EFTA00157568

Absolutely. 
-- with hit secretary? 
Yes. 
4 
Mid did she take notes? 
5 
Yea. she did. 
6 
Pardon me/ 
she did. 
0. 
Shp took notes. 
Just by pen and paper? 
Pen and paper. 
10 
Not • ...hind 
like the court reporter? 
11 
12 
Q. 
Were you taped? Did sormbody tap. record you: 
13 
14 
D. 
Did he show you the notes that nut took down? 
IS 
36 
typed up and show yew the transcript? 
37 
II 
0. 
NO? Now, how long was Mr. CrittOn at your 
19 
house then? 
20 
A. 
Tar about half an hour. 
21 
0. 
And Old you thew that he wee coming? Did he 
22 
call ahead of tint/ 
75 
yeah. 
24 
had. to, what did you *apart was going to 
25 
Page :61 
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Me was going to Care In end elk questions 
2 
about fht0 C000. 
O. 
So that did he say? 
A. 
Sue questions that you guys are asking tn. 
5 
exactly the sane gist Ions. 
6 
0. 
Nothing mere? 
A. 
8401Cally what you saw, what pfu did, what 
8 
your 300 description was, wiNst you did. his you start 
9 
your day, has we your day And how was -- Mat nee you 
10 
Started. what tare you finish and what you did, and what 
11 
was your rtsponsibilities. 
And that wee It. 
12 
0. 
Okay. 
And were you paid anything for that/ 
1) 
A. 
Absolutely not. 
The only minty that I got, it 
14 
was free you for this S47 check for coming in Mn. 
IS 
O. 
Okay. 
16 
A. 
And 1 will take no money Iron nobody. 
I7 
0. 
Okay. 
Vera there -- ware there any other 
It 
tines that you talked to either Mr. CrItton or anst0dy 
19 
from his office? 
20 
21 
0. 
you described every tine that you've ever 
22 
talked to either Mr. CrIttOn or people from his *Ma? 
2) 
A. 
No, sir. 
24 
O. 
You've described all those times that you've 
25 
talked to Mr. CrItton or people fron hi s office? 
I'm 
ISLII 512-7500 
55001 Coon txtterIir. ACD.CY, 
0•11 0,2-5500 
Page 141 
1 
not asking the question clearly. 
2 
Ind you talk to Mr. Craton any other list/ 
3 
No. 
1 talked to Mr. Critter. twice, once In ny 
house, ono. yesterday. 
O. 
Now, hew about Mr. Jock Goldberger, 
6 
Mr. Epstein's crtolnal defence attorney. did you over 
7 
talk to hist 
8 
A. 
9 
0. 
Did you ever talk to Alan Dershovits about any 
10 
Of these hatters? 
Me, sir. 
12 
O. 
Or Roy Slack? 
13 
A. 
Me, sir. 
14 
0. 
Now. l'n lei* going back Over Dome different 
IS 
things that you sent lead. 
16 
You laid that there we a POIndex that you 
11 
created of mints or women? 
le 
A. 
Not It was a nave lust woman. 
It was 
19 
companies, air condition COMpenlee. 
It W44 cleaning 
20 
corpanlee. 
It was suppliers. 
And It was 
It 
was • 
21 
aoltdex that i telt It there. 
22 
Old you have • list 
of girls 
on your /*laden? 
21 
MR. COITION: 
Pone. 
IS 
THE WITNESS: 
No. 
Me had a Inn of girls In 
25 
• -- In a -- In a sheet with plastic 
thst we hove 
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all the message therapists. 
It vas too pales or 
2 
three pages el people in a plastic sheet that we 
had It where 
- Dy the telephotos. 
'that was It. 
4 
eV NR. DERMA: 
5 
O. 
Mate the name!? 
6 
A. 
glans and phones. 
Q. 
Telephone neonatal.
8 
9 
Whet About addresses? 
10 
No, no addressee. 
11 
What about dates? 
12 
A. 
Wo. sir. 
I) 
0. 
And who prepared the hot? 
14 
A. 
Either Mo. Maxwell -- It. 
Maxwell. 
15 
O. 
Was it typed? 
16 
A. 
Yeah. 
They welt typos. 
17 
O. 
Mo. 
Typo. 
18 
A. 
yeah. 
19 
O. 
Who typed It? 
20 
A. 
I don't know who type It. 
but It cane from Nea 
21 
York. 
22 
0. 
the list? 
23 
A. 
Yeah. 
24 
0. 
Did you -- did you give the information that 
25 
went into the list? 
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Page 21 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002635 
EFTA00157588

Page 165 
1 
2 
O. 
where wee the Ilet kept? 
In any Plate,. It at. In Mr*. Maxwell's 
4 
desk. It was one in the kitchen, one in my *lace, one 
In my coon because aneana IWat in sty rare and I have 
to cell these people. It was one in the new hews when 
7 
they build the new house. It w0 all over. NM It win 
0 
also those -- those tiles for the house -- the house 
9 
running operation. 
10 
0. 
Vas It the ease Bet that was In ell thaw. 
placea7 
12 
A. 
Basically, yes. 
.3 
CO. 
Vas the list updated? 
14 
Yes. 
15 
Did you keep a copy of the list? 
16 
A. 
Mo. I don't have a copy of the list. 
17 
0. 
when you left Mr. EpsteirOs employment. you 
10 
didn't take a copy with you? 
19 
A. 
Not at all. 
20 
O. 
And when you worked for Mr. Epstein, you 
21 
didn't write notes about what you did and what yOu eau? 
22 
2) 
O. 
007 
24 
A. 
Ito. I had too such to do. 
25 
You cildn•t put anything in a oorchter about 
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whet you saw at the house? 
2 
A. 
Ito. sir. 
O. 
Dld you ever talk to your ate about whet you 
ass at the house? 
A. 
la ke what? Sew about what? 
6 
0. 
About the ditellos. 
About the message.. 
Did 
you ever talk to your wife about that? 
4 
A. 
Yeah. 
And that's one of the reasons that : 
never send my K1(0 after -- this hap -- those dtldos end 
10 
things like that happened right at the end of wry stay 
11 
thene. 
It never happened before. Right at the lea 
12 
couple banns before I left. 
And that --
13 
O. 
and that's when young gtrL 
-
It 
IS. CRIlION: 
Let hit finish his answer. 
IS 
Tat INIMESS: 
Amity 
ray' worry about wee 
16 
that sty wife will panic. 
And 1 newer send her up 
there to clean up the rooms or anything else. 
19 
BY MR. BERGER: 
le 
0. 
Is that when young One Stetted Ceiling to the 
20 
bean? 
2/ 
MR. CRITICS: FOOD. 
22 
TIM ININCSS: One girl that I can think of. 
22 
BY MA. BERGER: 
24 
O. 
Just oho? 
21 
A. 
One gsrl. That Niel that she show a 
the 
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picture 
2 
-
I
Page 16? 
That's the only one that t can think she was 
4 
young, but I don't know how old. 
Q. 
Do you still have the transcript Iron -- icon 
6 
the police in front of you, iron the Mate Attorney's 
1 
01f1e0 
It'. below that. it's at the bottom. Kamp 
9 
10 
You see? Torn to page 9. 
II 
Page 9. 
Nom, look at we. 
It says. page 10. 
12 
but It also says page 9. 
I9 
3o you got page 9? 
14 
Page 9 and page 10. 
15 
O. 
Okay. 
16 
A. 
e.. *key. Pam 9. Okay. 
17 
0. 
t want you to see page 9. 
Id 
MR. CRITIOS. Yu want the tranecript page 97 
19 
Mk. IWERGOR: Yeah. 
20 
In MR. BERGER: 
21 
0. 
Let me lest make sure you' r• on the right 
22 
page. Yeah. 
IY 
Look at line I). 
24 
It says. answer. 740. sit. Neatly no. Me 
25 
saw Oa or w0 youn0 ones In the last Year.' 
Oa: 407-7500 
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2 
IS. CRITTON: Form. It's taken out of 
contest. There's no question. 
4 
BY M. BERGER: 
5 
0. 
DO you sag thine words? 
6 
A. 
01d they sees -- did they seem young to 
No. sir. fleetly were no. Me saw two young ones in the 
0 
lest year. 
9 
O. 
well. It eetually says, *we saw one or two 
10 
young Omni In the lest year.' 
11 
A. 
we am one or two young ones in the last 
12 
year. Retor• that they wore all a0ults.°
13 
0. 
The One Or two young Ones In the lest year 
14 
test you're referring to. who are they? 
IS 
A. 
One waoll end the another one was: 
16 
0. 
Don•t  
 on that. Stay? Conn write on 
17 
that with your deo-
10 
Loot at paragraph -- look et Ina 19. 
19 
20 
Q. 
It says. quote, : zerreber one girl wa• young. 
21 
unquote. 
22 
Do you see that? 
2) 
Yeah. 
24 
IS. CRIT704: torn. 
25 
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Page 22 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002636 
EFTA00157589

