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Page 201 
1 
Q. 
With regard to 
did it ever appear to you 
2 
that she was forced to come to Mr. Epstein's home? 
3 
A. 
I don't think so. I don't know if it was 
4 
forced between them, but I never saw force. I never 
5 
saw -- I was there the first time Ms. Maxwell met her 
6 
immediately that she went into the spa, when she was 
7 
walking into the spa. And I was surprised to see that 
8 
afternoon she was at the house. 
9 
Q. 
Did you ever see anyone forcing Ms. R. onto 
10 
the Epstein's premises; that is, either by grabbing her 
11 
by the arm or by the hand and dragging her in? 
12 
A. 
No. Either her or nobody else. 
13 
Q. 
Did you ever see Ms. -then 
she came to 
14 
the home where she appeared to be -- that is, when she 
15 
arrived at the home to be upset or angry or distraught? 
16 
A. 
No. 
17 
Q. 
And specifically with regard then 
she 
18 
left on those occasions where you saw her in person 
19 
leave the house, did she appear to be in the same, I'd 
20 
say, overall demeanor and mood when she left as she had 
21 
been when she came? 
22 
A. 
Yeah, normal. She was normal. 
23 
Q. 
Did she smile? 
24 
A. 
Yeah. 
25 
0. 
Say hello to you? 
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1 
A. 
They all smile after they got paid. 
2 
MR. CRITTON: All right. That's all I have. 
3 
Thank you, Mr. Alessi. 
4 
THE WITNESS: You're welcome. 
5 
MR. WILLITS: I don't have any questions. 
6 
MR. BERGER: Okay. 
7 
MS. EZELL: I do. 
8 
RECROSS EXAMINATION 
9 
BY MS. EZELL: 
10 
Q. 
Sorry. Let me find my place, here. 
11 
First of all, forgive me. I didn't mean to • 
12 
mislead anyone. It is Figueroa, not Santiago. I think 
13 
he lived on Santiago Street. 
14 
A. 
Yeah. Santiago Street in Royal Palm Beach. 
15 
Q. 
Right. And I confused the two. 
16 
A. 
My head is not going very well now, 
17 
Q. 
Do you need to take a break? 
18 
A. 
Please. No, I am fine. I am fine. 
19 
Q. 
Well, it was my head that wasn't going very 
20 
well then. 
21 
You mentioned that your wife, I believe you 
22 
said that -- let me start over. 
23 
I believe you said one reason you wanted to 
24 
stay was that it was causing psychological problems 
25 
A. 
Yes, it is. 
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1 
Q. 
-- and problems with your marriage? 
2 
A. 
Absolutely. 
3 
Q. 
What kind of psychological problems? 
4 
A. 
I say, psychological problems. I says, 
5 
marital problems. That would be a better answer it. 
6 
Because the stressful was on me. If there was a dust, 
7 
spot of dust, they never came to her. And she was able 
8 
to -- she was over involved with the cleaning crew, but 
9 
it was never from Mr. Epstein or Ms. Maxwell yell, they 
10 
will never go ao 
ask, hey, 
y this 
11 
doesn't look good. 
12 
And, so, I had all the blame. And the only 
13 
person I have to take it out was my wife, unfortunately. 
14 
And that was the worst mistake, to have my wife working 
15 
in there. 
16 
Q. 
Did she ever complain to you or seem disturbed 
17 
by what she thought was going on there? 
18 
A. 
No. She never saw anything. 
19 
Q. 
Was there ever a guest there by the name of 
20 
Tommy Matola? 
21 
A. 
Tommy Matola? No. Not when I was there. 
22 
Q. 
You mentioned this morning that there were 
23 
some visitors who were very important men, Noble Prize 
24 
winners? 
25 
A. 
Yes, ma'am. 
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1 
Q. 
Are you -- do you recall a Martin Nowak? 
2 
A. 
I think that sounds familiar. If he is an old 
3 
guy, old man? 
4 
Q. 
I think so. Mathematician? 
5 
A. 
Yes. 
6 
Q. 
Biologist? 
7 
A. 
Yes. His name Martin. I recall that, yes. 
8 
Q. 
And do you recall a guest, Murray Gell-Mann? 
9 
A. 
