes of a massage?
A. Because I was told to either Ms. Maxwell will
call, I will call or Mr. Epstein will told me, call this
girl at that time. Sometimes it was 1:00 in the
morning. Sometimes it was within the afternoon.
Sometimes it was after the movies. They usually go into
a movie every night after dinner. And sometimes were
girls that come at 10:00, 10:30.
Q. How would you know what number to call?
A. I had a list.
Q. Okay. Was this a list that you prepared or
was given to you?
A. I had a list that it was in my Roladex.
Q. Okay. So as part of your job there was a
Roladex?
A. Yes.
Q. Who put the information on the Roladex?
A. I think I did most of the times or I was given
a piece of paper, says, call this girl, put a number.
And I will call her. And if she was coming back, then
I'd put her as a regular massage therapist.
Q. Do you know how these females would be
transported to the Epstein house?

Page 31
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

Royal Palm Beach.
She had -- she was living with a boyfriend and
another person in this apartment complex in Royal Palm
Beach.
Q. Okay. Do you happen to remember any other
areas of the county where you transported any of the
females?
A. I transport her -- one back to a house in
Jupiter.
Q. Okay.
A. That's what I can remember now.
Q. Did you ever speak to any of these females
that you have mentioned -- let's talk specifically about
the ones that you have named, D., J., A., C., J. -about what they did there at the Epstein house?
A. No. They did massage therapy.
Q. And how did you know they were actually
providing massages?
A. Most of them, they had business card and they
left me business cards. And some of them asked me to
call them to provide them work.
And I says that was not my job. My job was to
call whoever they wanted. Either when she -Ms. Maxwell want a massage, she will told me, I want a
massage at this time with this person.

Page 30
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

A. Ninety-nine percent they -- they would drive
their own cars.
Q. And when they did not drive their own cars,
how -A. Some, they were transported by the boyfriends
or the husbands and they wait outside.
Q. How about, are you aware of any of the females
being transported to the house by virtue of a taxi?
A. I think it was an occasional time that I have
to send a girl in a taxi, if I was going to be busy for
transporting them.
Q. Did you ever provide transportation to any of
the females who were there for purposes of massage?
A. Yes, I did.
Q. Okay. Do you remember where you went?
A. I remember specifically on V., -Q. Okay.
A. -- that she used to live with her boyfriend in
Royal Palm Beach.
Q. All right.
A. And when she went the first time, she -- she
went by herself. I never had to bring her back. But
later I was told by Mr. Epstein to go and pick her up.
And she give me the -- or he give me the address and the
phone, so I call her and I went and pick her up from

Page 32
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

Q. Uh-huh.
A. Or Mr. Epstein will call me and he says, get
this girl at this time.
So it was not my job to pick and choose these
girls.
Q. Did you have anything to do with paying any of
these females?
A. Occasionally, yes, I did.
Q. Can you describe that?
A. The most -- the regular girls that came to the
house, sometimes they got paid once every night or every
day or I knew them and they would just say, just keep a
tab of the hours and I will pay amount at the end of the
week.
Q. And how were they paid, by cash or check?
A. Most of the times, I would says, 95 percent of
the times I was paid by check.
Q. I mean, the females?
A. The females, -Q. The females were paid?
A. -- I would pay them by check.
Q. Out of what account?
A. I was -- I have an account that I was from the
bank for Jeffrey Epstein and my name was on it. I would
sign the checks. I will make a copy of a check. I will

8 (Pages 29 to 32)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 33
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

make the girl sign a paper that they receive check for
$500 for five massages.
Q. And do you remember where that -- what bank
that account was with?
A. I think Palm Beach National Bank on Worth
Avenue.
Q. Did you ever have any occasions to make
deposits to that account?
A. Yeah.
Q. Where would the cash or checks come from to
make deposits?
A. Checks. There was checks, big checks for
Mr. Epstein.
Matter of fact, one time I was so scared. It
was a couple million dollar checks that I -- he told me
to go and deposit.
Q. You said that usually these girls were paid by
check. Were there occasions when the females would
be -A. There were occasions -Q. -- paid by cash?
A. -- where the girls says, do you have any cash,
John? They were asking for cash.
I says, let me take a look. So I check my
petty cash box that we have for the house for the

Page 35
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

Q. -- the employment of Mr. Epstein, who were the
other employees? You mentioned Sarah Kellen. Anybody
else there?
A. The chef, but the chef also work in Europe, so
he was travelling with him.
Q. Right.
A. He had a room.
Then it was another renovation of the house in
the middle -- about a year and a half before my
departure. And there was a house built for the -- away
from the -- from the main house. It was a service
house. There was couple rooms in there with a kitchen
and a living room. So he will have a room in there, the
chefs.
Q. Okay. Does the name L. ring a bell?
A. No. Never saw her.
Q. Do you recognize the name Joe Joe as somebody
who worked for Mr. Epstein?
A. Joe Joe? Joe Joe, as far as I knew, it was -I met him. He was the house man in New York.
Q. Okay.
A. It was him and his wife -Q. All right.
A. -- that were the people, they handled the
house in New York.

Page 34
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

expenses. And if I have it, I pay it. If not,
Mr. Epstein will pay.
Q. Did you ever have any concerns that any of the
females coming to the Epstein house for the purposes of
massage might be under the age of 18?
A. No, because I never saw younger, young, young
girls. And mostly that I was told they were massage
therapists.
Q. Told by who?
A. By Ms. Maxwell or Mr. Epstein.
Q. Did you ever have any dealings with Sarah
Kellen about the females who came to provide massage
services?
A. No. Sarah Kellen came about, I would says,
the most two months before my departure.
Q. Okay. Do you think that you would be able to
recognize any of the females if you saw them or their
pictures?
A. Pictures? Yeah, I think so.
Q. Did you ever have any discussions with any
fellow employees about the females who were coming to
provide massage services?
A. No.
Q. At the time that you left -A. Yes, sir.

