EFTA00182344

Page 270 
1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
2 
3 
JANE DOE NO. 2, 
CASE NO: 08-CV-80119 
4 
Plaintiff, 
5 
Vs. 
6 
JEFFREY EPSTEIN, 
7 
Defendant. 
8 
9 
10 
Vs. 
JEFFREY EPSTEIN, 
Defendant. 
13 
JANE DOE NO. 3, 
CASE NO: 08-CV-80232 
Plaintiff, 
11 
12 
CONDENSED 
,14 
JANE DOE NO. 4, 
CASE NO: 08-CV-80380 
15 
Plaintiff, 
16 
Vs. 
17 
JEFFREY EPSTEIN, 
18 
Defendant. 
JANE DOE NO. 5, 
CASE NO: 08-CV-80381 
Plaintiff, 
19 
20 
21 
22 
23 
24 
25 
Vs 
JEFFREY EPSTEIN, 
Defendant. 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182344

I 
JANE DOE NO. 6, 
CASE NO: 08-CV-80994 
2 
Plaintiff, 
3 Vs. 
4 
JEFFREY EPSTEIN, 
5 
Defendant. 
6 
7 
8 
9 
10 
Mt* DOE NO. 7, 
Plaintiff, 
Vs. 
JEFFREY EPSTEIN, 
Defendant. 
11 
12 
13 
Plaintiff, 
14 Vs. 
15 JEFFREY EPSTEIN, 
16 
Defendant. 
17 
18 
19 
20 
21 
22  
23 
24 
25 
CASE NO: 08-CV-80993 
CASE NO: 08-CV-80811 
CASE NO: 08-CW80893 
JANE DOE, 
Plaintiff, 
Vs. 
JEFFREY tPSi e N, 
Defendant. 
Page 271 
1 
2 
3 
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S 
6 
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8 
IN THE CIRCUIT COURT OF THE 15Th 
JUDICIAL CIRCUIT IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
CASE NO. 502008CA037319=0d48 AB 
Plainbff, 
Vs. 
JEFFREY EPSTEIN. 
Defendant 
9  
10 
11 
12 
1031 Ives Dairy Road 
Suite 228 
13 
North Miami, Florida 
August 7, 2009 
14 
1:15 p.m. to 5:30 p.m. 
15 
16 
CONTINUED 
17 
VIDEOTAPED 
18 
DEPOSITION 
19 
of 
20 
ALFREDO RODRIGUEZ 
21 
22 
23 
24 
25 
taken on behalf of the Plaintiffs pursuant 
to a Re-Notice of Taking Continued Videotaped 
Deposition (Duces Tecum) 
Page 273 
Page 272 
1 JANE DOE NO. II, 
2 
Plaintiff, 
3 
Vs. 
4 
JEFFREY EPSTEIN, 
5 
Defendant. 
6 
7 
8 
9 
10 
CASE NO: 08-CV-80469 
JANE DOE NO. 101 
CASE NO: 08-CV-80591 
Plaintiff, 
Vs. 
JEFFREY EPSTEIN, 
Defendant. 
11  
12 JANE DOE NO. 102, 
CASE NO: 08-CV-80656 
13 
Plaintiff, 
14 Vs. 
15 JEFFREY EPSTEIN, 
16 
Defendant 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 APPEARANCES: 
2 
3 
MERMOSTEIN & HOROWITZ PA 
BY: ADAM HOROWITZ- ESQ. 
4 
18205 Biscayne Boulevard 
Suite 2218 
MINN, FlorIda 33160 
Attorney for lane Doe 2, 3, 4, 5, 
6, and 7. 
5 
6 
7 
8 
10 
11 
12 
13 
14 
PODHURST ORSEOC 
BY: KATHERINE W. EZELL, ESQ. 
15 
25 West Hagler Street 
Suite BOO 
16 
Miami, Rorida 33130 
Attorney for Jane Doe 101 and 102. 
17 
18 
LEOPOLD-KUVIN 
19 
BY: ADAM 3. LANGIRD, ESQ. 
2925 PGA Boulevard 
20 
Suite 200 
Palm Bead, 
ens, Florida 33410 
21 
Attorney for 
22 
23 
24 
25 
ROTHSTEIN ROSPMFELDT ADLER 
BY: BRAD J. EDWARDS, ESQ., and 
CAM HOLMES, ESQ. 
Las Olas Oty Centre 
Suite 1650 
401 East Las Olas Boulevard 
Fort Lauderdale, Hods 33,EL 
Zita for Jane Doe and M. 
Page 274 
2 (Pages 271 to 274 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182345

1 
2 
3 
APPEARANCES: 
RICHARD WILLITS, ESQ. 
Page 275 
1 
2 
2290 10th AVenue North 
3 
4 
Suite 404 
4 
5 
Lake Worth, Florida 33461 
Attorney for 
5 
Appeared vialaone. 
6 
6 
7 
7 
BURMAN, CRUTCH, LUTTIER 
8 
8 
COLEMAN, LLP 
9 
9 
BY: ROBERT CARTON, ESQ. 
515 North Flagler Drive 
10 
Suite 400 
11 
10 
West Pakn Beach, Florida 33401 
12 
11 
Attorney for Jeffrey Epstein. 
13 
12 
14 
13 
ALSO PRESENT: 
15 
14 
JOE LANGSAM, VIDEOGRAPHER 
16 
15 
17 
16 
18 
17 
19 
18 
20 
19 
21 
20 
21 
22 
22 
23 
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24 
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Page 276 
1 
CONTINUED INDEX OF EXAMINATION 
1 
2 
WITNESS 
DIRECT CROSS REDIRECT RECROSS 
2 
3 
3 
ALFREDO RODRIGUEZ 
4 
4 
5 
(8y Ms. Ezell) 
278 
441, 467 
5 
6 
(By Mr. Willits) 334 
453, 469 
7 
6 
(Ely Mr. Critton) 
338 
464 
7 
9 
(By Mr. Edwards) 
419, 454, 468 
10 
8 
11 
9 
(By Mr. langino) 
452 
12 
10 
13 
11 
14 
12 
CONTINUED INDEX OF MINTS 
13 PLAINTIFFS 
PAGE 
15 
14 3 Drawing 
315 
16 
15 4 Photograph 
327 
17 
16 
17 
5 Photograph 
331 
6 Photograph 
331 
18 
18 7 Photograph 
331 
19 
19 8 Photograph 
331 
20 
20 
21 
9 Report 
446 
(Exhibits 4, 5, 6, 7, and 8 were retained by Ms. 
21 
Ezell.) 
22 
22 
23 
23 
24 
24 
25 
25 
Page 277 
Deposition taken before MICHELLE PAYNE, Court 
Reporter and Notary Public in and for the State of 
Florida at Large, in the above cause. 
THE VIDEOGRAPHER: This is a continuation 
of the deposition of Alfredo Rodriguez. 
Today is Friday, August the 7th, the year 
2009, starting time approximately 1:15 p.m. 
Will the court reporter please swear in 
the witness? 
Thereupon, 
ALFREDO RODRIGUEZ, 
having been first duly sworn or affirmed, was 
examined and testified as follows: 
MR. CRITTON: Before we get started just 
with regard to Ms. Ezell represents Jane Doe 
101 and 102, the alleged time of her 
Incidents as of least have been plead in the 
complaint for 101 is '99 -- I'm sorry, '98 
through 2002, with Jane Doe 102 the Spring 
of -- Spring/Summer of 2003. Mr. Rodriguez 
never even began employment until '04 and 
'05. I think her questioning I think -- I 
can't say she doesn't have standing based on 
the court order, but I would say it's 
Page 278 
completely irrelevant and immaterial and has 
no probative value with regard to this 
particular witness based upon the two 
clients at least that are in suit at this 
point in time. 
MS. EZELL: As Mr. Critton well knows I 
represent a number of other clients whose 
cases have not been filed and I believe we 
do have standing to ask questions, and I do 
intend to do that today. 
EXAMINATION 
BY MS. EZELL: 
Q. Mr. Rodriguez, you stated last time that 
there were guests at the house, frequent guests, 
friends from Harvard. 
Do you remember that testimony? 
A. Yes, ma'am. 
Q. And was there a lawyer from Harvard named 
Alan Dershowitz? 
A. Yes, ma'am. 
Q. And are you familiar with the fact that 
he's a famous author and famous lawyer? 
A. Yes, ma'am. 
Q. How often during the six months or so 
that you were there was Mr. Dershowitz there? 
3 (Pages 275 to 278) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182346