Mary Gell-Mann? 
10 
MR. WILLITS: I think you said 
11 
MS. EZELL: Murray. 
12 
MR. WILLITS: -- Murray and he said Mary. 
13 
BY MS. EZELL: 
14 
Q. 
Murray, Murray Gell-Mann. And, again, I'm 
15 
speaking of these -- these 
16 
A. 
Is that a man or a woman? 
17 
Q. 
I believe it's a man. 
18 
A. 
Murray Gell-Mann. Could be, but I don't 
19 
recall. 
20 
Q. 
Do you recall the name Jerry Edelman? 
21 
A. 
No. 
22 
Q. 
What about -- can't read my own writing 
23 
here -- Henry Risorski (phonetics)? 
24 
A. 
Henry Risorski, yes. Yes. 
25 
Q. 
Was he a frequent visitor or 
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1 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A. 
Not too frequent. But, also, he was a 
science -- I think so, he was into the science. 
Q. 
And Larry Summers? 
A. 
Larry Summers. Yes. Larry Summers was a 
lawyer? 
Q. 
I think perhaps he was the president of a 
college? 
A. 
I don't know. 
Q. 
No? 
A. 
No. 
Well, then among those that you recall, 
Q. 
Mr Nowak, the biologist and Mr. Risorski, did they ever 
have massages that you can recall? 
A. 
I cannot recall, no. 
Q. 
Was it your impression that Mr. Epstein liked 
to surround himself with extraordinarily bright people? 
A. 
Yes. 
MR. CRITTON: Form. 
BY MS. EZELL: 
Q. 
And is it your impression, also, that he's 
rather bright and brilliant himself? 
A. 
Yes. 
MR. WILLITS: Form. 
BY MS. EZELL: 
Q. 
Did -- did you ever gain the impression that 
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1 
he was some sort of brain scientist? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: No. No. No. I know his 
4 
background. And I -- over the years I learn how he 
5 
come up and into the business and how he make his 
6 
fortune. And I don't think he was a brain 
7 
scientist. 
8 
BY MS. EZELL: 
9 
Q. 
Nobody ever told you that? 
10 
A. 
No. 
11 
Q. 
If you take a look again at page 9 of the 
12 
transcript, Exhibit 2? 
13 
A. 
Okay. 
14 
Q. 
Let me call your attention to line 2, which 
15 
begins with the question: "Did he have girls come over 
16 
to give massages?" 
17 
A. 
Yes. 
18 
Q. 
And you said: "Yes." 
19 
A. 
Yes. 
20 
Q. 
The next question is: "How many massages 
21 
would he have in one day?" 
22 
And I think you said earlier, maybe --
23 
sometimes they'd have three a week? 
24 
A. 
No. No. That was not the question. 
25 
Sometimes he had one, two or three a day. 
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1 
Q. 
That's what I wanted to ask you. Up to three 
2 
a day sometimes? 
3 
A. 
Up to three a day. 
4 
Q. 
And did that happen often? 
5 
A. 
Very often. Or he had yoga in the morning or 
6 
in the afternoon it was a massage. I don't know that 
7 
again. When it was yoga, it was in the pool house. 
8 
When it was massage, it was upstairs. So I don't what 
9 
they did when closed doors, you know. But it was a 
10 
couple of these girls that were yoga experts and they 
11 
were massage therapists at the same time, so I don't 
12 
know. But there were -- many times there were two, 
13 
three massages a day. 
14 
Also, she had a massage just about every day. 
15 
Q. 
Meaning, Ghislaine? 
16 
A. 
Yes. 
17 
Q. 
Then on line 12, the question was: "Did the 
18 
massage therapists seem young to you?" 
19 
And you said: "Mostly, no. You saw one or 
20 
two young ones in the last year." 
21 
A. 
Yeah. 
22 
Q. 
Then, again, still --
23 
MR. CRITTON: Object to form. 
24 
BY MS. EZELL: 
25 
Q. 
-- still talking about the massage therapist, 
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1 
they asked you: "What do you mean, when they looked 
2 
young?" On line 17. 
3 
Do you see that? 
4 
MR. CRITTON: Form. 
5 
THE WITNESS: Yeah. 