Page 36
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

Q. Did you ever personally observe a massage
taking place in the Epstein house?
A. Never.
Q. Did you ever have occasion to clean
Mr. Epstein's bedroom after a massage?
A. Every time.
Q. Did anyone assist you with that?
A. Sometimes.
Q. Who would be -- who would assist you?
A. Depends on the day of the hour. Sometimes the
cleaning crew that we had, if it was the right date, the
right time, they will go out and clean up. But most of
the time I was involved. I was the one.
Q. Did you ever observe any vibrators in
Mr. Epstein's bedroom after a massage?
A. Yes, I did.
Q. How many?
A. Two.
Q. How many massage tables were there at the
Epstein residence while you worked there?
A. It was permanent massage tables or we had
tables for every room of the house. So it was about the
blue room, the red room. It was a massage table for the
balcony. It was on Mr. Epstein's bathroom,
Ms. Maxwell's bathroom. There was Ms. Maxwell's

9 (Pages 33 to 36)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 37
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

bathroom was in the same quarters, his quarters.
So we had quite a bit of expensive tables.
Q. Did you ever get a massage while you were
working for Mr. Epstein?
A. I wasn't that lucky.
Q. Okay. I'm sorry.
A. I don't want to lie. Yes, I did. By a guy.
It was a -- occasionally it was male massage
therapists there, there were called. They did massages
for Mr. Epstein and Ms. Maxwell.
And one time I had some pains in my back and I
was given as a gift.
Q. Now, there came to be an incident where you
were arrested that caused you to be terminated from
Mr. Epstein?
A. No.
Q. Were you terminated from Mr. Epstein's
employment?
A. Yes.
Q. Did you promise to pay him back some money?
A. Yes.
Q. Did you make all the payments?
A. Yes, I did.
Q. When was the last time you made a payment?
A. I made a payment immediately, the same

Page 39
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

Q. The latter?
A. The latter.
Q. What, if anything, can you remember or tell us
about your separation agreement?
A. It was basically an agreement between him and
myself that we will leave after all those years of
service.
And I regret to agree with the amount, but it
was $30,000 for me and $20,000 for my wife.
And it was -- he give my wife the car that she
usually drive. It was a minivan, Chrysler minivan, as
part of the -- as part of the separation. She loved
that car and she did all the shopping, it was done in
that car.
So Mr. Epstein was kind enough to give her the
car.
The rest of the stuff is, was mainly lawyer
stuff that you can't understand. But basically that was
it. And that it was a part that I think I can -- I
would says, it was more or less that I will not sue him
later or he cannot sue me for any reasons or -- and it
was like a confidentiality issue in that separation
agreement.
Q. And do you understand that in this instance
you are subpoenaed under the power of the Court?

Page 38
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

payment, same amount.
Q. The full amount?
A. Full amount.
Q. Okay. It wasn't a payment plan?
A. No.
MR. WILLITS: I don't have any other
questions. You want to take a short break?
MR. CRITTON: Would you like to take a short
break?
THE WITNESS: I'm fine.
VIDEOGRAPHER: Off the record, 10:56.
(Brief recess.)
CROSS EXAMINATION
BY MS. EZELL:
Q. I'm Catherine Ezell. I want to ask you a few
questions about some things that came up during your
deposition, your earlier questioning in this deposition.
A. Okay.
Q. The book of policies that you mentioned that
was there by the time you left, I just wanted to
clarify, was that done by somebody in Palm Beach to be
used by different households in Palm Beach or was it
done by someone employed by Jeffrey Epstein to apply to
all the homes he -A. Yes.

Page 40
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

A. Absolutely.
Q. And that would include matters that would
otherwise be confidential?
A. Can you repeat that again?
Q. Yeah. Do you understand that because you're
under subpoena by the Court to give your testimony, -A. Today.
Q. -- truthfully -- yes.
A. Uh-huh.
Q. That the confidentiality agreement would not
control; the Court's subpoena -A. Oh, yeah.
Q. -- controls?
A. I understand that.
Q. You mentioned Ghislaine Maxwell did photo
shoots and kept an album?
A. Yes. She was fanatic about photographs -camera. She had a whole bunch of different cameras and
she took all the pictures all over.
Q. Did you ever observe her doing a photo shoot
of V.?
A. No.
Q. Did you ever observe her doing a photo shoot
of any of the other young women whose names you
mentioned?

10 (Pages 37 to 40)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 41
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

A. Young woman?
Q. Yes.
A. No, I can't remember. I know that she went
out and took pictures in the pool because later on I
would see them at the desk or at the house.
And nude -- 99.9 percent of the time they were
topless. They were European girls. They were -Q. You stated that you believe V.'s name was P.,
but you weren't sure?
A. Not sure.
Q. Could it have been R.?
A. R., yeah. Yeah. Could have been.
Q. I want to show you a picture and have it
marked as an Exhibit to this deposition.
MS. EZELL: And did we have the agreement
beforehand that we've been having all along that
we're just using initials and not names?
MR. WILLITS: My client has waived the
confidentiality as to herself. But I certainly
agree as to everybody else.
MR. LANGINO: As do I.
MS. EZELL: Is that okay?
MR. CRITTON: That's what we agreed to on the
last.
MS. EZELL: Right.

