EFTA00101322

Page 81 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE No.08-CV-80119-CIV-MARRA/JOHNSQN 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
Related cases: 
08-80232, 08-80380, 98-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-61092 
VIDEOTAPED DEPOSITION OF 
VOLUME II 
Tuesday, September 8, 2009 
10:12 a.m. - 3:45 p.m. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33401 
Reported By: 
FPR 
Notary Public, State of Florida 
PROSE COURT REPORTING AGENCY 
West Palm Beach Office 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401-377-676-2895) 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000357 
UkUgha6e-4b914O1-baNtglaWdo 
EFTA00101322

Page 82 
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APPEARANCES: 
On behalf of the Plaintiffs: 
4 
5 
6 
7 
8 
9 
10 
11 
WILLIAM J. BERGER, ESQUIRE 
ROTHSTEIN ROSENFELDT ADLER 
12 
401 East Las Olas Boulevard, Suite 1650 
Fort Lauderdale, Florida 33301 
13 
RICHARD WILLITS, ESQUIRE 
RICHARD H. WILLITS, P.A. 
2290 10th Avenue North, Suite 404 
' 
461 
STUART MERMELSTEIN, ESQUIRE 
MERMELSTEIN & HOROWITZ, P.A. 
18205 Biscayne Boulevard, Suite 2218 
Miami, Florida
0 
14 
15 
KATHERINE W. EZELL, ESQUIRE 
PODHURST ORSECK, P.A. 
16 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
17 
18 
19 
ADAM J. LANGINO, ESQUIRE 
LEOPOLD KUVIN 
20 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens, Florida 33410 
21 
22 
23 
24 
25 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra 
Electronically signed by Sandra 
Townsend (401-377-676.2895} 
Townsend (401-377-676-2895} 
FOIA Confidential Treatment Requested / Fed. 
GJ SUBPOENA RESPONSE 000358 
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EFTA00101323

Page 83 
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On behalf of the Defendant: 
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3 
4 
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7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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ROBERT J. CRITTON, ESQUIRE 
BURMAN, CRITTON & LUTTIER 
515 North Flagler Drive, Suite 400 
West Palm Beach, Florida 33401 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townydelonuc mull
 
ent Requested! Fed. 
28951 
Iliatc3ca0-c86eAb91-8d01-ba20bcae87de 
t.
l r
un
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PROCEEDINGS 
2 
3 
Deposition taken befor 
Court 
4 
Reporter and Notary Public in and for the State of 
5 
Florida at Large, in the above cause. 
6 
- - - 
7 
(Continued from Volume I.) 
8 
VIDEOGRAPHER: We're going back on the record 
9 
at 12:52. 
10 
CROSS EXAMINATION 
11 
BY MR. LANGINO: 
12 
Q. 
Hello 
My name is Adam Langino and I 
13 
represent■ 
I'll have fewer questions than the rest 
14 
of everybody, since I'm going next in line. But one of 
15 
the things I wanted to ask you --
16 
MR. CRITTON: Before you get started, let me 
17 
just put on my objection. 
18 
Adam, your client i.
who alleges that 
19 
she was at Mr. Epstein's house sometime, I think, 
20 
on one occasion in the summer of '03. 
21 
This witness is neither relevant, nor 
22 
material, nor can it lead to the admissibility of 
23 
any relevant information regarding my client. So I 
24 
understand -- so you certainly can notice him, but 
25 
I'll move to strike all of the questions and 
(561) 832-7500 
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(561) 832-7506 
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2 
3 
4 
5 
your 
6 
A. 
I am not sure, sir, but I think I started full 
7 
time on my salary, I was on the roll in 1991. 1991, 
8 
January 1, 1991. 
9 
Q. 
In 1991, you started full time with 
10 
Mr. Epstein? 
11 
A. 
Yes, working for him alone. I left all my 
12 
clients, I left -
13 
Q. 
And in what year did you start part time at 
14 
his house? 
15 
A. 
1990. '90. 
16 
Q. 
You mentioned earlier that some of the massage 
17 
therapists you paid with checks? 
18 
A. 
Yes. 
19 
Q. 
And some of the massage therapists you paid 
20 
with cash? 
21 
A. 
Sorry. Can you repeat the question? 
22 
Q. 
Sure. You mentioned earlier that you paid 
23 
some of the massage therapists with checks and some with 
answers in response to your questions. 
MR. LANGINO: Thank you. 
BY MR. LANGINO: 
Q. 
One thing I wasn't sure about was the date of 
employment. When did you start with Mr. Epstein? 