6 
BY MS. EZELL: 
7 
Q. 
Then you go on to say: "I remember one girl 
8 
was young. We never asked how old she was. It was not 
9 
my job." 
10 
And the questioner said: "Right. I 
11 
understand." 
12 
And you said: "I imagine she was 16 or 
13 
17," --
14 
A. 
That's correct. 
15 
Q. 
-- "in my judgment." 
16 
A. 
Yes. 
17 
MR. CRITTON: Form, I think. 
18 
BY MS. EZELL: 
19 
Q. 
There was -- the only people being discussed 
20 
in all of this conversation were the massage therapists, 
21 
right? 
22 
MR. CRITTON: Form. 
23 
THE WITNESS: Well, we discuss about N., this 
24 
girl that I mention in here. I thinking about her 
25 
because -- what's her name? 
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Page 209 
1 
BY MS. EZELL: 
2 
Q. 
V.? 
3 
A. 
V. 
I think she was a massage therapist for 
4 
sure, because we set up the tables for her. But at 
5 
this 
6 
7 
minute. Let's make i 
That's all. 
8 
MR. CRITTON: 
9 
THE WITNESS: 
And I lost my 
10 
concentration. 
11 
MR. CRITTON: Why don't you read his response 
12 
to him? 
13 
She can read it back to you. 
14 
(Previous answer was read.) 
15 
THE WITNESS: Yeah. I was -- in this 
16 
statement I was thinking of her,
- no, V. 
17 
BY MS. EZELL: 
18 
Q. 
R.? 
19 
A. 
Sorry again. 
20 
It was N.B. that I knew she was underage and I 
21 
knew it because I went to the high school and pick her 
22 
up. 
23 
Q. 
But she was not a massage therapist, 
24 
A. 
No, she was not. 
25 
Q. 
-- as far as you know? 
MS. EZELL: Let me just -- excuse me. Just a 
Okay. I'm sorry. 
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Page 210 
1 
A. 
As far as I know, she was not. 
2 
Q. 
And you were talking throughout this page 
3 
about those girls that came to give massages? 
4 
MR. CRITTON: Form. 
5 
BY MS. EZELL: 
6 
Q. 
Correct? 
7 
MR. CRITTON: Form. Argumentative. Asked and 
8 
answered. 
9 
THE WITNESS: No. If I says she was a massage 
10 
therapist, I would says, no. But, then again, I 
11 
don't know if she was a massage therapist, too. 
12 
BY MS. EZELL: 
13 
Q. 
Okay. You do mention N. on page 21 of your 
14 
statement. 
15 
If you look at line 7, you mention a young 
16 
girl, but she was not a massage therapist? 
17 
A. 
Let me take a look. Page 21. 
18 
Q. 
At about line 7. 
19 
A. 
Line 7. 
20 
MR. CRITTON: But it in the context of your 
21 
answer --
22 
MS. EZELL: Sure. 
23 
MR. WILLITS: And the question, too. 
24 
THE WITNESS: Question: "How" -- let me start 
25 
it from the beginning -- from the end. 
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1 
Many of the -- it's been a while. It was J. 
2 
It was D. It was R. It was so many, V., L. It was 
3 
so many names, that I think if you name -- if 
4 
you -- any girl's name, she's been there probably, 
5 
S., J., J. 
6 
It was also a young girl but she was not a 
7 
massage therapist. She came to the house as a 
8 
friend. 
9 
I talking about B. because I knew she was not 
10 
a massage therapist because she went to high school 
11 
and she was a singer, an opera singer and she was 
12 
brought to the house by her mother. So I knew they 
13 
had nothing to do with massages. They were friends 
14 
and they were going to the movie with her, dinner 
15 
with her. And she had -- I think she travelled 
16 
with her, too. They travel. 
17 
Q. 
My only point is, that on page 9 you were 
18 
talking about the massage therapists. And you said that 
19 
you remember that there were a couple of young ones the 
20 
last year. 
21 
And, so, among the young massage therapists 
22 
that you might remember in the last year, would V. be 
23 
that person or 
24 
MR. CRITTON: Form. 
25 
BY MS. EZELL: 
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1 
Q. 
-- would be the young one? 
2 
A. 
Yeah. 