Page 43
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

V.R.? Obviously the tape preserves it. We're not
asking the tape gentleman to edit it.
MS. EZELL: Right.
MR. BERGER: So how is it preserved that V.R.
means your client's full name?
MS. EZELL: Well, we had just agreed in
previous depositions that that's the way it would
read. The written transcript would not have the
full name, but would just have the initials.
MR. BERGER: I'm not so sure that constitutes
an identification by Mr. Alessi that's going to be
clear. But this is the first deposition I've
attended, so I'm not sure if I'm -- if what I'm
saying has been dealt with or not.
MR. MERMELSTEIN: I think we're working on
good faith. Mr. Critton is agreeing that the
name -- and I don't think anyone's going to come
back later and say, oh, you meant Vince Robinson or
anything like that, so...
MR. BERGER: Well, I'm not -- I'm not talking
about Mr. Critton. Bob Critton I have the full
trust in. I'm just talking about a jury watching
this or reading this transcript believing that
Mr. Alessi has accurately identified one of these
victims. That's all. I don't know if you've all

Page 42
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

MR. CRITTON: For the court reporter, at
least, in terms of the -- I guess in terms of the
transcript she gives to us, if you would just use a
first initial and a last initial.
MR. WILLITS: So when you ask about V., it
would be V.R. is what the court reporter would
write down?
MS. EZELL: Right.
MR. CRITTON: But make sure everybody uses the
full name, because that way we'll have two
initials.
MR. WILLITS: When they speak, but she's going
to write it down as initials. Is that what you're
saying? I'm confused about everything.
MR. CRITTON: The reason is, is there may be
25, you know, there may be three V.s. So if you
just mention V. and it just shows up as a V., it
won't make sense. So ergo you need to do that.
But Carolyn Andriano, his client, she gets the
whole megillah.
MR. WILLITS: Right.
MR. BERGER: How is it preserved that we're
talking about your client? You gave her full name
a minute ago. How is it preserved if she's -- the
court reporter is going to change the full name to

Page 44
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

thought about that.
MS. EZELL: Well, for one thing, the jury
might, if they're -- if they're hearing or reading
his testimony, they most likely would be seeing the
video, which would have the full name. Unless the
Judge allows us to block out names and we haven't
come to that point.
MR. MERMELSTEIN: I think the idea at trial,
V.R., if it's read to the jury would become then
V.R. It would be read as V.R. But if it's filed
with the Court, this transcript, it will be V.R.,
and that way it doesn't have to be redacted.
MR. WILLITS: As I also understood it, if
there would be any question at all, we could simply
ask the court reporter and she would say, according
to my notes, V.R. is Virgil Robinson and not -- or
whatever her notes show. Wouldn't she be the final
authority?
MS. EZELL: Well, she would certainly have
that record.
MR. CRITTON: You could listen to the tape.
It would be pretty easy. I think we're making it a
lot more complicated than it need be.
MR. WILLITS: For once, I agree.
MR. CRITTON: I think it will be all right.

11 (Pages 41 to 44)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 45
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

MS. EZELL: I'm going to ask -- I don't know
whether you've still been serially designating
Exhibits or whether we're doing them separately for
deposition.
MR. CRITTON: I think we cannot trust that
people will do them serially. I'd do them with
each one.
MS. EZELL: Then would you mark this, please,
as Exhibit 1 to this deposition.
And I'm just going to state on the record that
I will keep that original. We will not attach it
to the deposition.
(Exhibit number 1 was marked for
identification purposes and retained by Counsel for the
Plaintiffs.)
THE WITNESS: Yes, that's -BY MS. EZELL:
Q. Can you identify that -- the young woman in
those pictures?
A. Yes.
Q. Who is it?
A. That's V. -- V. Now that you says R., that
is V.R. definite, a hundred percent.
MR. CRITTON: Let me just note my objection,
as I did in A. Rod's deposition or Mr. Rodriguez's

Page 47
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

THE WITNESS: Could have been. But, you know,
I am not -- I don't think I am a very good judge of
ages. If you ask me how old you are, I really
couldn't tell you.
MR. CRITTON: Kathy thinks she's 25.
MS. EZELL: In my dreams.
THE WITNESS: Now, again, I must tell you, I
was never told to check any i.d.s on any of the
people who work at the house.
BY MS. EZELL:
Q. I understand that. And, so, I think I'm just
trying to establish that you didn't consider it part of
your job description to worry about or consider the
ages -A. No.
Q. -- of the young women that came there?
A. Absolutely not. Absolutely not.
Q. And, so, you never really focused on that or
particularly thought about it if they seemed young?
MR. CRITTON: Form.
THE WITNESS: I don't -- I didn't see that
many young girls, you know, young, underage girls
at the house. I never saw except the two girls
that I mentioned that I think it was underage was
N. for sure because she was still in high school.

Page 46
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

deposition, that I know you're going to confiscate
Exhibit number 1. I think it's inappropriate. I
think I should be allowed to have a copy of
Exhibits that are being used in deposition. But
I'll file a motion with the Court so we don't get
into a pulling match over your Exhibits.
MR. BERGER: I would ask that the court
reporter initial that.
MS. EZELL: Sure.
Oh, you did?
MR. WILLITS: She marked it.
MR. BERGER: Did she put her initials or did
she just put a number or a letter?
MR. CRITTON: She's nodding that she did
everything that she usually does, which means,
initials, date and number.
MR. MERMELSTEIN: You can talk.
MR. WILLITS: But when you talk, use your
initials.
BY MS. EZELL:
Q. How old did you think V.R. was at the time she
began coming to Mr. Epstein's home?
A. She could have been 17, 18, 19.
Q. Could she have also been 15?
MR. CRITTON: Form.

