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housekeeping tasks on an everyday basis while you were 
2 
employed there? 
3 
A. 
No. 
4 
Before my wife went in? 
5 
Q. 
No. After your wife. 
6 
A. 
No. No. Not a full-time housekeeper. 
7 
Q. 
But you said your wife was hired after the 
6 
housekeeper left? 
9 
A. 
Yes. 
10 
Q. 
But -- so the person who left before your wife 
11 
came, was she doing housekeeping chores? 
12 
A. 
Yes, she was doing the housekeeping chores. 
13 
Q. 
Well, who did it then after your wife became 
14 
employed there, because she wasn't doing the 
15 
housekeeping? 
16 
A. 
I was. I was doing it and then we hire people 
17 
for to help us. 
18 
Q. 
So you were the main person doing the 
19 
housecleaning? 
20 
A. 
Yeah. 
21 
Q. 
And during -- between that time that your wife 
22 
started and when you left the employment, was there a 
23 
separate housekeeper employed during that time? 
24 
A. 
No. Full time? No. 
25 
Q. 
Full-time housekeeper? 
PROSE COURT REPORTING AGENCY, INC. 
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1 
A. 
No. 
2 
Q. 
What about a part-time housekeeper? 
3 
A. 
No. Like I told you, daily basis we call this 
4 
company. And then they will come in with four or five 
5 
girls and clean the whole house. 
6 
Q. 
This is the crew you were talking about? 
7 
A. 
The crew. 
8 
Q. 
But the crew didn't come when Mr. Epstein was 
9 
there? 
10 
A. 
Right. 
11 
Q. 
So on an everyday basis when Mr. Epstein was 
12 
there, you were the only person who was cleaning? 
13 
A. 
Me -- yeah, or my wife will help. 
14 
Q. 
At your instruction? 
15 
A. 
That's right. 
16 
Q. 
But you don't ever remember her cleaning up 
17 
after massages? 
18 
A. 
No. No. 
19 
Q. 
Is it possible that you instructed her to 
20 
clean up? 
21 
A. 
It's possible, but --
22 
MR. CRITTON: Form. Asking him to speculate. 
23 
BY MR. MERMELSTEIN: 
24 
Q. 
You can answer. 
25 
A. 
It's possible. 
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1 
Q. 
When girls would come to give a massage, where 
2 
would they come in the house? Would they come to the 
3 
front door? 
4 
A. 
Mostly came to the back kitchen door. 
5 
Q. 
The back kitchen door? 
6 
A. 
Uh-huh. 
7 
Q. 
Okay. And is there a bell there? Would they 
8 
knock or how would they --
9 
A. 
There's a door bell. 
10 
Q. 
A door bell? They would ring the door bell? 
11 
A. 
Uh-huh. 
12 
Q. 
And who generally would answer the door? 
13 
A. 
Me or my wife. 
14 
Q. 
So you would let them in? 
15 
A. 
Uh-huh. 
16 
MR. CRITTON: Stuart, can I just ask you? You 
17 
use the term, girls. I assume you just mean, that 
16 
means female woman. It can mean anything? It has 
19 
no age bracket to it? 
20 
MR. MERMELSTEIN: That's correct. I'm not 
21 
referring specifically to ages right now. 
22 
THE WITNESS: No. 
23 
BY MR. MERMELSTEIN: 
24 
Q. 
So as I understand it, the girl would come to 
25 
the kitchen entrance, which is the service entrance, 
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correct? 
2 
A. 
Uh-huh. 
3 
Q. 
You have to say yes or no. 
4 
A. 
Yes, sir. 
5 
Q. 
If you answer uh-huh, that's not clear, so you 
6 
have to answer yes or no. 
7 
A. 
Okay. 
8 
Q. 
And you would typically open the door? 
9 
A. 
Yes, sir. 
10 
Q. 
And what would happen then? 
11 
A. 
Then I will keep her in the kitchen and go to 
12 
Mr. Epstein and find out where they want to have the 
13 
massage, or if it was for him or for Ms. Maxwell. And I 
14 
immediately, if they were reReat gl.jj.s—that are -- they 
15 
will know exactly where to go. And I will go up with 
16 
them, set the tables, and they will wait for him or her 
17 
to go in the room and they sit there until they come up. 
18 
Q. 
So did you generally already know that they 
19 
were coming at the time that they knocked on the door? 
20 
A. 
Yes, uh-huh. 
21 
Q. 
So you had an appointment schedule? 
22 
A. 
