EFTA01247530

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CIVIL DIVISION 
Plaintiff, 
vs. 
CASE No. 
502008CA028051XXXXMB AB 
JEFFREY EPSTEIN, 
Defendant. 
DEPOSITION OF 
VOLUME I 
October, 20. 2009 
10:10 a.m. 
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida 
ESQUIRE 
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October 20, 2009 
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IR na chicory cceer OF TIM FIFTRI26111 JOICTAL CIRCUIT 
111 AND FOR PAlM SIAM CCM', FLORIDA 
CIVIL DIVISION 
CASK No.5132COSCAOTSCD/XXX/30 AS 
Plaintiff, 
JRFIRIT errotte. 
Defendant. 
DITPGItlalvel)P1R=- 
111044411. October. 20. 2009 
10110 - 1,10 p.a. 
%sported Sy: 
Teresa IabaIon, RPR. PPR 
Notary Public. Stab of Florida 
Neat Palt leach Office 
Job  
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APPEARANCES' 
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ROBERT 0. CRITTON, JR.. ESQUIRE 
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BURIMN CRITTON LIMIER & COLEMAN. LLP 
303 Banyan Boulevard. Suite 400 
West Riatairda 
33401 
Phoe: 
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On behalf of PORNO 
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On behalf of the Defoxlant: 
A 
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'WS 
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On behalf or Wanda 
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On behalf M PMaLMt in reWmd Cabe No 08-80811 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE No.06-CV-60119-CIV•MARRAMOHNSON 
PIIe I, 
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1 
JEFFREY EPSTEIN, 
Deist 
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Related cases 
08-80232, 08-80380. 93-8038 I. 08-80904. 
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08-80993. WSW 1. 004/0893. 0943469. 
09-80591. 0940656. memex.09-elos2 
II 
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DEPOSITION OF 
VOLUME I 
Tuesday. Ocfcbts 20. 2009 
1010 - 3:33 p.m 
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Reported By: 
TINOS. Whalen. APR, FPR 
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WINO PROC. STIDO of Fbrkla 
West Palm Beech Office Job is116991 
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Phone: 800.330.6952 
561 659 4155 
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25 
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• • 
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INDEX 
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' " 
WITNESS 
DIRECT CROSS REDIRECT RECROSS 
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BY MR 
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In
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190 
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BY LEL 
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208 
:o 
BY ma= 
156 
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BY MR. 
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EXHIBITS 
as 
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NUMBER 
DESCRIPTION 
PAGE 
IS 
DEFENDANTS EX. I COPIES, COMPOSITE PHOTOGRAPHS 103 
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DEFENDANTS EX. 2 COMPO9TE FICNE MESSAGE BOOK 147 
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DEFENDANTS EX 3 COPY OF PHOTOGRAPH 
162 
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MID 
- Volume 
October 20, 2009 
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PROCEEDINGS 
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0 
How long have you been employed by 
Mr. Epstein? 
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Deposition taken before Teresa Whalen: 
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A It will be live years this November 17th. 
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Registered Professional Reporter, Florida 
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0 
So you started November 17th, 2004? 
Professional Reporter, and Notary Public In and for 
A Yes. sir. 
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the State of Florida at Large, in the above cause. 
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And how did you get hired by Mr. Epstein? 
- - 
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A Through an agency. 
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Thereupon, 
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What agency? 
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MIS) 
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A It's Regal Domestics. 
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having been first duly sworn or affirmed. was examined 
to 
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And what was your position that you were tired 
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and testified as knows: 
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by Mr. Epstein la? 
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THE WITNESS: I do. 
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A Housekeeper-
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DIRECT EXAMINATION 
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0 
We've taken the deposition of another witness 
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MR 
Does anyone want to put on the 
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in this case, Alfredo Rodriguez. Aro you familiar with 
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record what case INS is bang taken in? I noticed 
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that name? 
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it ire. versus Epstein. I don't know if anybody 
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A 
Yes. 
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cares to say who your clients me, what the case 
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0 
And that person. I believe he represented that 
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style is or 
hi 
else for when she types it up. 
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he was also maybe a house manager. IS that correct? 
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MR 
I don't have a problem with 
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A Correct. 
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that. Are we doing initials? 
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0 
Would he have been, at some point in time, 
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MR 
Yeah. Initials. 
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your boss or your superior? 
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MRS 
Okay. 
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A 
Yes. 
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BY MR. 
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0 
That's somebody who you answered to, 
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0 
All right. Will you state your name for the 
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Alfredo Rodriguez? 
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A (Nodang head). Sometimes 
record. 
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A 
1 Ma
You have to say yes or no. you 
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card nod your hoed. 
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BY I.E. 
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Yes? 
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A Yes. 
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MR. CRITTON: No. no. Site said SOMNIMOS. 
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then yeingaijaper Muth. 
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MR.
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laden put anything in her 
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mouth. I don't want the record -
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MR. CRITTON: Let me take It back. You said 
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yes. but she started to say something before she 
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vas Interrupted. 
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BYMi
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O That's line. You cal answer the question. 
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then well irettua 
On the deposition.
: Did you want to explain that 
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further? 
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THE WITNESS: Because we wore supposed towed( 
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O Have you ever lived at Jeffrey Epstein's 
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together. Nit he was bossy. he was bossy. 
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location of 358 El Brillo Way? 
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BY I.E. 
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A 
No, sir. 
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0 
Okay. Have you ever had your deposition taken 
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0 
Whore are you currently employed? 
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before Ike this? 
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A Mr. Epstein. 
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A No. 
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0 
And what address do you report to work? 
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0 
All right. Well, there is one oourt repater, 
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A 358 El Brae Way. 
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n very easy In casual conversation to nod your 
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October 20, 2009 
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head or shake your head, and she can't take that down. 
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A 
All right 
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O It's also very easy to say uh-huh or huh-uh, 
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but it kind of looks the same on paper, so you can't do 
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that either. I'm going to wait until you finish your 
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answer, and you have to wait until I finish my question, 
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because if we talk over one another, then the court 
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reporter can't get it down. 
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A Okay. Yes, sir. 
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O All right. So if you don't understand the 
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questiOn, sell me you don't understand and I'll try to 
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ask a better question. 
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A 
Yes. 
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O Okay. So you were hired in November ol 2004 
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to be the housekeeper for Mr. Epstein? 
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A 
Yes. 
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0 
And when you were hired, who exactly hired 
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you, who — let me strike that. 
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When you were hired to be the housekeeper for 
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Mr. Epstein, who did you interview with? 
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A Ms. Maxwell. 
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O Is that Ghislaine Maxwell or just 
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Leine Maxwell? 
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A 
Ghislaine Maxwell. 
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O And where did the interview take place? 
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that it's clean and appropriately. what's this... 
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O And as I understand this property, there is a 
3 
main house and then there's also a staff house on the 
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property. is that right? 
A Yeast 
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O And when the guests would come over, would you 
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stay in the main house. or would you go to the staff 
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house? 
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Can we get a time frame to the 
question? 
BY MR. -
O Over the last five yews while you worked 
there. 
A I usually stay in the staff house and do the 
laundry, then I go to the kitchen and then tidy the 
kitchen. 
O You were hired in November of 2004. and what 
were your hours that you worked there back in November 
of 2004 when you were hired? 
A Eight to five. 
O How many days a week? 
A Depends. 
O Flow would the schedule be relayed to you? 
A When Mr. Epstein is there, then I'm supposed 
to report, but usually it's live days a week. 
10 
1 
A At 358 El Belo Way. 
2 
O And what did Ms. Maxwell and you speak about 
3 
prior to your being hired as the housekeeper'? 
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A My duties. 
O And what did she tell you your duties would 
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be? 
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A To tidy, to make beds, do laundry 
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O Did she tell you what would take ptace in the 
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house on a day-to-day basis? 
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A No. 
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O So going into that position, you had no idea 
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who the guests would be or who the people Coming in the 
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house would be, or what would generally go on? 
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A Can you simplify the question? 
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O Sure. When you talked about with 
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Ghlslaine Maxwell at this interview, your duties being 
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you would make the bed and tidy up, did she also tell 
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you that there would be a lot of guests, there would be 
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a few guests, did she talk to you about that at all? 
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A 
She mentioned Petri there are guests, we 
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have to, like, you know, prepare the room, and, what's 
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this. attend to the guests. 