Page ItO 
1 
Who were you referring to? 
2 
■ 
And then you see undOr that at lir* 
22. It 
4 
says, quote. but t imagine she wee 16. 17. 
In my 
5 
Judgment She wee 16, 17. unquote. 
6 
Do you ass that? 
7 
MR. CRIESON: 
Motu. 
0 
tilt WITNESS: 
Yeah. 
9 
BY MR. BERGER: 
10 
Mere you referring toll? 
MN. EltIllfg: 
torn. 
12 
7HE WITNESS: 
I think so, yeah. 
It 
Oh. can 1 road this again? 
14 
BY MR. SERGE*: 
15 
O. 
Sum, 90 ahead. 
Tate your tine. 
16 
A. 
• Euring the last year while you wet* working 
I? 
for him, what do you mean. they look young? 
Did they 
IS 
look like they were still 
in high school? 
Yes. 
And the 
19 
only one that 1 knew vas in high school was. 
20 
tememb*t one girl was young 
he 
Maw
21 
she was. 
1 never •skr.d.luate old she was. 
1 think ail 
22 
was In the lost year of high school. 
23 
Right. 
Understand. 
24 
0.1eatich. 
25 
But I Imagine she woe 16. 12 
I don't know. 
rata: 41:-//00 
pane* Clue? Ran 
/ATOM ACKNCY, INC. 
04:1 0/1-IIC4 
Page 170 
1 
In any Judgment she wee 16, 17.. 
2 
f wee toning about, I was OOOOOOO ng about N. 
al that time. 
O. 
se at lint. 22. look at lino 22. 
5 
A. 
Yee. elf. 
*Aye. Peet* Out I inegine the ..es 16. 17. 
O 
You were referring to who? 
9 
A. tom 
10 
O. 
Okay. 
YOu can put that down. 
11 
You mentioned Jog Jo.. 
You said Joe Joe waa 
12 
the house man in New York/ 
13 
Y••. 
1 Mat be Joe. 
14 
And do you know his full 
name? 
15 
A. 
Joe Joe work with has wife. 
they wet. 
16 
Puntanella iptoneticsl. 
rentanolla. 
..104, Joe and Lynn 
12 
was his wife. Muntenia)... 
IS 
O. 
When I. the last time you talked to them? 
19 
A. 
Vow. Never talked to them again in over ten 
O 
years. 
O. 
Now. you arentithed in response to Ma. troll's 
2 
doettiOns. y.)../ sold sOmethIng aboutIlis 
father. 
De you 
2) 
repeater talking about that? 
S 
Q. 
Now do you know that person yam her fathom( 
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Page 171 
1 
A. 
Because either she told re or He. MuftwIl told 
2 
3 
And she -- I think he Is the one who bring her to the 
4 
house that afternoon. 
5 
6 
Q. 
Moo. you said you know -- you knew who Alan 
7 
Dershovits or you know who Alan oershowitr ie. right: 
A. 
Many tames. 
9 
0. 
And he vas at the house? 
10 
A. 
He's been at the hogs. a lot of thaw.. 
11 
O. 
Was he ever at the house when there were natal 
12 
Wean at the house? 
13 
14 
O. 
50? 
11 
A. 
They were never noted wOman et the house. sir. 
14 
1 reemed>er One OnfavIOn when one English 
1/ 
girl 
-- I think she was English or Conan girl 
-- ten* 
le 
to the house. 
And Usually in Europe they .100 tOPlegg. 
19 
they don't ever anything. 
But she was taking the sun 
20 
outside and site home to the house with nothing on and 
21 
cr.... thorn rut. 
I Berl, net In this Mute. 
you don't 
22 
do It. 
you go outside, put the towel and cone In here. 
23 
because she cote to get ...lathing floe the kitchen 
24 
wearing nothing. 
M0 I did not allow that. 
25 
0. 
But when Alan DarOhcorltt was there, were there 
601 gt2.-../ 
...mat COURT IMOWEIN4 AGENCY. IsC. 
50e'eawrww
WIVIIKOUNPOI0CIOPO 
0411 012-3104 
rage 172 
1 
any women that were legless, 
2 
A. 
NO, not that I Can remember. 
1 
O. 
that about whoa Prince Andrew was there? 
4 
A. 
Not that 1 Con remoter. sir. 
• 
O. 
Old you ever see AlOn DeTehOwItz welting 
6 
•rourel naked? 
A. 
No, sir. 
O. 
mow about Prince Andrew? 
Na.
A. 
 sir. 
10 
Il 
12 
II
14 
O. 
Let me 90 back for a minute to the 
15 
confidentiality 
provision In the separation agreenont. 
16 
Ord you -- did you discuss with anybody why 
17 
there had to be a confide* tttttt 
y provision? 
Old you 
IS 
talk to somebody about that? 
19 
A. 
No. 
No. 
I discuss It with Mr. Epstein when 
20 
to told no, he finally 
caw out and says. John -- 1 Wm* 
21 
they were OOing t0 try to replace us. 
And -- rind we got 
22 
vp0et beceuatt 1 was not ready to leave yet. 
But at the 
23 
fame time we were eMeCtind t0 be lett Out. 
And I left 
24 
there before they decide t0 let we go. 
25 
AM 1 went to -- 1 remember very clearly. 
1 
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Page 23 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002637 
EFTA00157590

Page 172 
went to his office in the pool house and it was -- I 
telt to bin and says. John. -- I went with ease faxes 
that Cane to Ay Office end they wets people interviewing 
• 
• for my Job. So I feel oily pissed about it. 
5 
And I went t0 his Office end said. Jeffrey. 
what is this? And what le this? And what Is this? 
Me says, well. that's Ghleilidne. I'. not 
involved Into that. 
And I says, okay. 
We're going to leave, 
10 
Jeffrey. That's it. We're done. And what you going to 
It 
do for flea 
12 
And he says, well, whet you want? 
13 
And 1 says, give a 
at least • years ** 
1 ** v. 
14 
And thatit, what it turn out to be, around 
15 
$50,000, Plus the van. 
16 
And he says, okay, John, wish you good luck. 
And the lest day f was there we shake hands and we left. 
IS 
but 
relationship with his. It was gad. It 
19 
was friendly. At the beginning of the -- sq job roe 
20 
very friendly. Then he Changed When Ms. Maxwell cone 
21 
in. 
1 didn't lite to work for her. She was a bitch. 
22 
AM she make us life hell. And that's ay we left. Out 
23 
it owl not with Mr. Epstein. 
24 
Q. 
to you know why there was • confident I. •i It y 
25 
provision in your •goosent7 
lap. 013-7500 
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A. 
NO. Itel'a lawyer sluff. 
I dent know. 
2 
MA. BERGEA: Okay. That's ell I have. 
CR06.9fAMINATICW 
AY MR. COITTON: 
5 
0. 
Mr. Alessi, my name Is BOO <fatten, a> you 
6 
Baia and I represent Mr. Epstein. 
8 
0. 
You've tan -- this Oep00itiOn Started et 
9 
10:00. It's almost -- It's closing in On 2:00 but for 
It 
about 45 lariat! Or an hour that we took for lunch. l'n 
tf 
going to try to be relatively brief to we can get you 
12 
out el here. fikey? 
Il 
A. 
okay. sir. 
14 
O. 
You've been asked gasttene by five different 
IS 
lawyer* who represent various Plaintiffs In this ease. 
16 
A. 
Yes, sea. 
17 
In age instances you've beer, asked the sea 
IS 
question multiple times? 
19 
A. 
Yid. sir. 
20 
O. 
The tesaneny -- you've also been asked a 
21 
number of questions abut your separation free 
22 
Mr. Epstein sonatina. at the end of Oiasdler Of '02 and 
2) 
the entrance Or your entering Into e elipatatiOn 
24 
agreewant with him? 
25 
512.7103 
ia00E COURT PEPOcala areal. lilt. 
meameaaa
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int: ill2-/a06 
Page 125 
Q. 
Correct? 
2 
A. 
Yes. 
Q. 
And abaequently there was an InCidant in 2002 
4 
that you•vo described in scam detail, based on the 
questions that have been asked. end you and its. Epstein 
6 
resting an ratable agreement: you repaid his the mass 
7 
that you had token and you petted? 
8 
A. 
Yes. 
• 
0. 
Is that a fait statement? 
10 
A. 
And I will have to add something to that. 
11 
Ron we talk at the lunCheOnette, we have Coffee. he 
12 
aye. John, If you were at sly best emplOyee that I ever 
13 
have and that you would not take Cafe Of fly nether, I 
la 
would have put you sway. And that's the way he car Out 
15 
to me. 
14 
And I says. I like you and let's -- Just pay 
17 
so beck in one or two weeks. because I send the natty 
18 
back end it get lest. So he give me another --ant hid. 
14 
but ha lawyer says, you got another month to ay. Se 
20 
between I got the sonar -- the sorry order was lost in 
21 
the mail. So 1 send at beet. I pay everything, 56,110. 
22 
I think it was 6110. And that was It. 
2) 
Q. 
And I'm moor interested, not so nich in the 
25 
detail', Mr. Alen'', but the Color. 10 t0 speak, the 
25 
lawyers 3eve put on this. is. is that as a result of 
'5611 822-7500 
most COORY REPORTING AGENCY. INC. 
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•••••••••••••••••••••••••••mornIanalip 
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Page 176 
your aparation from Mr. Epstein in late-2002 and the 
incident in 2001, that somehow y0 ha 
colored our 
testteony to help Mr. fisSain today. 
Rol my question to you Ito 
Nave you told us 
the truth today a to every question that's been asked 
and the questions that are going to be sake0 of you? 
7 
A. 
r0 every one of you. 
MR. WILLITS: Object I. the form of the 
9 
question. 
10 
DR IC. CRITTOW: 
ll 
O. 
And with regard to the agreenents that you 
12 
entered Into with Mr. Epstein. In particular the 
I) 
confidentiality agreement, you were asked a question bi 
ll 
Ms. Ezell whether you understood that you're not bound 
15 
by anfidentiality today. And you responded in the 
16 
•fflrmative, tight? you tag/rasa that you're to all 
17 
us -- to answer every question fully tO the best Of your 
le 
knowledge? 
19 
Absolutely. 
20 
O. 
Pal that you have dons today? 
21 
A. 
Yes. 
22 
0. 
Okay. 
23 
10.. IIILLITS: ObBlet to the fore Of the 
24 
quablOn. 
27 
BY MR. CRITTOM: 
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3504-022 
Page 24 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002638 
EFTA00157591