24 
cash? 
25 
A. 
Yes, sir. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
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afc3ca0-c86e-4691-8d01-ba20bcae87de 
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1 
Q. 
Were there any general differences between 
2 
those massage therapists that you paid with checks and 
3 
those that you paid with cash? 
4 
A. 
No, sir. It was -- when I was there always 
5 
was a hundred dollars an hour rate. That was for 
6 
everybody. 
7 
Q. 
Did you ever hear Jeffrey Epstein talk about 
8 
his massages? 
9 
A. 
No, sir. 
10 
Q. 
At one point you said that you're not -- this 
11 
might be summarizing your testimony -- that you may not 
12 
be the best guesser of ages. Is that something that you 
13 
may have said earlier today? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: Yeah. Yeah. I think I -- you 
16 
can be thirties, twenties. I don't know. 
17 
BY MR. LANGINO: 
16 
Q. 
Do you have any children? 
19 
A. 
20 
21 
22 
Q. 
Are either of your children female? 
23 
A. 
No. 
24 
Q. 
25 
A. 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra TowiMaVallactiy
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1 
Q. 
2 
A. 
3 
Q. 
Do you have any relative that you had spent a 
4 
significant amount of time with that would be a female 
5 
teenager? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: No, except my daughter. 
8 
BY MR. LANGINO: 
9 
Q. 
Cousin? 
10 
A. 
My daughter, no. 
11 
Q. 
Before when we first started speaking with 
12 
you, you talked a little bit about your business. Are 
13 
you still working? 
14 
A. 
No. 
15 
Q. 
is that correct? 
16 
A. 
Yeah. Yeah. It was my -- my -- it was me, 
17 
only me. 
18 
Q. 
19 
20 
A. 
21 
Q. 
Are any of your children or any of your family 
22 
members 
23 
A. 
No. They have their own business. 
24 
Q. 
You mentioned a few times today that you were 
25 
never told to check the identification of any of the 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 632-7506 
Electronically signed by Sandra Townsend (401-377-676.2895) 
Electronically signed by Sandra Townsend 1401.377.676-2895) 
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Page 88 
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massage therapists that came to give massages? 
2 
A. 
That's correct. 
3 
Q. 
How come you said that a couple of times 
4 
today? 
5 
MR. CRITTON: Form. 
6 
THE WITNESS: You asked me. They asked me. I 
7 
think I just answer questions. 
8 
BY MR. LANGINO: 
9 
Q. 
As you reflect back in your time working for 
10 
Mr. Epstein, today do you believe you turned a blind eye 
11 
to some of the ages of the women or females that worked 
12 
for Jeffrey Epstein with massages? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Can you repeat the question? 
15 
BY MR. LANGINO: 
16 
Q. 
Sure. As you sit here today and reflect back 
17 
on your time working for Jeffrey Epstein, do you believe 
18 
you turned a blind eye or ignored, purposely ignored the 
19 
ages of the females that gave him massages? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: I don't know. I don't. 
I 
22 
cannot -- I'm not a judge. I don't know. I don't 
23 
know. I don't think so. Sincerely, I don't think 
24 
so. 
25 
BY MR. LANGINO: 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-575-2895) 
Electronically signed by Sandra Towrregemixtst28,51 
eatment Requested / Fed. 
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Page 89 
1 
Q. 
When you were working for Mr. Epstein, did you 
2 
have any doubt that the girls who provided him massages 
3 
were not of the proper age or not older than 18 years 
4 
old? 
5 
MR. CRITTON: Form. 
6 
THE WITNESS: No. 
7 
BY MR. LANGINO: 
8 
Q. 
Did you keep up with Mr. Epstein's -- keep 
9 
informed of Mr. Epstein's criminal case while it was in 
10 
the paper? 
11 
A. 
Only what was on tv. What it was on tv, 
12 
that's how I found out. 
13 
Q. 
How do you feel about Mr. Epstein today? 
14 
A. 
I feel bad, sincerely I feel bad, because he 
15 
was -- with me, with my family, with my wife, he was a 
16 
very generous guy, extremely -- I don't know what the 
17 
word is in English -- but he would press for perfection. 
18 
I mean, and that was a very stressful job. But, 
19 
otherwise, I have no problems with him at all. And I 
20 
feel bad about it, what's happened in his life. 
21 
Q. 
Have you had any contact with Mr. Epstein 
22 
after you ended working there? 
23 
A. 
After I work -- after I end working with him? 
24 
Yes, I did. 
