EFTA00158250

Page 1 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO:502008CA028051XXXXMB AB 
-• 
Plaintiff, 
- vs -
JEFFREY EPSTEIN 
AND 
Defendants. 
DEPOSITION OF JANUSZ BANASIAK 
Tuesday, February 16, 2010 
10:09 - 2:30 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
Job No.: 1317 
(561) 832.7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthla hopkins (601461-976-2934) 
Electronically signed by cynthla hopkins (601-051-976-2934) 
Electronically signed by cynthla hopkins (601-051-976-2934) 
205891d-Uaa-42b3-ae22-b5d3c7182d1e 
3507-01 I 
Page I of 2(X) 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
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APPEARANCES: 
2 
On behalf of the Plaintiff, III 
3 
BRADLEY J. EDWARDS, ESQUIRE 
FARMER, JAFFE, WEISSING, EDWARDS 
4 
FISTOS & LEHRMAN, P.L. 
7 
8 
9 
10 
11 
13 
14 
15 
On behalf of the Defendant, Jeffrey Epstein and the 
Witness: 
16 
17 
JACK ALAN GOLDBERGER, ESQUIRE 
ATTERBURY GOLDBERGER & WEISS, P.A. 
18 
and Jane Doe: 
On behalf of the Plaintiff Jane Does No.'s 1 
through 8. 
STUART MERMELSTEIN, ESQUIRE 
MERMELSTEIN & HOROWITZ, P.A. 
20 
21 
22 
23 
24 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
205891d-Uaa-42b3t30182dle 
3507-011 
Pagc 2 of 2(X) 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
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Page 3 
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- - - 
INDEX 
VOLUME
I 
- - - 
5 
WITNESS: 
DIRECT 
CROSS 
REDIRECT 
6 
JANUSZ BANASIAK 
7 
BY MR. EDWARDS 
4 
8 
9 
10 
11 
EXHIBITS 
12
13 
14 
EXHIBITS 
DESCRIPTION 
PAGE 
15 
PLAINTIFFS' NO. 1 
PHOTO 
123 
16 
PLAINTIFFS' NO. 2 
PHOTO 
123 
17 
PLAINTIFFS' NO. 3 
PHOTO 
124 
18 
PLAINTIFFS' NO. 4 
PHOTO 
124 
19 
PLAINTIFFS' NO. 5 
PHOTO 
124 
20 
21 
22 
23 
24 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2C5aMd4eaa-42b3-ae22-b5d3cflUdle 
3507-01I 
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2 
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4 
PROCEEDINGS 
Deposition taken before Cynthia Hopkins, 
Registered Professional Reporter and Florida 
5 
Professional Reporter, and Notary Public in and for 
6 
the State of Florida at Large, in the above cause. 
7 
8 
Thereupon, 
9 
(JANUSZ BANASIAK) 
10 
Having been first duly sworn or affirmed, was 
11 
examined and testified as follows: 
12 
THE WITNESS: Yes, ma'am. 
13 
DIRECT EXAMINATION 
14 
BY MR. EDWARDS: 
15 
Q. 
Would you tell us your full name. 
16 
A. 
Janusz Banasiak. 
17 
Q. 
Could you spell that for us. 
18 
A. 
J-a-n-u-s-z, Banasiak, B like boy, 
19 
B-a-n-a-s-i-a-k. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2W5a9W4eaa42b3-m22-b&IUMIWU 
3507-011 
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Page 
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8 
Q. 
And where are you currently employed? 
9 
A. 
With Jeffrey Epstein. 
10 
Q. 
How long have you been employed with 
11 
Jeffrey Epstein? 
12 
A. 
Since February 2005. 
13 
Q. 
What do you do for him? 
14 
A. 
My position is called a house manager. So, 
15 
basically my duties is to make sure that house is in 
16 
good order when he is around visiting. 
17 
Q. 
And have your duties always been the same 
18 
since February, 2005 through --
19 
A. 
Yes. 
20 
Q. 
-- the present? 
21 
A. 
Yes. 
22 
Q. 
Okay. Have you ever had your deposition 
23 
taken before? 
24 
A. 
No. This is my first time. 
25 
Q. 