Page 279 
1 
A. Two or three times. 
2 
Q. And did you have any knowledge of why he 
3 
was visiting there? 
4 
A. No, ma'am. 
5 
Q. You don't know whether or not he was a 
6 
lawyer -- acting as a lawyer or whether he was 
7 
there as a friend? 
8 
A. I believe as a friend. 
9 
Q. Were there also young ladies in the house 
10 at the time he was there? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: Yes, ma'am. 
13 
BY MS. EZELL: 
14 
Q. And would those have included for 
15 instance, 
and 
16 
A. Yes, ma'am. 
17 
Q. Were there other young ladies there when 
18 Mr. Dershowitz was there? 
19 
MR. CRITTON: Form. 
20 
THE WITNESS: Yes, ma'am. 
21 BY MS. EZELL: 
22 
Q. Do you have any idea who those young 
23 
women were? 
24 
A. No, ma'am. 
25 
Q. Were any of those the young women that 
Page 281 
1 
Q. Can you tell me where those were? 
2 
A. One in the kitchen, and the one in the 
3 
formal -- the main entrance. And there was one 
4 more added later on, but there is two when I was 
5 
working there. 
6 
Q. Could you just give me a rough sketch of 
7 
the house of where the main entrance was and where 
8 
the kitchen was? 
9 
A. I'm not an architect but it's something 
10 like this. This is the kitchen, this is the main 
11 entrance. 
12 
Q. Will you mark the kitchen with a K, 
13 please, and the main entrance with ME? 
14 
A. This is the pool. 
15 
Q. The pool? 
16 
A. Yes, ma'am. 
17 
Q. And in the upper left? 
18 
A. In the terrace, yeah, there was a balcony 
19 here. 
20 
Q. And where were the staircases? 
21 
A. This Is one, the kitchen, one in the 
22 foyer, and the pool. 
23 
Q. Okay. And would you just put an F where 
24 the foyer staircase began? And KS where the 
25 kitchen staircase began. 
Page 280 
1 you have said came to give massages? 
2 
A. Yes, ma'am. 
3 
Q. And do you have any idea whether or not 
4 
Mr. Dershowitz was also receiving massages? 
5 
A. I don't know, Ma'am. 
6 
Q. I want to ask you to take this piece of 
7 
paper, please, and a pencil --
8 
MR. WILLITS: Can anybody hear me? 
9 
MS. EZELL: Yes. Can you hear me? 
10 
MR. WILLITS: I've heard nothing for 
11 
about a minute or so. 
12 
MR. CRITTON: Can you hear me now? 
13 
MR. WILLITS: Yes. 
14 
MS. EZELL: I'm asking questions, I'm 
15 
sorry. 
16 
MR. CRITTON: Why don't we go off the 
17 
record for a second. 
18 
(Thereupon, a discussion was held off the 
19 record.) 
20 
THE VIDEOGRAPHER: We're back on the 
21 
record. 
22 
BY MS. EZELL: 
23 
Q. Mr. Rodriguez, you indicated that there 
24 
were several staircases in the house? 
25 
A. Yes, ma'am. 
Page 282 
1 
And you said that later another staircase 
2 
was added? 
3 
A. Yeah, we rehabilitated this, you know, 
4 
but you asked me how many stairs there were, to 
5 
answer your question there were three. 
6 
Q. Three. So where was the third one? 
7 
A. The pool, this leads to the pool. 
8 
Through the outside master bedroom you could go 
9 
downstairs to the pool. 
10 
Q. Okay. A stairway then from the outside, 
11 from outside the master bedroom? 
12 
A. Yes, ma'am. 
13 
Q. Down to the pool? 
14 
A. Yes, ma'am. 
15 
Q. One of your duties was to answer the 
16 door. Is that correct? 
17 
A. Yes, ma'am. 
18 
Q. Which door would you answer? 
19 
A. Mainly the kitchen. 
20 
Q. And why was that, why would people mainly 
21 come to the kitchen? 
22 
A. I'll say it was for practicable reasons 
23 
because not to go to the main -- it was shorter 
24 
because the entrance was here, so this was the 
25 driveway and we used to take into the back door of 
4 (Pages 279 to 282) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182347

Page 283 
1 
the kitchen and they will wait there. 
2 
Q. All right. Would you just put BD where 
3 
the back door of the kitchen was, please? 
4 
Now, these young women that came to give 
5 
Mr. Epstein massages, would they usually come to 
6 
the kitchen door? 
7 
A. Yes, ma'am. 
8 
MR. CRITTON: Form. 
9 
BY MS. EZELL: 
10 
Q. Did any ever come to the front door? 
11 
A. Very rarely. 
12 
Q. And you would let them in the kitchen? 
13 
A. Yes, ma'am. 
14 
. And then how did you then turn them over 
15 
to 
16 
MR. CRITTON: Form. 
17 
THE WITNESS: I will call her. 
18 
BY MS. EZELL: 
19 
Q. How would you call her? 
20 
A. On her cell phone and she will know they 
21 were waiting in the kitchen. 
22 
Q. And would you bring them In the kitchen 
23 
and then just leave? 
24 
A. Yes, ma'am. 
25 
Q. And where would you go? 
Page 285 
1 
A. You're welcome. 
2 
Q. Could you see the pool from the staff 
3 
house? 
4 
A. No, ma'am. 
5 
Q. How would you know, or would you know 
6 
when the young women were brought downstairs after 
7 giving the massages? 
8 
MR. CRITTON: Form. 
9 
THE WITNESS: I will hear the commotion, 
10 
some voices, but I was not told they were 
11 
leaving. 
12 
BY MS. EZELL: 
13 
Q. And so did you have any duties that had 
14 anything to do with their leaving? 
15 
A. Check the security and see if the gate 
16 was closed, that the cars were locked because the 
17 garage were here. 
18 
Q. Would you put a G where the garage was? 
19 
I believe you testified that you were 
20 required to have on your person $2,000 everyday? 
21 
A. More or less, Ma'am. 
22 
Q. And if you open the door and a young 
23 woman wa there to give a massage you would call 
24 
and go back to the staff house? 
25 
A. Yes, ma'am. 
Page 284 
1 
A. To my -- to the staff house that was 
2 
here. 
3 
Q. Good, I was going to ask you to show me 
4 
where the staff house is. Just put SH. 
5 
A. It was just maybe five feet, I used to 
6 stay here. 
7 
Q. Okay. So what you're saying, it's about 
8 five feet from the kitchen? 
9 
A. More or less, yes. 
10 
Q. Was it connected to the house? 
11 
A. No, it's detached but it's very close 
12 proximity. 
13 
Q. Okay. So to get to the staff house would 
14 
you come out the kitchen door? 
15 
A. Yes, ma'am. And I came through my --
16 there was two entrances, one through the laundry 
17 
here and one to the main entrance to the staff 
18 
house. 
19 
Q. All right. And what was your usual 
20 
pathway if you left the kitchen to enter the staff 
21 house, how would you generally do it? 
22 
A. Normally I will came to the laundry, the 
23 laundry was here and my office was next to the 
24 laundry. 
25 
Q. Okay. Thank you. 
Page 286 
1 
Q. And then you believe 
would 
2 
come in and lead the young woman upstairs. 
3 
Correct? 
4 
MR. CRITTON: Form. 
5 
THE WITNESS: I'm sorry, can you repeat 
6 
your question? 
7 
BY MS. EZELL: 
Q. I'll try to, yes. 
9 
When you would answer the door and there 
10 
would be a young lady there to give a massage. 
11 
A. Yes, ma'am. 
12 
Q. I believe you testified you would let her 
13 in the kitchen. 
14 
A. Yes, ma'am. 
15 
Q. And you called IMIM? 
16 
A. Yes, ma'am. 
17 
Q. And you then left her in the kitchen 
18 alone? 
19 
A. Yes. 
20 
Q. And went to the staff house? 
21 
A. Yes, ma'am. 
22 
Q. And sometimes you heard the commotion 
23 when the young woman was leaving --
24 
A. Yes, ma'am. 
25 
Q. -- but you didn't necessarily see them 
5 (Pages 283 to 286) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182348

1 
Page 287 
1 leave. Is that correct? 
2 
A. Exactly, yes, ma'am. 
3 
Q. How did 
tr nsmi the money that you 
4 
were keeping to 
to pay those young 
5 
women? 
6 
A. 
would tell me who to pay and how 
7 
much, [lithe way we work. 
8 
Q. And when would she tell you that? 
9 
A. She will call me by phone and say I'll 
10 
give so much to so on and so forth. 
11 
Q. Okay. Was that at the conclusion of the 
12 
massage? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Yes, ma'am. 
15 
BY MS. EZELL: 
16 
Q. Okay. Then I'm a little confused because 
17 I thought you said that you didn't see them when 
18 they left from giving the massage. 
19 
A. She will call me and she will say pay X, 
20 
Y, or Z, and that's the way I knew how much and to 
21 whom. But sometimes they would leave and I didn't 
22 pay those, I don't know who paid them. 
23 
Q. Okay. So if she calls you and told you 
24 to pay X, Y, and Z $200, would you then go back 
25 into the kitchen and give X, Y, and Z $200 each? 
1 
2 
3 
4 
5 
6 
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Page 289 
A. Yes. The whole south face of the house, 
but this was 
Q. All rig t.
 so did she usually work 
with her laptop on the dining room table? 
A. She will have all over the house but she 
will sit down here to work on the desk. 
Q. Do you know whether she kept any lists of 
names of girls to come and give massages? 
A. She did, Ma'am. 
MR. CRITTON: Form. 
BY MS. EZELL: 
Q. And do you know in what form she kept 
those? 
A. She had notes, you know, she always have 
papers, but I don't know. 
Q. Do you recall seeing the papers with 
telephone numbers on them? 
A. A couple of times. 
Q. Do you know whether she also kept records 
on the computer relating to the girls? 
MR. CRITTON: Form. 
THE WITNESS: Yes, ma'am. 
BY MS. EZELL: 
Q. And how do you know that? 
A. Everything was recorded in -- everything 
Page 288 
1 
A. Sometimes in the kitchen, sometimes in 
2 
the driveway I will pay them in an envelope, you 
3 
know. 
4 
Q. Okay. And she would tell you how much to 
5 
pay them? 
6 
A. Yes, ma'am. 
7 
Q. Where was Ms. 
when you would call 
8 
her to tell her that there was someone at the 
9 
kitchen door to give a massage? 
10 
A. She was inside the house so I call her on 
11 her cell and say, Alfredo, leave them in the 
12 kitchen, but I don't know where she was. 
13 
Q. Okay. Did she have an office? 
14 
A. No, ma'am. 
15 
Q. Did she have a computer in the house? 
16 
A. Yes. 
17 
Q. Where was her computer? 
18 
A. She had a laptop but she usually work in 
19 the dining room. 
20 
Q. And where was the dining room? 
21 
A. All this area facing the garde 
" 
22 north -- I'm sorry, facing south, and 
23 
was at her desk here. 
24 
Q. So did the dining room have large 
25 
windows? 
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 290 
we did as employees we used to record and kept in 
the internal circuit we used to have among the 
employees. 
Q. And so would it be, if I understand you 
correctly then, was there some sort of a program 
so that ou could access Information that 
Ms. 
was putting into that program and she 
coul access information you put in? 
A. Yes, ma'am. 
Q. And did you also send each other e-mails 
that way or did you use a different program for 
e-mails? 
A. 
didn't send direct e-mails to me 
but shellicall me on her cell. But I was 
supposed to send through Otrix to other 
employees. 
Q. E-mail them through Citrix? 
A. Yes, ma'am. 
Q. Okay. And who would those other 
employees be, have been, I mean, while you were 
there? 
A. Mrs. Maxwell, Bella in New York, mostly 
the main people, you know, Bella and --
Q. Lesley was --
A. Lesley, yes, the secretary, and somebody 
6 (Pages 287 to 290) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182349