8 
10 
0. 
And, so, we
 -- you've done great. You've 
11 
prObobly done better then the lawyers today. but you'd 
12 
lite to get this over today are finished? 
Il 
A. 
I NT* 4^. 
14 
0. 
All right. 
There have been a IOC Of questions 
15 
about your 30bdeSCCIP410.1 end OinieS at Mr. Epstein's. 
16 
And If 
I understood It correctly, is basically, 
SACO you 
17 
became the full-time house manager. you were responsible 
10 
for all aspects of the °per:ND:n0f the VI Drill* 
19 
residence? 
20 
A. 
1 was. 
DI 
PM. WILL170: 
00)4Nt to toe torn Or tne 
22 
goNdliOn. 
2) 
BY MR. CRITTCP: 
24 
0. 
And during the tine that you were responsible 
25 
for ell aspects of the Cl 811110 residence, that 
5411 831.25po 
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(561) 412-7506 
amemonswoomesphos
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PbOe in 
• 
Included not only maintenance and repair, but 
2 
appropriate stalling. laundry. cleaning, shopping. 
1 
cooking, whatever -- whatever needed to be done at the 
4 
Ns? 
That's correct. 
MR. WILLITS: (elect to the Ions of the 
question. 
SY MR. CRITTOM: 
And during the tine that you were there as the 
10 
as the house manager Iron 1892 up until 
December of 2002, you did all those dofferent types of 
12 
responsibilities: is that a fair etatoment2 
Yes. 
14 
KR. WILLITS: Cblect to the form of th. 
IS 
question. 
16 
ST MR. CRITTCAM 
I/ 
And at some point -- let no strike that. 
fe 
The Original 0061. so to speak, that you Cut 
19 
was with Mr. Epstein: that is. when you beCams the 
20 
full-tine house riknagOti Is !Not true? 
21 
A. 
That's true. 
22 
0. 
And cone point within -- what? 
o year or 
23 
so, I think Kra .. Ara .. 
24 
25 
(561/ 5 /2.7500 
PAOS1 MORI arPORTION ACRIOCY, INC. 
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Page 179 
1 
L444. 
2 
0. 
-- was no longer Mr. Epostmin", -- Dr. Eva 
Anderson was no longer Mr. Cpatosin's girlfriend, 
--
• 
A. 
That's correct. 
5 
0. 
-- and a nw girlfriend 
ease In and that was 
• 
Chi•laine Maxwell? 
A. 
/hat 
correct. 
8 
0. 
And when Ma. Maxwell can in, she, in essence, 
• 
took over as your immomdkale supervisor? 
10 
A. 
/hat'. 
correct. 
0. 
During the tins that you worked for 
12 
Mr. Epstein. did you have • good, excellent. fair. 
whet 
13 
was -- how would you describe your relationship with 
14 
him? 
15 
A. 
Good, excellent or (air. 
16 
I will 
think .200d. 
I/ 
And did yew interact with him very much or 
18 
doer he interact with anybody very ouch? 
19 
A. 
Be doesn't Interact very mach. 
At the early 
20 
years. yes, he did Mme to the kitchen and we used to 
21 
sit dawn In the kitchen and he would discuss my kids, my 
22 
family, hie family, and he will 
talk to me. 
21 
At the end of my stay there, it was --
24 
was -- we were told not even to look at his face. 
Mot 
25 
even to -- this was done by -- this. was even done by, 
04 
-5. ,5:50 
Pa0:4 CCVIN loterisr. KAMM INC. 
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Page 180 
1 
they hire a Countess (COM Europe to write this book are 
2 
to write ideas Of how the house of royalty should be. 
And that's the way Ms. Mammal' wanted the hokum* to run, 
4 
es • royal house. 
And I 
woos pissed off at that are 1 
5 
never agreed with that and I never went with the book. 
6 
I threw the book away. 
And that was it. 
7 
MA. CA:TTCM: 
tat it rove as con responsive to 
my question. Move to strike. 
M. WILLITS: He shOUld allowed to finish what 
10 
he thinks Is responsive to your question, even if 
11 
you don't agree. 
12 
RY NR. C111411010 
1) 
0. 
Mere you finished. sir/ 
Yes, 1 finish. 
IS 
M. CR111620: See, he's (inosw-d 
16 
M. N1LLITS: Me wasn't, but okay. 
IT 
BY St. CAlITCM: 
18 
0. 
I'm trying to -- listen carefully to ny 
19 
question because l'n trying to get you out of Pare 
20 
sooner rather than  
21 
if I IIII4eflit001 your testimony Is. 
15 
22 
you had -- you considered your relationship wits 
23 
Mr. Epstein to be good during those years) 
24 
25 
Q. 
And would you describe your relationship with 
(561) 812-7700 
PkOst COURT SSPOR/INGSAINCY, INC. 
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3504-022 
Page 25 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002639 
EFTA00157592