All right. The rules are pretty simple. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2c175891c1-3eaa-42b3-ae22-b5d3c7182dle 
3507-011 
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We only have one court Reporter, so it's important 
2 
that we don't talk over one another. I will wait 
3 
until you finish your answer. You wait for me to 
4 
finish my question. 
5 
A. 
Okay. 
6 
Q. 
Give us an answer similar to what you are 
7 
doing that we all understand. It's easy when we get 
8 
into a casual conversation and nod your head or 
9 
shake your head, but the court reporter can't take 
10 
it down so just something verbal. 
11 
A. 
Okay. 
12 
Q. 
If I ask a question you don't understand, 
13 
tell me you don't understand. 
14 
A. 
Okay. 
15 
Q. 
So, who hired you to work with Jeffrey 
16 
Epstein in February of 2005? 
17 
A. 
Who hired me? 
18 
Q. 
Right. 
19 
A. 
I got the phone call from my agency because I 
20 
signed with agency that Jeffrey Epstein looking for the 
21 
position in Palm Beach. 
22 
Q. 
And what agency was that? 
23 
A. 
This was Regal Domestic, Regal Domestic. I .37 
24 
not sure but something with the Domestic. The office 
25 
was in Maryland. I signed to the Internet. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthla hopkins (601-051-976-2934) 
Electronically signed by cynthla hopkins (601-051-976-2934) 
Electronically signed by cynthla hopkins (601-051-976-2934) 
(561) 832-7506 
2W5a9W4eaa4211.1-m224,MUMMU 
3507-011 
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9 
10 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
Q. 
Okay. 
A. 
I signed a few of them. Then one of them, the 
one who called me they were the one from Maryland. 
Q. 
And what was your 
A. 
They told me that they had an opening position 
in Palm Beach, Florida. 
Q. 
And did you know Jeffrey Epstein before 
working with him? 
A. 
No, no. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2C5aMd-Usa-2b3-ae22-bSacflUdle 
3507-011 
Pagc 7 of 2(X) 
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Page 8 
17 
Q. 
And when you started in 2005 when you 
18 
heard that there was a job position with Jeffrey 
19 
Epstein, did you interview for that position? 
20 
A. 
Yes. 
21 
Q. 
Who did you interview with? 
22 
A. 
First I got interviewed with Ghislaine 
23 
Maxwell. 
24 
Q. 
And that's G-h-i-s-l-a-i-n-e, Maxwell? 
25 
A. 
Right, right. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d75891d-Uaa-42b3-ae22-bSac7182dle 
3507-01I 
Pagc 8 of 2(X) 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
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Page 9 
1 
Q. 
Where did that interview take place? 
2 
A. 
In New York. 
3 
Q. 
And it was for the position as house 
4 
manager in the Palm Beach house, correct? 
5 
A. 
Right. 
6 
Q. 
That's at 358 Albrillo way? 
7 
A. 
Correct. 
8 
Q. 
Why were you interviewed in New York, if 
9 
you know? 
10 
A. 
Because at that time I was living in New York 
11 
with my friends and so --
12 
Q. 
Where did the interview take place in New 
13 
York? 
14 
A. 
In her house on 65th Street. 
15 
Q. 
Whose house, do you know? 
16 
A. 
Ghislaine Maxwell. 
17 
Q. 
So, Ghislaine Maxwell interviewed you back 
18 
in 2005 at her house in New York for a position at 
19 
Jeffrey Epstein's house in Palm Beach? 
20 
A. 
Right. 
21 
Q. 
And what did the interview consist of? 
22 
What did she ask you? 
23 
A. 
She asked me basic questions, you know, what's 
24 
my previous employer, how long I work for them and 
25 
basically she was checking my resume. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75a9td4eaa42b3-m224Mtterifadle 
3507-011 
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Page 1C 
1 
Q. 
Okay. And did she ask you about a 
2 
starting salary? 
3 
A. 
No, not yet. We just was a preliminary 
4 
interview, checking. 
5 
Q. 
How long was the interview? 
6 
A. 
How long? 
7 
Q. 
Yes. 
8 
A. 
How long did it last? 
9 
Q. 
Yeah. How long did the interview last? 