Yeah. Because most of the times I was doing 
23 1/ 
the calling, you know. I called J., come in at 3:00 
24 
this afternoon. And she will told me, no, I cannot, get 
25 
somebody else. And I knew it the time they were coming. 
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So I was expecting them most of the time. 
2 
Q. 
So you would expect them, they would come in 
3 
and then you would escort them upstairs? 
4 
A. 
Uh-huh. 
5 
Q. 
So --
6 
A. 
I'm sorry, sir. 
7 
Q. 
Yes? 
8 
A. 
Yes. 
9 
Q. 
But first you would find Mr. Epstein and check 
10 
to see if he's ready or find Ms. Maxwell to check to see 
11 
if she's ready? 
12 
A. 
Yes. 
13 
Q. 
And which staircase would you -- would you 
14 
take them up? 
15 
A. 
Either way. 
16 
Q. 
You would take them either the main staircase 
17 
or the servant staircase? 
18 
A. 
Yes. 
19 
Q. 
Why would you take the main staircase, since 
20 
you're already in the kitchen? 
21 
A. 
That's what I says, either way. We can go 
22 
through the main staircase or we go to the kitchen 
23 
staircase. So we use both. 
24 
Q. 
Okay. Well, I'm talking specifically to 
25 
escort a girl upstairs. 
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1 
A. 
I escort the girls up there either way, both 
2 
ways. 
3 
Q. 
And, so, when you walked to the upstairs 
4 
bedroom, let's take the example of when Mr. Epstein is 
5 
getting a massage? 
6 
A. 
Yes. 
7 
Q. 
Mr. Epstein wouldn't be up there yet; is that 
8 
correct? 
9 
A. 
That's correct. 
10 
Q. 
He would be downstairs somewhere? 
11 
A. 
Uh-huh. 
12 
Q. 
Would there be a place 
13 
MR. CRITTON: Form. 
14 
BY MR. MERMELSTEIN: 
15 
Q. 
-- where he would normally be while, you know, 
16 
he's waiting for the massage to be set up and ready? 
17 
A. 
18 
Q. 
19 
A. 
20 
Q. 
21 
A. 
22 
Q. 
23 
stairs with the girl for the massage, what would you do 
24 
then? 
25 
A. 
Go back to my duties. 
Yes. 
Where is that? Where would he be? 
Either at his desk or the pool house. 
And those were on the first floor? 
Yes. 
And, so, when you arrived at the top of the 
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1 
Q. 
You would just leave? Would the massage table 
2 
already be set up? 
3 
A. 
He knew already that the girls -- the girl 
4 
went upstairs and it was up to him to come up. 
5 
Q. 
Did you have conversations with any of these 
6 
girls? 
7 
A. 
Sometimes. 
8 
Q. 
What kind of things would you talk about? 
9 
A. 
Regular things. Nothing that I can remember. 
10 
Nothing. Just... 
11 
Q. 
Did any of them ever tell you their ages? 
12 
A. 
No, sir. 
13 
Q. 
Did any of them ever assure you that they were 
14 
18? 
15 
MR. CRITTON: Form. 
16 
BY MR. MERMELSTEIN: 
17 
Q. 
Or over? 
18 
A. 
No, sir. 
19 
Q. 
No one ever mentioned anything about age? 
20 
A. 
No, sir. 
21 
Q. 
How did the girls appear to you? Did they 
22 
appear to be very young? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: Again, the same question you ask 
25 
me. Everybody ask me the same thing. They could 
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have been 16 or 20. Most of them were, I would 
2 
says, over 20. And some woman, it was over 60. 
3 
And one time she came to the door. The husband was 
4 
waiting outside. And Ms. Maxwell saw this woman, 
5 
that somebody recommend her. And Maxwell says to 
6 
me, John, you have to find an excuse. We don't 
7 
want her. 
8 
So I had to pay this woman and find an excuse 
9 
that they going to have to go. And she -- they 
10 
never had a massage with her. 
11 
But there was -- most of them were womans. 
12 
They were not girls. 
13 
BY MR. MERMELSTEIN: 
14 
Q. 
So the woman who was over 60 was sent away; 
15 
she was rejected, correct? 
16 
MR. CRITTON: Form. 
17 
THE WITNESS: It was -- I was told to send her 
18 
away. 
19 
BY MR. MERMELSTEIN: 
20 
Q. 
And it was your understanding when you were 
21 
told to send her away, it was because of her age, 
22 
correct? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: I don't know. I don't know. I 
25 
was told to send her away. 
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1 
BY MR. MERMELSTEIN: 
2 
Q. 
What was your understanding as to why they 
3 
were sending her away? 