Page 291 
1 else, I don't recall. 
2 
Q. Was there anyone else that you could 
3 
e-mail? 
4 
A. We could e-mail anybody in the 
5 
organization. 
6 
Q. On that particular program? 
7 
A. Yes, ma'am. 
8 
Q. And so who else would be in that 
9 organization? 
10 
A. Other household managers from Paris or 
11 the Island, Manhattan. 
12 
Q. Do you know whether Ms. 
kept any 
13 
pictures of the young women who would come to give 
14 massages on her laptop? 
15 
A. Yes, ma'am. 
16 
Q. You saw those pictures? 
17 
A. Yes. 
18 
Q. Were the pictures uniform? And by that I 
19 mean, were they all taken, for instance, there at 
20 the house so that they would all be fairly 
21 standard? 
22 
MR. CRITTON: Form. 
23 
THE WITNESS: They will be all over, you 
24 
know, sometimes out of the country and 
25 
sometimes in the house. 
Page 293 
IN 
1 
A. I don't remember ma'am. 
2 
Q. Did you ever see 
using that 
3 
small compact camera to tae a picture of the 
4 
girls? 
5 
A. Yes, ma'am. 
6 
MR. CRITTON: Form. 
7 
BY MS. EZELL: 
8 
Q. When you saw her doing that where were 
9 
they, the girls? 
10 
A. The dining room, the library, the first 
11 floor of the house. 
12 
Q. Did you ever see Ms. Maxwell taking 
13 
pictures of the girls? 
14 
A. No, ma'am. 
15 
Q. Did you ever see Mr. Epstein taking 
16 
pictures of the girls? 
17 
A. No, ma'am. 
18 
Q. Were you ever told by anyone that Mr. 
19 Epstein sometimes took pictures of the girls? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: Yes, ma'am. 
22 
BY MS. EZELL: 
23 
Q. And do you recall who told you that? 
24 
A. I think it was IIII. 
25 
Q. Do you recall what she said about that? 
Page 292 
1 BY MS. EZELL: 
2 
Q. Were these pictures that were taken by 
3 
someone for the purpose of keeping them in that 
4 
program? 
5 
A. I don't know. 
6 
MR. CRITTON: Form. 
7 
BY MS. EZELL: 
8 
Q. Or opposed to, for instance, one of the 
9 
you 
ladies bringing a picture to give to 
10 Ms. 
11 
A. I don't know. 
12 
Q. You don't know where the pictures came 
13 from? 
14 
A. No, ma'am. 
15 
Q. Do you know was there anyone staying in 
16 the house who often took pictures of young women? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: There was several cameras 
19 
in the house and they were used often, but I 
20 
don't know who used them. 
21 BY MS. EZELL: 
22 
Q. Okay. Do you remember what kind of 
23 cameras they were? 
24 
A. The small compact camera. 
25 
Q. Any other kind? 
Page 294 
1 
A. He likes photography and he likes -- like 
2 
a hobby. 
3 
Q. Do you know which camera or what kind of 
4 
camera he used to take those pictures? 
5 
A. No, ma'am. 
6 
Q. And you said I think you never saw him 
7 
taking them? 
8 
A. Yes. 
9 
Q. So --
10 
MR. CRTTTON: Yeah meaning correct? 
11 
THE WITNESS: Yes. 
12 
BY MS. EZELL: 
13 
Q. Was it your understanding that he took 
14 
those pictures upstairs? 
15 
MR. CRITTON: Form. 
16 
THE WITNESS: Yes, ma'am. 
17 
BY MS. EZELL: 
18 
Q. And when you had occasion to go upstairs 
19 do you recall seeing camera equipment? 
20 
A. No, ma'am. 
21 
Q. Were you ever told that he took pictures 
22 of the girls nude? 
23 
A. No, ma'am. 
24 
Q. Were you ever told that he liked to have 
25 pictures taken of the girls nude? 
7 (Pages 291 to 294 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182350

Page 295 
1 
MR. CRITTON: Form. 
2 
THE WITNESS: No, ma'am. 
3 
BY MS. EZELL: 
4 
Q. I believe you were asked before in the 
5 
deposition about the stairway leading from the 
6 
kitchen upstairs and whether or not there were 
7 
pictures on that stairway. 
8 
A. Yes, there were pictures. 
9 
Q. Were those pictures some of them of nude 
10 young women? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: Not on the stairway, they 
13 
were in the foyer in the second -- on the 
14 
foyer and the foyer leading to the master 
15 
bedroom. 
16 
BY MS. EZELL: 
17 
Q. I see. Were those -- what size generally 
18 
were those pictures? 
19 
A. They were, you know, I'll say three by 
20 five. 
21 
Q. So very large --
22 
A. Yes, ma'am. 
23 
Q. -- pictures? Were there lots of 
24 
photographs just around the house on top of 
25 
furniture in the various rooms? 
Page 297 
1 BY MS. EZELL: 
2 
Q. And was that already installed when you 
3 
came there? 
4 
A. Yes, ma'am. 
5 
Q. Where is it you -- first of all, did they 
6 
tell you where the equipment was Installed? 
7 
A. No. 
8 
Q. Did you have any understanding of where 
9 
the equipment was installed? 
10 
A. No. 
11 
Q. Do you know whether or not there was 
12 surveillance photography equipment upstairs and 
13 downstairs? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: Yes, ma'am. 
16 BY MS. EZELL: 
17 
Q. And how do you know that? 
18 
A. I read it through the FBI report after 
19 the fact that I -- after I left the job. 
20 
Q. Before reading through the FBI report did 
21 you have any knowledge of the fact that there was 
22 surveillance equipment both upstairs and 
23 downstairs? 
24 
A. No, ma'am. 
25 
Q. While you were there was there ever an 
Page 296 
1 
A. Yes, ma'am. 
2 
Q. And were any of those photographs of 
3 
young women in the nude? 
4 
A. Yes, ma'am. 
5 
Q. Did you recognize any of those young 
6 
women? 
7 
A. Yes, a couple. 
8 
Q. And who was it that you recognized? 
9 
A. Elland some other girl from Brazil 
10 that was in t 
house but I don't remember her 
11 name. 
12 
Q. Was this a girl that would come and stay 
13 in the house or one of the girls that would come 
14 and give massages? 
15 
A. They will stay at the house. 
16 
Q. Stay at the house. Do you recall a 
17 
picture of the girl, of a young women nude in a 
18 
hammock? 
19 
MR. CRITTON: Form. 
20 
THE WITNESS: No, I don't remember. 
21 BY MS. EZELL: 
22 
Q. Was there surveillance equipment 
23 
installed in the house? 
24 
A. Yes, ma'am. 
25 
MR. CRITTON: Form. 
Page 298 
1 occasion when someone came to do any maintenance 
2 
or repair on the surveillance equipment? 
3 
A. Yes, ma'am. 
4 
MR. CRITTON: Object to the form of the 
5 
last question. 
6 
MS. EZELL: Pardon? 
7 
MR. CitITTON: Form of the last question. 
8 
BY MS. EZELL: 
9 
Q. Did that happen more than one time? 
10 
A. I believe so, yes, ma'am. 
11 
Q. Do you have any recollection of who came 
12 
there, either the name of the company or the name 
13 of the person who would come to repair or do 
14 maintenance on the video equipment? 
15 
A. We used to have a young technician from 
16 Ohio who used to maintain all the computers and he 
17 
would be the only one dealing with those things. 
18 
Q. So he maintained the computers and the 
19 video equipment. 
20 
A. Yes. 
21 
Q. Is that correct? 
22 
MR. CRITTON: Form. 
23 
BY MS. EZELL: 
24 
Q. Do you have any recollection of what his 
25 name was? 
8 (Pages 295 to 298) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami 
EFTA00182351