10 
A. 
Maybe 20 minutes, half an hour. 
11 
Q. 
All right. After that interview, what's 
12 
your next contact with either Ghislaine Maxwell, 
13 
Jeffrey Epstein or anybody else associated with that_ 
14 
job? 
15 
A. 
My second interview with Jeffrey Epstein after 
16 
a few days. 
17 
Q. 
And where did that take place? 
18 
A. 
In his office on Madison Avenue. 
19 
Q. 
What's the address there? 
20 
A. 
I don't remember physical address. It was 27, 
21 
51st Street. Madison and 51st Street, corner. I don't 
22 
remember physical address. 
23 
Q. 
Okay. And what did you speak with 
24 
Mr. Epstein about during that interview? 
25 
A. 
Same thing. He ask me how long I work for III 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
Ninagld-Uaa42b3-m22-b5d3criWWle 
3507-011 
Page 10 of 200 
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Page 11 
what was my duty, basically the same 
thing. 
Q. 
Did you talk about salary with him? 
A. 
No. 
Q. 
All right. So, what happened in that 
interview to further your position with Jeffrey 
Epstein? 
A. 
After I finish interview with him I, I waiting 
for a few days. And I got the phone call from secretary 
that I had been accepted and offered the job. 
Q. 
Okay. Who made that phone call to you? 
A. 
One of the secretary. I don't remember her 
name right now. She told me that they agreed to hire 
me. 
Q. 
Is this a secretary that is located in the 
New York office? 
A. 
Yes, yes. It was a call from the New York 
office. 
Q. 
And she told you that you were being 
offered the job? 
A. 
Right. 
Q. 
And at that point in time were you offered 
a salary? 
A. 
Yes. 
Q • 
Okay. So up to that point, you had made 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2C5aMd4eaa-2b3-ae22-b5d3c7182dle 
3507-011 
Page 11 of 2(X) 
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Page 12 
1 
it clear to them that you wanted a job but not 
2 
necessarily how much you wanted to be paid? 
3 
A. 
Yes. 
4 
Q. 
All right. And what was your starting 
5 
salary? 
6 
A. 
It was $58,000, I think, yeah. 
7 
Q. 
Did Jeffrey Epstein or anybody else during 
8 
this interview process tell you why the house 
9 
manager position had become available, meaning 
10 
somebody quit or why it was vacant? 
11 
A. 
No, no, he didn't. Nobody mention it. 
12 
Q. 
Okay. Do you know who the house manager 
13 
was prior to you being the house manager? 
14 
A. 
When I get to Palm Beach, one of the people 
15 
who work over there they told me that this guy working 
16 
currently for him Alfredo Rodriguez. 
17 
Q. 
Alfredo Rodriguez? 
18 
A. 
Yes. 
19 
Q. 
And who told you that Alfredo Rodriguez 
20 
was the previous house manager, do you remember who? 
21 
A. 
I think it was 
. She is 
22 
currently employed with him. 
23 
Q. 
is still employed by him, 
24 
right? 
25 
A. 
Yes. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d75891d-Uaa-42b3-ae22-bSac7182dle 
3507-011 
Page 12 of 2(X) 
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Page I -3 
1 
Q. 
And she's a housekeeper or something? 
2 
A. 
Right. 
3 
Q. 
All right. So, when this secretary of New 
4 
York calls and offers you the job at $58,000, you 
5 
accept the job? 
6 
A. 
Yes. 
7 
Q. 
And do you remember about what month that 
8 
was that January 2005 or so? 
9 
A. 
No. I think I start February 2005, but I, I 
10 
got a phone call I think it was end of December, 2004. 
11 
Q. 
Okay. So, the previous interview with 
12 
Ghislaine Maxwell and Jeffrey Epstein happened 
13 
sometime in late 2004? 
14 
A. 
Right. 
15 
Q. 
Okay. And when you say you got the job in 
16 
February 2005, is that when you came down to Palm 
17 
Beach to start working? 
18 
A. 
Yes. 
19 
Q. 
So, you had a month or so to gather your 
20 
stuff and get down? 
21 
A. 
Correct. 
22 
Q. 
And did you move down with anybody? 
23 
A. 
