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Ms. Maxwell as not being as good? 
2 
A. 
Yes. 
3 
Q. 
When -- you were -- you had an opportunity 
4 
over lunch, Mr. Berger gave you a copy of a statement 
5 
that you gave to the State Attorney's Office on 
6 
November 21, 2005, we've marked as Exhibit, I think, 
7 
Exhibit --
8 
MR. CRITTON: What did we mark it as, 2? 
9 
THE WITNESS: At what page? 
10 
MR. WILLITS: Yes. It was 2. 
11 
MR. CRITTON: Thank you. 
12 
BY MR. CRITTON: 
13 
Q. 
No, just statement, the whole statement. 
14 
You had an opportunity to look at it over 
15 
lunch? 
16 
A. 
Yes. 
17 
Q. 
And that's a statement you gave back on 
18 
November 21st of 2005? 
19 
A. 
Uh-huh. 
20 
Q. 
Is that correct? 
21 
A. 
That's correct. 
22 
Q. 
And at that time you were there with 
23 
Mr Murrell, who was your attorney. And you gave a 
24 
statement and I think as well your wife spoke with the 
25 
State Attorney's Office? 
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A. 
That's correct. 
2 
Q. 
And whatever questions the State Attorney 
3 
asked of you at that time, I assume you fully answered; 
4 
is that correct? 
5 
A. 
Absolutely. 
6 
Q. 
And then page 9 where Mr. Berger took you with 
7 
regard to the questions -- and before I get -- I'm going 
8 
to come back to page 9 in a minute. 
9 
But if I understood your earlier testimony in 
10 
response to one of the lawyers who asked you questions, 
11 
is, there were a number of European women, all who you 
12 
deemed to be 20-plus years old, that would travel with 
13 
Mr. Epstein to various places and as well would come to 
14 
the house from time to time? 
15 
A. 
That's correct. 
16 
Q. 
And I think you testified in response to 
17 
Mr. Berger's questions today, is that the only female 
18 
that you understood that came to the house during the 
19 
time that you were the house manager who you knew to be 
20 
under the age of 18 was III 7
21 
A. 
That's correct. 
22 
Q. 
And you knew she was under 18 because you 
23 
would pick her up from high school? 
24 
A. 
That's correct. 
25 
Q. 
And that's a young girl who I think you 
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said --
2 
A. 
16, 17. 
3 
Q. 
And I think you said she never was involved in 
4 
giving any massages to Mr. Epstein? 
5 
A. 
I don't think so, never. 
6 
Q. 
And the times that you saw her, Mr. Epstein 
7 
was mentoring her on a career which ultimately turned 
8 
into her becoming an actress? 
9 
A. 
I think so. Yeah, that was the main purpose. 
10 
Q. 
And on multiple occasions when she would be 
11 
over, she would be over there at Mr. Epstein's home with 
12 
her mother; is that correct? 
13 
A. 
Yes, that's correct. 
14 
Q. 
And of the girls that came or the women that 
15 
came to give massages to Mr. Epstein over the years you 
16 
were there, I think you've described on page 9 of your 
17 
deposition that you may have seen a hundred or 200 
18 
different massage therapists? 
19 
A. 
It could be less. I don't think it's more 
20 
than 200, but it could be less than 200, yes. It was 
21 
it was 11 years or 12 years or 13 years of constant 
22 
people going in and out and people that were coming to 
23 
the house, he will bring for another state, he will 
24 
bring in his planes. People that it came from Europe, 
25 
massage therapists, there were men and woman. They live 
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in Miami, we -- so it was so many that I cannot remember 
2 
how many. 
3 
Q. 
Okay. And I understand that. I'm just 
4 
referring back to your statement where it says at page 
5 
9, line 9, the question was: "Yeah. Yeah. Not the 
6 
same girl. I mean, during 11 years I probably saw a 
7 
hundred, 200 different massage therapists." 
8 
Do you see that? 
9 
A. 
Yes. 
10 
Q. 
All right. And if I understood your testimony 
11 
is, the ones the -- that is, of the massage therapists, 
12 
as you've just described, you saw some men? 
13 
A. 
Yes. 
14 
Q. 
You saw more women? 
15 
A. 
More woman. 
16 
Q. 
And all of the women, at least from your 
17 
viewpoint, were 18, 19 or older? 
18 
A. 
Yes. 
19 
MR. CRITTON: Why don't you change your tape 
20 
right now. 