25 
When this case, when this criminal case 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377.676-2895) 
Electronically signed by Sandra Towrrofxleraliaatingletnt Requested! Fed. 
3atc3ca0-c86e-4b91-8d01-ba20bcao87de 
a
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started, I got home and I had a card, a business card 
2 
from a police officer. I think it wab
 from the 
3 
Palm Beach Police Department. 
4 
And -- and I got scared. And I was trying to 
5 
find out what it's all about. Because it was an 
6 
occasion with Mr. Epstein that we had a disagreement. 
7 
We settled that. Everything was well and we went our 
8 
friendly ways and never heard from him again. 
9 
And I received this from the police department 
10 
that we need to talk to you. And, so, I got scared. 
11 
And I called the office in New York. 
12 
I says, I would like to speak to Mr. Epstein. 
13 
And he come on, and I said, I told him, I 
14 
says, Jeffrey, what's going on? What's happening? I 
15 
thought it was related to the problem that I had 
16 
personally with him settled. 
17 
And I says -- no, he says. And he says to me, 
18 
it's nothing to do with that, has nothing to 
19 
do with it. I've been 
I don't know if he told me I 
20 
been sued or I been -- it's a problem with me, they're 
21 
investigating something and I cannot talk to you. That 
22 
was the end. And that's it. 
23 
Q. 
Any other conversations with Mr. Epstein --
24 
A. 
No. 
25 
Q. 
-- since that conversation? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend (401,377-67B-2895) 
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Page 91 
1 
A. 
No. 
2 
Q. 
At some points you were caught stealing from 
3 
Mr. Epstein; is that true? 
4 
A. 
We settled with him as a borrowing money from 
5 
him. Okay? 
6 
MR. BERGER: As what? 
7 
THE WITNESS: Borrowing. 
8 
MR. LANGINO: Borrowing. 
9 
BY MR. LANGINO: 
10 
Q. 
When you took the money from Mr. Epstein, --
11 
A. 
Yes, sir. 
12 
Q. 
-- did he give you permission to take that 
13 
money? 
14 
A. 
No. 
15 
Q. 
At any point did you take a firearm from 
16 
Mr. Epstein? 
17 
A. 
No. 
18 
Q. 
At any point did you enter Mr. Epstein's 
19 
property when you were not allowed to be there? 
20 
A. 
Yes. 
21 
Q. 
And was that the incident where you took some 
22 
money from him? 
23 
A. 
Yes. 
24 
Q. 
Can you explain to me how you and Mr. Epstein 
25 
came to an agreement that the cops would not be called? 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377.676-2895) 
Electronically signed by Sandra Towng8R16400nW
itinlin
an _04
t 
uested / Fed. 
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1 
A. 
He called me and he say, 
we need to 
2 
talk. 
3 
I says, okay. Where? 
4 
And -- and we met at a luncheonette in Palm 
5 
Beach and we have a friendly conversation. He asked 
6 
about my kids, about my family. 
7 
Then -- is this related to Mr. Epstein's case? 
8 
Q. 
It is. 
9 
A. 
Because I prefer to keep this -- this -- I was 
10 
not incriminated. I was not -- I went to the police 
11 
department. I made my statement and there was no 
12 
charges filed. 
13 
I don't think I would like to continue with 
14 
this. 
15 
MR. CRITTON: Let me just put on the record as 
16 
I think it's completely irrelevant, immaterial, 
17 
it's not calculated to lead to the --
18 
THE WITNESS: And it was after --
19 
MR. CRITTON: Let me just finish putting my 
20 
objection on. 
21 
As I understand it, it occurred long before he 
22 
ever got the card from the police. I think you're 
23 
harassing him. I think you're trying to intimidate 
24 
him and I think it's inappropriate. 
25 
BY MR. LANGINO: 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Sandra Townsend (401-377-676-2895) 
Electronically signed by Sandra Townsend 1401-377476-2895) 
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Q. 
How did you feel about Mr. Epstein being loyal 
2 
to you as an employee for him by not getting you into 
3 
further trouble with the police? 
4 
MR. CRITTON: Form. 
5 
THE WITNESS: I feel that it was part of a 
6 
relationship over 13 years that I did a lot of 
7 
extra work. And I was more or less says, hey, 
8 
you did it for me, I do it for you. And that 
9 
was it. And we end up as friends. We did not 
10 
break it apart. 
11 
BY MR. LANGINO: 
12 
Q. 
As you sit here today, do you have a sense of 
13 
personal loyalty to Mr. Epstein? 
14 
A. 