raga 181 
Ms. Maxwell as not being as 0000? 
A. 
Its. 
O. 
When -- you ware -- you had an OppOrtunIty 
• 
over lunch. Mr. Berger gave you a copy Of a Statement 
5 
that you gave to the State Attorney's Office on 
6 
Mohnalfla 21, 200$. we've wetted as eahibit. I think. 
• 
ExhIbit 
M. rAITTONI What did we mark it is. 2? 
Ter 1,1710$5: At whet page? 
10 
IS. WILLITS: Yeti. It was 2. 
11 
M. CRITTON: Thank you. 
12 
AY NA. CR1TTOM: 
13 
0. 
no, 3ust st•tanent, the weal,. st•wmant. 
14 
You had an opportunity to look at it over 
15 
lunch? 
16 
A. 
Yea. 
I/ 
Q. 
And that'. • at•tenent you gay• back on 
Is 
November 21st of 2005? 
19 
A. 
Uh-huh. 
20 
Q. 
IS that correct? 
21 
A. 
That's Correct. 
22 
O. 
And at that tine you wore there with 
23 
in. Murrell. who was your attorney. And you gave • 
statement and I think as well your wit* spoke with the 
25 
St•t• Attorney's Office? 
061) 412-1100 
Pnara 0:001 PRPOPriltd ArfloCY, 1MC. 
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•-vatemane 
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-
0411 632-750i 
Sege IS? 
A. 
That's correct. 
2 
O. 
And whatever questions the State Attorney 
asked of you at that time. T segues you fully answered; 
4 
Is that correct? 
5 
A. 
Absolutely. 
6 
O. 
Md then page 9 when Mr. Barger took you with 
• 
regard to the questions -- and before I get -- 
going 
to cone back to page 1 in a chute' 
gut if : understood your earlier testimony In 
10 
response to one of the lawyeis who asked you inflations, 
11 
la, thaw wee a Tauber of European women, ell who you 
12 
deesed to be 20-plus years old, !hat would travel with 
13 
Mr. ['whenn to various piece., and am well would cow to 
le 
the bowie free time to tine? 
15 
A. 
That 'a cox rect 
Id 
O. 
Md I think you testified In response to 
17 
Mr. Mager's queatioas today, is that the only female 
IS 
that you understood that Can to the house Outing the 
It 
time that you were the house asnager who you knee to to 
20 
under the age of 18 
21 
A. 
That's correct. 
22 
Md you knee she was under le beci.fle 
23 
24 
A. 
That's correct. 
23 
0. 
And teat's • young <AEI who I think you 
(3611 • 12- I)cO 
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0411 811-1506 
Page IS? 
• 
A. 
16, I?. 
And 1 think you said she never was involved in 
giving any ma/wages to Mt. Epstein? 
A. 
1 don't think so, never. 
And the tine, teat you e.g her. Mr. Epstein 
• 
was 
8 
9 
A. 
I think so. Yeah, that was the main purpose. 
10 
0. 
And on multiple occasion. when she would be 
over. she would be over there at Kr. Epstein's homeM 
12 
la that correct? 
13 
A. 
Yes, that's correct. 
14 
O. Md of the girls that can or the woven that 
15 
calla to give Minfleges to Mr. Epstein over the years you 
16 
were there, t think you've described on page 9 of your 
17 
deposition that you nay have seen a hundred or 200 
IS 
different neseage therapists? 
11 
A. 
It could be les*. I don't think It's more 
20 
than 200, but it could be less than 200. yes. It was --
21 
lr waa IL ware or 12 years or 13 years or constant 
22 
People going in and out and people that were coning to 
23 
the house, he will bring foe another state, he will 
24 
bring in 1110 planes. People that it Came ttOre Curer, 
25 
message therapists, there were men and wen. 
They live 
15611 4)2-75OO 
NOE COURT nEPOWINC AGENCY. 10.1. 
0611 On."). 
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eassoweenosmatemmeweieninime, 
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Page 184 
1 
in Miami. we -- so it was so nany that I cannot remember 
2 
how many. 
3 
O. 
Okay. And I Understand that. I'm lust 
4 
referring back to your statement where It says at page 
9. line 1, the geesition woe: "Yeah. Yeah. Not the 
6 
Sara girl. t *man. during 11 years l pzobably say a 
hundred. 200 different na•hige therapists." 
$ 
Co you see that? 
10 
Q. 
All right. And It I understood your testimony 
11 
is, the ones the -- that to. of the massage therapists. 
12 
as you've lust described, you saw some non? 
Men 
14 
Q. 
You sew more hound 
15 
A. 
More wrist 
16 
Q. 
AM all of the wonen. at least from your 
viewpoint. were 10, 19 or older? 
IS 
A. 
Yes. 
19 
M. CRITIOM, Why don't you change your taps 
20 
fight new. 
21 
TIOCCalteletelt: Orr the record at 2354. 
22 
(Brief removers.) 
23 
VIDECCAAOMER) Mere back on the record et 
24 
2:55. 
25 
BY IS, CRITIOM: 
061) 812-1100 
PROCR WNW RIPOrnin AGulh- t. INC. 
wavflawmflartenameanionainemes 
tmoweavereatmeineemiltglaarlininsbomemumaparampasommmiteseieweennainiamem 
chtnadohyrtnitttleht• 
tatll $11-1106 
3504-022 
Page 26 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002640 
EFTA00157593

Page 185 
1 
Q. 
Mr. Alessi. In the 11 years that you worked 
2 
for Mr. Pastan, with regard to the menage 
3 
therapists -- and 1'r inking 
about all of them, women, 
4 
Awn, the ones that rem IS. 19, 20, of the ones that 
5 
were older -- did you ever see -- or, first of all, 
did 
6 
you ever hear any complaints about -- Iran the manna. 
• 
therapists about the manage they had given to 
• 
Mr. Epstein? 
9 
10 
Q. 
Old you ever ne a manage therapist during 
11 
these 11 years that appeared to you to be distraught? 
12 
A. 
Never. 
13 
0. 
TO be in some torn or a shock? 
14 
A. 
Never. 
15 
O. 
TO be Stared? 
16 
A. 
I never eve anybody 'Cared. 
12 
O. 
Old you ever ne atone who 1OOA44 like they 
IS 
were upset or crying? 
If 
A. 
No. sir. 
20 
0. 
1 thank you, In response to Mr. -- well, not 
21 
sure who one the question -- but they 
you were 
22 
asked whether you ever note to the individuals --
23 
21 
O. 
-- when they cars down. And 1 think you and 
25 
from tine to tine you mlobt have some small talk with 
11611 02-1500 
rang CON' AnGairim5 Marl. :NC. 
1561) 422-,506 
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1 
them afterward? 
2 
A. 
Yeah. 
O. 
Did you taually See then if they Came down? 
4 
A. 
Yeah. 
• 
O. 
SO you Would hake had an Opportunity t. 
6 
Observe their appearance. Correct? 
• 
A. 
Theta Gennt. 
O 
0. 
Have you nen people whoa loot <115tfe........ht• in 
9 
shOfk, nand, 
upset, angry In the pest -- not message 
10 
therapietel -- have you seen people In your nee 
11 
experience'? 
12 
A. 
Ob. yeah. Yes. 
12 
MR. MERNELATEIN: 
Object to the Torn. 
It 
DT M. CRITTOM: 
15 
0. 
So if -- all, 
let no ask it this way: 
In 
16 
your life 
experiences before you worked for Mr. Epstein, 
I] 
and, In Caul, during the tan 
you worked for 
IS 
Mr. Epstein, have you seen Individuals not associated 
19 
with Mr. Epstein who Appeared to be distraught, in 
20 
shoot, sued, 
upset, angry or 1nfeNi 
21 
22 
MR. NEWEISTEIN: 
Object to fore. 
2) 
DT MR. CRITTON: 
24 
O. 
Have you seen people who appeared to you in 
25 
have been traumatised by a particular 
event? 
061) 012-7100 
MME COURT REPORTING AGENCY. otc. 
...et -it tat-. • t—eot--emettint..... 
• " "" " '" " ' ""
""1"7:O42.11=tten.... 
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0611 a12-7506 
MR. I€RMEL$TEIN: 
Object to form. 
TEE WITNESS: 
Tee. 
3 
DY MR. CRITION: 
4 
O. 
Nave you even people who see. to De 
well. 
I 
5 
asses you've seen people who have yelled Or 'Craned as 
6 
• result or some event that had occurred in taut 
presence? 
0 
Yes. 
On the ransage therapists that you Saw at 
10 
Mr. Epstein'is house non 1992 up until 
the time you left 
21 
In December of /02, did you ever see any type or 
12 
reaction. distraught, shock. scared, upset, crying. 
II 
disheveled, Injured. disoriented, yelling or screaming 
14 
for help at any tine? 
IS 
16 
0. 
Once the menage -- once -- let use *trite 
IT 
that. 
IS 
If 1 understood your testimony. you helped set 
19 
up -- either you set up the rocs or you helped set up 
20 
the menage room? 
21 
A. 
22 
Q. 
Ara you might be the person Or It might be 
23 
someone else who would lead the massage thenplets 
or 
24 
the tonle up to the coon, the mete or the female up to 
25 
the town. 
1541) [)2.1100 
rh3:t Can PRPORT:aN St23Ct. INC. 
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'INQININATEMW/fn 
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11611 0J?-710t 
Page 155 
A. 
Yes. sig. 
2 
O. 
Once that person was upstairs. you then would 
3 
Coin ban damn and as one your multiple duties 
downoteln? 
5 
A. 
Absolutely. 
6 
0. 
As to what occurred during the course of a 
sanaMmh do you have any personal knowledge during the 
6 
11 years you were then? 
9 
A. 
There was absolutely no way to know Or to lot 
ID 
Into CM fine. 
The windows were what they hove, ti-ose 
11 
automatic electric 
shutters. 
They were completely dark, 
12 
fOnpletely • hundred percent dark, the (Vona. 
And It 
13 
was -- nobody Now It. 
1 Lome it when 1 was at the house 
14 
that I never saw anything win ring 
on "aide. 
IS 
O. 
So you have no personal knowledge what 
16 
occurred during any particular menage> 
17 
Nothing. 
le 
0. 
And I think you said -- well, lot rm strike 
19 
that. 
20 
In other individual. 
whom you have done work 
21 
for at bag houses an palm beach, did those people from 
22 
time to tine have manages. too? 
23 
A. 
I never work In • house Inside es I did mark 
21 
for Mr. Epstein. 
23 
0. 
Routs an outside sksintenance work? 
Inli 0)2-ISO? 
:POSE 00:44 PIMPING AGENCY. INC. 
ilammtnemorenwhemensinsisse 
sass 
TteMle 
l61•n •05 
aevw 
$4•Carmerfwers44 
061) 6,2-/504 
3504-022 
Page 27 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002641 
EFTA00157594