21 
VIDEOGRAPHER: Off the record at 2:54. 
22 
(Brief recess.) 
23 
VIDEOGRAPHER: We're back on the record at 
24 
2:55. 
25 
BY MR. CRITTON: 
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Q. 
Mr. Alessi, in the 11 years that you worked 
2 
for Mr. Epstein, with regard to the massage 
3 
therapists -- and I'm talking about all of them, women, 
4 
men, the ones that were 18, 19, 20, or the ones that 
5 
were older -- did you ever see -- or, first of all, did 
6 
you ever hear any complaints about -- from the massage 
7 
therapists about the massage they had given to 
8 
Mr. Epstein? 
9 
A. 
No. 
10 
Q. 
Did you ever see a massage therapist during 
11 
those 11 years that appeared to you to be distraught? 
12 
A. 
Never. 
13 
Q. 
To be in some form of a shock? 
14 
A. 
Never. 
15 
Q. 
To be scared? 
16 
A. 
I never see anybody scared. 
17 
Q. 
Did you ever see someone who looked like they 
18 
were upset or crying? 
19 
A. 
No, sir. 
20 
Q. 
I think you, in response to Mr. -- well, not 
21 
sure who asked the question -- but they -- you were 
22 
asked whether you ever spoke to the individuals --
23 
A. 
Yes. 
24 
Q. 
-- when they came down. And I think you said 
25 
from time to time you might have some small talk with 
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them afterward? 
2 
A. 
Yeah. 
3 
Q. 
Did you usually see them if they came down? 
4 
A. 
Yeah. 
5 
Q. 
So you would have had an opportunity to 
6 
observe their appearance, correct? 
7 
A. 
That's correct. 
8 
Q. 
Have you seen people who look distraught, in 
9 
shock, scared, upset, angry in the past 
not massage 
10 
therapists -- have you seen people in your life 
11 
experiences? 
12 
A. 
Oh, yeah, yes. 
13 
MR. MERMELSTEIN: Object to the form. 
14 
15 
16 
17 
18 
19 
20 
21 
A. 
Yes. 
22 
MR. MERMELSTEIN: Object to form. 
23 
BY MR. CRITTON: 
24 
Q. 
Have you seen people who appeared to you to 
25 
have been traumatized by a particular event? 
BY MR. CRITTON: 
Q. 
So if -- well, let me ask it this way: In 
your life experiences before you worked for Mr. Epstein, 
and, in fact, during the time you worked for 
Mr. Epstein, have you seen individuals not associated 
with Mr. Epstein who appeared to be distraught, in 
shock, scared, upset, angry or injured? 
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MR. MERMELSTEIN: Object to form. 
2 
THE WITNESS: Yes. 
3 
BY MR. CRITTON: 
4 
Q. 
Have you seen people who seem to be 
well, I 
5 
assume you've seen people who have yelled or screamed as 
6 
a result of some event that had occurred in your 
7 
presence? 
8 
A. 
Yes. 
9 
Q. 
On the massage therapists that you saw at 
10 
Mr. Epstein's house from 1992 up until the time you left 
11 
in December of '02, did you ever see any type of 
12 
reaction, distraught, shock, scared, upset, crying, 
13 
disheveled, injured, disoriented, yelling or screaming 
14 
for help at any time? 
15 
A. 
No, sir. 
16 
Q. 
Once the massage -- once -- let me strike 
17 
that. 
18 
If I understood your testimony, you helped set 
19 
up -- either you set up the room or you helped set up 
20 
the massage room? 
21 
A. 
Uh-huh. 
22 
Q. 
And you might be the person or it might be 
23 
someone else who would lead the massage therapists or 
24 
the female up to the room, the male or the female up to 
25 
the room? 
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1 
A. 
Yes, sir. 
2 
Q. 
Once that person was upstairs, you then would 
3 
come back down and resume your multiple duties 
4 
downstairs? 
5 
A. 
Absolutely. 
6 
Q. 
As to what occurred during the course of a 
7 
massage, do you have any personal knowledge during the 
8 
11 years you were there? 
9 
A. 
There was absolutely no way to know or to get 
10 
into the room. The windows were what they have, those 
11 
automatic electric shutters. They were completely dark, 
12 
completely a hundred percent dark, the rooms. And it 
13 
was -- nobody saw it. I knew it when I was at the house 
14 
that I never saw anything was going on inside. 