Page 48
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

And she -- she had dinner with her mother, a couple
times with her mother. And she become an actress.
She's an actress and she has done movies. And he
help her in her career.
That's the only girl that I knew she was young
because she was going to high school and I pick her
up from high school sometimes. But she was not a
massage therapist. She will go for dinner. And
they will go for the movies and she sang sometimes
because she was a singer. So she sung at the
house. Beautiful girl. Very talented.
That's the only girl that I know that it
was -- I would says, underage.
BY MS. EZELL:
Q. Okay. Did -- who told you that V.R. was a
massage therapist?
A. Nobody.
Q. Did you assume that she was a massage
therapist because you were told she was coming to give a
massage?
A. No. I assumed she was a massage therapy
because I was -- I drove Ms. Maxwell to Mar-a-lago,
Donald Trump's residence. And I wait in the car while
Ms. Maxwell got a -- I think it was a facial or massage.
I don't know. But that day I remember this girl, V.,

12 (Pages 45 to 48)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 49
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

walking down from the main lobby towards the spa of
Mar-a-lago. And I was driving Ms. Maxwell up, up the
ramp. It's a little ramp there.
And Ms. Maxwell says, stop. And she went and
talked to -- she went inside.
And that afternoon around 5:00 I saw V. came.
She came to the house already, so she was there already.
That was the first day I knew. And then she would come
regularly.
Q. Did you ever meet any of V.'s family?
A. No. I think she was -- one time I think her
father drove her there. And I met -- I don't know if it
was the boyfriend or husband or -- but he had to wait,
make him wait outside while she was at the house.
Q. Do you know the name or recognize the name
Tony Santiago?
A. I think it was him.
Q. That was her -A. I know he had an old beat-up car, Camaro or
Mustang. I know it was very old car that I make him
wait on the street one time. I make him come out of the
driveway because we have to move some cars around.
Q. Did there ever come a time when Tony Santiago
was welcome in the kitchen?
A. I think he came once in the kitchen, but

Page 51
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

there. So I would says, between three months maybe
before I left. And I think I left at the end of the
year, so it could have been -- I remember it was a very
hard day because I had to wait in the sun outside in a
convertible and I was dying, waiting for an hour for
Ms. Maxwell. I think it was in the summer of 2002.
Q. And if I remember correctly, you left in
November or December of 2002?
A. Yes.
Q. So that might have been perhaps July or August
of 2002?
A. Uh-huh.
Q. And, so, as I understand it, you only saw V.R.
come to that house during the last three months of your
time at Mr. Epstein's?
A. Yes.
Q. Do you have any -- any sense or can you
approximate how many times she came?
A. I cannot give you a number, but I would says,
two, three times a week.
Q. You mentioned that sometimes you would have to
call these massage therapists in the middle of the
night. Did you ever have to call V. for Mr. Epstein in
the middle of the night?
MR. CRITTON: Form.

Page 50
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

Ms. Maxwell told me to get him out.
Q. Did she tell you why?
A. No. She didn't -- I guess she didn't want to
become, you know, everybody -- because some of these
people came with their husbands and they wait outside.
And I guess she didn't want this to become a norm for
everybody to bring their companions while they have -they will do a massage for her.
Q. During the time you were there, did you ever
know of Tony Santiago bringing any other girls to
Mr. Epstein?
A. No. I knew that sometimes I saw V. bring
other girls with her, not Tony Santiago.
Q. Do you remember the names of any of those
girls -A. No, I don't.
Q. -- that V. brought?
A. That was at the end of my stay there. No.
That was a very -- at the very end of the last month of
my stay.
Q. Did you give -- I don't believe I asked you,
but if I did, forgive me. Did you give us an
approximate year in which you were taking Ms. Maxwell to
Mar-a-lago and saw V.R. for the first time?
A. That was at the -- at the end of my stay

Page 52
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

THE WITNESS: No. No.
BY MS. EZELL:
Q. Did there come a time while you were there
that V.R. stayed in the house?
MR. CRITTON: Form.
THE WITNESS: I don't think so. I cannot
remember. No.
BY MS. EZELL:
Q. How many bedrooms were there upstairs?
A. One, two, three -- one, two, three, four -four -- so that would be five, five bedrooms.
Q. Five. And, so, would one have been
Mr. Epstein's bedroom?
A. Yes. His quarters was big, huge quarters.
Q. Sort of a suite?
A. Yeah. And he has -- this is the room. His
bathroom was here and her bathroom was here. The main
room was here. And we have -- it was two sets of doors
before -- two sets of double doors before you can go
into the suite. There was one on top of the stairway
and one in the middle of the hallway. And then you walk
into the -- into the suite.
Q. Okay. And you -- you just put a red eight by
11 folder in front of you?
A. Yeah.

13 (Pages 49 to 52)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 53
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

Q. And you said, "this is the room."
Do you mean that is Mr. Epstein's room?
A. And Ms. Maxwell.
Q. And Ms. Maxwell?
A. Yes.
Q. And his bath was on one side and hers was on
the other?
A. Yes. Yes, ma'am.
Q. So did she not have a separate bedroom?
A. Ms. Maxwell? No. Sometimes she slept in a
different bedroom. Don't ask me why.
Q. Okay. But generally at that point in time she
was still -A. Yeah.
Q. -- sleeping in, for most nights, the same
bedroom -A. Yeah.
Q. -- as Mr. Epstein?
A. Uh-huh.
Q. And then there was the service quarters, the
service department?
A. The service quarters before we moved down to
the other house, it was in one corner of the property in
the second floor.
Q. And what -- what other bedrooms were there?

Page 55
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

A. Yes.
Q. And who, if anyone, stayed in the blue room?
A. Yes, many.
Q. Guests who would come and go?
A. (Nods head.)
Q. And in the red room?
A. Same thing.
Q. Again, guests?
A. Yes.
Q. And did you say that N.B. did spend nights
there?
A. No, not that I remember.
Q. She never did?
A. Not that I remember, no. Because she was not
there until the whole length of time that I work for
Mr. Epstein. She was there for maybe a year or two
years. Then she moved to California. She was -- moved
the whole family to Hollywood.
Q. And that's N.B.?
A. N.
Q. You mentioned Dr. Eva Anderson?
A. Uh-huh.
Q. I believe you said she had been a girlfriend
of Mr. Epstein's -A. Yeah.