2 
3 
that. 
Peg. 169 
I was the maintenance guy outside. 
All right. 
And if -- well, let a. atnke 
You're aware that there'. alt aorta of spaa. 
• 
The breakers? 
PGA7 
Trump? 
6 
A. 
AbOOlutelY. 
• 
0. 
The Ritz Carlton? 
The Pour Seasons? 
And 
$ 
probably a thousand other places la Palo Beach County? 
9 
ebb. V1LLIIS: Object to the form of the 
10 
questIon. 
11 
BY NI. COITTON: 
12 
Vali, let ye strike that. 
11 
Ara um: ewers that therm'. norm them ran 
14 
plated that sOmmicie Can get a naelage in Pain Reach 
15 
County? 
16 
A. 
Of COurse. 
I? 
0. 
Are you aware that there's probably more than 
16 
a hundred places, saybe a thousand places In Palm Pooch 
Ig 
County true Boca Raton up through Jupiter and all the 
20 
way out west where people can get a therapeutic or a 
al 
tesseister 
22 
A. 
Yes. 
2) 
0. 
And I assume you more aware, that -- or are 
24 
you aware Of that during the tine period that you worked 
25 
for Cf. EpfteIn? 
0611 8)2-7500 
COOS? APPOWfirh AceriCr. INC. 
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0617 012-7504 
Page 190 
1 
A. 
Yes. 
0. 
And I think you told us that you were aware 
that there were nstMege SChCele? 
4 
A. 
Yes. 
5 
0. 
And IS It your Ondertitendleg that generally 
6 
massages an given in • -- Ina room with a table where 
the lights are generally turned dorm? 
A. 
And music on. yeah. 
9 
0. 
All right. 
You were asked • question about 
10 
vibrators or I think that the word was sex toys. 
11 
If you'll 
turn to page 20 of your st•torent, 
12 
sir. 
13 
rf sou look at page 
it you juat glance at 
14 
line 9 --
IS 
A. 
Okay. 
16 
O. 
-- through limo 22. Lie 
a chance. 
If you'll 
17 
just leek at that. then I'll ask you a couple questions. 
10 
Road to yourself, p10460. Others:1Se, the 
19 
court reporter will have to take down everything you 
20 
say. 
21 
A. 
Yeah. 
22 
0. 
And at least the stetenent that you gave beck 
2) 
in -- on NOverber Ilet 
of 2005, almast 
&boost four 
24 
years ago no., you describe that there ver• -- that you 
25 
•sw two [Kase of meaner, or vibrator.: 
is that 
111.11 el2-7500 
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Page 191 
Correct? 
2 
That•• correct. 
And la that your boot recollection. 
AM you ail 
4 
here today> 
A. 
That . * the best recollection. 
6 
0. 
And one of the vibrators, you said was. as you 
described earlier, 
looked like a 01100? 
Right. 
10 
O. KILLITS: 
Onyeet to the form of the 
11 
question. 
12 
BY IR. CRITTOSI 
0. 
well, le t me ask you this: 
Nos the item that 
14 
you described, that's described at lines 12, II and le. 
IS 
and IS -- 12, IS and 14 on page 20. is that what you 
16 
described, is that what you were talking about es the 
dlldo? 
1$ 
A. 
Yes. 
19 
0. 
And I muse you're familiar with chat a cliblo 
20 
15? 
2: 
A. 
I know that it's 
One Of these --
22 
0. 
YOu don't have to describe it. 
Just are you 
21 
familiar with whet one is? 
24 
A. 
No, I don't. 
1: n not really bmiller 
with 
25 
that type of instruments. 
But what did I 
wen it end IR 
1141: 432- ):7 ' 
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Page 192 
I 
It true now. Is It true When I make this statement. It 
was a big rubber oan• 
--
I 
Penis? 
4 
A. 
-- looking penis, with double heed, two head,. 
1 
6 
A. 
And I don't klICS. haw Is It even called. 
Rad I 
sorry. 
It's 
a little 
unpleasant. 
Q. 
That . . all right. 
The second Item that you described was a neck 
10 
and heck vibrator; is that Correct? 
11 
A. 
Yeah. 
They neve this vlbrotOrS, they have the 
12 
cordless and they hare these bells and they have 
it 
different types of these vibrator*, tog. 
14 
P. 
Like you man get then at Brook:atom or
IS 
stmethIng like that? 
16 
A. 
Yeah. 
Yeah. 
Yes. sir. 
11 
0. 
So at least when you were at Kr. Isabela's. 
16 
and I think as you described in response to lawyer's 
19 
questions today, so during the last couple of mOritha 
20 
that you worked at Mr. Epstein's you sew these two 
21 
vibrators? 
22 
A. 
Yes. 
2) 
0. 
And On those. two occasions you'd take those 
24 
vibrators. If you went up to clean aftetwords, you'd put 
25 
on your gloves, pick then up with • to-el avM you'd 
1561, $12-7500 
Pio= COURT SEPON7INC Kent, 
INC. 
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1561: 012.1506 
3504.022 
Page 28 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002642 
EFTA00157595

Pale 195 
clean them off and you'd put 'Mum back In 
2 
Xis. Maxwell's 
A. 
Closet. 
-- closet in her bathroom) 
NA. MILLMA: Object to the form of the 
queptIOn. 
7 
VIE WITNESS: I put It beet In the Closet and 
8 
Inside the closet there was a laundry basket that 
9 
Is Mere she had those. 
10 
BY M. CRITTOth 
11 
Q. 
And as to whether or not sorm.one actually used 
12 
those itena or hot they were used. all you know Is you 
13 
found than --
14 
A. 
1 flog It in the Oink. 
IS 
MA. BERGER: 
Objection. Mr. Britton is 
IG 
Metifying. 
beading. 
MA. WILLITS: 
Objection. also. to the fora. 
18 
BY MR. CRITIC*: 
19 
O. 
Lot i.e ask you thin 
no you know. if 
: 
20 
uml aaaaa nd it correctly, 
you toyed the, tea vibrators. 
II 
One IOC the neck and Yet and Eno Other One tnet you 
22 
described at a 01100. yew 10tt4 then In the sink on 
23 
those few occasions near the end of your sopleynent? 
24 
25 
NA. AIROGA: 
Objection. 
TeetIfYln0. 
beading. 
15611 elI-7500 
mddr cove? 
netmct, INC. 
:54I, e11-15414 
elialteettledletveeetweielvelenaleell. 
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1 
2 
3 
4 
reg. 194 
Tat 1417MASS: 
I find it in the sine. 
BY RN. Chirnhi: 
Q. 
And then you would clean up and put it bock in 
A. 
I will put try rubber gloves, get a towel, put 
than under the sink. run the meter and put then in the 
7 
closet. 
And you put the. back In Ms. Maxwell's closet/ 
9 
Closet. 
10 
O. 
Why? 
fl y Into her closet? 
Because they were always kept there. 
12 
Q. 
All right. 
You tut/ fled earlier, 
is that if 
13 
IC 
either be you or Y. Itivarel I, It 
understood you 
IS 
correctly? 
16 
A. 
Yeah. 
17 
0. 
Okay. 
18 
A. 
At the end -- at the end of my nay was also 
19 
another girl, 
that Call. 
And then she was 
20 
handling everything, as far an cells to these girls. 
SI 
050 nr. spatean ever mete %Mee raised 
22 
I never heard. 
23 
If Kr. tyst•in was not In residence. that la, 
24 
If he was in Mew Tort or non place •Ise other than rein 
25 
Beach. did you and your oleo etlli 
stay at the hole or 
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MUM you go to One of your apartment] 
2 
A. 
Y. 
Ye went to our apartment. 
3 
0. 
And then when he wasn't there. would you hive 
pretty mom regular house around the haute? 
5 
A. 
 
 such. 
 