4 
MR. CRITTON: Form. Asked and answered nine 
5 
times now. 
6 
MR. MERMELSTEIN: He hasn't -- he hasn't 
7 
answered my question yet. 
8 
MR. CRITTON: He has. 
9 
MR. MERMELSTEIN: Go ahead. 
10 
THE WITNESS: Why? 
11 
BY MR. MERMELSTEIN: 
12 
Q. 
Please answer the question. 
13 
A. 
Can you repeat the question? 
14 
Q. 
What was your understanding as to why they 
15 
sent her away? 
16 
MR. CRITTON: Form. 
17 
THE WITNESS: My understanding was either they 
18 
were busy or they didn't want her. 
19 
BY MR. MERMELSTEIN: 
20 
Q. 
What was your understanding as to why they 
21 
didn't want her? 
22 
MR. CRITTON: Form. Harassing. 
23 
THE WITNESS: I don't know. I didn't 
24 
didn't make too much of it. 
25 
BY MR. MERMELSTEIN: 
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1 
Q. 
But every other woman or female who came over 
2 
to give a massage was much, much younger, correct? 
3 
A. 
Yes. 
4 
Q. 
So this 60 year old woman was a significant 
5 
exception, correct? 
6 
MR. CRITTON: Form. Argumentative. 
7 
BY MR. MERMELSTEIN: 
8 
Q. 
You can answer. 
9 
A. 
I don't know how to answer that question. You 
10 
ask me to 
11 
Q. 
Let me ask you this. 
12 
MR. CRITTON: Why don't you let him answer the 
13 
question before you interrupt him. 
14 
BY MR. MERMELSTEIN: 
15 
Q. 
All right. Go ahead. Please answer. It 
16 
didn't look like you were --
17 
A. 
I don't know how to answer that question, you 
18 
asking me what is your opinion of that. 
19 
And I told you, my opinion of that, either 
20 
they saw the girl -- I don't think Mr. Epstein ever saw 
21 
the woman. But Ms. Maxwell saw the woman in the 
22 
kitchen. And she told me, John, pay her and send her 
23 
away. 
24 
Q. 
Okay. 
25 
A. 
That was it. 
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1 
Q. 
So Ms. Maxwell looked at the woman? 
2 
A. 
Right. 
3 
Q. 
Did she have a conversation with her? 
4 
A. 
No. 
S 
Q. 
She just looked at her and then said to you to 
6 
send her away, correct? 
7 
A. 
Yeah. Pay her and send her away. 
8 
Q. 
Do you recall seeing women who came to give 
9 
massages who were in their 50s? 
10 
A. 
Yes. 
11 
Q. 
There were women in the 50s? 
12 
A. 
Yes. 
13 
Q. 
How often did that happen? 
14 
A. 
Not too often, but it was -- it was woman that 
15 
they were in the 50s. I says, again, could have been 
16 
49, 45. I don't know. I don't know the ages, but it 
17 
older woman. 
18 
Q. 
How many middle-age women do you recall coming 
19 
over to give massages? 
20 
MR. CRITTON: Form. 
21 
THE WITNESS: I don't remember how many, but I 
22 
would says<161:71 
23 
D.D. was, I would says, in the 40s. And she 
24 
came very, very often. And I understand she was a 
25 
massage specialist and a yoga instructor, too, at 
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1 
the same time. 
2 
So that was one of -- and there was another 
3 
woman that she was supposed to be a teacher at the 
4 
school of massage therapy that I can't remember her 
5 
name. But that's it. I mean... 
6 
BY MR. MERMELSTEIN: 
7 
Q. 
So those two you remember who were older? 
8 
A. 
Two. And it was a couple guys that were older 
9 
that -- some guys that were older, too, guys. 
10 
Q. 
Did Mrit!!!'llYIYLIffflaasage...S__dS.TTLbY 
11 
men? 
12 
A.
l
.
13 
Q. 
And did Mr. Epstein ever have massages done by 
14 
these older women? 
15 
A. 
Yes. 
16 
Q. 
When you escorted the female in this case for 
17 
the massage to the upstairs bedroom 
correct? 
you 
18 
would then leave? 
19 
A. 
Yes. 
20 
Q. 
You would then walk back downstairs? 
21 
A. 
Yes. 
22 
Q. 
Correct? 
23 
And would you then -- would you -- you had 
24 
already told Mr. Epstein that she's there, correct? 
25 
A. 
That's correct. 
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1 
Q. 
And at some point later then Mr. Epstein would 
2 
come upstairs, correct? 
3 
A. 
That's correct. 