No, just myself. 
I 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
24:175a91d4eaa-42b3-m224,WW1WWle 
3507.011 
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Page 14 
8 
Q. 
So, you came down in February 2005 and 
9 
began working. What did you, what did you first 
10 
start doing for Jeffrey Epstein? 
11 
A. 
First I doing? I don't remember nothing 
12 
special. 
13 
Q. 
Okay. Well, were you working 
I will 
14 
rephrase it. Were you working only for Jeffrey 
15 
Epstein or were you working also for Ghislaine 
16 
Maxwell, the other person who interviewed you, or 
17 
anybody else in the house? 
18 
A. 
I guess only for him because she was visiting 
19 
a few times house, but I am employed by him. 
20 
Q. 
Okay. What was your understanding at that 
21 
time as to the relationship between Ghislaine 
22 
Maxwell and Jeffrey Epstein? 
23 
A. 
They were like partners in business. 
24 
Q. 
Okay. What business was that, if you 
25 
know? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2W5a9W4eaa42b3-m22-bUft718:Wle 
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Page 15 
1 
A. 
I don't know what kind of business but she was 
2 
the one who organized I would say employment with this 
3 
organization. So, whatever I need, if I have some kind 
4 
of problem, I contact her. She was the one who decided 
5 
what I have to answer my problems with, what I was 
6 
supposed to do. 
7 
Q. 
How many times did you have problems where 
8 
you had to go through her? 
9 
A. 
Well, not big problems. Just a question of 
10 
what certain, how to do certain things. For example, 
11 
what kind of flowers I have to buy, what kind of things 
12 
he likes, what time I supposed to serve him coffee in 
13 
the mornings, sort of organizing things. 
14 
Q. 
Those are things that you wouldn't ask 
15 
Jeffrey Epstein directly? 
16 
A. 
No, no. He doesn't like those things to ask 
17 
him directly. He would like to prefer either through 
18 
his assistant or like I say, Ghislaine Maxwell. 
19 
Q. 
Is that still the same today? 
20 
A. 
Yes, still the same. Unless, something happen 
21 
that I need to, nobody is around and I need to urgently 
22 
contact him, I go to him directly. 
23 
Q. 
So, for the most part if you have a 
24 
question or at least -- let's go back to 2005, you 
25 
had a question about what needed to be done in the 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75891d-3eaa-42b3-ae2265d3c7182dle 
3507.011 
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Page 16 
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house, day-to-day stuff, you would ask Ghislaine 
2 
Maxwell? 
3 
A. 
Right. 
4 
Q. 
And would she normally, back in 2005, be 
5 
at the house in Palm Beach for you to ask her or 
6 
would you have to call her in New York? 
7 
A. 
To the phone up in New York. She was visiting 
8 
the house but most of the time I spoke with her on the 
9 
phone. 
10 
Q. 
Okay. Let's talk specifically about that 
11 
year in 2005. How often would Ghislaine Maxwell be 
12 
at the Palm Beach house when Jeffrey Epstein was at 
13 
the Palm Beach house? 
14 
A. 
I would say about once a month since I started 
15 
work. 
16 
Q. 
All right. Well, it was a bad question 
17 
because I understand that Mr. Epstein has several 
18 
homes, right? 
19 
A. 
Right. 
20 
Q. 
And he is sometimes in New Mexico or New 
21 
York or Florida or the Island or somewhere, right? 
22 
A. 
Right. 
23 
Q. 
So, I guess the first question is in 2005, 
24 
how often was Jeffrey Epstein at the Palm Beach 
25 
house on a weekly basis? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
(561) 832-7506 
2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 
3507.011 
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Page 17 
1 
A. 
Probably like two, three times a month. 
2 
Q. 
And when he would come to the Palm Beach 
3 
house two or three times a month, how long would he 
4 
stay typically? 
5 
6 
A. 
Three days, sometimes two, sometimes four, 
depends, you know, but it was no regular -- but no more 
7 
than four days I would say. 
8 
Q. 
Okay. And of those two or three trips to 
9 
Palm Beach, are you telling me that Ghislaine 
10 
Maxwell would usually come for one of them per 
11 
month? 
12 
A. 