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O And what did you understand that to mean that 
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you have to attend to the guests? 
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A You have to prepare the room and see to it 
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O So am I correct in understanding that there 
was one schedule when Mr. Epstein was in town, and the 
schedule may be a little bit different it Mr. Epstein 
was out of town? 
A 
Yes, sir. 
O All right. Tell me the differences when 
Mr. Epstein Is in town versus when Mr. Epstein was not 
in town. 
A If he stays like three or four days, then I'm 
supposed to be there. and then the house is to be 
cleaned. And then when they do not come, then I can 
either go there, or I'm gven free days off. 
Cr 
Three days off? 
A 
No. A free day. 
o 
Oh. okay. But typically back in 2004 when you 
were hired, you worked an average of about five days a 
week; is that correct? 
A Yes. 
o 
All right. And I guess by the way that you're 
explaining it, of Mr. Epstein was in town for a longer 
period of time, you may work more than five days. and if 
Mr. Epstein was not in town, you may work less than five 
days? 
A 
YOS. 
o 
Okay. Did you ever talk to Mr. Epstein prior 
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to being hired? 
A No. sir. 
O Where did this meeting, within the house where 
did the meeting with Ghislaine Maxwell take place? 
A In the living room. 
O Aside from telling you that you were going to 
be required to make the beds and just generally tidy up, 
did she specify anything else that you would be required 
to do? 
A No. 
O 
And when you went to the interview. Obviously 
youtre going to this very big house and you talked to 
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Did she tea what you would be paid at that 
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time? 
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A Not yet. 
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Did you show up that Saturday? I guess that's 
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November 17th of 2004? 
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A No, that's not. 
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No. Was it prior to November 17th of 2004. or 
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after? 
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A 
After. 
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Okay. The interview that you first went to 
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was November 17th. 2004 with Ms. Maxwell; is that the 
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date that you gave us? 
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A 
I cannot remember. 
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0 
The only reason I'm using that date is I 
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believe the question I asked was when did you start 
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working for Mr. Epstein, and I thought the date that you 
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gave me was November 17th. 2004. 
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A 
Yes. 
19 
0 
Okay. And in the course of this whole thing. 
20 
it sounds like you interviewed with Ghislaine Maxwell. 
21 
there were other interviewees, you received a call and 
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you were asked to try out on a Saturday? 
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A 
Yes. 
24 
0 
And where does that Saturday fall in related 
25 
to November 17th, 2004? 
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Ghislaine Maxwell. right? 
2 
A 
Yes. 
3 
0 
And did you decide right then that you Med 
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this and that you were going to change professions and 
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you were going to be his housekeeper? 
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A No. 
7 
0 
Okay. Then walk me through that, how did you 
8 
go about eventually accepting the position? 
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A 
I didn't expect to be hired. because there 
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were other interviewers (sic). interview people that 
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were to be interviewed. 
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0 
Okay. 
13 
A 
And then I receive a call from Ms. Maxwell it 
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I like. I can do a try-out. 
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0 
Okay. Did the tell you how long this try-out 
16 
period would last? 
17 
A No. 
18 
0 
And what did you tell her when sho made that 
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offer for you to try out? 
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A 
I told her that I am still taking care of this 
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patient, so she said if you like, you can come Saturday 
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and try it. 
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0 
Okay. And what did you tell her, did you 
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accept that? 
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A 
Yes,Idid. 
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A When I accepted the fob offer. 
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0 
Okay. And did they tel you at that time sten 
3 
you accepted the job offer how much you WOW Going to he 
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paid? 
s 
A Yes. 
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0 
What was that? 
7 
A It was 32.000 per annum. 
0 
And haS your salary increased ovor time? 
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A Yes. sir. 
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0 
And can you walk us through the increments of 
11 
increase n your salary? 
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A It was PronliSed yearly increase' 
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0 
By whom? 
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A Ms. Maxwell 
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0 
Was that at the lime whon you wore 
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interviewed, or look the job? 
17 
A Yes. sir. 
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0 
Did the promise you what your yearly Increase 
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would be? 
20 
A No. 
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0 
And have you received a yearly increase every 
22 
year? 
23 
A Idid. 
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0 
And what has that yearly increase been? 
25 
A Up to 42. 
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October 20, 2009 
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Today? 
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A Yes. 
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So you're making $42,000 today. and that's the 
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meet that you've made over the five-year period you've 
worked for Mr. Epstein? 
A 
Yes, sir. 
O At the lime when you -- when we took 
Alfredo Rodriguez's deposition, he described you as a 
very religious Catholic woman. Does that accurately 
describe you? 
MR. CRITTON: Let me just object to the form. 
You can answer the question If 
you understood it. 
THE WITNESS: I am a Catholic and I go to 
mass. 
BY MR. 
O Is that something you go to regularly? 
A III have time. I go regularly. 
O When do you normally go to mass? 
A Sunday masses and weekdays. 
o 
How many weekdays? 
A 
111 can, every day. 
o 
And in the five-year period that you've worked 
for Mr. Epstein, have you tried to go every day it you 
could? 
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O Okay. So legs talk about lhat. Back in 
November o12004, you were to working 8:03 a.m. to 
5:00 p.m. And when Cod that schedule change from 8:00 
5:00? 
A 
When? When the house was renovated. 
O When was that, do you remember the year? 
A 
2006. 
O Okay. 
MR. CRITTON: I'm sorry. '06? 
THE WITNESS: '06. 
BY MR. -
O So from November 2004 through '06, I'm correct 
in presumi ng that your schedule was an average cativo 
days a week from 8:00 a.m. to 5:00 p.m.? 
A At that time I go nine o'clock. I go to the 
house at nine o'clock. 
O Starting in 2006? 
A Yes. 
O So when your schedule changed from 8:00 ti 
5:00. in 2006 you started going to the house, 
Jeffrey Epstein's house, at nine o'clock? 
A Yes, sir. 
O And you would stay until what time? 
A Sometimes 5:00, sometimes later. 5:30. 
o 
Would that depend on what needed to be done? 
18 
1 
A No. 
2 
0 
In a typical week would you normally go on 
3 
Sunday to mass? 
4 
A Yes, sir. 
5 
0 
And how many days during the week will you 
6 
also attend mass? 
7 
A If the schedule permits, then Igo, but if 
not, then I don't go. 
9 
0 
So is there a way that you could 9-IVO me an 
10 
average of how many times a week that you go during the 
11 
week to mass? 
12 
A This lime? 
13 
0 
Right. Yeah. I guess today, these days. 
14 
A I attend Sunday masses only. 
15 
0 
And back in 2004, vmen you first started with 
16 
Mr. Epstein? 
17 
A I filed to go it I have the time. sir. 
18 
O Was there ever a time that you went every day? 
19 
A No. 
20 
0 
But your testimony is that if time permitted, 
21 
you tried to Go every day? 
22 
A Yes. 
23 
0 
Is there a reason why now these days you only 
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attend on Sundays? 
25 
A Because my time schedule has changed. 
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A Yes. 
O How have you received your money. has it been 
by Check, by cash, in terms of payment from Mr. Epstein? 
A It's directly deposited to my bank 
O Do you know who directly deposits your money? 
A MP? 
O Yeah. Mother Its Ghislaine Maxwell or a 
corporation or Jeffrey Epstein. do you knew who the 
direct depositor is of your check? 
MR. CRITTON: Form. 
THE WITNESS: Mr. Epstein. 
BY MR. -
O Okay. Over the five years that you have been 
working at Mr. Epstein's house, how many conversations 
have you had directly with Mr. Epstein? 
A What's this, what year? 
O Wel. in the last five years, how many 
conversations have you had &cc* with Mr. Epstein? 
MR. CRITTON: Form. 
THE WITNESS: The past year it's just good 
morning, how aro you. you're doing a good job. 
BY MR. -
O Okay. How was it prior to that, did you talk 
to him more? 
A This time more. 
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October 20, 2009 
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1 
O Now you talk to him more? 
2 
A Because I serve him breakfast. so... 
3 
O And is that an additional responsibility that 
4 
you didn't have before? 
A 
Yes. 
6 
O In the live-year penod that you've worked 
7 
there, can you name for me all of the other employees 
8 
who have worked at the Jeffrey Epstein house? 
9 
A 
After Alfredo Rodriguez left, there was 
10 
Jerome. the gardener, and now it's Yanusz. 