Page 54
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

A. In the service quarters?
Q. No.
A. In the total amount?
Q. On the second floor.
A. On the second floor.
Q. Other than -A. It was the -- it was a pink room, we called
the pink room. We called the blue room. And the parrot
room. We call a parrot room because there was a crazy
designer, all full of parrots. It look like you were in
the jungle. But that was changed, so that became the
blue room.
So it was the blue room, the red room and the
pink room. That was the main guest, for the main guest
rooms.
Then it was my room and we have like a little
sitting area for ourselves, for myself.
And upstairs there were one, two, three, four,
five, six, six bathrooms.
Q. During the time you were there who, if anyone,
stayed in the pink room?
A. Many people.
Q. Guests?
A. Yes.
Q. Who would come and go?

Page 56
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

Q. -- before -A. I understand.
Q. -- Ms. Maxwell?
A. Yeah.
Q. And were there times when she would stay in
the house?
A. Yes.
Q. Would she stay in the house when Ms. Maxwell
was there as well?
A. Yes.
Q. And did she have sort of a regular room there?
A. Let me repeat. Can you repeat that again, the
questions before? Because I think I says, yes, when
Eva -- when Maxwell was there, I not think -- I can't
remember Eva being there. She was there for a little
bit because they become friends after that and they have
dinners and lunches and she would come, because Eva got
married and she had kids and -- and they were -- called
Mr. Epstein, Uncle Jeffrey.
So they become friends. And -- but I don't
think she ever slept at the house again because she had
her own house in Palm Beach.
Q. When you first went there to work would she
sometimes sleep at the house? Was that before she was
married?

14 (Pages 53 to 56)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 57
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

A. Yes. Before she was married, yeah. They
split up and she went her own way.
Q. Did she marry a Glen Dubin (phonetics)?
A. That's correct. And Mr. Dubin used to come to
the house, too.
Q. Do you know, was Sarah Kellen ever one of the
massage therapists before she became an assistant?
A. I don't know if she was a massage therapist.
I don't remember setting up a massage table for her. I
think she was an assistant. And she would call -- at
the end of my stay, I was -- tried to pull aside from my
obligations and Sarah was doing all the phone calls and
all the arrangement and all the looking out for these
girls for the -- for massage therapists. They were
constantly.
Q. When did that role get transferred from you to
Ms. Maxwell, the role of looking after girls and calling
the girls?
A. I didn't look after -- out for girls.
Ms. Maxwell was the one that recruit -- I remember one
occasion or two occasions she would says to me, John,
give me a list of all the spas in Palm Beach County.
And I will drive her from one to the other one to PGA
and Boca. And she will go in, drop credit cards -- not
credit cards, but business cards, and she come out. And

Page 59
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

Q. And they called him uncle, you said?
A. They called him uncle.
Q. Did you ever learn what Tony Santiago did for
a living?
A. No.
Q. Have you had any occasion to see him since the
time you left Mr. Epstein's employ?
A. No.
Q. And you don't -- do you have any idea where he
is?
A. I have no idea. I remember an incident, one
time the -- I went to pick her up at Royal Palm Beach
and she was crying and I went and knock at the door and
she was crying. And she says, well, -- I think it was
Tony or -- because she used to live with these other
guys, too. There were two guys and her or two couples.
I don't know the arrangements there. But I remember
that she told me the -- Tony or her boyfriend had got
mad and ripped the furniture, he cut the furniture in
pieces and he even broke the screens. Because I was -when I went into to knock the door, the screen was all
ripped up like it was cut.
And she told me that he got mad at -- I don't
know what happened. I never saw him in there.
Q. Did she tell you he had hit her or beaten her

Page 58
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

then we go to -- she will recruit the girls. Was
never -- never done by me or Mr. Epstein or anybody
else, that I know.
I don't know about Sarah because Sarah was
there at the last, last -- probably last weeks of my
stay there. So I cannot say anything about Sarah.
Q. Was there any point in time -- well, let me
ask you this way: Did -- you said sometimes you would
call the girls to come -A. Uh-huh.
Q. -- to give them massage. And sometimes
Ms. Maxwell would?
A. Yeah.
Q. Did there come a time when she took that over
entirely from you -A. No.
Q. -- or that continued -A. That's continued.
Q. -- until you left?
A. Yeah.
Q. Do you remember, is Jeffrey Epstein godfather
to one of the Dubin children?
A. I don't know if he godfather. I don't
remember that. But he was very fond to these children,
the children.

Page 60
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

at all?
MR. CRITTON: Is the she, V., V.R.?
MS. EZELL: Yes. Thank you.
BY MS. EZELL:
Q. Did you ever see during the time you were
there photographs of V. in the house, the Epstein house?
V.R. in the Epstein house?
A. I don't think so. I don't think so.
Q. Did you ever see photographs of V.R. in
Ms. Maxwell's albums?
A. No.
Q. At the time you were employed by Mr. Epstein,
were there any hidden cameras?
A. No.
Q. You do know that he installed some after you
left, correct?
MR. CRITTON: Correct.
THE WITNESS: I don't know.
BY MS. EZELL:
Q. Wasn't there a camera involved in the incident
that -- the incident in which you took money from
Mr. Epstein?
A. Yeah. Yes. But I don't know if he install it
or not. That's what he told me.
Q. Okay.