4 
Q. 
And where would you go? 
5 
A. 
To my duties, to the kitchen or to my office. 
6 
Q. 
And I think you testified earlier that the 
7 
doors of the bedroom would be closed during this 
8 
massage? 
9 
A. 
He would close the door. 
10 
Q. 
So Mr. Epstein, when he would arrive upstairs, 
11 
would close the door? 
12 
A. 
Yes, sir. 
13 
Q. 
And about how long would the massage last 
14 
generally? 
15 
A. 
Usually an hour. 
16 
Q. 
And what would happen at the end? 
17 
A. 
They would come down. Most of the repeat 
18 
girls, they would bring the towels themselves and dump 
19 
it by the kitchen by the laundry room we had there, in 
20 
order to help us. Other girls, they just left it up 
21 
there and they would come down. 
22 
Either Mr. Epstein will pay or I will pay 
23 
them. 
24 
Q. 
Did they --
25 
A. 
Or Ms. Maxwell will pay them. 
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1 
Q. 
Did Mr. Epstein walk down with the girls or 
2 
did he stay upstairs? 
3 
A. 
Sometimes, sometimes no. Sometimes he took a 
4 
nap or he took a shower. I don't know what they did in 
5 
the room. I don't know. I don't know. Sometimes he 
6 
went down right away. Sometimes he stay up there. 
7 
Q. 
So when they came down, they would go to the 
8 
kitchen; is that correct? 
9 
A. 
Yeah, most of it. 
10 
Q. 
And were you there waiting for them or did you 
11 
have --
12 
A. 
My office was right next to the kitchen, so 
13 
was there -- and the kitchen was the focal point of the 
14 
house basically. So they have to go to the kitchen 
15 
either to get pay or to go to their cars. 
16 
Q. 
Did you converse with any of the girls when 
17 
they came down after the massage? 
18 
A. 
Very little. Very little. 
19 
Q. 
Did you ever observe a girl who appeared 
20 
upset, surprised, shocked, anything of that nature when 
21 
they came down? 
22 
A. 
Never. Never. 
23 
Q. 
And sometimes you would pay them, correct? 
24 
A. 
That's correct. 
25 
Q. 
How much would you --
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1 
A. 
A hundred dollars 
assa-ge-r--
2 
Q. 
A hundred dollars a massage? Were there ever 
3 
any exceptions? 
4 
A. 
That's the -- I_never pay any more than a 
5 
hundred dollars per massage. 
6 
Q. 
Were there times when two girls came? 
7 
A. 
Two girls came at the same time? 
8 
Q. 
Correct. 
9 
A. 
Yeah. There were times when two girls come in 
10 
at the same time and one will go to one room, the other 
11 
will go to the other room. Or one -- I would set up two 
12 
tables in his room or I will ask him, where you want to 
13 
set the massages? He will told me, set in the blue room 
14 
and set them in my room. Or set them in Ghislaine's 
15 
room and the red room, depends on who people were there. 
16 
But there were times where two of the girls at the same 
17 
time, yes. 
18 
Q. 
Was there ever occasions where there was a 
19 
girl who waited downstairs while one 
while the other 
20 
girl went upstairs? 
21 
A. 
No. 
22 
Q. 
That never happened? 
23 
A. 
I cannot remember. 
24 
Q. 
Was there ever an occasion where you paid a 
25 
girl who waited and didn't actually give a massage? 
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1 
A. 
No. 
2 
Q. 
That never happened? 
3 
A. 
Never happened. 
4 
Q. 
You mentioned that Mr. Epstein put you in 
5 
contact with Mr. Murrell; is that correct? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: Not Mr. Epstein. 
8 
BY MR. MERMELSTEIN: 
9 
Q. 
Huh? 
10 
A. 
It wasn't Mr. Epstein. 
11 
Q. 
Mr. Epstein's investigator put you in contact 
12 
with Mr. Murrell? 
13 
A. 
That's correct. He gave me his name. 
14 
Q. 
And did you pay Mr. Murrell out of your own 
15 
pocket? 
16 
A. 
No, I didn't pay nothing. 
17 
Q. 
Who is -- what was your understanding as to 
18 
who was paying for Mr. Murrell? 
19 
A. 
I don't know. I don't know who was paying for 
20 
it. 
21 
Q. 
You never asked Mr. Murrell who was paying his 
22 
bill? 
23 
A. 
No, he never send me a bill. 
24 
Q. 
Did you think that Mr. Murrell was doing it 
25 
for free? 
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1 
A. 
I don't know. 
2 
Q. 