 such, yeah. 
That wan the 
6 
days that we had to have the cleaning crew, 1 evil, 
too 
to go to the house end oversee the cleaning operation, 
8 
oversee the gardener beceuee there wee not, when they 
10 
so we have to take case of the pool, the chlorine and 
11 
all that stuff. 
12 
Q. 
So you would still 
do your regular but you 
13 
could finish pretty such 5:00 to 5:00? 
14 
Yes. 
'Mat was much easier. 
15 
And when he woe -- Mar often would he 
16 
generally be In Palm Beath? 
17 
A. 
TOO much. 
10 
O. 
All right. But If -- would he be here at 
19 
least a couple --
20 
A. 
I would says. at least three tines a year -- a 
21 
month. three 'inks • nonth. three iiiii nd• • month. 
22 
Usually they come in on a Thureday. 
erten 
they left 
a 
23 
Monday or Tuesday. 
24 
Q. 
And then they go wherever else they were going 
25 
end then things would get toot to mere of • 9:00 tO 5:00 
15611 0)2-1500 
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Page 196 
type WOWS? 
2 
A. 
That's right. 
3 
Q. 
And if he was in residence. that's when your 
job became nurh more all oncomploole47 
5 
A. 
exhausting. 
6 
Q. 
Okay. 
Tou more asked about a female nailed 
7 
I= 
I think you originally thought it wasIIII. but 
9 
10 
You recall now; is that correct/ 
11 
Yes. Yes. 
12 
Q. 
And I think you described her. I think your 
I) 
Ye0011eCtiOn was. Is that you temetter her being at the 
11 
house the last few months that you worked for 
15 
Mt. EpetOin? 
16 
A. 
Yeah. 
The lest few Meths. 
11 
0. 
And that's the only time that you eentdifer her 
IS 
actually 00Ing there? 
19 
A. 
Yeah. 
20 
O. 
BeCaVee tau actually ['Kell 
when OM used to 
21 
work at M aaaaa lags. end then you recall her starting to 
22 
23 
A. 
To the house. 
24 
Q. 
-- Ns. Apstein's basil 
A. 
Right. 
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EFTA00157596

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Page 105 
And 1 think you teat!lle0 that at one tie* you 
bed t0 pick Mr up and oho lived at Mc house or *he was 
living with Mr boyfriend at some hoes* Oct in Royal 
Palm beach, is that corsoct? 
That". right. 
Did you know anything MoutlIIIII? 
Not necessarily. Mot that 1 can geneses... 
1 
/Mew the One time either Ms. Maxwell or Kr. Epstein told 
ne 
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BY Mt. COITION: 
Ass. [sell used -- she referred to • Tony --
KS. ELELL: Santiago. 
OWE WITNESS: Monaco. 
10 
BY It. COITION: 
11 
Have you ever beard of • 
12 
KS. EtELI-1 Thank you. You're right. 
1) 
ME WITNESS: I know that hid nand was Cony. 
14 
but 1 don't know if it was Santiago Of 
I 
15 
don't otmembet the last MM. I never *poke TO 
16 
hire. except ask his to Mee his CM Ond tine. 
17 
BY KR. COITTON: 
14 
And Old Mf. 
got It wrong -- did 
19 
bring 
to the Pp 
 hem• en more 
20 
thon one occasion? 
21 
22 
0. 
And did you consider her, at leant Iron nos: 
2) 
viewpoint. tom um one of the individuals who Ca to 
24 
give 005504103, 
25 
A. 
She Wes 'supposed to en a massage therapist. 
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O. 
And, so. Kr. ..ct 
least Mr. -
2 
Tony -- asmming, if I asked you to •••Line Me nano nes 
3 
was he *mars that 
Was 
4 
coming to Mr. Epstein's house to give him • message? 
5 
A. 
t dent knee if he was aware of it. 
No was 
6 
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12 
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Page 30 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002644 
EFTA00157597

Page 201 
1 
Q. 
With regard tea 
did it ever appear to you 
2 
that she mac forced to cone to Nr. Epstein s home? 
A. 
I don't think so. I don't know If it was 
4 
forced between them, but I never nos force. 
I never 
saw -- 1 was there the first 
time Ms. Maxwell net Mr 
immediately that she went Into the ape s who.: she was 
7 
walking into the spa. 
And 1 was surprised to see tow: 
0 
afternoon she was et the house. 
9 
0. 
Did you ever see anyone fiitClilg= 
onto 
10 
the Opsteln: s poem sssss that is. either by grabbing her 
by the armor by the hand and dragging her in? 
12 
A. 
me. 
Either her or nobody else. 
13 
o. 
Did you ever see 
whorl she Cue to 
14 
the MNa where she appeared to be -- that is, when mt. 
IS 
arrived at the hone to be tweet or angry or dratFought? 
16 
17 
10 
left on those occasions where you saw her in person 
19 
eeeee the house, did she appear to be In the mine, I : d 
20 
say, overall deipenner and mood when she left as she had 
21 
been often new none, 
22 
Yeah, normal. 
She was normal. 
23 
Did she smile, 
24 
Yeah. 
)5 
Say hello to yowl 
No. 
And spectElcally with regard to= 
when she 
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15 
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17 
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19 
20 
21 
22 
23 
24 
25 
Page 702 
1 
A. 
rimy all smile after they got paid. 
2 
MR. CAIITC44: 
All right. 
that's all 
I have. 
Thank you, Mr. A 
. 
THE WITNESS: 
You're welcome. 
5 
MM. N1LL17S: 
I don't have any questions. 
6 
MA. StilfdA: 
Okay. 
MS. EZELL: 
1 do. 
RECROSS CUM:NATION 
9 
BY 05. UCLL: 
O. 
Sorry. 
Let ne find ny place, here. 
First of all, 
forgive re . 
I didn't neon to 
mislead anyone. 
It is 
not Santiago 
Noy head is not going very cell n0w: so... 
Do you need to take • break? 
A. 
Please. 
Not I err fine. 
I M line. 
Q. 
Well. It was my head that waiin't going very 
well then. 
You mentioned that your wife, I believe you 
said that 
let Me  
V•r. 
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8 
9 
10 
12 
13 
14 
IS 
16 
0. 
Old she •ver conplain to you or saes elleturbed 
17 
by what she thought wes going on there? 
10 
A. 
No. 
9M humor saw anything. 
19 
0. 
Was there ever 4 Idlest these by the nen* of 
20 
Today Hat0147 
21 
A. 
Teeny Motels? Na. 
Not when I His there. 
22 
0. 
YOu mentlOned tae nOrning that there ware 
23 
soma visitors 
who were very InpOttant men. Noble Prise 
24 
whiners> 
25 
A. 
7••. na•at. 
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Are you -- de you recall • Martin Nowak? 
I think that soenda familiar. 
If he Is an old 
guy. old man? 
4 
I think so. Methematicien? 
Yee. 
6 
Q. 
Biologist? 
A. 
Yes. 
Nis rime Martins 
I recall the., yes. 
0 
0. 
And do you recall • guest, Murray Gell-Mann? 
9 
A. 
Mary Gell-Nalm7 
10 
MA. MILLETS: 
t think you said --
11 
its. EZELL: 
Murrey. 
12 
KR. WILLITS: 
-- Murray and he said wry. 
1) 
BY MS. [BELL: 
14 
0. 
Murray. Morey Gell-Mann. 
And. again. Pm 
15 
spotting of these -- these --
16 
A. 
le that a man Or a woman? 
17 
0. 
I believe It's 
• nen. 
Ie 
A. 
Murray Coll -Mann. 
Could be, but I don't 
If 
recall. 
20 
Co you recall the name Jerry Edelman? 
21 
22 
O. 
What about -- can't reed my own wrItsny 
2) 
here -- henry 41204441 1pholustIce17 
24 
Moray Rlsorski. yes. 
Yes. 
25 
was he • frequent visitor 
or --
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Page 3Iof35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002645 
EFTA00157598