11 
O And those are the house managers'? 
12 
A 
Yes. 
13 
O And then you work there? 
14 
A Right. 
15 
O Aside from yourself. Jerome. and Janusz. was 
16 
there anybody else that you can remember working at the 
17 
house in the past live years in any position? 
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A 
Yes. 
19 
O Who else? 
20 
A 
21 
O 
That's 
22 
A 
Yes. 
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O What does she do there? 
24 
A 
She's the personal assistant. 
25 
O Personal assistant to whom? 
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1 
A 
Yes. 
2 
O When did you talk to Lyn Fontanilla about 
3 
4 
A It was just through the conversation. 
5 
O What would cause you to be in a conversation 
6 
with this person in New York? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: She calls me, I call her. 
9 
BY MR. 
10 
O You're friends? 
11 
A 
Yes. 
12 
O Do you still talk to her today? 
13 
A 
Yes. 
14 
O 
And does she work for Mr. Epstein as well, to 
15 
your knowledge? 
16 
A 
She does. 
17 
O 
And does Jojo, her husband, also work for 
18 
Mr. Epstein as well? 
19 
A 
Yes, sir. 
20 
O 
Where do they work? 
21 
A 
In New York. 
22 
O 
At Mr. Epstein's house in New York? 
23 
A 
Yes, sir. 
24 
O 
And have you talked with them about your 
25 
duties and has she talked to you about her duties? 
22 
1 
A Mr. Epstein. 
2 
O And as his personal assistant, what have you 
3 
observed her to do for him? 
4 
A Can you rephrase your question? 
5 
O I can try. You sad that she's his personal 
6 
assistant. What does that mean, what does she do? 
7 
A Order things that I need. Ordi whats this. 
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O So it's your testimony that 
has 
9 
been. tor the past the years that you ve worked there. 
10 
has been somebody that you have observed to order things 
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that you reed? 
12 
A If I need something. than I go to ask 
M
I
 
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O Oka . What other things have you seen 
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do for Mr. Epstein? 
15 
A I have not, that's the any thing I know. 
16 
O Who told you that 
is 
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Mr. Epste,rts personal assistant? 
18 
A Coworker. 
19 
O Who is that? 
20 
A In New York. 
21 
O What's that person's rerne? 
22 
A Lyn. 
23 
O Lyn who? 
24 
A Fcetanala. 
25 
O Is that Jojo's wife? 
24 
1 
A 
YeSi sir. 
2 
O Arid your duties are similar to Lyn's duties in 
3 
New York? 
4 
A 
No. Because that's a bigger house than... 
5 
O Palm Beach? 
6 
A 
Yes, sir. 
7 
O 
IS It your understanding that 
you know, 
8 
we're going to gel into the past two years where 
9 
Mr. Epstein has either been in jail or he's been on 
10 
house arrest in Palm Beach, so I'm going to ask you 
11 
first for the first three years that you worked there 
12 
and Mr. Epstein was traveling, was Mr. Epstein spending 
13 
the majority of his time in Palm Beach or in New Yolk or 
14 
elsewhere. il you know? 
15 
A He comes 
we don't know the schedule, we 
16 
receive a call, then we prepare, he's coming. 
17 
O You say we receive a call. Who receives the 
18 
calf? 
19 
A 
Esther Alfredo or Janusz. 
20 
O Depending on who the house manager is at the 
21 
time? 
22 
A 
Yes. 
23 
O And the call comes from whom, from Dhislaine 
24 
or from Jeffrey Epstein? 
25 
A I don't know. 
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25 
1 
O Okay. What's your understanding of Lyn's role 
2 
In Jeffrey Epstein's life up in New York? 
3 
A She's housekeeper, too. 
4 
O And your understanding of Jojo's role' 
5 
A A driver. 
6 
O Does he also serve as a house manager, similar 
7 
to the way Alfredo Rodriguez was in Palm Beach? 
A No. 
9 
O Whon you say a driver, who does he drive. it 
10 
you know? 
11 
A Mr. Epstein. 
12 
O All right. Mr. Epstein obviously hasn't been 
13 
in New York for quite some time: isn't that your 
14 
understanding? 
15 
A 
Yes. 
16 
O So Jcicts still employed up In New York as a 
17 
driver for Mr. Epstein, right? 
18 
A He also does housework, helps Lyn. 
19 
O Have you discussed with Lyn whether or not 
20 
young girls visit the house in New York? 
21 
MR. CRITTON: Form. 
22 
You can answer that. 
23 
BY MR. 
24 
O He didn't like the loan el my question so he's 
25 
able to object. but you can still answer. 
1 
2 
3 
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5 
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27 
MR. CRITTON Form. 
BY MR. 
O
Do 
you understand his question? 
BY MR. -
O Do you understand my question? 
Do you know that is whim he's 
asking you? 
THE WITNESS: Yes. 
I think the question was do you 
know whether or not Mr. Epstein pled guilty to 
comes. 
Was Mal the 
Ion? 
MR. 
Sure. 
MR. CRITTON: That was not his question. 
BY MR. -
O Okay. Well, do you realize that Mr. Epstein 
pled guilty to crimes? 
A Plead guilty? From the news. 
O Okay. So when you say you saw the news, which 
is whore this portion or our discussion began, aro you 
referring to the news related to Mr. Epstein and the 
charges, the criminal charges or criminal investigation 
surrounding him; is that the news you're talking about,
A Yes. 
26 
1 
You can still answer If you 
2 
understand the question. 
3 
THE WITNESS: No. 
4 
BY MR. 
O YouVe never talked to Lyn about young girls 
6 
being in the house in New York? 
7 
A When the news came up, so that's how we 
8 
talked. 
9 
O What do you mean, when the news came up? 
10 
A Whenever there was something on the news on 
11 
TV, then that's how we come to talk about it. 
12 
O Okay. When you say something came on the 
13 
news, you're talking about In terms of a criminal 
14 
investigation of Mr. Epstein? 
15 
MR. CRITTON: Form. 
16 
THE WITNESS: Criminal? 
17 
BY MR. 
18 
O Well, you realize that Mr. Epstein went to 
19 
Jail, right? 
20 
A 
Yes. 
21 
O And that was after pleading guilty to some 
22 
crimes. You realize that, right? 
23 
MR. CRITTON: Form. 
24 
BY MR. 
25 
O I mean, that's why you go to jail. 
1 
2 
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O Okay. So when that came out are we talking 
about 2005, 2008, something in that area? 
MR. CRITTON: Form. 
BY MR. -
O Is that the first time you remember seeing the 
news on that subject? 
MR. CRITTON: Form. 
THE WITNESS: I cannot remember. 
BY MR. -
O All right Whenever it was, you bilked to Lyn 
about that? 
A No. I don't usually talk about it She calls 
and how aro you doing. then oh, like that. 
O Okay. And what was the discussion as It 
related to girls in either the New York house or the 
Palm Beath house between yoursetl and Lyn? 
MR. CRITTON: Form. 
THE WITNESS: She talks to me when she read in 
the news or she saw on the computer. 
BY MR. -
O Okay. And does she toll you about young girls 
being in the New York house? 
MR. CRITTON: Form. 
THE WITNESS: Sho did not 
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29 
1 
BY MR 
2 
0 
Okay. Have you talked to Jojo about that? 
3 
MR. CRITTON: Form. 
4 
THE WITNESS No. 
5 
BY MR. 
In working there for live years. at least the 
7 
time period pnor to Mr. Epstein going to jail. while 
9 
you were there you recognized a kit of young g rks in 
9 
the house. right? 
10 
MR. CRITTON: Form. proticate. 
11 
THE WITNESS. Young girls? 
12 
BY MR. 
13 
0 
Are you asking --
14 
A 
They are females. 
15 
0 
Where rid the females come from, did you know") 
16 
A I don't know. 
17 
Q Do you know why they were at tie house? 
19 
A For massage. 
19 
MR. CRITTON: Form. 
20 
BY MR. 
21 
0 
When is the first time that you heard about 
22 
females corning to Mr. Epstein's house for massages? 
23 
A Maybe two weeks after I started working. 
24 
0 
Al light. Sol you started November 17th of 
25 
2004, then sometime around early December of 2004. you 
31 
1 
0 
All right. And when is the first time that 
2 
you saw these girls come to the house' And by 'these 
3 
gins,' I'm talking about the girls that you were told 
4 
were here to give massages. 