1 
A. I don't remember, Ma'am. 
2 
New Albany, Ohio. 
3 
Q. From New 
4 
A. New Albany, Ohio. 
5 
Q. New Albany, Ohio. 
6 
business? 
7 
A. No, he worked for Mr. Epstein. 
8 
maintain all the computers. 
9 
Q. Was he there everyday? 
10 
A. No, ma'am. 
11 
Q. Do you know whether at that time Mr. 
12 Epstein had an office in Palm Beach? 
13 
A. Not outside the house, no. 
14 
Q. Do you have any knowledge of whether or 
15 not the video equipment was -- and I don't know 
16 the technical term, forgive me, but was it the 
17 
kind of equipment that would record for a certain 
18 amount of time and then record over that film? 
19 
A. I don't know. 
20 
MR. CRITTON: Form. 
21 BY MS. EZELL: 
22 
Q. You don't know? 
23 
A. No, ma'am. 
24 
MR. CRITTON: Just for clarification, I 
25 
may have misunderstood, but I thought he 
Page 299 
He came from 
1 
2 
3 
4 
Did he have his own 
5 
6 
He will 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 301 
video, even phones. 
Q. Would he also repair the televisions if 
they needed work? 
A. No. 
Q. No. Did you have any kind of intercom 
system in the house? 
A. Yes, ma'am. 
Q. And what kind of system was that? 
A. It was standard office equipment, Lucid 
Technologies maybe, but it was an intercom like we 
using right now. 
MS. EZELL: Just let the record reflect 
that the witness pointed to the telephone on 
the table that has a speaker phone. 
THE WITNESS: Yes, ma'am. 
BY MS. EZELL: 
Q. And did you use that in your work? 
A. Yes, ma'am. 
Q. And what did you use it for? 
A. Mr. Epstein used to page me when he 
needed me. 
Q. Did you have one of those phones in the 
kitchen? 
A. Yes, ma'am. 
Q. And was there one out in the staff house 
Page 300 
1 
said he didn't even know the video equipment 
2 
existed until he read the FBI report. 
3 
MS. EZELL: He said he didn't know that 
4 
it was upstairs and downstairs, I believe. 
5 
MR. CRITTON: I thought he said he didn't 
6 
know that it even existed. 
7 
MS. EZELL: I may be wrong. 
8 
BY MS. EZELL: 
9 
Q. Did you know it existed before you read 
10 the FBI report? 
11 
A. No, ma'am. 
12 
Q. I'm sorry, then I was wrong. 
13 
How did you know then that the young 
14 
technician from Ohio maintained the computers and 
15 the video equipment? 
16 
A. Because we used to request -- there were 
17 
always problems with the computers so he came to 
18 
the house and he was the programmer. It was very 
19 
sophisticated. 
20 
MR. CRITTON: Form to the last question, 
21 
move to strike the answer as nonresponsive. 
22 
BY MS. EZELL: 
23 
Q. How did you know then that he maintained 
24 
the video equipment as well? 
25 
A. Because he was in charge of computers, 
Page 302 
1 as well? 
2 
A. Yes, ma'am. 
3 
Q. Do you know where others were in the 
4 
house? 
5 
A. Probably have like 15 phones. We used to 
6 have three in the staff house, one in the cabana, 
7 two in the master bedroom, one in each room, 
8 kitchen, dining room, Mrs. Maxwell's office, the 
9 garage. 
10 
Q. Where was Mrs. Maxwell's office? 
11 
A. Under the stairs next to the kitchen. 
12 
Q. Can you give me some idea of what size 
13 space that was? 
14 
A. It was probably -- we change the floor. 
15 Twelve by five, something like that. 
16 
Q. And was the computer equipment in that 
17 
space? 
18 
A. Yes, ma'am. 
19 
Q. Do you know whether Ms. Maxwell kept the 
20 names and telephone numbers of the girls who came 
21 to do massages? 
22 
A. Yes, ma'am. 
23 
MR. CRITTON: Form. 
24 BY MS. EZELL: 
25 
Q. Do you know that because you saw the 
9 (Pages 299 to 302) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182352

Page 303 
Page 305 
1 names and phone numbers? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: Yes, ma'am. 
4 
BY MS. EZELL: 
5 
Q. Do you know if she kept pictures of the 
6 
girls on the computer? 
7 
A. Yes, she did. 
8 
Q. And you know that as well because you 
9 
happen to see them? 
10 
A. Yes, ma'am. 
11 
MR. CRITTON: Form to the last two 
12 
questions. 
13 
BY MS. EZELL: 
14 
Q. Were they similar to the pictures that 
15 
Ms. 
had on her computer? 
16 
MR. CRITTON: Form. 
17 
THE WITNESS: Yes, ma'am. 
18 
BY MS. EZELL: 
19 
Q. Did the pictures that they kept there 
20 look like pictures that were posed? 
21 
A. They were more casual. 
22 
Q. Did they look as though the person being 
23 
photographed knew that they were being 
24 
photographed? 
25 
MR. CRITTON: Form. 
1 computer? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: Yes, ma'am. 
4 
BY MS. EZELL: 
5 
Q. And did she generally have phone numbers 
6 for those girls? 
7 
A. Yes, ma'am. 
8 
Q. And were they generally pictures of the 
9 
girls? 
10 
MR. CRITTON: Form. 
11 
THE WITNESS: No, ma'am. 
12 
BY MS. EZELL: 
13 
Q. And did Ms. Maxwell have a list of the 
14 girls who came to give massages? 
15 
MR. CRITTON: Form. 
16 
THE WITNESS: Yes, ma'am. 
17 
BY MS. EZELL: 
18 
Q. Did she have telephone numbers generally? 
19 
A. Yes, ma'am. 
20 
MR. CRITTON: Form. 
21 BY MS. EZELL: 
22 
Q. Were there pictures on her computer of 
23 
the girls who came to give massages? 
24 
MR. CRITTON: Form. 
25 
BY MS. EZELL: 
Page 304 
1 
THE WITNESS: No, ma'am. 
2 
BY MS. EZELL: 
3 
Q. And what can you tell me about that, what 
4 
lead you to draw that conclusion? 
5 
A. They were probably taken in parties in 
6 
big reception or banquet. 
7 
MR. CRITTON: Let me offer as a 
8 
suggestion, not that you have to accept or 
9 
that you would, you're using the term young 
10 
girls generically, he has probably seen 
11 
many, many young girls, there was no --
12 
you've used it interchangeably with just 
13 
young girls versus young girls who may have 
14 
come to -- purported to give a massage and, 
15 
therefore, that may be a different answer, 
16 
so that's part of my form objection. 
17 
MS. EZELL: Okay, thank you. 
18 
BY MS. EZELL: 
19 
Q. When I asked you about Ms. 
whether 
20 
she had a list of the girls and telephone numbers, 
21 I think I asked about those girls that came to 
22 give massages, but let me go back and just ask it 
23 that way. 
24 
Did you notice that Ms. 
had a list 
25 of the girls that came to give massages on her 
Page 306 
1 
Q. Ms. Maxwell I'm talking about. 
2 
A. Yes, ma'am. 
3 
Q. And were those pictures the more casual 
4 
ones that you described when I asked whether or 
5 
not the subject looked as though she knew she was 
6 
being photographed? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: I'm sorry, can you repeat? 
9 
BY MS. EZELL: 
10 
Q. Yeah. The pictures of the young girls 
11 who came to the house to give massages that were 
12 on Ms. Maxwell's computer, did they appear to have 
13 
been taken when the girls knew they were being 
14 
photographed? 
15 
MR. CRITTON: Form. 
16 
THE WITNESS: I don't think they knew 
17 
they were being photographed. 
18 
BY MS. EZELL: 
19 
Q. I believe you said they were more casual 
20 pictures. 
21 
A. Yes, ma'am. 
22 
Q. Did you notice any nude photographs in 
23 those pictures? 
24 
A. Yes, ma'am. 
25 
MR. CRITTON: Form for the last question. 
10 (Pages 303 to 306) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182353

1 BY MS. EZELL: 
2 
Q. Among those pictures in Ms. Maxwell's 
3 
computer of the young women who came there to give 
4 
massages, were the nude photographs in that group 
5 
taken, did they appear to be taken In the house? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: No, ma'am. 
8 
BY MS. EZELL: 
9 
Q. You said before they appeared to be taken 
10 at receptions or banquets? 
11 
A. Yes, ma'am. 
12 
Q. And I'm a little confused about how they 
13 were casual and taken while the girls were nude at 
14 receptions and banquets? 
15 
A. What I saw there were parties in Russia, 
16 Eastern Europe, I don't know which country, but 
17 there were also pictures of nude girls in a 
18 
shower, for instance, in a shower stall. 
19 
Q. You said for instance, so were there 
20 other places other than the shower? 
21 
A. Yes, ma'am. 
22 
Q. Like what? 
23 
A. Gatherings, you know, in a party. You 
24 could tell everybody is smiling so I believe it 
25 was a place where they're having fun. 
Page 307 
1 
2 
3 
4 
5 
6 
Page 309 
Q. And was there more than one during the 
time you were there? 
A. Yes. 
Q. Do you remember their names? 
A. One was David, I don't remember the other 
one name. 
7 
Q. Did they appear to be American? 
8 
A. Yes, ma'am. 
9 
Q. Do you know the name 
10 
A. Could be, ma'am, but I'm not sure of his 
11 last name. 
12 
Q. Do you have any idea where those chefs 
13 
had gotten their training? 
14 
A. 
was working in San Francisco when 
15 
he was . 
.
16 
Q. Was he still there when you left Mr. 
17 
Epstein's employ? 
18 
A. Yes, to my knowledge, ma'am. 
19 
Q. Did the chef interact with the girls who 
20 
came to give massages? 
21 
A. In the kitchen, yes. 
22 
Q. And did he often offer them some food 
23 
while they were there? 
24 
A. Yes, ma'am. 
25 
Q. Were there occasions where a girl came to 
Page 308 
1 
Q. Were any of those pictures, if you 
2 
recall, taken in the cabana? 
3 
A. I don't remember. 
4 
Q. Do you recall there being parties and 
5 
gatherings in the cabana at the house? 
6 
A. I don't remember. 
7 
MR. CRITTON: Form. 
8 
BY MS. EZELL: 
9 
Q. When Mr. Epstein entertained did you have 
10 anything to do with seeing that the bars were 
11 stocked and that there was food that was needed 
12 and so forth? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: There was no alcohol in the 
15 
house, only for guests. But, yeah, he will 
16 
ask sometimes for food. 
17 
BY MS. EZELL: 
18 
Q. And do you ever recall him asking for 
19 
food for parties in the cabana? 
20 
A. No, ma'am. 
21 
Q. Was there a chef at the house on El 
22 Brillo Way when you were there? 
23 
A. I'm sorry? 
24 
Q. A chef. 
25 
A. Yes, there was. 
Page 310 
1 give a massage accompanied by another girl, or 
2 
another person, let me say? 
3 
A. Yes, ma'am. 
4 
Q. And sometimes was that other person a 
5 
woman and sometimes a man? 
6 
A. No, ma'am, always a woman. 
7 
Q. Always a woman. Usually would it have 
8 
been a woman about the same age as the young woman 
9 
coming to give the massage? 
10 
MR. CRITTON: Form. 
11 
THE WITNESS: Yes, ma'am. 
12 
BY MS. EZELL: 
13 
Q. Were you ever told by Ms. 
to pay 
14 
the person who came who didn't give a massage? 
15 
A. Yes, ma'am. 
16 
Q. Do you recall how much you paid that 
17 
person? 
18 
A. Yes, ma'am. 
19 
MR. CRITTON: Form. 
20 
BY MS. EZELL: 
21 
Q. Flow much? 
22 
A. 300 to 500 dollars. 
23 
Q. Were some of those young women who 
24 brought other young women for massages regulars, I 
25 mean, did they regularly bring other young women? 
11 (Pages 307 to 310) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182354