15 (Pages 57 to 60)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 61
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

A. But we settled that completely out of Court.
It was a, I will pay you back. I'm sorry. I made a
mistake. And that was the end of it.
Q. I understand. And, so, you have no idea then
where the cameras were -A. No idea.
Q. -- installed?
A. I was never back at the house after that.
Q. Okay. I just want to ask you if you recognize
any other names.
Do you recognize a name, E., who was a friend
of Ms. Maxwell?
A. E.T.? Yes.
Q. And was she English?
A. English. And she travel all the time with
them. Not -- I would says, not a hundred percent of the
time, but she travel maybe 60, 70 percent of the time
for a period of years.
MR. CRITTON: So I'm clear, is it Annie?
MS. EZELL: E.
THE WITNESS: E.T.
MS. EZELL: E. or E. I'm not sure.
MR. CRITTON: Thank you.
BY MS. EZELL:
Q. Did she have a regular room in which she

Page 63
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

the pool. But other than that, they were regular
massages.
Q. Did you know a young lady named C. who would
come to the home?
A. C. She was also English?
Q. I don't know?
A. I think I remember a C.
Q. And was she one that came to give massages?
A. C., C., C., C., C., C.
When you deal with all these girls' names. I
think C. was, yes, she was a massage therapist. But I
think she used to -- I could be wrong, but I think she
live in New York and she travelled with them once in a
while.
Q. Were some of the women that travelled with
Mr. Epstein models, to your understanding?
A. Very beautiful models. Very nice. Very,
very -- most of them were models, models.
Q. Did you know anyone named C.F.?
A. No. C.F. no. No.
Q. Jean Luc Bruhel?
A. Jean Luc? Jean Luc was a guy.
Q. I know that. Did you know him?
A. Yes, I know him.
Q. Who was he?

Page 62
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

stayed -A. Yes.
Q. -- when she was there? Which one was that?
A. That was the pink room. When she came, she
stay in the pink room.
Q. And do you have any idea what her relationship
to Ghislaine Maxwell was?
A. I understand she was her assistant. And she
will answer the phones. And she will go shopping with
her sometimes. And she will -- basically they were
friends. I don't think she -- I don't think she was a
massage therapist ever. I don't think she ever was a
massage therapist.
Q. Do you know whether the young women that you
referred to as massage therapists came there to give
massages to both Mr. Epstein and Ms. Maxwell?
A. Yes.
Q. And do you know if E. was ever included in
that activity?
A. I have no idea because when they went upstairs
they shut all the doors and it was absolutely pitch
black in the room. It was no -- we never saw any
massages done. Occasionally we saw a massage, like, if
Ms. Maxwell wants a massage by the pool, I would set up
the table by the pool and they will have a massage at

Page 64
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

A. He was -- he -- matter of fact, I went to his
house a couple of times with Mr. Epstein. And he was a
friend of Mr. Epstein. He was a -- he was French, I
think, French. And he was -- as far as I know, he had a
model agency in Miami, one of the big model agencies in
Miami.
Q. And do you know whether or not Mr. Epstein had
any interest in that model agency?
A. No. No idea.
Q. Do you know whether or not they were business
partners in any way?
A. No, I don't.
Q. Did he ever come over for massages?
A. He came to the house couple times. I think
he -- it might have been occasions where he stay
overnight.
MR. CRITTON: Move to strike as
non-responsive, to at least your question.
BY MS. EZELL:
Q. You indicated that you had been to his home.
So did he have a home in Palm Beach?
A. No. He has a home in Miami Beach.
Q. Miami Beach.
Did you know anyone named D. or D.B.?
A. D.?

16 (Pages 61 to 64)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 65
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

Q. D.
A. It sounds familiar, but I cannot tell you for
sure.
Q. You mentioned some of the chefs. You didn't
mention -A. There was -Q. -- Ryan Dion (phonetics). Was there someone
there named Ryan Dion?
A. No. It was a kid from New York. His name was
Don Perry. Perry?
Q. And would he travel with Mr. Epstein?
A. Yeah.
Q. Now, when -- before the addition out back was
done, I believe you said the chefs would stay back there
sometimes?
A. Uh-huh.
Q. Before then, where did the chefs stay?
A. In the blue room in the back, the one close to
mine.
Q. Did you ever meet any of Mr. Epstein's family;
his brother, for instance?
A. Absolutely, yes.
Q. And what was his brother's name?
A. Mark Epstein.
Q. Would he come and visit regularly?

Page 67
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

Q. And do you know what he did for a living?
A. He has -- I knew he had a printing company,
printing the big logos, the big movie projection
company.
Matter of fact, my son, when he graduate, he
went to work for Mark for about couple months in New
York as a -- as a -- as a trainee. I don't think he
ever got paid, but he -- he was trying to learn the
business and Mark gave him a job. That was for few
months.
Q. How often would Mark Epstein come to Miami?
A. Not too often. Not too often.
Q. When he came, do you know, did he participate
in having the massages?
A. No.
MR. CRITTON: Form.
THE WITNESS: Never.
BY MS. EZELL:
Q. He did not?
A. Never.
Q. And how do you know that?
A. Because it was never -- I was never told to
set up a massage in any of the rooms for Mark or his
mother. They were not too close.
Q. Mark and Jeffrey Epstein are not too close?

Page 66
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

A. Regularly.
But I was more involved with her mother. I
took care of her mother, Mr. Epstein's mother. She was
a very ill lady. I don't know if she's still alive or
not, but I lost contact.
Q. How often would she come to visit?
A. She didn't come to visit too often. She had
an accident, a very bad accident. She lost her trachea,
so she had a -- how they call the -- the thing they put
them in your neck to talk?
Q. Sort of a voice box. I don't know the
technical name.
A. I don't know the technical name, -Q. Right.
A. -- but they open her throat and she had this
thing to talk and she had to cover her throat to talk.
And I was more involved with her than her own
kids. I took her to Miami for the operation. I was
there for the operation. And she -- we have a lot of
fun with her. I mean, she -- she was a very good lady.
Q. Now, other than Mark Epstein, were there any
other brothers and sisters?
A. No. He only has one brother that I know.
Q. And where does he live?
A. He lives in New York.