MR. CAUTION: Form. 
6 
THE WITNESS: I cannot remember specifically 
7 
the day and the time. 
8 
BY MR. -
9 
0 
These massages take place every day that 
le 
Mr. Epstein's in town, right? 
11 
MR. CRITTON: Form, leading 
12 
THE WITNESS: Not always. 
13 
BY MR. 
14 
0 
Okay. So it the testimony in this case by 
15 
other witnesses has been that Mr. Epstein has these 
16 
gifts over at his house to give him a massage every day 
17 
than you would disagree with that testimony? 
18 
MR. CRITTON: Fern. improper question. 
19 
THE WITNESS: Because there are times that I'm 
20 
not there in the house. 
21 
BY MR. 
• 
22 
0 
Okay. Every day that you are there in the 
23 
house and Mr. Epstein is also there. girls come over m 
24 
his house to give him massages, as you understand it? 
25 
MR. CRITTON: Form, leading. 
30 
1 
heard about young girls or girls coming to Mr. Epstein's 
2 
house for the purposes of giving him a massage' 
3 
MR. CRITTON: Form. 
4 
BY MR. 
• 
0 
Is that right? 
6 
A 
Young girls? Theyre females. and I was told 
7 
they come to do massages. 
• 
Who told you that? 
9 
A 
Alfredo. 
10 
0 
Alfredo told you that the girls did massages? 
11 
A 
Ho told me when I started there that there are 
12 
massages to be done, and then that's when I heard it 
13 
first from him. 
14 
0 
And then did you witness the girls come over 
15 
that you were told were there to give massages? 
16 
MR. CRITTON: Form. That she actually saw, is 
17 
that what you're -- let me just object to the form. 
18 
MR. 
I said the word saw. so I mean. 
19 
there's no. We. mixing words there. Yes. that 
20 
she actually saw. 
21 
MR. CRITTON. There's a distinction between 
22 
seeing the grls coming and seeing the massages. 
23 
BY MR. 
24 
a Did you See the girls come to the house',
25 
A 
Sometimes. 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
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24 
25 
32 
BY MR. 
O Is trial a fair statement? 
MR. CRRTON: Form. loading. 
Also can we gel a time frame? 
You mean now, or prior" 
BY MR. -
O Between 2004 and the lime that Mr. Epstein 
went to jail in 2008. 
MR. CRITTON: Same objection. 
Do you understand the question? 
THE WITNESS: No. 
BY MR. -
O 
Okay. Between 2004 and the time that 
Mr. Epstein went to jail in 2008, on occasions whore you 
were in the house and Mr. Epstein was in town, is it a 
lair statement that girls came over to give him a 
massage every day? 
MR. CRITTON: Form. 
THE WITNESS: Between what year again? 
BY MR. -
O 
When you started working and the time when 
Mr. Epstein went to grit 
MR. CRITTON: Same objection. 
THE WETNESS: Yes. 
0 
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33 
BY MR. -
O Al right. And Mien you wore in the house and 
Mr. Epstein was also in town, would there be usually one 
massage per day. or two massages, or more? 
A 
Maybe three. 
O Okay. So on a typical day when you were in 
town, you were in the house and Mr. Epstein wash town. 
irs your testimony that he would have an average of 
three massages a day? 
A Not average. I'm 
I want to correct that. 
o 
Correct it. please. 
A What's this, average? Can you... 
o 
Okay. I think I see what you're saying. 
Some days there would be two and some days 
there would be three, and you don't want to commit to an 
average? 
A 
Yes. Because sometimes I'm not aware. I'm in 
the staff house. 
O Okay. Al right. I understand what you're 
saying. 
But the days when you are In the house and 
Mr. Epstein is there. you see days when there are two 
massages per day and some days when there are throe 
massages per day? 
A 
Yes. 
35 
1 
whets this, to their appearances or to their what their 
2 
attre is. 
3 
0 
All right. Haven't you made a comment lo 
4 
Alfredo Rodriguez in the past that those girls that are 
S 
coming over to give massages are too young? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: I cannot remember. 
8 
BY MR. -
9 
0 
Isn't that something that you have believed? 
10 
MR. CRITTON: Form. 
11 
THE WITNESS: What you mean. believe? 
12 
BY MR. 
13 
0 
Isn't that something that you have thought in 
14 
your head, these girls that are coming over to the house 
15 
that are supposedly giving Mr. Epstein massage are Soo 
16 
young? 
17 
MR. CRITTON: Form. 
is 
THE WITNESS: At my ago, these people are 
19 
young to me. so... 
20 
I'm past sixty. so they are young. 
21 
BY MR. 
22 
0 
Well, haven't you also made the statement to 
23 
Mr. - we'l come back to that statement. 
24 
When these girls would come in the house, you 
25 
said sometimes you would answer the door, right? 
34 
1 
0 
All right. And these people that are coming 
2 
over that you were told by Atfredo Rodriguez are there 
3 
to give Mr. Epstein a massage, isn't it typical that 
4 
they would arrive by taxicab' 
5 
MR. CRITTON: Form, leading. 
THE WITNESS: I did not know about that. 
BY MR. 
O 
Oo you know how any of these 
one more 
question before I ask the next one. 
Are they always female masseuses? 
A 
Yes. 
O 
And are you aware of how these female 
13 
masseuses would arrive to Mr. Epstein's house between 
14 
the time you started working and the time he went to 
15 
jail? 
16 
A No. Because I'm inside the house. 
17 
0 
Okay. Can you describe these females for us? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: I don't pay attention to their, 
20 
what's this, because I just do my job. open the 
21 
door if I'm 
what's this. I hear the doorbell 
22 
rang. 
23 
BY MR. 
24 
0 
Okay. 
25 
A So I don't eke, really pay attention lo. 
10 
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IS 
16 
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36 
1 
MR. CRITTON: Form. 
2 
BY MR. -
3 
0 
And you would see these --
4 
MR. CRITTON: Wan. Can INA.. 
s 
II you use the word 'female,' I'm not gang to 
6 
object to most of your questions, as opposed to 
7 
'girls.' because I don't Mow what you mean by 
that. So I'm going to keep objecting. 
Whatever you want. I just... 
MR. 
Yeah, I know. I'm just talking 
about the gds that wotid come over is give 
massages.
MR. CRITTON. It you want to cal them 
ferrules. I have no el:Section. It you call them 
gins, I don't know what that means. Ferrules, I 
do 
MR. 
Okay. 
MR. CFUTTCN I m not telling you how to 07 
11. I'm just telling you --
MR. 
No, no. I appreciate it. 
BY MR. 
0 
The females that would come over to give 
massages. calm times you would answer the MO( when the 
door rang? 
A Sometimes. 
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37 
0 
Okay. And sometimes who else would answer the 
2 
dew? 
3 
A Altred0. 
4 
0 
And what door would the females enter through? 
• 
A 
The kitchen door. 
6 
0 
And is that the door that other guests would 
7 
also enter through? 
8 
A 
Sometimes. 
9 
0 
Why was that door chosen as the door for the 
10 
female masseuses to enter through, do you know? 
11 
A No. I don't. 
12 
0 
What would happen, what would be the next step 
13 
as these females would enter through the kitchen door? 
14 
A I don't know, because I just let them and then 
15 
gelnish my work. 
16 
0 
Okay. And then would their next contact be 
17 
with 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: If I see= 
then yes. But I 
20 
just let them stay in the kitchen and then go to 
21 
the staff house and continue the laundry. 
22 
BY MR. 
23 
0 
Isn't it your understanding that these females 
24 
were on a schedule as to when 10 cone over to give 
25 
Mr. Epstein a massage? 
39 
1 
that rotated. were talking about fifty, a hundred, two 
2 
hundred (afferent females that you saw? 
3 
MR. CRITTON: Form 
4 
THE WITNESS. I 00 not count 
5 
BY MRa 
6 
0 
You saw a lot of different female faces that 
• 
were supposedly there to give him a massage. nghl7
a 
MR. CRITTON: Fern leading. 
9 
THE WITNESS: Sometimes the same female comes 
10 
back. so... 
11 
BY MR 
12 
0 
And other times It would be different females? 
13 
A Yes. 
14 
0 
All right. And can you approximate the age of 
is 
these females that would come over to the house/ 
16 
MR. CRITTON: Form. 
17 
THE WITNESS: load not ask their age. 