Page 311 
1 
MR. CRITTON: Form. 
2 
THE WITNESS: Yes, ma'am. 
3 
BY MS. EZELL: 
4 
Q. And were there some who maybe came just 
5 
once or twice with other young women? 
6 
A. That's correct, ma'am. 
7 
Q. Now, where would the young woman who was 
8 
bringing another young woman go during the time 
9 
the person that she brought was upstairs giving 
10 the massage? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: I will take them to the 
13 
kitchen and 
would take them from 
14 
there. 
15 BY MS. EZELL: 
16 
Q. Do you know where she took them? 
17 
A. No, ma'am. 
18 
Q. Were they ever taken to just sit in the 
19 living room and wait? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: I don't know, ma'am. 
22 
BY MS. EZELL: 
23 
Q. These pictures of nude young women taken 
24 In gatherings where they were smiling, did they 
25 appear to you to be taking part in an orgy? 
Page 313 
1 
shower, I don't know whether he ever used 
2 
plural. 
3 
BY MS. EZELL: 
4 
Q. Was there more than one picture of a girl 
5 
in the shower? 
6 
A. There were two girls in the shower. 
7 
Q. Two girls in the shower together? 
8 
A. Yes, ma'am. 
9 
Q. And were those two girls engaged in 
10 
something sexual? 
11 
A. Yes, ma'am. 
12 
Q. And I may have asked you this question, 
13 
forgive me if I did, did you know those two girls? 
14 
A. No, ma'am. 
15 
Did Ms. Maxwell have nude pictures of 
16 
on her computer? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: I don't know, ma'am. 
19 
BY MS. EZELL: 
20 
Did you ever meet a young woman named 
21 
who had an association with Ms. Maxwell? 
22 
MR. CRITTON: 
? 
23 
MS. EZELL: 
24 
THE WITNESS: I don't remember, ma'am. 
25 
BY MS. EZELL: 
Page 312 
1 
MR. CRITTON: Form. 
2 
THE WITNESS: I don't know, ma'am. 
3 
BY MS. EZELL: 
4 
Q. Do you know the word cavorting? 
5 
A. No, ma'am, I don't know. 
6 
Q. I need my Thesaurus. You said they were 
7 
smiling, did they appear to be having a good time? 
8 
A. Yes, ma'am. 
9 
Q. Did they appear to be doing anything 
10 sexual? 
11 
A. Yes, ma'am. 
12 
Q. And in these instances were there girls 
13 
doing sexual things with other girls? 
14 
A. Yes, ma'am. 
15 
Q. And I'm still talking about the pictures 
16 on Ms. Maxwell's computer. 
17 
A. Yes, ma'am. 
18 
MR. CRITTON: You're talking about the 
19 
group shots that he's mentioned from Russia 
20 
and Eastern Europe? 
21 
MS. EZELL: And girls in the shower. 
22 
MR. CRITTON: Let me object to the form 
23 
then the way you just now described that. 
24 
MS. EZELL: He said for instance. 
25 
MR. CRITTON: He had said a girl in the 
Page 314 
1 
Q. Did you ever have any conversations with 
2 
Ms. Maxwell about any of the women in those 
3 
pictures? 
4 
A. No, ma'am. 
5 
id you ever have a conversation with 
6 
about any of the pictures of the 
7 
girls in her computer? 
8 
A. No, ma'am. 
9 
Q. You were asked last time about the creams 
10 and lotions that Mr. Epstein typically had 
11 available to him and you said you thought there 
12 
was a favorite one but you couldn't remember it. 
13 
A. Spa. 
14 
Q. Spa, you did say Spa. 
15 
A. Yeah. 
16 
Q. Thank you. 
17 
Where did the stairway from the kitchen 
18 
lead -- to where did it lead? 
19 
A. To the second floor between the first and 
20 second bedrooms. 
21 
Q. Were either of those bedrooms the master 
22 bedroom? 
23 
A. No, ma'am. 
24 
Q. Could one go up that staircase through --
25 
could one go up that staircase and reach the 
12 (Pages 311 to 314) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182355

Page 315 
1 master bedroom? 
2 
A. Yes, ma'am. 
3 
Q. And how would you do that? If you want 
4 
to turn the page over for the upstairs you could 
5 
do that. 
6 
A. Okay. 
7 
MR. CRITTON: Are you going to mark this 
8 
as an exhibit? 
9 
MS. EZELL: Uh-huh. 
10 
MR. CRITTON: Would that be Exhibit 3? 
11 
MR. EDWARDS: I think so. 
12 
(Exhibit No. 3 was marked for 
13 
Identification.) 
14 
THE WITNESS: This is the master bedroom, 
15 
master bath, and there were one, two -- the 
16 
rest of the bedrooms were here and the 
17 
master bedroom was here. This is master 
18 
bath one and master bath two. 
19 
So the staircase came to the second floor 
20 
like this and it was between the first and 
21 
second bedroom. And you could go through 
22 
here and you enter a foyer with double doors 
23 
here, double doors here, and you enter the 
24 
master bedroom. 
25 
BY MS. EZELL: 
Page 317 
1 
Q. White. By the way, I have some more 
2 
water, would you like some? 
3 
A. Thank you, ma'am. 
4 
Q. I figure if I'm a little dry you may be 
5 
too. 
6 
I believe one of the items that you 
7 
mentioned that sometimes had to be picked up after 
8 
girls were there giving massages was a back 
9 
massager. 
10 
A. Yes, ma'am. 
11 
Q. Could you describe that for me, please? 
12 
A. It was a piece about this big. 
13 
Q. Would you say that's about 18 inches? 
14 
A. Yes, ma'am. And two prongs with the 
15 rubber tips and a cord. 
16 
Q. Okay. 
17 
A. Or it could be detached too. 
18 
Q. Do you have any recollection of what make 
19 that was? 
20 
A. No, ma'am. 
21 
Q. Were there any other massagers that you 
22 recall seeing there regularly? 
23 
A. Those are the ones I remember. I think 
24 they are from Sharper Image, but I don't --
25 
Q. Okay. Were there often girls around the 
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 316 
Q. All right. How would you get to the 
master bathroom on that end? 
A. You go through these double doors, go 
around the bed and you gain access to the master 
bedroom -- master bathroom, sorry. 
Q. And then there was another master 
bathroom on the other side of the room? 
A. Yes, ma'am. 
Q. Where generally did the massages take 
place? 
A. Right here, ma'am. 
Q. And is that in the master bathroom? 
A. Master bathroom, yes. 
Q. Do you recall what color the tile was in 
that bathroom? 
A. There was carpet. 
Q. Was there tile on the walls or marble 
or --
A. There was a sauna here with marble but 
outside the sauna everything was carpet, and the 
walls, they didn't have any tile. Oh yes, I will 
say four feet off the floor they will have marble. 
Q. And do you remember what color marble it 
was? 
A. White. 
Page 318 
1 pool at the house? 
2 
A. Yes, ma'am. 
3 
Q. And were these sometimes the same girls 
4 
that came to give massages? 
5 
A. Yes, ma'am. 
6 
Q. Were there girls in addition to those who 
7 
came to give massages who hung around the pool? 
B 
A. The girls who were staying at the house. 
9 
Q. Okay. And so they weren't girls who just 
10 
regularly came to hangout around the pool? 
11 
A. No, ma'am. 
12 
MS. EZELL: Excuse me. Can we go off the 
13 
record for a minute? 
14 
(Thereupon, a recess was had.) 
15 
THE VIDEOGRAPHER: We're back on the 
16 
record with tape number two. 
17 
BY MS. EZELL: 
18 
Q. Mr. Rodriguez, did you receive a subpoena 
19 that asked you to bring documents with you to the 
20 deposition? 
21 
A. Yes, ma'am. 
22 
Q. And did you bring any with you? 
23 
A. I couldn't find anything at my house. 
24 
Q. Okay. I believe we talked about a 
25 journal that you kept, and you looked for that? 
13 (Pages 315 to 318) 
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EFTA00182356