Taw 205 
at la frequent. But. also, he was 
2 
Selena -- I think so. he was into the rielenCe 
0. 
And Larry Saner.? 
4 
A. 
Larry Vowsere. Yes. Larry Sugars ea: 
S 
lawyer? 
6 
O. 
I think peal*, he was the president 01 a 
7 
4711•00? 
4 
A. 
1 don't knOah 
9 
0. 
DIO? 
10 
A. 
Mon 
11 
0. 
Well. then emOng those that you recall. 
12 
Mr. Nowak, the biologist and Mr. itiscasa, did they ever 
I) 
have Lampee that you an recall? 
14 
A. 
I cannot recall. ea. 
IS 
O. 
Was It your Irpression that Mr. Ipiawirs Ilawg 
16 
to surround himself with sssss ordinarily 
bright people? 
I? 
Tee. 
14 
10. CRITTOM: 
rem. 
19 
BY MS. EZELL: 
20 
O. 
And la it your lyrsaslm. 
also. that he's 
21 
rather bright and brilliant 
havelf? 
22 
A. 
Yes. 
21 
HR. WILLITS: 
Fan. 
24 
BY MIL EZELL: 
25 
O. 
Ord -- did you eves gain the lar•aslon that 
nal; el?-7500 
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2 
MO. CIOTTOW: 
Form. 
?WE WitaMS: 
MO. 
No. 
Mo. 
1 know hla 
4 
backgrand. 
And 1 -- over the years I learn tow he 
Lose up and into the business and how he make his 
6 
fortune. 
And 1 don't think he was a brain 
7 
scientist. 
BY MS. 
9 
nobody ever told you that? 
10 
11 
0. 
If you take a look again et page 9 01 the 
12 
transcript, Exhibit 2? 
1) 
A. 
Okay. 
14 
O. 
Let a 
call your attention to line 2, which 
15 
begins with the question: 
'Did he have girls 
come over 
16 
to give massages?' 
17 
A. 
Yes. 
16 
fad you Maid: 
10 
Yea. 
20 
0. 
The next question is: 
elaw many anages 
21 
would he hart in one day?" 
22 
fad 1 think you said earlier, 
maga --
2) 
sOallas 
they'd have three a an
,
21 
A. 
Mo. 
No. 
That an not the question. 
21 
Scnetaes he had one, two or throe a day. 
(S41; 677.10:e 
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Page 207 
1 
Q. 
Teat's what I wanted to ask you. 
Up to three 
2 
a day wometimal 
3 
A. 
Up to three a day. 
4 
Q. 
And did that happen often? 
5 
A. 
Very often. 
Or he had yoga in the meriting Or 
6 
In the afternoon It was a massage. 
I don't know that 
7 
again. 
When it was yoga, it 
was in the pool house. 
When it was massage, It was upstairs. 
So I don't what 
9 
they did when closed doors, you know. 
But it was • 
10 
couple of these girls 
that were yoga experts end they 
11 
were massage therapists at the sae time, so 1 don't 
12 
know. 
But there were -- may tines there are two. 
1) 
three Nosaarpea a day. 
14 
Also. she had a massage PAS{ about every day. 
IS 
Meaning, Gaetano? 
16 
A. 
Va. 
I? 
O. 
Then On line 12, the question was: 
'Did the 
14 
massage therapists nor 
young to you?' 
le 
axe you and: 
'Mostly, no. 
You maw one or 
20 
two young pens in the last year.' 
21 
yeah. 
22 
Tan. again, still 
--
2) 
M. CRITION: 
Oblect to MOT. 
21 
BY M.S. EZELL: 
25 
Q. 
-- still talking about the massage therapist. 
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1 
they asked you: 
'What do you mean, when they looked 
2 
young?' 
On line I/. 
3 
Do you see that? 
4 
M. CRITIVOI: 
Porn. 
5 
THE WITNESS: 
Yeah. 
6 
BY MS. EZELL: 
7 
Q. 
Then you go on to ear 
- 1 reaeMer oo. girl 
wee yang. 
Me never asked how 014 sine was. 
It was not 
ay job.. 
10 
And the fraestiOner said: 
'Eight. 
1 
11 
understand.' 
12 
And you said: 
1 livela 
she was 16 or 
13 
It 
That's correct. 
IS 
'Sr. sty ludgmont. e
16 
Yes. 
17 
HA. China: 
fora 
I think. 
14 
BY MS. EZELL: 
19 
O. 
mare was -- the only people being discussed 
20 
in all of this conversation were the massage therapists. 
21 
right? 
22 
MA. CEITTON: 
Form. 
23 
THE anCESS: 
Well, we discuss aboutill, 
this 
24 
girl 
thin 1 Matton in here. 
I thinking about her 
2s 
because -- what's her nano? 
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Page 32 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00002646 
EFTA00157599

Page 201 
1 
BY MS. EZELL: 
2 
Q. Et 
A. me I think she was a assa0e therapist for 
'sore, because we set up the tables for ber. But et 
tine --
6 
MS. EZELL: Let ne lust -- excuse me. Just a 
minute. 'Att i e aske It= 
That's all. 
I
. CRIT1:10 Okay. 
l'n 
THE WITNESS: MI 
Arid I loet 
10 
Concentration. 
11 
HR. CMITTOM, enhy don't you reed Pile response 
12 
to inn? 
Ii 
She can read It back to you. 
14 
'Previous answer woe read.) 
IS 
THE SITMES0: Yeah. 
I was -- In this 
16 
•tatenent 1 was thinking of her.- 
-
-
 