Page 68
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

A. I would says, they were not. I don't think
so. That was my opinion.
Q. Do you know the name Daniel Estes?
A. No.
Q. Do you know the name Matt Groning (phonetics)
-- Groning?
A. No.
Q. I think you mentioned Mr. Wexler?
A. I believe so.
Q. That you knew him early on?
A. Yes.
Q. And did some work for him?
A. Also his mother. I work on his mother house
in Palm Beach.
Q. Did he also have a home in Palm Beach?
A. Before -- he had a home in Palm Beach before I
went to work for his mother. So I never work on his
home. But I work on his mother home. I don't know if
it was his home or that was used to -- Mrs. Wexler used
to live there.
Q. Did he come over to the Epstein home
frequently?
A. Occasionally.
Q. Did he ever participate in the massages?
A. No.

17 (Pages 65 to 68)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 69
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

MR. CRITTON: Form.
THE WITNESS: No, not that I can remember.
BY MS. EZELL:
Q. Do you know if he and Mr. Epstein were
involved in any businesses together?
A. Mr. Epstein, I never knew what businesses he
was involved. He will -- I was completely shut off of
all of the business, except for the office, transfer of
communications or faxes. But I have no idea of the
relationship with other business partners.
Q. Did you ever have to deal with his -- the
office in New York with someone named Lesley in New
York?
A. The secretary?
Q. Yes.
A. Yeah. I would call -- I would call Lesley
almost every day or other secretaries, they live in New
York. Basically it came a point when Mr. Epstein will
call New York and New York call me to do things for
Mr. Epstein. But he was on the phone or busy or
something and he would call the office and the office
will send me an e-mail or call me or -- it was a
constant report with the office in New York.
Q. And did you in turn sometimes call New York to
get a message to Mr. Epstein?

Page 71
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

Diane's secretary, she stay there for a week with her
kids and we took care of her.
Who else? Mr. Trump. That's a celebrity.
Mr. Robert Kennedy, Junior. Mr. Frederick Fekkai.
Q. Who is that?
A. Fekkai, Frederick Fekkai, the famous
hairstylist. Who else? I don't think I can remember
anymore.
Q. David Copperfield, the magician?
A. No, I never saw him.
Q. You never saw him.
Now, would these -- the people that you named
were all people that you saw visiting in the home?
A. Yes. Also was a Noble Prize winners, the -- I
can't remember his name. It was an old gentleman. He
was a Noble Prize, chemistry, I think, or mathematics.
There was a couple -- a couple of those, very -- also,
we had at one time at the house, it was a reunion of
very Noble Prize winners. But I don't know. They're
not famous, I guess. I can't remember their names.
Very important people.
Q. Was that a dinner or a reception?
A. I think it was a lunch.
Q. A lunch.
President Clinton, did you ever --

Page 70
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

A. Yes.
Q. Did you ever overhear Mr. Epstein talking to
any people that you would consider celebrities?
A. Yes. I knew some -- many celebrities.
Q. Who -- what celebrities did you understand
that he spoke with?
A. He spoke to it?
Q. Yes.
A. I don't know who he spoke to because I never
listen to his conversations. But I saw guests at the
house that were celebrities.
Q. Who did you see at house?
A. Many. It was senators. It was Senator
Mitchell, George Mitchell. It was Prince Andrew. It
was Princess Sarah.
Q. Princess?
A. Sarah, the wife of Andrew.
Q. Sarah Ferguson?
A. Ferguson.
And it was a couple Misses, Misses Yugoslavia,
Miss Germany that I don't even know the names. But they
were a lot of queens and other famous people that I
can't remember. It was a very famous lawyers that I'm
sure you know, Alan Dershowitz, who spend at the house a
couple times. And he slept there. He -- Princess

Page 72
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

A. I met President Clinton on Mr. Epstein's plane
in the last, I think it was the last month or just
before I left -- I left, I met President Clinton in
Miami at his plane. We drove him to Miami.
Q. And do you know, was that a trip -- were they
going on a trip to Africa?
A. I hear about it, but it was not when I was
there.
Q. So that was not the time that you drove -A. No, I was already out.
Q. And Kevin Spacey, did you ever meet him?
A. No. I hear about it on the news, but I never
met him.
Q. Were Prince Andrew and Princess Sarah friends
of Ms. Maxwell?
A. Both of them.
Q. Both Ms. Maxwell and Mr. Epstein?
A. Yeah.
Q. Did -- did they ever have massages when they
were there?
A. Prince Andrew did. I think Sarah was there
only once and for a short time. I don't think she slept
in there. I cannot remember. I think she was visiting
Wellington and she came to the house and we met her.
But Prince Andrew, yes, Prince Andrew spent weeks with

18 (Pages 69 to 72)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 73
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 75

us.

1
2
Q. Where would he sleep?
3
A. In the main room, the main guest bedroom.
4
That was the blue room.
5
Q. And, so, when he would come and stay, during
6
that time would he frequently have massages?
7
MR. CRITTON: Form.
8
THE WITNESS: I would says, daily massages.
9
They have a daily massage.
10
BY MS. EZELL:
11
Q. Was it sometimes more than one a day?
12
A. I can't remember if he had more than one, but
13
I think it was just a massage for him. We set up the
14
tables and -Q. Do you have any recollection of V.R. coming to 15
16
the house when Prince Andrew was there?
17
A. It could have been, but I'm not sure.
18
Q. Not sure. When Mr. Dershowitz was
19
visiting, -20
A. Uh-huh.
21
Q. -- how often did he come?
22
A. He came pretty -- pretty often. I would says,
23
at least four or five times a year.
24
Q. And how long would he stay typically?
25
A. Two, three days.