18 
BY MR. 
19 
0 
You saw they face and you saw their 
20 
appearance. Would you be surprised if some of these 
21 
females were thirteen years Old? 
22 
MR. CRITTON: Form You're asking her to 
23 
speculate and guess. 
24 
THE WITNESS: I did not see any thirteen years 
25 
38 
1 
MR. CRITTON: Form. 
2 
THE WITNESS: No. I don't know. 
3 
BY MR. 
• 
0 
Okay. Well, each time that the girls would 
5 
come over to give Mr. Epstein a massage, he would be up 
6 
in his master bedroom already: is that correct? 
7 
MR. CRITTON: Form. 
8 
THE WITNESS: I don't know. 
9 
BY MR 
10 
0 
In the period of time between 2004 when you 
11 
started working and when Mr. Epstein went to jail. can 
12 
you approximate or estimate the number of these females 
13 
that would come over to Mr. Epstein's house to allegedly 
14 
give him a massage? 
15 
A No. 
16 
0 
Are we talking more than fifty, more than a 
17 
hundred? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS I did not count. 
20 
BY MR. 
21 
0 
But there were many cOtterent girls, right? 
22 
MR. CRITTON Form. 
23 
THE WITNESS: Many females. 
24 
BY MR. 
25 
0 
It was not like there were only ten females 
40 
BY MR. 
2 
0 
Okay. Would you be surprised if some of those 
3 
girls were fourteen years old? 
4 
MR. CRITTON: Same objection. 
5 
THE WITNESS: Fourteen? I don't know. 
6 
BY MR. 
• 
0 
Could they have been fifteen years old? 
• 
MR. CRITTON: Same objection. 
9 
THE WITNESS: Maybe more than that. 
10 
BY MR. 
la 
0 
Maybe more than that? 
12 
A 
Yeah. 
13 
0 
But maybe less than that? 
14 
MR. CRITTON: Form. 
THE WITNESS: I don't know. 
16 
BY MR. 
17 
0 
The truth is, you don't know how old these 
18 
females were, but these females that were there to give 
19 
him a massage were young, in your mind? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: Some look young, but then they. 
22 
what's this? 
23 
BY MR 
24 
0 
You knew that something that was going on 
25 
there was not right. isn't that true? 
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41 
1 
MR. CRITTON: Form. argumentative 
2 
MR. 
Jack. we're catching some music 
3 
coming over. 
4 
(Brief recess in proceedings.) 
5 
BY MR. 
6 
O As you saw these young females coming over to 
7 
Mr. Epstein's house to give him a massage. you knew in 
8 
your heart of hearts that something was wrong? 
9 
MR. CRITTON: Form. argumentative. 
10 
THE WITNESS: I was told that theyre going to 
11 
do a massage. 
12 
BY MR. 
13 
0 
I realize you were told that. Okay. ISM it 
14 
true that each of those girls was then led upstairs to 
15 
Mr. Epstein's bedroom; that was the routine. right? 
16 
MR. CRITTON: Form. predicate 
17 
THE WITNESS: I don't know. When I'm there. 
18 
then I 
most of the time I just go to the. what's 
19 
this, to the staff house. 
20 
BY MR. 
21 
0 
When the girls would arrive — when the 
22 
females would arrive. you would go to the staff house? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: First sometimes I would offer 
25 
them drinks, and then, whets this. 
43 
1 
THE WITNESS: I did not find any sex toys. 
2 
BY MR. 
3 
0 
You never, in your employment with 
4 
Mr. Epstein, found sex toys in the room after these 
5 
females left from giving him a massage? 
6 
A There was only this. like I thought it was for 
7 
massage. Mars il, Mars what I saw. 
8 
0 
Okay. Have you ever — are you familiar with 
9 
the armoire that is in Mr. Epstein's room, bedroom? 
10 
A 
Yes. 
11 
0 
And have you ever put items away In that 
12 
armoire? 
13 
A No. sir. 
14 
0 
If Alfredo Rodriguez testified that you and he 
15 
had a conversation about the sex toys in Mr. Epstein's 
16 
bedroom and your comment being it's not right --
17 
A No, sir. 
18 
0 
mars not something you would agree with? 
19 
A We did not converse about sex toys. 
20 
0 
Have you talked to Mr. Epstein today about you 
21 
having your deposition today? 
22 
A No, sit 
23 
0 
And this is your attorney who is hero next to 
24 
you? 
25 
A 
Yes, sir. 
42 
1 
BY MR. 
2 
0 
MI right. So did you talk to some of these 
3 
females? 
4 
A No. Just like you care for water or some 
5 
&inks, soda or something. 
6 
0 
All right. Cid you ever discuss religion with 
7 
any of these females? 
A No, sir. 
9 
0 
When these females would go upstars, how long 
10 
would oath typically stay upstairs with It. Epstein? 
11 
MR. CRITTON: Form, predicate. 
12 
THE WITNESS: I don't know, but I was told by 
13 
Alfredo that it would take one hour. 
14 
BY MR. 
15 
0 
All right. And when the females would leave, 
16 
wasn't one of your reSPonstilities to dean the room 
17 
where the massage lack place? 
18 
A Yes, sir, to tidy. 
19 
0 
To bdy? 
20 
MR. CRITTON: Form. 
21 
BY MR. 
22 
0 
And In doing so, isn't it true that many CMOs 
23 
after these females lob, you found vibrators and sex 
24 
toys scattered on the floor and in the roan? 
25 
MR. CRITTON: Form. 
1 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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44 
O And is that somebody that you paid to be your 
attorney? 
A bleak. 
O That's somebody that Mr. Epstein has paid to 
be your attorney? 
A 
Yes. 
O 
When you were hired, did you sign any 
agreement of oonfidentiakty that you wouldn't talk 
about the matters that happened within the house? 
A 
Yes, sir. 
O 
When did you sign that agreement? 
A 
When I received papers to sign for like my 
evaluation, all the forms needed for employment. like 
tax forms. 
O Okay. And do you have a copy of that 
agreement? 
A 
Maybe in my house. 
O That's something that you think was provided 
to you, or was the only copy kept with Mr. Epstein or 
Ms. Maxwell? 
A 
We wore given duplicate, duplicate copy. 
O Well, lot me toll you that I
 resent three 
girls that in this case aro■ 
and 
who were three of the girls that you and I have been 
talking about as females that went to Mr. Epstein's 
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45 
1 
house to give him massages. Okay. Would it surprise 
2 
you to know that when they went to his house they were 
3 
as young as thirteen, fourteen, and fifteen years old? 
4 
MR. CRITTON: Form. 
5 
THE WITNESS: I didn't know, sir. 
6 
MR. CRITTON. Asked and answered. 
7 
BY MR. 
0 Would it surprise you to know that once inside 
9 
his bedroom, he instructed them each lo get naked? 
do 
A 111d not. 
11 
MR. CRITTON: Let me just object to the form. 
12 
You're asking her to speculate on something she 
13 
knows nothing about. It serves no PuthoSe. It's a 
14 
great argument, but it serves no purpose. 
15 
MR. 
I know you're not happy with the 
16 
line d questioning, you do this every time in 
17 
deposition. 
18 
MR. CRITTON: But it serves no purpose, its 
19 
never going to be admissible whether she's 
20 
surprised or not. It's like saying. you know, 
21 
would it - well, never mind. 
22 
You know, would it surpnse you that the 
23 
Afghan election •-
24 
MR. 
Are you trying to make this line 
25 
of questioning go on longer? 
47 
1 
years old? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS' I do not know about that. 
4 
BY MR. EDWARDS: 
5 
0 
Okay. And after this line of questioning 
6 
related to things that happened in Mr. Epstein's bedroom 
7 
dial were actually not massages at all, does this help 
8 
to refresh your recollection as to the sexual toys or 
9 
devices that you have found in his bedroom? 
10 
MR. CRITTON: Form. 
11 
THE WITNESS: I only found one, that massage. 
12 
I thought it was a massage thing. 
13 
BY MR. EDWARDS: 
14 
0 
All nght. 
15 
A 
You know that thing, and then I thought it's 
16 
for -- that thing I only see. 
17 
MR. CRITTON: Just so the record is clear, I 
is 
think we all agree that she look her hand and 
19 
like --
20 
MR. EDWARDS: She thought it was a back 
21 
massager. 