Page 319 
1 
A. Yes, ma'am. 
2 
Q. And you couldn't find it? 
3 
A. I
ati
 to Detective 
4 
Q.
5 
A. Yes, ma'am. 
6 
Q. You mentioned that you called Mr. 
7 
Jean-Luc Bernell about a recommendation when you 
8 
were looking for a job. 
9 
A. Yes, ma'am. 
10 
Q. And did you know him from his visits in 
11 the home? 
12 
A. Yes, ma'am. 
13 
Q. Did you say that his wife's name was Eva? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: No, ma'am. 
16 
BY MS. EZELL: 
17 
Q. Do you know what his wife's name was? 
18 
A. Eva was a model, a former model from 
19 years past who was friend of Mr. Epstein. 
20 
Q. Do you know if she was married to Glenn 
21 Dubin? Do you know Mr. Dubin? 
22 
MR. CRITTON: Form. 
23 
THE WITNESS: I believe, yeah, I'm not 
24 
sure, ma'am. 
25 
BY MS. EZELL: 
Page 321 
1 
BY MS. EZELL: 
2 
Q. Did they ever visit Mr. Epstein at the 
3 
home when you were there? 
4 
A. Yes, ma'am. 
5 
Q. How old was the little girl at that time? 
6 
A. Eight years old. 
7 
Q. Did the girl's father come to visit as 
8 
well? 
9 
A. Yes, ma'am. 
10 
Q. And do you remember his name? 
11 
A. No, ma'am. 
12 
Q. Do you remember hearing anything about 
13 what he does for a living? 
14 
A. No, ma'am. 
15 
Q. Can you describe him? 
16 
A. Tall, American born, I will say 50 years 
17 old. 
18 
Q. What color hair did he have? 
19 
A. At that time it was black with a few 
20 white hairs. 
21 
Q. Were there drawings of nude women in the 
22 house? 
23 
A. No, ma'am. 
24 
Q. Were there paintings of nude women in the 
25 
house? 
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 320 
Q. Is she now a doctor? 
A. No, she was a model, her husband could be 
a doctor but I don't think she is. 
Q. Okay. So is Jean-Luc Bemell married; to 
your knowledge? 
A. I don't know, ma'am. 
Q. I think I must have gotten confused 
because we were talking about the picture in the 
house of the little girl who is lifting up her 
skirt or her underpants, I'd forgotten what it 
was. 
A. Yes, ma'am. 
MR. CRITTON: Form. 
es, ma'am. 
Q. Do you know where she and her mother 
live? 
A. They live in Manhattan. 
MR. CRITTON: Form. 
Page 322 
1 
A. Yes, ma'am. 
2 
Q. Did any of those appear to be 
3 
Ms. Maxwell? 
4 
A. Yes, ma'am. 
5 
Q. You mentioned that 
who was still 
6 
working there when you left --
7 
A. Yes, ma'am. 
8 
Q. -- was a very religious woman --
9 
A. Yes, ma'am. 
10 
Q. 
— and would sometimes be upset about 
11 seeing pictures of nude girls or having to pick up 
12 sex toys, et cetera. 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Yes, ma'am. 
15 
BY MS. EZELL: 
16 
Q. And you said that you remembered her 
17 crying because there was a picture of the Pope 
18 next to a picture of a naked girl. 
19 
MR. CRITTON: Form. 
20 
THE WITNESS: Yes, ma'am. 
21 BY MS. EZELL: 
22 
Q. Do you know who that naked girl was? 
23 
A. I don't remember, ma'am. 
24 
Q. I believe David Copperfield's name came 
25 
up in the last deposition as someone who would 
14 (Pages 319 to 322) 
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Page 323 
1 call or visit. 
2 
A. Yes, ma'am. 
3 
Q. Were you ever there when he visited? 
4 
A. Yes, ma'am. 
5 
Q. And do you remember did he spend the 
6 
night? 
7 
A. No, ma'am. 
8 
Q. Did he come for dinner? 
9 
A. Yes, ma'am. 
10 
Q. Did that happen more than one time when 
11 you were there? 
12 
A. Yes, ma'am. 
13 
Q. Do you remember whether or not any of the 
14 young ladies who came to perform massages also 
15 
stayed for dinner? 
16 
A. No, ma'am. 
17 
MR. CRITTON: Just so Ifs clear, no, you 
18 
don't remember? 
19 
THE WITNESS: No, they were not there. 
20 BY MS. EZELL: 
21 
Q. Did any of them ever stay for dinner? 
22 
Just any dinner, not the dinner with David 
23 
Copperfield. 
24 
A. You said they, the girls? 
25 
Q. The girls who came to give massages. 
Page 325 
1 
we are start with it and then you can use 
2 
the initials after that for all I care. 
3 
BY MS. EZELL: 
4 
Q. Do you remember a girl named. 
5 
A. I heard that name. 
6 
Q. So I will refer to her as 
from now 
7 
on. 
8 
I'm going to show you a document, we can 
9 
mark it but I'm not going to leave it. I'm going 
10 to take the exhibit. 
11 
MR. CRITTON: Wait a minute. Are you 
12 
going to make a copy of it? 
13 
MS. EZELL: No, I'm not going to leave a 
14 
copy. 
15 
MR. CRITTON:. All right. Then I object 
16 
to you showing him a document that is not 
17 
part of this record. 
18 
MS. EZELL: Then object and the Judge can 
19 
rule, but I'm going to ask him to look at 
20 
this document. We can mark it as Exhibit 4. 
21 
THE WITNESS: Oh yeah. 
22 
BY MS. EZELL: 
23 
Q. Do you remember this young woman? 
24 
A. Yes. 
25 
MR. CRITTON: Let's see. 
Page 324 
1 
A. No, ma'am. 
2 
Q. In the earlier part of the deposition you 
3 
stated that you didn't drive the girls but then 
4 
later you remembered that you did sometimes have 
5 
to drive them. 
6 
A. Yes, ma'am. 
7 
Q. Do you remember a young woman named 
8 
who came there? 
9 
A. Yes, I do remember. 
10 
MS. EZELL: And again, we're going to 
11 
have the same agreement, if we use a girl's 
12 
name it will be shown on the transcript as 
13 
the initials only. 
14 
MR. EDWARDS: Agreed. 
15 
MR. CRITTON: Why don't you give him the 
16 
initials? Because in reading the transcript 
17 
we could end up with 25 l's ores ores, 
18 
in looking at it by just using the first, I 
19 
am just offering a suggestion because none 
20 
of us will remember who in the heck these 
21 
people are. 
22 
MS. EZELL: So you're asking me to give 
23 
both names so we would have two initials? 
24 
MR. CRITTON: He may not recognize either 
25 
the first or the second name but as long as 
Page 326 
1 
BY MS. EZELL: 
2 
Q. And was she one of the ones who came to 
3 
the house to give massages? 
4 
A. Yes, ma'am. 
5 
Q. Do you remember her name? 
6 
A. No, ma'am. 
7 
Q. Is it possible she was le? 
MR. CRITTON: Form. 
9 
THE WITNESS: I hear that name but I 
10 
cannot say for sure. 
11 BY MS. EZELL: 
12 
Q. Okay. Did she come often to the house? 
13 
A. Yes, ma'am. 
14 
Q. Were you ever aware of her being 
15 
photographed? 
16 
A. No, ma'am. 
17 
Q. I asked you about David Copperfield 
18 
before and let me ask you again. In thinking 
19 about it is it possible that you remember that she 
20 
was there for dinner with David Copperfield? 
21 
MR. CRITTON: Form, asked and answered. 
22 
THE WITNESS: Possible, yes, ma'am. 
23 
BY MS. EZELL: 
24 
Q. Did you ever meet her parents? 
25 
A. No, ma'am. 
15 (Pages 323 to 326) 
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Page 327 
1 
Q. I'll take the pictures back. 
2 
MR. CRITTON: Just put on the record that 
3 
my dient obviously could be here at the 
4 
deposition, or anyone's clients could be 
5 
here at the deposition and have full arrest 
6 
to the information that's being provided, by 
7 
taking the photograph back I'm not going to 
8 
be able to provide to that client, nor will 
9 
I have possession of it so I could discuss 
10 
that photograph, it's now been explored with 
11 
this witness. 
12 
(Exhibit No. 4 was marked for 
13 Identification.) 
14 
BY MS. EZELL: 
15 
Q. Do you recall that on occasion you drove 
16 this young woman to or from Mr. Epstein's house? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: I don't remember, ma'am. 
19 
BY MS. EZELL: 
20 
Q. Do you ever recall driving her by the 
21 airport and showing her Jeffrey Epstein's plane? 
22 
MR. CRITTON: Form. 
23 
THE WITNESS: Yes, ma'am. 
24 
BY MS. EZELL: 
25 
Q. Do you ever recall one time perhaps by 
Page 329 
1 
BY MS. EZELL: 
2 
Q. You mentioned last time that Mr. Epstein 
3 
asked you to go and rent a car for one of the 
4 
girls who gave him massages. 
5 
A. Right. 
6 
Q. Do you know if that was IMI.? 
7 
A. I'm not hundred percent sure, ma'am. 
8 
Q. Do you know how long that girl kept the 
9 
car? 
10 
A. A couple of months. 
11 
Q. Did she bring it back to you or did she 
12 
turn it in at the agency? 
13 
A. She brought it back to me. 
14 
Q. Did you ever have any knowledge of Mr. 
15 
Epstein helping this girl with her college 
16 applications? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: I believe Mr. Epstein was 
19 
giving her money for good grades, that's 
20 
what I -- she told me, I understood that. 
21 BY MS. EZELL: 
22 
Q. Was this the girl that you were 
23 instructed by Mr. Epstein to take roses to at the 
24 
completion of her graduation? 
25 
A. I don't remember exactly, ma'am, but 
Page 328 
1 accident seeing her naked? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: Yes, ma'am. 
4 
BY MS. EZELL: 
5 
Q. How did that happen? 
6 
A. I told 
to go upstairs because I 
7 
saw Mr. Epstein leave, so we rushed upstairs to 
8 
clean and this girl was sleeping naked in the 
9 
sauna, she fall asleep there, there was nobody 
10 else there. 
11 
MR. CRITTON: Can I ask just for 
12 
clarification, is he talkie now about the 
13 
person he thought was. but he wasn't sure 
14 
or the person that's in photo four? 
15 
MS. EZELL: The person that's in 
16 
photo four. 
17 
THE WITNESS: Yes. 
18 
MR. CRITTON: Okay, thank you. 
19 
BY MS. EZELL: 
20 
Q. And just so we're clear, do you think 
21 this is M. but you're not sure? 
22 
MR. CRITTON: Form. 
23 
THE WITNESS: I heard the name so many 
24 
times but I know I took her, you know, in 
25 
the Suburban, so it was her. 
Page 330 
1 
there were so many faces, you know, but I cannot 
2 
say a hundred percent. 
3 
Q. But it's possible that this is the same 
4 
girl? 
5 
A. Yes, ma'am. 
6 
MR. CRITTON: Form. 
7 
BY MS. EZELL: 
B 
Q. And thinking about it carefully you still 
9 
believe she kept that car for two months? 
10 
A. Yes, ma'am. 
11 
Q. Do you recall an encounter with this same 
12 girl when you saw a strange vehide in the 
13 driveway one day? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: Yes, ma'am. 
16 BY MS. EZELL: 
17 
Q. And what happened then? 
18 
A. I saw, you know, an old car that didn't 
19 belong to the house so I went to the police 
20 department, so the police department follow me and 
21 they with flashlight they went Into the driver and 
22 ask her because she was -- I forgot I was suppose 
23 to pay her but it was late at night, 8:00 p.m., 
24 something like that, 8:30, so I recognize her and 
25 I said to the police department I know this girl, 
16 (Pages 327 to 330) 
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Page 331 
1 so I paid her and she went off. 
2 
Q. Do you recall how much you paid her? 
3 
A. Between two and 300 dollars, I believe. 
4 
Q. How often was Mr. Epstein in Palm Beach 
5 
during the period you were there? 
6 
A. He will stay two months -- I mean, two 
7 
weeks out of the month. 
8 
MS. EZELL: If I could please have these 
9 
marked as Exhibits 5 through 8. 
10 
(Exhibit No's. 5, 6, 7, and 8 were 
11 marked for Identification.) 
12 
MR. CRITTON: Do you want them in the 
13 
order you gave them? 
14 
MS. EZELL: It doesn't matter. 
15 
BY MS. EZELL: 
16 
Q. Would you look, please, at the exhibit 
17 
that has been marked as number -- what is it; 
18 
five? 
19 
A. Five. 
20 
Q. Five. Do you recall seeing this young 
21 woman at the house when you were there? 
22 
A. Yes, ma'am. 
23 
Q. And do you recall her name? 
24 
A. No, ma'am. 
25 
MR. CRITTON: Let the record reflect it's 
Page 333 
1 
Q. Possibly but you're not sure? 
2 
A. Yes, ma'am. 
3 
Q. Okay. Would you look, please, at the two 
4 
photographs that have been marked as Composite 
5 
Exhibit 7? 
6 
Do you recall seeing this girl come to 
7 
the house to give massages? 
8 
A. I don't remember, ma'am. 
9 
Q. Okay. That's perfectly all right. 
10 
MR. CRITTON: Who does that purport to 
11 
be; number seven? 
12 
MS. EZELL: 
13 
BY MS. EZELL: 
14 
Q. The last one is exhibit what? 
15 
A. Eight. 
16 
Q. Eight. Do you recall seeing this girl 
17 come to the house to give massages? 
18 
A. No, ma'am. 
19 
Q. Okay. 
20 
MS. EZELL: I don't have any other 
21 
questions right now. If anybody else wants 
22 
to go, if I could just reserve that if I 
23 
find something. 
24 
MR. WILLITS: I don't know who's next, 
25 
this is Richard Willits, I have a couple of 
Page 332 
1 
written on the photographs is a name, so 
2 
it's already being suggested to him, I think 
3 
that's inappropriate. 
4 
MS. EZELL: It shouldn't be there, I'm 
5 
sorry. If I can erase it I will, I didn't 
6 
realize it was on there. 
7 
MR. CRITTON: It's on all of them, Cathy. 
8 
MS. EZELL: You're right, sorry. 
9 
BY MS. EZELL: 
10 
Q. Looking at the girl iniarrber five, if I 
11 told you that her name was= would that 
12 
refresh your recollection as to who she was? 
13 
A. No, ma'am. 
14 
Q. Would you look, please, at the girl in 
15 the picture that's been marked as Exhibit 6? 
16 
Do you ever recall seeing that girl come 
17 to the house to give massages? 
18 
A. I cannot guarantee that, Ma'am. 
19 
Q. I understand, it's not the best picture 
20 in the world either, you can't see. 
21 
MR. EDWARDS: I don't know that I 
22 
understood the answer. You can't guarantee 
23 
it? 
24 
THE WITNESS: I cannot guarantee it, sir. 
25 
BY MS. EZELL: 
Page 334 
1 
questions. 
2 
MR. CRITTON: All right, you're up. 
3 
MR. EDWARDS: Hold on one second, 
4 
Richard, they're going to put a microphone 
5 
by the phone. 
6 
MR. WILLITS: I only have a couple of 
7 
questions. 
8 
(Thereupon, an interruption was had.) 
9 
THE VIDEOGRAPHER: We're back on the 
10 
record. 
11 
EXAMINATION 
12 
BY MR. WILLITS: 
13 
Q. Back on the record. Sir, my name is 
14 Richard Willits and I just have a couple of 
15 questions for you. 
16 
Do you remember a_younagirl coming to 
17 the house by the name of. or.? 
18 
A. I hear that name, sir. 
19 
Q. You know the name, does that ring a bell 
20 at all? 
21 
A. I hear the name in the house. 
22 
Q. Can you associate that name with a girl? 
23 
A. Yes, sir. 
24 
Q. I'm sorry? 
25 
A. Yes, sir, yes, I do. 
17 (Pages 331 to 334) 
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Page 335 
1 
Q. Do you remember whether she came to the 
2 
house on more than one occasion? 
3 
A. I heard her name several times from 
4 
sir, but beyond that I cannot say anything 
5 !. 
6 
Q. Okay. Who have you talked to about your 
7 
knowledge of Mr. Epstein in the last year? 
8 
A. My wife. 
9 
Q. Anyone else? 
10 
A. No, sir. 
11 
Q. Well, you talked to Mr. Critton. 
12 
A. We have a conversation in West Palm 
13 Beach. 
14 
Q. Yes. So you talked to your wife, you 
15 talked to Mr. Critton? 
16 
A. Yes. 
17 
Q. Had you talked to anyone else in the last 
18 year about Epstein? 
19 
A. No. 
20 
Q. Did you talk to Mr. Goldberger? 
21 
A. Yeah, I called Mr. Goldberger first 
22 
before I talked to Mr. Critton. 
23 
Q. Okay. So we have your wife, we have Mr. 
24 Critton, and we have Mr. Goldberger. 
25 
Do we have anyone else that you talked to 
Page 337 
1 
A. I give him a list of notes that I used to 
2 
take from frequent people -- I mean, people who 
3 
used to frequent the house and -- I'm sorry, it's 
4 
been a few years, I don't remember, but it was 
5 
those years, like it was a file with my personal 
6 
notes because he told me it was very important and 
7 
he kind of said can I borrow this from you, and he 
8 
still has those documents, sir. 
9 
Q. So even though they pertain to Mr. 
10 
Epstein you kept those notes at your residence? 
11 
A. Yes, sir. 
12 
Q. Okay. Where in your residence did you 
13 
keep those notes before you gave them to the 
14 
Detective? 
15 
A. In my bedroom. 
16 
Q. Did you have a file cabinet or --
17 
A. No. 
18 
Q. -- chester drawers or something? 
19 
A. No, they were laying next to some other 
20 
papers that I have. 
21 
Q. Did the other papers pertain to Mr. 
22 Epstein? 
23 
A. No, no, nothing else related to Mr. 
24 
Epstein. 
25 
Q. I'm just confused as to why you told us 
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 336 
in the last year? 
A. No, sir. 
Q. How about Mr. Epstein of course? 
A. No. 
Q. Where did you usually keep the journal 
with the names of the girls, in what part of the 
house? 
A. In the staff house. 
Q. Sorry? 
A. The staff house, the guest house. 
Q. Right. But you said you had a journal at 
your own residence with the names of the girls. 
A. I give the whole journal and all the 
information regarding this case, sir, to Detective 
sir. 
Q. Okay. And the materials that you gave to 
the Detective, were they kept -- were any of them 
kept at your own personal residence? 
A. Yes, they were with me, sir. 
Q. Okay. When you gave the materials to the 
Detective, did all of the materials you gave to 
him come from your residence? 
A. Yes. 
Q. Do you remember exactly what you gave to 
him? 
Page 338 
1 
before that you had a journal at home and today 
2 
you say that you gave everything to the Detective. 
3 
MR. CRITTON: Form. You also may have 
4 
missed a portion of his earlier testimony if 
5 
you couldn't hear something, but go ahead. 
6 
MR. WILLITS: Most likely. 
7 
THE WITNESS: What I said was I thought I 
had some information, and then I look with 
9 
my daughter and we couldn't find anything, 
10 
and I remember now that I outman° in 
11 
the file that I give to Detective 
12 
BY MR. WILLITS: 
13 
Q. Did anyone help you assemble those papers 
14 to give to the Detective? 
15 
A. No, sir. 
16 
MR. WILLITS: I don't have any other 
17 
questions. 
18 
CROSS EXAMINATION 
19 
BY MR. CRITTON: 
20 
Q. Mr. Rodriguez, my name is Bob Critton and 
21 1 represent Mr. Epstein as you're aware, I have a 
22 few questions for you. 
23 
What I would like to remind you at the 
24 
start of this is if you know something, tell us, 
25 if you don't know something tell us that. 
18 (Pages 335 to 338) 
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EFTA00182361