Not usually, sometimes. Not every time but 
13 
sometimes they, she comes. 
14 
Q. 
Okay. But at that point in time in 2005 
15 
you understood that Ghislaine Maxwell and Jeffrey 
16 
Epstein were business partners? 
17 
A. 
Right. 
18 
Q. 
Did you know at the time what Jeffrey 
19 
Epstein did for a living? 
20 
A. 
Yes. He was one, I overheard invest money 
21 
with other people. 
22 
Q. 
Okay. Who told you that or who did you 
23 
overhear? 
24 
A. 
I think I read in the paper or something. 
25 
Nobody --
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
(561) 832-7506 
2d75a9Idasa-42b3-se2265d3c7182dle 
3507-011 
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1 
Q. 
So, you don't actually think you overheard 
2 
it. You think you read it? 
3 
A. 
Right. It's hard to say right now. I don't 
4 
remember but probably most, yeah, I think I read in the 
5 
paper. 
6 
Q. 
Did you understand in 2005 that Ghislaine 
7 
Maxwell and Jeffrey Epstein had an intimate 
8 
relationship with one another? 
9 
A. 
No. 
10 
Q. 
You only believed them to have a business 
11 
relationship? 
12 
A. 
Right. 
13 
Q. 
Okay. And when Ghislaine Maxwell would 
14 
come to Florida, what did you or what did you 
15 
observe her and Mr. Epstein do back in 2005? 
16 
MR. GOLDBERGER: Form. 
17 
THE WITNESS: What would they do? I mean 
18 
what? 
19 
BY MR. EDWARDS: 
20 
Q. 
What was a typical day for Jeffrey Epstein 
21 
and Ghislaine Maxwell when she was in town at the 
22 
same time he was in town. 
23 
A. 
I would say that they have breakfast in the 
24 
morning. They spend time reading, talking on the phone, 
25 
meeting people, go to the movies sometimes. They did 
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entertain a lot. They did go out for dinners I would 
2 
say. 
3 
BY MR. EDWARDS: 
4 
Q. 
Did you know at that time what Ghislaine 
5 
Maxwell did for a living? 
6 
A. 
No. 
7 
Q. 
Do you know today even what she did? 
8 
A. 
No. 
9 
Q. 
No. Back in 2005 to your knowledge, did 
10 
Jeffrey Epstein have a girlfriend or female 
11 
companion that was more than just a business partner 
12 
to your knowledge? 
13 
A. 
No, I didn't know. 
14 
Q. 
And for the most part I am going to try to 
15 
go chronological from 2005 to the present, but for 
16 
this question for that entire period of time that 
17 
you have known Jeffrey Epstein, 2005 through today, 
18 
have you ever known Jeffrey Epstein to have somebody 
19 
who you would observe to be a female companion or 
20 
girlfriend? 
21 
A. 
Yes. 
22 
Q. 
Okay. 
When is the 
23 
first time that you believe you recognized 
24 
as a girlfriend to Jeffrey Epstein? 
25 
A. 
At one point, I don't remember exactly what 
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year was it, he told us that 
will take some part 
2 
of the organization, organizing, scheduling. And she 
3 
would decide, you know, which way household supposed to 
4 
work, and if you have any questions or problems, we 
5 
could contact her. So, since then I figure out that 
6 
she's the person who, who is close to him. 
7 
Q. 
When did he tell you that? 
8 
A. 
I don't remember. Maybe a year ago, two years 
9 
ago. 
10 
Q. 
Okay. Well, if we could put it in --
11 
obviously at this point in time Jeffrey Epstein is 
12 
on house arrest, right? 
13 
A. 
(Witness nods head). 
14 
Q. 
I'm sorry. It has to be verbal so she 
15 
could take it down. 
16 
A. 
Yes. 
17 
Q. 
And prior to that, he was serving a jail 
18 
sentence, right? 
19 
A. 
Right. 
20 
Q. 
Okay. I am only bringing this up to put 
21 
it in context as to when this -- when you realized 
22 
or were told information that led you to believe 
23 
was Jeffrey Epstein's girlfriend. 
24 
Was it while he was on house arrest, while he was in 
25 
jail, before that, after that? 
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