22 
MR. CRRTON: Probably was a back massager. 
23 
MR. EDWARDS: Give me a break_ 
24 
MR. CRITTON: No. You want to argue sex toys. 
25 
she's saying bath massager. Just let her testily 
46 
MR. CRITTON: No. But its just painful Ask 
2 
her stuff that she knows. 
3 
MR. 
I know it's painful. 
4 
MR. CRITTON: I could care less one way or the 
S 
other. It's just a waste of both our times.
6 
MR. 
YOlffe Setting Paid lot it No 
7 
defense attorney ever makes this argument on the 
• 
record. 
9 
MR. CRITTON: You know what. I get paid by a 
10 
lot of people, and I don't need to do frivolous 
11 
things in my mind, I'd rather just go home. 
12 
THE WITNESS: I don't know. 
13 
MR. 
Okay. 
14 
Do you understand the question? 
15 
THE WITNESS: Yeah. I do net know anything 
16 
about that part_ 
17 
MR. CRITTON: From the last time I objected, 
La 
can you just mark that. I want that two pages 
19 
marked so I can get that somehow separate and 
20 
apart. 
21 
THE COURT REPORTER: Okay. 
22 
BY MR. 
23 
0 
Would It come a8 a surprise to you that 
24 
Mr. Epstein used sexual devices such as vibrators on 
25 
Oath of my clients when they were fourteen or fifteen 
48 
as distinct from argumentative 
2 
MR. 
I'm letting her testily. 
3 
MR. CRITTON: Cathy. 
4 
BY MR 
5 
0 
The only thing that you found in his bedroom 
6 
was in the shape of something that you believed to be a 
7 
back massager; Is that fair? 
a 
A 
Yes, sir. Yes. 
9 
0 
Okay. Who was the deem° lady or 
10 
housekeeper prior to you, do you knot?? 
11 
A 
They have a cleaning crew. 
12 
0 
Prior to you? 
3 
A 
Yes. 
14 
0 
To your knowledge. has anybody ever left the 
is 
house, meaning left the employment or Mr. Epstein 
16 
because of anything that was taking place in the house? 
17 
A NO. Sir. 
18 
0 
Have you ever thought of leaving the 
19 
employment of lee. Epstein because of what was happening 
20 
in the house? 
21 
MR CRITTON. Form. 
22 
THE WITNESS. No. sir. 
23 
BY MR. 
24 
0 
Have you ever prayed for Mr. Epstein 
25 
because of what was happening 
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1 
A I pray for my co-employees and for my, what's 
2 
this, employers. 
3 
0 
Have you ever prayed for him related to these 
4 
females that come over to the house? 
5 
MR. CRITTON: Form. 
6 
THE WITNESS: I just lift his name to God, 
7 
that's it. 
8 
BY MR -
9 
0 
Have you ever prayed for the females that come 
10 
over to his house? 
11 
A !prayed for everyone. 
12 
Q Do you know what Mr. Epstein does for a 
13 
lying? 
14 
A I was told that he's an investor. 
15 
0 
Who told you that? 
16 
A Coworkers. 
17 
Q Which coworkers? 
18 
A Lyn and Jojo. 
19 
0 
Did Lyn and Joifoi --
20 
A 
And Alfredo. 
21 
0 
And Alfredo. 
22 
Did Lyn and Jcji ever tell you about 
23 
Mr. Epstein getting females over to the house in 
24 
New York for massages? 
25 
MR. CRITTON: Form. 
Si 
1 
THE WITNESS: Yes. I do not know what's 
2 
ha. 
ir
i
side. 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
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la 
19 
20 
21 
22 
23 
24 
25 
Okay. 
BY MR. EDWARDS: 
O Okay. And have you ever asked what is going 
on inside? 
A No. sir. 
O Is that something that you have chosen just 
not to Bid out about? 
MR. CARTON: Form. 
THE WITNESS: I was told that he's going to 
have a massage. 
BY MR. EDWARDS: 
O Is that something that you believe? 
A That's what I was told, and what's this. 
O You're aware of the allegations against 
Mr. Epstein that each of these girls that was coming 
over to his house — each of these females that was 
corning over to his house was engaging in sexual activity 
with Mr. Epstein. right? 
MR. CRITTON: Form. 
THE WITNESS: Could you read the question 
back? 
(A portion of Me record was read by the 
reporter.) 
50 
1 
THE WITNESS: They have visitors, that's what 
2 
I was told. 
3 
BY MR. 
4 
O Were you ever told that he gets massages by 
5 
females similar to the roamer in West Palm Beach? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: Yes. 
S 
BY MR. 
9 
0 
And who told you that? 
A Lyn. 
O And did she say with what frequency - 
A No, sir. 
O 
he has females come over? 
A No. sir. 
Q You didn't continue the conversation after she 
told you this? 
A No. I just listen, and then she talks and 
then that's it. We dont really, like, oh. no. 
Q So is it your testimony that you don't know 
what happens in the bedroom behind dosed doors with 
Mr. Epstein and these females? 
A No. sir. 
One second. I want to make 
sure you understand the question. 
25 
MR. CRITTON: Form. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
la 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
52 
MR. CRITTON: Form. 
Did you understand the 
question? 
Yes. you understand the 
question? 
THE WITNESS: Yes. 
And I think the question was 
are you aware of the allegations. 
BY MR. -
Q Ate you aware of the allegations? 
A Through TV news. 
O Have you talked to anybody else about these 
allegations being made against your employer? 
A 
With Janusz. 
O when did you talk to Janusz about trio 
allegations being made against your employee? 
A There is the scenario whenever I -- what's 
this - I heard the news, its oh, the boss is on the 
news. And that's it, to be honest. 
O And what would Janusz comment back to you, if 
anything? 
A 
Oh, he% in the news. So we did not really. 
like, talk about... 
O But It's one thing when your boss is on the 
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news and its for accolades or for awards, it's another 
thing when your boss is on the news related to 
allegations that he is engaging in sexual activity with 
minor females. Wouldn't you agree with that? 
MR. CRITTON: Form, argumentative.
THE WITNESS: Of course there's a difference. 
BY MR. 
O So did you talk to Janusz about the fact that 
there are allegations that he is engaging in sex with 
these minor females that are coming over to the house 
and you're told that they're giving massages? 
MR. CRITTON: Form, compound. 
THE WITNESS: Not really. Like we don't 
really discuss-discuss. We just oh. he's in the 
news. and then that's it. and I go to work because 
were so busy, so. . 
BY MR. -
O Do you talk to your fanny or anybody else 
about --
A 
No. 
O Let me finish my question. 
about the fact that many minor females have 
alleged that they have come over to Mr. Epstein's house 
and engaged in sexual activity with hirn in his bedroom 
55 
1 
like pry on other personal activities. 
2 
0 
Crimes are being committed against these girls 
3 
on a daily basis while you're wonting. And 
4 
hypothetically let's say you knew about it would you 
s 
report it? 
6 
A If I knew about it, of course. 
7 
0 
Sure. Uke if you walked in on it. then would 
8 
you report it? 
9 
MR. CRITTON: Form. 
10 
When you say 'le do you mean 
11 
a cnme? 
12 
BY MR 
13 
0 
Yeah. If you walked in on a crime? 
14 
A 
A crime? Of course. If its a crime, I val. 
15 
0 
Okay. rm going to ask you if you've ever 
16 
witnessed certain acts. First I'm going to read to you 
17 
directly from the Florida Statutes related to a cnme 
le 
called lewd and lascivious molestation. Okay. 
19 
A Atingle. 
20 
0 
Florida Statute 794.021. 
21 
Do you have a copy that she Can 
22 
read along with you perhaps? 
23 
MR. EDWARDS: I don't have a copy, but 
24 
hand it to her as soon as Fve read it. 
25 
Thank you. 
54 
1 
while they were under the age of eighteen? 
2 
MR. CRITTON: Form. 
3 
THE WITNESS: No. 
4 
BY MR. 
0 
Are you aware now that your employer, 
6 
Mt Epstein, is a registered sex offender? 
7 
A I heard about it. 
8 
0 
Does that bother you? 
9 
A 
Sometimes, but I don't know if the allegations 
10 
is true, so... 
11 
0 
Because you don't know wtat's going on behind 
12 
closed diten, right, you have no idea? 
13 
MR. CRITTON: Form, argumentative. 
14 
BY MR. 
15 
0 
I hear you. 