no. • 
I? 
BY NIS. EZELL: 
18 
0. 
19 
A. 
Sorry again. 
20 
It war= 
that 1 knew she was undone". and 
21 
knew IC because 
22 
El 
23 
0. 
Out Ohl' wee net a balmier therapist. 
--
24 
P. 
W. she was not. 
75 
0. 
-- as far se you know? 
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Page 210 
1 
As far as I knew. she was not. 
2 
0. 
And you were tel
 thiewohowt this peg* 
3 
about triode girls 
that Cone to give nefs41.3? 
4 
MR. C14151040 
Form. 
5 
BY MS. EZELL; 
Correct? 
MR. CRITION: ?GM. Azgenentralve. Asked end 
answered. 
THE 10111195, No. If I say, she was e russeile 
10 
therapist, i would says, no. But. then ageln, 1 
11 
don't know If she was e ner0age therapist. TOO. 
12 
BY Ma. EZELL: 
12 
0. 
Okay. 
You do mention. 
On page 21 Of yOur 
le 
st•tørent. 
15 
If you look at line /, you mention a yoking 
16 
girl, 
but aha on not • sonar 
therapist? 
17 
A. 
tet ne take a look. 
Pepe 21. 
114 
Q. 
At about line 7. 
19 
A. 
Lino T. 
20 
NM. 041:704b 
but It In the context of your 
21 
answer 
-
22 
MS. EZELL: 
Sure. 
21 
MR. PILLI19: 
NO the gmestiOn. t00. 
74 
IhIC NITSMSS: 
West ion: 
- Pee-  -- let me start 
25 
It Iron the beg Inning-- from the end. 
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Page 211 
Many of the 
been a whilw. 
it was II 
2 
It was. 
It id. 
It wee so many._ 
lt was 
3 
ao 'many nave., that 1 think al yes hone -- If 
4 
you 
any girl 'a name, she's been there probably. 
5 
6 
It wee else • Young girl but she wee not • 
7 
'assess* therapist. She c••• to the house es a 
friend. 
I talking aboutIllbecause I knew shoo was not 
10 
a manage therapist 
because ahe went to high school 
11 
end she vas • singer, an opera singer and she wee 
1I 
brought to the house by her nether. 
So I knew they 
13 
had nothing to do with massage.. 
They were friends 
14 
end they mite going to the none with her. dinner 
15 
with her. 
And she had -- I think she travelled 
16 
with her, too. 
They travel. 
I? 
O. 
Its only point Is. that on page 9 you were 
IS 
talking *beat the massage fhtroplete. 
AM you said that 
If 
you remember that there were • couple of young ones the 
20 
last year. 
21 
And, so, linen, the young mesas.* therapists 
22 
boa you night remerber in the lent year. reovIclaw. 
23 
that person or 
24 
NH. CIIITTON, Yore 
25 
BY MS. CULL/ 
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Page 212 
1 
-- would be the young au*? 
2 
A. 
Yeah. 
3 
0. 
You state0 that Ma. Maxwell was very hard On 
4 
you and you pot blamed for everything. 
and that you --
5 
you liked th0 job and you liked Mr. Epstein. bat you 
6 
didn't 
like working for Kr,. Maxwell? 
1 
A. 
That's correct. 
0. 
Can you tell or why. Other than that ar, 
9 
bland 
you for everything? 
10 
A. 
She cane Crow a very wealthy tally 
and She 
11 
was 
luet ny opinion? 1 give ty persons] Opinion - 
12 
that she was rotten Spoiled and she tiled to arise the 
Il 
house Ilk, it palace sen not a none. 
14 
I was -- I discussed It with her, many. eeny 
IS 
times we have 4111Cue$1011$. 
And ffiemelblies I even re/tune 
le 
to de her orders. kneeing trot 
: wee going to be beck's 
1/ 
kip by Mr. Epstein or de the right thing. eg thinking bl 
11 
running the how.* should be. But se never had • good 
11 
relationship et All fro. the beginning, 1 don't think 
20 
ao. Out I was -- hare to he her driver and she will go 
21 
and shop ell over the malls and 1 will have to do behind 
22 
her, pay for It and bring the bags to the car. 
23 
Next day or the ana day she vell] do shopping 
24 
and buy and soy, John, go to this store end get It. 
It 
25 
was a lot or work. 
:t was a lot that she created and 
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Page 33 of 35 
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
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Page 215 
1 
non Of this lobo that she c 
***** d. 
2 
0. 
And one of those things nu and had to do 
3 
with her was to take her to different 
Spas? 
4 
A. 
Yes. 
Q. 
And there she would recruit young widen to 
6 
nee and do passage'? 
7 
A. 
Because she was COgInh. 
And she didn't knew 
the area too such es well as I knew. 
SO she -- She 
9 
says. John, mote a list 
of ell the nasssge -- the spas 
10 
In the area free Jupiter to Roca Ranh. 
And we went to 
11 
all the wain spas. 
AM then we went tO the '<Imola for 
12 
Minale therapists, and all the massage parlors, and 
13 
massage. the Small Miner. 
14 
So I make a list 
from the telephone book era 
15 
lee would go UFOS One to the another one. 
I would wall 
16 
in the car and she goes In. 
If 
And sometime she took a couple minutes end 
IS 
walk out with card•, bu ****** cards. 
And that -- she 
If 
did the recruit trig. 
20 
And Isom then. she pick up the girls 
and that 
21 
was the end of it. 
I neves did any reCrultin 
and I 
22 
never realty aid bin doing it. 
23 
0. 
You really never sus? 
24 
A. 
Omer mew Mr. Epstein recruiting anybody. 
2) 
MS. 
All right. I haw no otter 
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Page 214 
I 
questions. 
'Blank you, sit. 
M. HIEMMLS7[10: I just haw* • couple follow 
up. 
4 
R[000453 EXPOUNATION 
5 
011 10. MERIMIAIIIM: 
0. 
Kr. Ale'''. 
I'll 
be very brief. 
You testified 
that a peace as server Casa and 
0 
gave hag the subpoena to appear Mare today. Correct? 
A. 
Yes. 
0. 
for your deposition? 
A. 
Yes. 
12 
0. 
Did you call anyone lifter 
you received the 
11 
subpoena to talk to them *ben thla? 
14 
15 
O. 
You didn't Call anyone? 
16 
It 
0. 
bid you -- how did you cone in contact with 
IS 
Mr. Penton's office to set up the meeting that you 
If 
discussed? 
20 
A. 
Nis -- his secretary left ne a monies 
on 
21 
sy -- In my machine. 
22 
had then you milled back? 
23 
then I coiled Diet. 
24 
0. 
And you set up the meting that y. .. new 
25 
A. 
And we set up a mettird for the Labor Day. 
ini) 4112-7500 
Inn COURT IMPOSING Mann. IPM. 
1)411 02-7504 
--
N"'"" h”Olf 
Sege 211 
Labor MAY. Monday. 
2 
Q. 
What about -- but you 'aid a month and • half 
3 
ago - 
on. this was before you were subpoenaed. Is when 
4 
you had the noting at your house with Mr. --
5 
A. 
Yea. before I was subpoenaed. 
6 
O. 
Mw did that noting 
con about? 
Now did that 
7 
get set up? 
We called who? 
A. 
Okay. 
before -- I an stuck on this question. 
9 
I don't know. 
I think it was Mr. Craton office. 
I 
10 
think It was Mr. Critton office. 
They call M. 
And 
11 
they left ne a mange that I must discuss -- Call Kr. 
12 
-- yeah. 
I had a message in ny phone that to cell 
Mr. <Mtn 
because he would like tO speak to use about 
14 
Jeffrey Epstein. 
That wee the messed.. 
15 
Ma : call It. 
Shen I abet* to him 
we set 
16 
up en appointment. 
1 wa s sick at net tine. And he 
17 
came to my noun and we discussed it. 
10 
Other than Mr. Critter.. --
19 
Yee. 
20 
0. 
In the int few months have you spoken to 
21 
moan about the civil 
cases or your testinny? 
22 
A. 
No, not even my kids. 
23 
Q. 
Did you discuss this nth 
your wire? 
24 
A. 
My wife, yes. 
My kids. no. 
25 
0. 
What did you and your wife talk about? 
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Sage 216 
A. 
Van thing. what's Wing On. 
How bed the 
2 
situation was. 
3 
O. 
What do you Meat, 'Mu On the situation wasp
4 
A. 
How -- I guess how he got Into this mass. 
0. 
How Ht. Epstein got into this mess? 
Inds head." 
Can you be ware OpeCIIIC ke to what you end 
your wife said? 
A. 
No. 
It was just the publicity. 
you know, that 
10 
has age wee en the -- on the magazines and the paper 
II 
and tv. 
And : thought that that would newer happen. 
12 
0. 
had you and your wife felt bad for Mr. Epstein 
13 
because of that? 
14 
A. 
You know. after you know somebody end he 
15 
locund a friend of your. for ten years, I think you 
16 
feel bed, no matter how bad he ha. men. 
And I dmi't 
17 
know what he his done or what -- whet the final result' 
IS 
Of this will be. 
I still 
will 
feel bad about it, 
just 
19 
because the person that he was and how generous he was 
20 
with me and other people. 
21 
O. 
Just to be clear. Other than Mi. [Minn 
*Al 
22 
your wife, you haven't spoken to anyone else &Wet the 
23 
clan cases or your deposition teensy:my? 
24 
No, sir. 
25 
MM. MXIMEASSUBIt 
All right. 
Matta all 1 
el2-7500 
MOM court &storied 04micr. :we. 
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" ..."....""
Milit=ana'rwla 
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41,10C4..C,AP/C COM 
041) 0,2.1104 
3504-022 
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have. 
MA. COITION: I have One last question. 
ROCROSSM(MMNAT101 
Page 217 
RI MR. PleSTMO: 
I want to just cIser up one thing, Mr. Almst. 
6 
CO to page 9. 
7 
A. 
rage 9, loots like the one that is Import:mt. 
That's right. Ne've belabored this one to 
9 
death. 
10 
Mt. WILL170: 
I think the Ink has sum off the 
Ii 
page by now. 
12 
by MR. COMMON: 
33 
Q. 
W. txhabit 2. This is the ototentat that 
II  
you gave to the State Attorrsy's Office on Ikkember 21st 
15 
Of •05. 
16 
Mr. Bargee asked you questions about the young 
17 
girl. MO. Ezell just eked yaw sone maestlons about 
)0 
that. 
19 
So what 1 wont to do is Clarify. so that 1 
20 
an*. what -- to trusties no confusion, at least In the 
PI 
record. 
22 
On page t. lane 16, It says: 'During the last 
23 
year when you were working with hitt, Mu do you mean 
21 
they looked young? Did they look like they were still 
25 
In high '<hoot?' 
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INC. 
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Sitnem excused.) 
cephaltion was cmel.d. I.
6 
10 
11 
12 
1) 
14 
If 
10 
17 
IS 
19 
20 
21 
22 
2) 
24 
25 
ha0e 211 
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Nom 218 
And your answer was: *I remster one girl wee 
• 
young. We never asked how Old she was. It we. not Ry 
I 
yobs' 
4 
Old 1 reed that question and anSwOr Correctly? 
A. 
Tnet's correct. 
0. 
If I understood your toetinOny In response to 
• 
Mr. Berger, the girt 
that you were OSSOtrIng to, because 
• 
there's • ***** lenge to high school, •••aM,
O 
Yeah, that's: cermet. 
10 
11 
Me. 
didn't leak to re like a IO year 
12 
old. 
I) 
S. wmcirs: 
All right. Thank you. That's 
le 
ell I have. 
IS 
O. SMUTS: 
YOU have the right 10 end and 
16 
sign this deposition If it ta typed up. In not 
17 
going to be ordering it: but if mmebody types it 
IS 
up you have the right to read and ohm it or you 
19 
can :sloe that right. It's up to you entirely. it 
20 
you want tO waive the right to road it, tell the 
21 
Mort reporter you want to waive the right. 
22 
TIM WIIMESS: Can you repeat that 0011n? 
23 
M. CAITMO: Why don't we go Oft the record. 
24 
(Discussion held eft the record.i 
25 
IRK WITNOSA: I waves that right. 
1 don't 
(501) 412.1100 
PROS COMM RKPOW INC MtaCY. INC. 
••••••••• "min. ••••••••evenagatat...........• ce..• 
11411 a)3-155t 
3504-022 
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