MR. LANGINO: Go ahead. Sure.
BY MS. EZELL:
Q. You said that you set up the massage tables.
And would you also set up the oils and the towels?
A. Yes, ma'am.
Q. And I think I read one time you said they used
40 or 50 towels a day?
MR. CRITTON: Form.
THE WITNESS: That's correct. There was a
tremendous amount of work in the house, especially
laundry towels, because they were -- we have
towels, piles of towels. And they use in the pool.
There was a lot of people in the pool and there
were a towel that went in the floor, we have to go
and pick it up, wash it. So it was -- it was a lot
of towels, yes.
BY MS. EZELL:
Q. And did you ever have occasion to go upstairs
and clean up after the massages?
A. Yeah, uh-huh.
Q. Did you ever find any vibrators in that area?
A. Yes. I told him, yes.
MS. EZELL: And did you ask that? I'm sorry.
MR. CRITTON: Yes.
MS. EZELL: I don't know how I missed that.

Page 74
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

Q. Did he have massages sometimes when he was
there?
A. Yes. A massage was like a treat for
everybody. If they want it, we call the massage and
they have a massage.
Q. Now, Mr. Trump had a home in Palm Beach,
correct?
A. Uh-huh.
Q. So he didn't come and stay there, did he?
A. No, never.
Q. He would come for a meal?
A. He would come, have dinner. He never sat at
the table. He eat with me in the kitchen.
Q. Did he ever have massages while he was there?
A. No. Because he's got his own spa.
Q. Sure.
MS. EZELL: I don't have any other questions
right now. I'd just like to reserve if something
comes up to ask. But, otherwise, you may go ahead.
MR. LANGINO: It is noon, so I don't know what
everybody else's schedule is. I don't know how
you're feeling.
THE WITNESS: I am fine.
MS. EZELL: I do have another question. May I
ask it?

Page 76
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

BY MS. EZELL:
Q. Since I did miss it, if you don't mind, let me
just ask you again.
Would you describe for me what kinds of
vibrators you found?
A. I'm not familiar -- not too familiar with the
names, but they were big dildos, what they call the big
rubber things like that (indicating). And I used to go
and put my gloves on and pick them up, put them in the
sink, rinse it off and put it in Ms. Maxwell -Ms. Maxwell had in her closet, she had, like, a laundry
basket, one of those laundry basket that you put laundry
in. She have full of those toys. And that was -- and
that was me being professional, leaving the room ready
for bed when he would come back to the room again.
Q. Okay.
A. That happened a few times, few times.
Q. Were there other sex toys that you found in
the area -A. No.
Q. -- sometimes? You mentioned she kept them in
a basket in her closet?
A. She kept them in her basket. She had some
videos there and she have a costume there. I know that
she bought it, that she brought it with her.

19 (Pages 73 to 76)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004

 Page 77
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

Q. What kind of costume?
A. I don't know. It was a black, shiny costume.
I never saw it on her.
Q. Was it leather?
A. No. I think it was like a vinyl. But we were
very fussy about touching any of that stuff. We just...
MS. EZELL: No other questions. Thank you,
sir.
THE WITNESS: You're welcome.
MR. LANGINO: I shouldn't have more than a
half hour's worth of questions, if everybody is
okay to power through.
MR. BERGER: I probably have a half hour to an
hour.
MR. LANGINO: Okay.
MR. BERGER: Unless you cover what I cover.
MR. MERMELSTEIN: I could say the same thing,
so probably less than that.
MR. LANGINO: So I guess my question is -MR. BERGER: I think we ought to take a break.
MR. LANGINO: That was my question.
MR. BERGER: We're going to take a break.
Do you have any problem with that?
THE WITNESS: No. Whatever you guys want to
do.

Page 79
1
2
3
4
5
6
7
8
9
10
11
12
13
14

CERTIFICATE OF OATH
STATE OF FLORIDA
COUNTY OF PALM BEACH

I, the undersigned authority, certify that
JUAN ALESSI personally appeared before me and was duly
sworn on the 8th day of September, 2009.
Dated this 19th day of September, 2009.

____________________________________
15
16
17
18
19
20
21
22
23
24
25

Sandra W. Townsend, Court Reporter
Notary Public - State of Florida
My Commission Expires: 6/26/12
My Commission No.: DD 793913

Page 78

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

(Lunch recess.)
(Continued to Volume II.)

Page 80
1
2
3
4
5
6
7
8

CERTIFICATE
STATE OF FLORIDA
COUNTY OF PALM BEACH
I, Sandra W. Townsend, Court Reporter and
Notary Public in and for the State of Florida at Large,
do hereby certify that the aforementioned witness was by
me first duly sworn to testify the whole truth; that I
was authorized to and did report said deposition in
stenotype; and that the foregoing pages numbered 1 to
78, inclusive, are a true and correct transcription of
my shorthand notes of said deposition.

9
10
11
12
13
14
15
16

I further certify that said deposition was
taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and
completed as hereinabove set out.
I further certify that I am not attorney or
counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
action.
The foregoing certification of this transcript
does not apply to any reproduction of the same by any
means unless under the direct control and/or direction
of the certifying reporter.

17
18

Dated this 19th day of September, 2009.
19
20

_____________________________________
21

Sandra W. Townsend, Court Reporter
22
23
24
25

20 (Pages 77 to 80)
(561) 832-7500

PROSE COURT REPORTING AGENCY, INC.

Electronically signed by Sandra Townsend (401-377-676-2895)
Electronically signed by Sandra Townsend (401-377-676-2895)

(561) 832-7506

76ef564a-4a1c-4dee-87ac-479898cc7004