16 
Have you ever asked your employer if the 
17 
allegations being made against him are true or if they 
18 
are not true related to his sexual activities with 
19 
underage females? 
20 
A 
No. 
21 
0 
Isn't that something that you, as a religious 
22 
person, would want to know, whether that's true that 
23 
that's what's going on in the bedroom every day while 
24 
you're at work? 
25 
A Sir, I go there to work, not to, what's this, 
56 
1 
BY MR. -
2 
0 
II reads as follows: 
3 
A person who intentionally touches in a lewd 
4 
and lascivious manner the breasts, genitals. 
5 
genital area, or buttocks, or the clothing covering 
6 
them of a person less than sixteen years of age, or 
7 
forces or entices a person under sixteen years of 
8 
age to so touch the perpetrator, commits lewd or 
9 
lascivious molestation. An offender eighteen years 
10 
of age or older who commits lewd or lascivious 
11 
molestation against a victim twelve years of age or 
12 
older but less than sixteen years of age commits a 
13 
felony of the second degree. 
14 
Have you ever observed — if you want to see 
15 
the law, you Can. Have you ever observed that crime 
16 
committed in his house? 
17 
A No, sir. 
le 
MR. CRITTON: Form. 
19 
What statute was that? 
20 
MR. 
It's 794.021, subsection five. 
21 
MR. CRITTON: Thank you. 
22 
BY MR. 
23 
0 
Subsection seven of that same statute, lewd 
24 
and lascivious exhibition, indicates: 
25 
A person who intentionally masturbates, 
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57 
1 
intentionally exposes the genitals in a lewd or 
2 
lascivious manner, or intentionally commits any 
3 
other sexual act that does not involve actual 
4 
physical or sexual contact with the victim in the 
• 
presence Cl a victim who Is loss than sixteen years 
6 
of age commits lewd or lascivious exhibition. An 
7 
offender eighteen years of ago or older who 
fl 
commits a lewd or lascivious exhibition commits a 
9 
felony el the second degree. 
10 
Have you seen that crime committed in 
11 
Mr. Epstein's house? 
12 
A NO. Sk. 
13 
MR CRITTON: Form. 
11 
BY MR. 
15 
0 Me 
of the allegations by multiple 
16 
female girls that allege that these are the crimes that 
17 
were taking place behind closed doors when they wore 
18 
just minor females; are you aware of those allegations? 
19 
MR. CRITTON: Form. 
20 
Do you understand the question? 
21 
MR. CRITTON: Asked and answered. 
22 
Do you understand the question? 
23 
MR. CRITTON: And argumentative. 
24 
THE WITNESS: From the news, I heard that from 
25 
the news. 
1 
2 
3 
4 
6 
7 
9 
10 
11 
12 
13 
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59 
BY MR. -
O Have you ever worked for anyone that had this 
many young females come over to hS house every day? 
A No. sir. 
O Have you ever heard anybody say that these 
girls are making this up or that this did not happen, 
these sexual acts did not happen in Mr. Epstein's 
bedroom? 
MR. CRITTON: Form, argumentative. 
BY MR. 
O By that I mean Mr. Epstein. Ghislaine Maxwell? 
A No. sir. No. 
O Did 
ever say any of those sifts 
were making this up? 
A No. sir. 
MR. CRITTON: Form. 
BY MR. 
O So those gins aro making these allegations, 
you work in Mr. Epstein's house? 
A 
Yes. 
O 
And you've never heard anybody deny these 
allegations, have you? 
MR. CRITTON: Form. argumentative. 
THE WITNESS: I do my lob, we don't. bko. 
talk. 
58 
1 
BY MR. 
2 
0 
And are you also aware that many Cl these 
3 
girls did not know one another that 1112177 these ferrate 
4 
masseuses. are you aware of that? 
• 
MR. CRITTON. Form. 
6 
THE WITNESS. I don't know. 
7 
BY MR. 
8 
0 
Okay. When those girls that said come 
9 
where these females that would come eve' where 
so 
you were told they were ovine massages would come over, 
la 
how many would come over at any time. meaning would they 
12 
come over with twisty at time. or one teatime? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Somedmes one at a fins. 
15 
BY MR 
16 
0 
And given the number el these females that are 
17 
making these allegations. doesn't It cause you to 
18 
believe the allegations that there are so many of tarn 
19 
and their stories are so strikingly sIrrSar as to what's 
20 
laking place in Mr. Epstein's bedroom? 
21 
MR CRITTON: Form, predicate. speculation. 
22 
argurnentabve 
23 
THE WITNESS: I don't know what's happening in 
24 
the bedroom. I did not see anything that case me 
25 
alarm. 
1 
2 
3 
4 
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a 
9 
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BY MR. 
O So is that a no, you've never heard anybody 
deny Mat? 
MR. CRITTON: Form. 
THE WITNESS: No. sir. 
BY MR. 
O When was the last time you talked to 
Ghislaine Maxwell? 
A I answer the phone when she... 
O Okay. When you first started working there 
back in November of 2004, she was the person who you 
interviewed with, right? 
A Yes, sir. 
O Was the somebody who you would regularly see 
at the house during that period of time? 
A Not regular. 
O How often would you see her in the house back 
in the late 2004. when you wore hired. trough 2005? 
A Three limes. 
O Three times a week? 
A No. During the period of that I was there. 
O Okay. During the entire live-year period you 
were there you only saw Gtislaine Maxwell three times? 
A Not five years. 
O Okay. From the end of 2004 through 2005 you 
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61 
i 
saw her three times? 
2 
A 
Yes. sir. 
3 
0 
During --
4 
A Maybe more a less three times. 
5 
0 
During 2006 how often did you see her? 
6 
A 2006? He was in New York so I Saw her. 
7 
0 
You worked for Jeffrey Epstein but you worked 
In New York? I'm sorry. 
9 
A I saw Ms. Maxwell in New Yak. 
10 
0 
I think I understand. Primanty, though. you 
11 
ware WI working at the 358 El Brillo location? 
12 
A Yes. 
13 
0 
However. at some point in time that yew you 
14 
took a trip to the New York house and you saw her there? 
15 
A In her house. 
16 
0 
In Ghislaine Maxwell's house? 
17 
A 
Yes. 
18 
0 
What was the occasion for you to go see her up 
19 
there? 
20 
A Lyn was having I think surgery. 
21 
0 
And when was that? 
22 
A I cannot recall the month, but it's I think 
23 
2006. 
24 
0 
So this is alter the criminal investigation 
25 
into Mr. Epstein, or before, if you remember? 
3 
4 
5 
8 
7 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
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63 
MR. CARTON: But if you just asked her, say 
2 
did you ever have a discussion with her about it, 
if she says yes, then well hnd out what it is. 
If she didn1 have one. why ask the question? 
Go ahead 
THE WITNESS: There was no discussion. 
There's no question pending. 
Wait for Mr. Edwards to ask his question and answer 
the question if Cu understand it 
BY MR. 
O How long were you at Ghislaine Maxwell's hOuse 
this time that you visited her in 2006? 
MR. CAUTION: Form. 
THE WITNESS: I cannot remember, because I 
BY MR. -
O Back and forth? 
A 
Yes. 
O From West Palm Beach to New York? 
A 
Yes. 
O Why were you up in Ghislaine Maxwell's house 
in New York? 
A I help over there when she has a party. 
O Okay. And then after the party you would 
return to West Palm Beach? 
62 
1 
MR. CRITTON: Form, predicate. 
2 
THE WITNESS: 2006? After. 
3 
BY MR. 
4 
0 
Okay. And while you were up there with 
5 
Ohislaine Maxwell. did you talk to her about the 
6 
criminal investigation of Mr. Epstein? 
7 
A No. sir. 
8 
0 
At any point in time when you were up there. 
9 
did she say to you a you overheard 
let me ask yOu 
10 
this way: Did she say to you that the allegations are 
11 
false --
12 
MR. CRITTON: Form. 
13 
BY MR. 
14 
0 
-- that are being made against him? 
15 
MR. CRITTON: Form. There's no predicate that 
16 
a discussion ever took place about anything. 
17 
THE WITNESS: There was no discussion about 
18 
that. 
19 
MR. 
Mr. Clifton. it you could just 
20 
object to the form. Obviously this witnesses just 
21 
takes your wads and she's going to recite them to 
22 
me. II you want to say lack of predicate. okay, 
23 
fine. But to say no discussion 100k place and then 
24 
she says no discussion took place, we're leading 
25 
the witness here, its obvious. 