Page 339 
1 
You're not required to speculate, you're 
2 not required to guess, you're not required to 
3 
assume because some lawyers ask you a leading 
4 
question or suggested in a report or like the 
5 
police report like Mr. Mermelstein and Mr. Edwards 
6 
did, that did you tell the police officers X, Y, 
7 
or Z without showing you the statement. You're 
8 
not required to guess, I want personal knowledge, 
9 not speculation. Do you understand? 
10 
A. Yes, I do. 
11 
Q. All right. Now, when Mr. Edwards and --
12 
Mr. Horowitz is here today for Mr. Mermelstein, 
13 but you remember a lawyer asked you some questions 
14 last time you were here? 
15 
A. Yes. 
16 
Q. That is he started and he went on for a 
17 few hours. Do you recall that? 
18 
A. Yes, I remember. 
19 
Q. He asked you do you remember telling the 
20 police officer Y, X, or Z. 
21 
Do you remember that? Do you remember 
22 that's how he phrased his question? 
23 
A. Yes, yes. 
24 
Q. He never showed you a statement that you 
25 made to the police department; did he? 
Page 341 
1 
marked up, no, you can't. 
2 
MR. CRITTON: I just want to show him. 
3 
Thank you, Cathy. 
4 
BY MR. CRITTON: 
5 
Q. This is the first what Ms. Ezell was kind 
6 
enough to provide is the first part of your 
7 
deposition, it was transcribed by the court 
8 
reporter and provided by all counsel. 
9 
Do you understand that? 
10 
A. Yes, I understand that. 
11 
Q. And no one has provided that to you yet 
12 
today; have they? 
13 
A. No. 
14 
Q. Now, I think you told us that with the 
15 
police officers you gave a taped statement. 
16 
Did I understand you correctly? 
17 
A. Yes. 
18 
Q. And the only conversation that you had 
19 with the police officers, and it may have been a 
20 state attorney, it was somebody named Ms. Weiss 
21 who I think was referenced in the questions, the 
22 on time that you talked with at least Officer 
23 
and the State Attorneys Office from Palm 
24 
Beac County was in a taped statement. 
25 
Is that correct? 
2 
3 
4 
5 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 340 
A. I'm sorry? 
Q. He didn't show you a document that said, 
question, you know, what is your name; answer, my 
name is Alfredo Rodriguez --
MR. WILLITS: Object to the form of the 
question. 
MR. CRITTON: You need to let me finish 
it first. 
MR. WILLITS: I'm sorry, I thought you 
were. 
BY MR. CRITTON: 
Q. He never showed you a statement of what 
the question was and the answer that you gave. 
True? 
MR. WILLITS: Object to the form of the 
question. 
THE WITNESS: I don't exactly understand 
your question. 
BY MR. CRITTON: 
Q. Do you know what a deposition is? 
A. Yes, I am. 
Q. That's what you're doing here. 
MR. CRITTON: Could I borrow your 
deposition for just a minute? 
MR. HOROWITZ: The transcript? It's 
Page 342 
1 
A. No. 
2 
Q. Did you talk with them separate and apart 
3 
from that? 
4 
A. Yes, I did. 
5 
Q. Okay. Did they tape that statement? 
6 
A. No. 
7 
Q. You told us you also spoke with 
8 
representatives of the FBI? 
9 
A. Yes. 
10 
Q. Okay. And you distinguished between the 
11 FBI and between Officer 
12 
A. Yes. 
13 
Q. So how many times did Officer ME 
or 
14 
Detective S 
I think he's from the Palm 
15 
Beach Police Department speak with you? 
16 
A. Like three or four times. 
17 
Q. But he only took one statement? 
18 
A. One taped. 
19 
Q. I'm sorry, one taped statement? 
20 
A. Yes. 
21 
Q. All right. So as to whether r not if 
22 
you said something to Officer 
or not that 
23 
you would be able to confirm, that would only have 
24 
been in a taped statement, one taped statement out 
25 of the three, approximately three times he spoke 
19 (Pages 339 to 342 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182362