No. No. Matter of fact, that iot has left me 
15 
a lot of sequels, psychological problems. It was 
16 
extremely damaging to my marriage. Right after I left 
17 
we broke lir. with my wife. I walk away. I left my 
18 
house. I left my family. I end up with a woman that 
19 
she need the money and that's why I went in there and 
2C 
got the money. 
21 
And that's what I think you wanted to hear. 
22 
And I want to end it there. 
23 
I have no -- nothing -- I think my stay there, 
24 
in reflecting the job, I was not paid well enough for 
25 
what we did. And too late now. 
(561) 832-7500 
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1 
Q. 
The overall theme of my question is: The fact 
2 
that Mr. Epstein chose not to get you in trouble with 
3 
the police further, trouble with the police --
4 
A. 
Uh-huh. 
5 
Q. 
-- so many years ago, has today that caused 
6 
you or pressed upon you to maybe soften your testimony 
7 
or change your testimony at all? 
8 
A. 
Absolutely not. 
9 
Q. 
Have you ever spoken with any independent 
10 
investigators regarding the actions, the criminal 
11 
actions that occurred at Jeffrey Epstein's home? 
12 
A. 
Yes. 
13 
Q. 
When did that occur? 
14 
A. 
Right after I receive a card from the police 
15 
department, when I call Jeffrey and I ask him, what's 
16 
going on? 
17 
He says, I cannot talk to you. Somebody will 
18 
talk to 
you. 
19 
And then I got a call from this guy that I 
20 
cannot recall his name now. Talked to me and we met at 
211 
Carabbas. And we talked -- what? -- about 15 minutes. 
22 
And he asked me questions just like you guys are asking 
23 
me and I says exactly the same answers. 
24 
And he says, well, there's an investigation 
25 
against Jeffrey. You has nothing to do with it. You 
(561) 832-7500 
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have nothing to do, nothing to worry about it, but if 
2 
you want to hire a lawyer to protect yourself. 
3 
And I asked -- my question to him was, I don't 
4 
want to net inoriminated into snmethinn that. von know. 
5 
somebody trvina to incriminate me for -- for my lob. 
6 
And he says, no, no, no. But if you want to 
7 
get a lawyer, that's fine. 
8 
And that's where I got Mr. Murrell and he—lust 
9 
came to us, to sian this, to -- that was the end of it. 
10 
Q. 
Who got Mr. Murrell for you? 
11 
A. 
Who got it? Mr. Epstein. 
12 
Q. 
When you met with this investigator at 
13 
Carabbas, 
14 
A. 
Yes. 
15 
Q. 
-- did he record your conversation 
16 
A. 
No. 
17 
Q. 
-- in any way? 
18 
After this meeting at Carabbas, did you meet 
19 
with any other investigators? 
20 
A. 
No. 
21 
Q. 
After -- during your inspection of the massage 
22 
room after these massages had been completed with 
23 
Mr. Epstein, --
24 
A. 
Uh-huh. 
25 
Q. 
-- do you remember seeing any -- anything that 
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you would describe as blood? 
2 
A. 
No, never. 
3 
Q. 
Do you remember seeing anything that you would 
4 
describe as a sexual fluid? 
5 
A. 
No, never. 
6 
Q. 
When you worked for Jeffrey Epstein, the woman 
7 
that you were married to, what is her name or -- what is 
8 
her name? 
9 
A. 
The woman that I was married to? 
10 
Q. 
I think -- the reason I'm asking is because 
11 
earlier today when you first spoke, I thought I 
12 
remembered you saying that you -- both you and your 
13 
wife --
14 
A. 
That's my --
15 
Q. 
-- worked for Mr. Epstein? 
16 
A. 
It's still my wife. It's still my wife. We 
17 
didn't -- we got two ways away from a divorce and the 
18 
lawyers were taking my money by pipeline. 
19 
Q. 
And what is her name? 
20 
A. 
And we decide not to divorce and we still 
21 
together. 
22 
Q. 
Sorry. I missed that. But what is her name? 
23 
A. 
24 
Q. 
Let me just look through my notes to see if I 
25 
have any other questions. 
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Page 97 
1 
A. 
Okay. 
2 
Q. 
Thank you very much. 
3 
A. 
Welcome. 
4 
CROSS EXAMINATION 
5 
BY MR. MERMELSTEIN: 
6 
Q. 
Good afternoon, 
7 
8 
A. 
Yes, sir. 
Q. 
My name is Stuart Mermelstein. I represent a 
9 
group of the Plaintiffs in these cases and I have some 
10 
questions for you as well. 