15 
Q. 
So you have no personal knowledge what 
16 
occurred during any particular massage? 
17 
A. 
Nothing. 
18 
Q. 
And I think you said -- well, let me strike 
19 
that. 
20 
In other individuals whom you have done work 
21 
for at big houses in Palm Beach, did those people from 
22 
time to time have massages, too? 
23 
A. 
I never work in a house inside as I did work 
24 
for Mr. Epstein. 
25 
Q. 
Yours was outside maintenance work? 
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A. 
I was the maintenance guy outside. 
2 
Q. 
All right. And if -- well, let me strike 
3 
that. 
4 
You're aware that there's all sorts of spas. 
5 
The Breakers? PGA? Trump? 
6 
A. 
Absolutely. 
7 
Q. 
The Ritz Carlton? The Four Seasons? And 
8 
probably a thousand other places in Palm Beach County? 
9 
MR. WILLITS: Object to the form of the 
10 
question. 
11 
BY MR. CRITTON: 
12 
Q. 
Well, let me strike that. 
13 
Are you aware that there's more than ten 
14 
places that someone can get a massage in Palm Beach 
15 
County? 
16 
A. 
Of course. 
17 
Q. 
Are you aware that there's probably more than 
18 
a hundred places, maybe a thousand places in Palm Beach 
19 
County from Boca Raton up through Jupiter and all the 
20 
way out west where people can get a therapeutic or a 
21 
massage? 
22 
A. 
Yes. 
23 
Q. 
And I assume you were aware that -- or were 
24 
you aware of that during the time period that you worked 
25 
for. Mr. Epstein? 
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A. 
Yes. 
2 
Q. 
And I think you told us that you were aware 
3 
that there were massage schools? 
4 
A. 
Yes. 
5 
Q. 
And is it your understanding that generally 
6 
massages are given in a -- in a room with a table where 
7 
the lights are generally turned down? 
8 
A. 
And music on, yeah. 
9 
Q. 
All right. You were asked a question about 
10 
vibrators or I think that the word was sex toys. 
11 
If you'll turn to page 20 of your statement, 
12 
sir. 
13 
If you look at page -- if you just glance at 
14 
line 9 --
15 
A. 
Okay. 
16 
Q. 
through line 22. Take a chance. If you'll 
17 
just look at that, then I'll ask you a couple questions. 
18 
Read to yourself, please. Otherwise, the 
19 
court reporter will have to take down everything you 
20 
say. 
21 
A. 
Yeah. 
22 
Q. 
And at least the statement that you gave back 
23 
in -- on November 21st of 2005, almost 
almost four 
24 
years ago now, you describe that there were -- that you 
25 
saw two types of massagers or vibrators; is that 
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correct? 
2 
A. 
That's correct. 
3 
Q. 
And is that your best recollection, as you sit 
4 
here today? 
5 
A. 
That's the best recollection. 
6 
Q. 
And one of the vibrators, you said was, as you 
7 
described earlier, looked like a dildo? 
8 
A. 
Right. 
9 
Q. 
And --
10 
MR. WILLITS: Object to the form of the 
11 
question. 
12 
BY MR. CRITTON: 
13 
Q. 
Well, let me ask you this: Was the item that 
14 
you described, that's described at lines 12, 13 and 14, 
15 
and 15 -- 12, 13 and 14 on page 20, is that what you 
16 
described, is that what you were talking about as the 
17 
dildo? 
18 
A. 
Yes. 
19 
Q. 
And I assume you're familiar with what a dildo 
20 
is? 
21 
A. 
I know that it's one of those --
22 
Q. 
You don't have to describe it. Just are you 
23 
familiar with what one is? 
24 
A. 
No, I don't. I'm not really familiar with 
25 
that type of instruments. But what did I saw it and is 
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it true now, is it true when I make this statement, it 
2 
was a big rubber man's 
3 
Q. 
Penis? 
4 
A. 
-- looking penis, with double head, two heads. 
5 
Q. 
And --
6 
A. 
And I don't know how is it even called. And I 
7 
am sorry. It's a little unpleasant. 
8 
Q. 
That's all right. 
9 
The second item that you described was a neck 
10 
and back vibrator; is that correct? 
11 
A. 
Yeah. They have this vibrators, they have the 
12 
cordless and they have these balls and they have 
13 
different types of those vibrators, too. 
14 
Q. 