3 
Q. 
You stated that Ms. Maxwell was very hard on 
4 
you and you got blamed for everything, and that you --
5 
you liked the job and you liked Mr. Epstein, but you 
6 
didn't like working for Mrs. Maxwell? 
7 
A. 
That's correct. 
8 
Q. 
Can you tell me why, other than that she 
9 
blamed you for everything? 
10 
A. 
She came from a very wealthy family and she 
11 
was -- just my opinion; I give my personal opinion --
12 
that she was rotten spoiled and she tried to drive the 
13 
house like a palace and not a home. 
14 
I was -- I discussed it with her, many, many 
15 
times we have discussions. And sometimes I even refuse 
16 
to do her orders, knowing that I was going to be backed 
17 
up by Mr. Epstein or do the right thing, my thinking of 
18 
running the house should be. But we never had a good 
19 
relationship at all from the beginning, I don't think 
20 
so. But I was -- have to be her driver and she will go 
21 
and shop all over the malls and I will have to go behind 
22 
her, pay for it and bring the bags to the car. 
23 
Next day or the same day she will do shopping 
24 
and buy and 
to this store and get it. It 
25 
was a lot of work. It was a lot that she created and 
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Page 213 
1 
most of this jobs that she created. 
2 
3 
with 
4 
5 
6 
7 
8 
9 
10 
11 
12 
massage therapists, and 
13 
massage, the small massage. 
14 
So I make a list from the telephone book and 
15 
we would go from one to the another one. I would wait 
16 
in the car and she goes in. 
17 
And sometime she took a couple minutes and 
18 
walk out with cards, business cards. And that -- she 
19 
did the recruiting. 
20 
21 
was the end of it. I never did any recruiting and I 
22 
never really saw him doing it. 
23 
Q. 
You really never saw? 
24 
A. 
Never saw Mr. Epstein recruiting anybody. 
25 
MS. EZELL: All right. I have no other 
all the main spas. And 
Q. 
And one of those things you also had to do 
her was to take her to different spas? 
A. 
Yes. 
Q. 
And there she would recruit young women to 
come and do massages? 
A. 
Because she was English. And she didn't know 
the area too much as well as I knew. So she -- she 
says, 
ake a list of all the massage -- the spas 
in the area from Jupiter to Boca Raton. And we went to 
then we went to the schools for 
all the massage parlors, and 
And from then, she pick up the girls and that 
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Page 214 
1 
questions. Thank you, sir. 
2 
MR. MERMELSTEIN: I just have a couple follow 
3 
up. 
4 
RECROSS EXAMINATION 
S 
BY MR. MERMELSTEIN: 
6 
Q. 
I'll be very brief. 
7 
You testified that a process server came and 
8 
gave you the subpoena to appear here today, correct? 
9 
A. 
Yes. 
10 
Q. 
For your deposition? 
11 
A. 
Yes. 
12 
Q. 
Did you call anyone after you received the 
13 
subpoena to talk to them about this? 
14 
A. 
No. 
15 
Q. 
You didn't call anyone? 
16 
A. 
No. 
17 
Q. 
Did you -- how did you come in contact with 
18 
Mr. Critton's office to set up the meeting that you 
19 
discussed? 
20 
A. 
His 
his secretary left me a messages on 
21 
my -- in my machine. 
22 
Q. 
And then you called back? 
23 
A. 
Then I called back. 
24 
Q. 
And you set up the meeting that you mentioned? 
25 
A. 
And we set up a meeting for the Labor Day, 
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1 
Labor Day, Monday. 
2 
Q. 
What about -- but you said a month and a half 
3 
ago -- oh, this was before you were subpoenaed, is when 
4 
you had the meeting at your house with Mr. 
5 
A. 
Yes, before I was subpoenaed. 
6 
Q. 
How did that meeting come about? How did that 
7 
get set up? Who called who? 
8 
A. 
Okay. Before -- I am stuck on this question. 
9 
I don't know. I think it was Mr. Critton office. I 
10 
think it was Mr. Critton office. They call me. And 
11 
they left me a message that I must discuss 
call Mr. 
12 
-- yeah. I had a message in my phone that to call 
13 
Mr. Critton because he would like to speak to me about 
14 
Jeffrey Epstein. That was the message. 