11 
Your wife, 
does she live at the same 
12 
address as you now? 
13 
A. 
Yes, she does. 
14 
Q. 
Now, when you began working full time for 
15 
Mr. Epstein, I believe you said that was around 1991; is 
16 
that correct? 
17 
A. 
Yes. 
18 
Q. 
Was your wife, was she hired at the same time 
19 
as you? 
20 
A. 
No. She was hired three years after. 
21 
Q. 
And how did that come about that your wife was 
22 
hired? 
23 
A. 
My wife was hired because we had a housekeeper 
24 
that she was doing the cleaning and she left. Then we 
25 
had another housekeeper, Polish girl, and she left. 
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Page 98 
And then by that time my kids went to college 
and my wife was at home. And I suggest my wife to come 
3 
to work with me, to help me. 
4 
Q. 
So you recommended to Mr. Epstein that he hire 
5 
your wife? 
6 
A. 
Yes. 
7 
Q. 
And he did? 
8 
A. 
Yes, he did. 
9 
Q. 
And what were her job duties there? 
10 
A. 
Her only job duties were shopping, basically 
11 
the shopping, getting movie tickets, show tickets, buy 
12 
books, bring the food to Mrs. Epstein's -- Mr. Epstein's 
13 
mother, sometimes drive Mrs. Epstein to the doctors. 
14 
She was not involved -- and sometimes she did 
15 
some cleaning for me. 
16 
Q. 
Did she live with you in the upstairs 
17 
apartment? 
18 
A. 
Most of the nights we had an apartment right 
19 
across the bridge on Flagler that it was my -- my 
20 
property. And we had an apartment there. 
21 
So she went home. She didn't like to stay 
22 
there. But I had to stay there because my job starts 
23 
from 5:00 in the mornina to 10:00 at nicht 
24 
Q. 
And did 
eave her employment the same 
25 
time as you? 
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Page 99 
1 
A. 
Yes, we did at the same time. 
2 
Q. 
You testified that you would come into the 
3 
bedroom and clean up after massages; is that correct? 
4 
A. 
That's correct. 
5 
Q. 
Did you -- were there occasions where you had 
6 
your wife help you with that? 
7 
A. 
No. No. 
8 
Q. 
Were there 
did she have occasion to go into 
9 
the master bedroom? 
10 
A. 
It was occasions before that she will help to 
11 
set up the tables once in a while, set up the oils and 
12 
the tables. But I will do the clean up after. 
13 
Q. 
Is there a reason for that? 
14 
A. 
I was more involved into the final appearance 
15 
of the house. And it was my responsibility to make sure 
16 
that every room was perfect after they left and before 
17 
they went to bed. 
18 
Q. 
Was there anyone else who assigned your wife 
19 
work other than you? 
20 
A. 
No. Ms. Maxwell, sometimes she would tell my 
21 
wife, go buy some stuff, go get this and go get that. 
22 
She was mostly -- my wife was mostly out of the house. 
23 
She was -- this house was Mr. Epstein would says, go get 
24 
me this book, go get me this magazine, go get me 
25 
tickets, movie tickets for this show and this show and 
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Page 100 
1 
this show. And she would have to travel -- and I was on 
2 
the phone with my wife constantly, buy this, get this, 
3 
get this -- and the food, and the food because it was a 
4 
five-star hotel. 
5 
Q. 
Did Ms. Maxwell or Mr. Epstein ever instruct 
6 
your wife to do housecleaning tasks? 
7 
A. 
No. I was blamed for everything. 
8 
Q. 
You were blamed for everything? 
9 
A. 
I was blamed for the good and the bad. 
10 
Q. 
Did you -- during the time your wife was 
11 
there, did you also have a hired housekeeper? 
12 
A. 
We have a crew of housecleaners. We have a 
13 
crew of people that would come to the house and do a 
14 
serial -- I mean, deep cleaning, you know, to the house. 
15 
Q. 
Was that every day? 
16 
A. 
Once a week -- no, it was twice a week. It 
17 
was Tuesday and Fridays. 
18 
It depends on Mr. Epstein's schedule because 
19 
he didn't -- he didn't want nobody at the house while he 
20 
WAC At the house. So we have to rearrange days for the 
21 
clean-up crew to come in. And I usually did that. As 
22 
soon as they left I bring the cleaning crew, get the 
23 
house ready and -- and get set for them for the next 
24 
trip. 
25 
Q. 
Did you have a housekeeper who did 
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PROSE COURT REPORTING AGENCY, INC. 
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FOIA Confidential Treatment Requested / Fed. 
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