You don't know. As far as you know, 
3 
Mr. Murrell could have been providing you legal services 
4 
for free? 
5 
A. 
No, I don't think it was provided me for free. 
6 
I don't think he ever -- that question ever come out of 
7 
Mr. Murrell. I was in Mr. Murrell's office for about 
8 
ten minutes. 
9 
And he says, well, I meet you tomorrow 
10 
there -- and that's it -- in order to protect you so 
11 
they don't incriminate you in any way. We left it at 
12 
that. He never send me a bill. He never send me -- I 
13 
never talk to Mr. Murrell again, never saw him again. 
14 
Q. 
And you never had any kind of understanding 
15 
with him as to how --
16 
A. 
No. 
17 
Q. 
-- how his bill was going to be paid? 
18 
A. 
No. 
19 
Q. 
Did you sign any kind of what we call, a 
20 
retainer agreement, anything where you hired him? 
21 
A. 
No. 
22 
MR. CRITTON: Just so you know, you have an 
23 
attorney -- nobody's going to tell you this 
24 
apparently. 
25 
You have an attorney/client privilege. Any 
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conversation that you had with Mr. Murrell, you and 
2 
your wife, is completely protected, as long as you 
3 
want to assert that privilege. 
4 
You can either assert it or not assert it. 
5 
That's your right. But nobody's apparently going 
6 
to tell you that, at least Mr. Mermelstein is not 
7 
going to tell you that. 
8 
MR. MERMELSTEIN: Well, I was trying to 
9 
avoid --
10 
MR. CRITTON: Well, you're asking questions of 
11 
what he said. 
12 
MR. MERMELSTEIN: I'm not asking them what 
13 
they said. 
14 
MR. CRITTON: Same thing. 
15 
MR. MERMELSTEIN: I'm asking him how he got 
16 
paid. 
17 
MR. CRITTON: No, you were -- read back your 
18 
questions where you were. 
19 
Anyhow, that's a right you have, 
20 
So much for the law. 
21 
MR. MERMELSTEIN: I was not asking him what 
22 
was said during any conversation. I asked him if 
23 
he signed a retainer. That's a fair question. 
24 
BY MR. MERMELSTEIN: 
25 
Q. 
Do you remember a girl who came to give 
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massages there by the name of III 7 
Does that name 
2 
sound familiar at all? 
3 
A. 
No. 
4 
Q. 
Do you remember an II? 
5 
A. 
No. 
6 
Q. 
What about a 
Do you remember anyone by 
7 
the name of III.? 
8 
A. 
No. 
9 
Q. 
Was it frequent that girls would come just 
10 
once and not appear again? 
11 
A. 
Frequently. 
12 
Q. 
These girls that would come, would they come 
13 
with their own equipment or supplies? 
14 
A. 
No. Some girls, they come in with a table, 
15 
the new girls they comsjILmit-h—a—tA121!ladIT21.2Li_
16 
told them, no, you don't need the tabl 
he will 
17 
leave it in the kit 
se we have tables in every 
18 
room in the house. 
19 
Q. 
Some of the girls, the first time they came 
20 
they didn't have anything, right? 
21 
A. 
They come with that table, one of the tables 
22 
they hang it in the shoulders, portable tables. But we 
23 
didn't have portable tables in the room. They were all 
24 
custom-made tables. 
25 
Q. 
Did some girls come without -- for the first 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
ukka-ase-ow4m-bankame 
EFTA00181668

Page 120 
1 
time without any supplies at all, whether equipment or 
2 
lotions or anything of that nature? 
3 
A. 
Probably. 
4 
Q. 
Did you have a question in your mind as to 
5 
whether they were professional at this business? 
6 
A. 
No. 
7 
Q. 
At massaging? 
8 
A. 
No. 
9 
Q. 
Why not? 
10 
A. 
It was not my job. 
11 
MR. CRITTON: Form. 
12 
BY MR. MERMELSTEIN: 
13 
Q. 
You just didn't think about it? 
14 
MR. CRITTON: Form. 
15 
THE WITNESS: If I was told that a girl is 
16 
coming, my job was to open the door, let her in and 
17 
let Mr. Epstein decide where he wants his massage. 
18 
And that was the end of it. 
19 
BY MR. MERMELSTEIN: 
20 
Q. 
Are you aware that sexual conduct between an 
21 
adult male and an underage female is criminal; it's 
22 
against the law? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: Of course I do. 
25 
BY MR. MERMELSTEIN: 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
3atc3ca0c86e-4b9f-t3d01-ba2Obcael37de 
EFTA00181669