Page 343 
1 
with you. 
2 
MR. EDWARDS: Form. 
3 
MR. HOROWITZ: Form. 
4 
BY MR. CRITTON: 
5 
Q. Is that correct? 
6 
A. Yes, correct. 
7 
MR. WILLIES: Object to the form. 
8 
MR. HOROWITZ: Join. 
9 
BY MR. CRITTON: 
10 
Q. And when we were here, I think it was 
11 last week or the last ten days anyway -- I could 
12 tell you. On July 29th of this year, and Mr. 
13 
Mermelstein started with your deposition and then 
14 others asked questions, when Mr. Mermelstein and I 
15 think Mr. Edwards asked questions about did you 
16 tell Officer 
X, Y, or Z, they didn't show 
17 you a statement, they didn't give you like a 
18 transcript like this and say see what the question 
19 and see what the answer is? 
20 
A. No. 
21 
MR. EDWARDS: Form. 
22 
MR. WILLIES: Object to the form of the 
23 
question. 
24 
BY MR. CRITTON: 
25 
Q. And you haven't had an opportunity to see 
Page 345 
1 
Q. When OfficerM took — spoke with 
2 
you on those approximately two times when he did 
3 
not take a taped statement, did he ever present 
4 
anything for you, anything in writing that he had 
5 
written to say, Mr. Rodriguez, I would like you to 
6 
review this to make certain that I took down 
7 
correctly what you said? 
8 
A. No, sir. 
9 
Q. If he had offered to do that would you 
10 have read what he wrote down to determine whether 
11 or not he took down that which you had said or 
12 told him? 
13 
MR. EDWARDS: Object to the form. 
14 
THE WITNESS: Probably I will read It 
15 
first. 
16 
BY MR. CRITTON: 
17 
Q. All right. And if In fact he had 
18 recorded something incorrectly or recorded in a 
19 particular way that he wanted it phrased and it 
20 was not accurate, would you have told him that? 
21 
MR. EDWARDS: Object to the form. 
22 
THE WITNESS: No, I never told him that. 
23 BY MR. CRITTON: 
24 
Q. Listen to mysiiin. 
25 
If he, Officer 
, had taken down 
Page 344 
1 your taped statement since you gave it many years 
2 
ago? 
3 
A. No, sir. 
4 
Q. Would you agree that your taped statement 
5 
would probably be a little more accurate than your 
6 
testimony today because of the time period that 
7 
has transpired? 
8 
A. That's correct. 
9 
MR. HOROWITZ: Object to the form. 
10 
MR. WILLIES: Object to the form of the 
11 
question. 
12 
BY MR. CRITTON: 
13 
Q. When you spoke with the FBI over at 
14 
Greens -- I think it was Greens Pharmacy? 
15 
A. Yes. 
16 
Q. Did they take a statement from you, that 
17 is, did they have a tape recorder or did they just 
18 make notes? 
19 
A. They took notes. 
20 
Q. All right. Did you sign anything? 
21 
A. No, sir. 
22 
Q. That Is like did they take notes of what 
23 you said and then you signed It to say yep, that 
24 accurately reflects what I said? 
25 
A. No, I didn't sign anything. 
Page 346 
1 
what you said and it was not accurate, that is, he 
2 
put his interpretation of what you said, would you 
3 Aid 
him that's not accurate, Officer 
4 
5 
MR. HOROWITZ: Form. 
6 
MR. EDWARDS: Object to the form. 
7 
THE WITNESS: I will tell him. 
8 
MR. CRITTON: Go ahead and change. We're 
9 
going to change the tape. We do have time. 
10 
Cathy, could I borrow back the 
11 
photographs, please? 
12 
While you're giving me those back, would 
13 
it be correct that you're going to keep --
14 
you took as you did with photograph 
15 
number four you took back five, six, seven, 
16 
and eight, and you're going to keep those 
17 
and not allow me or anyone else to have a 
18 
copy of them? 
19 
MS. EZELL: Yes. 
20 
MR. CRITTON: You're going to be equally 
21 
restrictive; right? 
22 
MS. EZELL: Right. 
23 
MR. CRITTON: All right. Thank you. 
24 
BY MR. CRITTON: 
25 
Q. You were shown photograph five of a lady, 
20 (Pages 343 to 346) 
Kress Court Reporting, Inc. 
7115 Rue Notre Dame, Miami Beach, FL 33141 
EFTA00182363