15 
And I call it. Then I spoke to him. We set 
16 
up an appointment. I was sick at that time. And he 
17 
came to my house and we discussed it. 
18 
Q. 
Other than Mr. Critton, 
19 
A. 
Yes. 
20 
Q. 
-- in the last few months have you spoken to 
21 
anyone about the civil cases or your testimony? 
22 
A. 
No, not even my kids. 
23 
Q. 
Did you discuss this with your wife? 
24 
A. 
My wife, yes. My kids, no. 
25 
Q. 
What did you and your wife talk about? 
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Page 216 
1 
A. 
Same thing, what's going on. How bad the 
2 
situation was. 
3 
Q. 
What do you mean, "how bad the situation was?" 
4 
A. 
How -- I guess how he got into this mess. 
5 
Q. 
How Mr. Epstein got into this mess? 
6 
A. 
(Nods head.) 
7 
Q. 
Can you be more specific as to what you and 
8 
your wife said? 
9 
A. 
No. It was just the publicity, you know, that 
10 
his name was on the -- on the magazines and the paper 
11 
and tv. And I thought that that would never happen. 
12 
Q. 
And you and your wife felt bad for Mr. Epstein 
13 
because of that? 
14 
A. 
You know, after you know somebody and he 
15 
becomes a friend of yours for ten years, I think you 
16 
feel bad, no matter how bad he has made. And I don't 
17 
know what he has done or what -- what the final results 
18 
of this will be. I still will feel bad about it, just 
19 
because the person that he was and how generous he was 
20 
with me and other people. 
21 
Q. 
Just to be clear, other than Mr. Critton and 
22 
your wife, you haven't spoken to anyone else about the 
23 
civil cases or your deposition testimony? 
24 
A. 
No, sir. 
25 
MR. MERMELSTEIN: All right. That's all I 
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Page 21,
1 
have. 
2 
MR. CRITTON: I have one last question. 
3 
RECROSS EXAMINATION 
4 
BY MR. CRITTON: 
5 
Q. 
I want to just clear up one thing, 
6 
Go to page 9. 
7 
A. 
Page 9, looks like the one that is important. 
8 
Q. 
That's right. We've belabored this one to 
9 
death. 
10 
MR. WILLITS: I think the ink has worn off the 
11 
page by now. 
12 
BY MR. CRITTON: 
13 
Q. 
It's Exhibit 2. This is the statement that 
14 
you gave to the State Attorney's Office on November 21st 
15 
of '05. 
16 
Mr. Berger asked you questions about the young 
17 
girl. Ms. Ezell just asked you some questions about 
18 
that. 
19 
So what I want to do is clarify, so that I 
20 
know what 
so there's no confusion, at least in the 
21 
record. 
22 
On page 9, line 16, it says: "During the last 
23 
year when you were working with him, what do you mean 
24 
they looked young? Did they look like they were still 
25 
in high school?" 
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Page 218 
And your answer was: "I remember one girl was 
young. We never asked how old she was. It was not my 
3 
job." 
4 
Did I read that question and answer correctly? 
5 
A. 
That's correct. 
6 
Q. 
If I understood your testimony in response to 
7 
Mr. Berger, the girl that you were referring to, because 
8 
there's a reference to high school, was 
9 
A. 
Yeah, that's correct. 
10 
Q. 
Not 
11 
A. 
No. 
didn't look to me like a 16 year 
12 
old. 
13 
MR. WILLITS: All right. Thank you. That's 
14 
all I have. 
15 
MR. WILLITS: You have the right to read and 
16 
sign this deposition if it's typed up. I'm not 
17 
going to be ordering it, but if somebody types it 
18 
up you have the right to read and sign it or you 
19 
can waive that right. It's up to you entirely. If 
20 
you want to waive the right to read it, tell the 
21 
court reporter you want to waive the right. 
22 
THE WITNESS: Can you repeat that again? 
23 
MR. CRITTON: Why don't we go off the record. 
24 
(Discussion held off the record.) 
25 
THE WITNESS: I waive that right. I don't 
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Page 219 
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think I need to see. 
(Witness excused.) 
(;reposition was concluded.) 
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