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64 
A 
Yes. 
O While you were up there, during any of the 
times that you were up there, did you have any 
conversations with Ghisleine Maxwell? 
A I think once. But it was oh, and what's this, 
it was just oh. I'm sorry about the bad news. mars 
it. 
O You said that? 
A 
Because we have only, like, short 
conversation, we just dent really, like, talk-talk. 
O When you're saying that a statement was made 
I'm sorry about the bad news, who made the statement to 
whom; she made it to you, Or you made it to her? 
A She made it. But that was — I really cannot 
remember how it was how, but it was, ake, 
sorry 
about the news. 
O Okay. What news was she referring to when she 
said to you I'm sorry to hear about the bad news? 
A She not say anything. I just 
I do not say 
anything about what the bad news is. 
O Okay. I guess what I'm asking is did you have 
a death in the family or something happen to you 
personally? Or why would she say this to you, d you 
know? 
A No. 
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65 
1 
0 
You have no idea why she said that statement? 
2 
A 
I think fiat it was about the news that was 
3 
going On about Mr. Epstein-
4 
MR CRITTON: Move to strike as speculation 
5 
BY MR. 
6 
0 
And did she elaborate on the news about 
7 
Mr. Epstein? 
A No, sir. 
9 
0 
During that conversation where she makes a 
10 
statement that she's sorry about the news. did she ever 
11 
tell you that the allegations being made against him are 
12 
false or unfounded Or untrue? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Our conversation was short. 
15 
BY MR 
16 
O So the answer is no? 
17 
A No. 
18 
0 
What is your understanding of 
19 
Ghislaine Maxwell's role In Jeffrey Epstein's life back 
20 
In 2004 and 2005 and 2006? 
21 
MR. CRITTON: Form. 
22 
THE WITNESS: She told me he was his bodnend 
23 
WO. 
24 
BY WI. 
25 
O Ghislaine Maxwell told you that 
6.7 
1 
0 
What did she say when you answered the phone? 
2 
A Oh, she was happy. I was happy to hear her 
3 
voice. And then she said oh, she was also happy to —
4 
she was so nice on the phone. 
S 
0 
What did she say? 
6 
A Oh, rice talking to you, 
7 
0 
Then did She ask to speak to somebody &se? 
8 
A To Mr. Epstein. 
9 
0 
Aside from Me telephone call one month ago. 
10 
how many limes has she called the house In the last 
11 
year? 
12 
A 
That was my only. what's this. my -- the time 
13 
that I was answer the phone and it was Ms. Maxwell. 
14 
0 
Do you know why She called Mr. Epstein? 
15 
A I do not know, sir. 
16 
0 
Have you ever seen scheduling logs, either on 
17 
a computer or on paper. with girls' names on n and 
18 
numbers? 
19 
A 
No. No, sir. 
20 
0 
Have you ever seen the names of these females 
21 
that are alleged to have been masseuses written on 
22 
anything? 
23 
A 
Yes, sir. 
24 
0 
What have you seen them written on? 
25 
A I lust saw names, and that's it. 
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66 
Jeffrey Epstein was her boyfriend? 
A When I was hired. 
O And then over the next year and a half when 
Jeffrey Epstein was in West Palm Beach, you only saw 
Ghislaine Maxwell at the house approximalely three 
times? 
A 
Yes, sir 
O Did you still believe that Ghislaine Maxwell 
and Jeffrey Epstein were boyfriend and girlfriend? 
MR. CRITTON: Form. 
THE WITNESS: At that time or what lime? 
BY MR 
O Yeah. Back then in 2004, 2005. 
A 
Yes. 
O All right. Is it your understanding that they 
are still boyfriend and girlfriend today? 
A I don't know. 
O Ghislaine Maxwell and Jeffrey Epstein, do they 
att talk to one another today? 
A I do not know, sir. 
O 
What Is the last time that you talked to 
Ghislaine Maxwell? 
A 
She called the house and I answered the phone. 
O How long ago? 
A 
About a month ago. 
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O Just the names. or the telephone numbers as 
wel? 
MR. CRITTON: Form. 
THE WITNESS: I cannot remember. 
BY MR. 
O Where did you see thls? 
A We have like butters party and there's a 
telephone there. 
O Is this in the staff house or the main house? 
A No. The main house. 
O And do you know who wrote the names? 
A No. sir. 
O How do you know that these were the names of 
the females that were alleged to have been masseuses? 
A 
Because there is time. 
O What do you mean, there is time? 
A Sometimes name and then the time. that's it. 
O What does the time indicate? 
A I cannot remember. 
O The time to you 
you know, I'm watching what 
you're doing, but the court reporter is not able to draw 
a pictured it. So I guess what I'm asking is you're 
saying there is 
on the tell-hand side there is a 
name. and on the right.hand side corresponding to that 
name there is a time written down? Is that what you 
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- Volume I 
October 20, 2009 
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incicated? 
A Yes. 
O And that time is incbtatNe of the appointment 
time when that female was supposed to be al 
Me. Epstein's house? 
MR. CRITTON: Form. 
THE WITNESS: I realty don't know if that's 
the one that incbcate who is coming. I just see 
names there and then time. 
BY MR. 
O Desaibe for me what this book looks like, or 
what this piece of paper looks like. 
A Someplace there are like white paper we write 
the names. ill hear — if somebody receives a call, and 
then we write the name of the person and the time. 
O 
It sounds like you've answered the phone for 
when one of these females has called? 
A Sometimes. 
MR. CRITTON: Form. 
BY IC. 
O How many tunes in the last five years have you 
answered the telephone when one of these females has 
called? 
MR. CRITTON: Form. 
THE WITNESS: I cannot remember. 
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BY MR. 
O 
and you would answer the phone? 
A Again, can you... 
o 
What would they say? Hi, this Is Mary, I'd 
like to come work, is there a lime available for me. 
Fm making this up. What would they say? 
MR. CRITTON: Form. 
BY MR. -
O If you know. 
A 
They just say the, what's this. The female 
will just 
telt Mr. Epstein I called. 
o 
Okay. Just tell him I called? 
A Uh-huh. 
O And you would write down the name of the 
person and the time the person called? 
A 
Yes. sir. 
When you get to a convenient 
breaking point. 
MR. 
Let's break. 
(Brief recess in proceedings.) 
It may De obvious to us in the 
room, but it may not be apparent in the cold record 
that English is not Ms. 
first language. 
So that's why I've interrupted a couple of times 
and asked her if she understands the question, 
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1 
BY MR 
2 
O PJI right. I asked this question that way 
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because you said sometimes we take the message. 
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A YeS. 
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0 And when you say we, you're inducing 
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yourself? 
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A 
Yee. 
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0 Okay. And when the female would call to 
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sthedne I mean. when the female could call. what 
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exactly would she say where you would write &yin a name 
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and a time? 
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A I d2n1 know if 
receive a call and 
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then I get the message and mite the name and the time 
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0 
Okay. It's just a message from whom? 
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A For Mr. Epstein. 
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0 
And who Is the Call that - the calls that 
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you're referring to. who are they, who is calling? 
is 
A They are fernele voices. 
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And are they asking to come over to give a 
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=Seaga, to work, to --
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A To work. 
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And what Is the language that the females 
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would typically use when they would call --
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W. CRITTON': Form. 
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because it's apparent to me sometimes that her 
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English isn't as eloquent as W. ■ 
3 
BY MR. -
4 
0 What is your first language. Ms. 
A Visayan and Tagalog. 
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0 Do you feel comfortable with taking this 
7 
deposition in English; meaning do you understand my 
8 
questions and are you giving me answers that are 
9 
truthful and accurate? 
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A 
Sometimes I have to ask you to rephrase 
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because. you know. 
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0 Okay. And when you've asked me to rephrase 
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and I've rephrased the question. have you understood it 
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and given me an answer that you feel is accurate? 
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A 
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0 
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A 
is 
0 
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A 
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0 Were you ever asked to talk lo the State 
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Attorney's Office? 
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A No. 
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0 Were you ever asked to talk to the United 
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States Attorneys Office? 
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A No. 
Yes. 
Okay. Did you ever talk to the police? 
No. 
Have you ever talked to the FBI? 
No. 
0 
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