Like you can get them at Brookstone or 
15 
something like that? 
16 
A. 
Yeah. Yeah. Yes, sir. 
17 
Q. 
So at least when you were at Mr. Epstein's, 
18 
and I think as you described in response to lawyer's 
19 
questions today, is during the last couple of months 
20 
that you worked at Mr. Epstein's you saw these two 
21 
vibrators? 
22 
A. 
Yes. 
23 
Q. 
And on those two occasions you'd take those 
24 
vibrators, if you went up to clean afterwards, you'd put 
25 
on your gloves, pick them up with a towel and you'd 
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clean them off and you'd put them back in 
2 
Mrs. Maxwell's --
3 
A. 
Closet. 
4 
Q. 
-- closet in her bathroom? 
5 
MR. WILLITS: Object to the form of the 
6 
question. 
7 
THE WITNESS: I put it back in the closet and 
8 
inside the closet there was a laundry basket that 
9 
is where she had those. 
10 
BY MR. CRITTON: 
11 
Q. 
And as to whether or not someone actually used 
12 
those items or how they were used, all you know is you 
13 
found them --
14 
A. 
I find it in the sink. 
15 
MR. BERGER: Objection. Mr. Critton is 
16 
testifying. Leading. 
17 
MR. WILLITS: Objection, also, to the form. 
18 
BY MR. CRITTON: 
19 
Q. 
Let me ask you this: Do you know, if I 
20 
understand it correctly, you found the two vibrators, 
21 
one for the neck and back and the other one that you 
22 
described as a dildo, you found them in the sink on 
23 
those few occasions near the end of your employment? 
24 
A. 
Yes. 
25 
MR. BERGER: Objection. Testifying. Leading. 
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THE WITNESS: I find it in the sink. 
2 
BY MR. CRITTON: 
3 
Q. 
And then you would clean up and put it back in 
4 
Ms. --
5 
A. 
I will put my rubber gloves, get a towel, put 
6 
them under the sink, run the water and put them in the 
7 
closet. 
8 
Q. 
And you put them back in Ms. Maxwell's closet? 
9 
A. 
Closet. 
10 
Q. 
Why? Why into her closet? 
11 
A. 
Because they were always kept there. 
12 
Q. 
All right. You testified earlier, is that if 
13 
you were going to call someone for a massage, it would 
14 
either be you or Ms. Maxwell, if I understood you 
15 
correctly? 
16 
A. 
Yeah. 
17 
Q. 
Okay. 
18 
A. 
At the end -- at the end of my stay was also 
19 
another girl, Sarah, Sarah that came. And then she was 
20 
handling everything, as far as calls to these girls. 
21 
Q. 
Did Mr. Epstein ever make these calls? 
22 
A. 
I never heard. 
23 
Q. 
If Mr. Epstein was not in residence, that is, 
24 
if he was in New York or some place else other than Palm 
25 
Beach, did you and your wife still stay at the home or 
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would you go to one of your apartment? 
2 
A. 
No. We went to our apartment. 
3 
Q. 
And then when he wasn't there, would you have 
4 
pretty more regular hours around the house? 
5 
A. 
Pretty much. Pretty much, yeah. That was the 
6 
days that we had to have the cleaning crew, I still had 
7 
to go to the house and oversee the cleaning operation, 
8 
oversee the gardener because there was not, when they 
9 
were there the gardener weren't supposed to make noise, 
10 
so we have to take care 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 much 9:00 to 5:00? 
14 
A. 
Yes. That was much easier. 
15 
Q. 
And when he was -- how often would he 
16 
generally be in Palm Beach? 
17 
A. 
Too much. 
18 
Q. 
All right. But if -- would he be here at 
19 
least a couple --
20 
A. 
I would says, at least three times a year -- a 
21 
month, three weeks a month, three weekends a month. 
22 
Usually they come in on a Thursday. Either they left a 
23 
Monday or Tuesday. 
24 
Q. 
And then they go wherever else they were going 
25 
and then things would get back to more of a 9:00 to 5:00 
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type routine? 
2 
A. 
That's right. 
3 
Q. 
And if he was in residence, that's when your 
4 
job became much more all encompassing? 
5 
A. 
Exhausting. 
6 
Q. 
Okay. You were asked about a female named 
7 
III. I think you originally thought it was III., but 
8 
M.? 
9 
A. 
Yeah. 
10 
Q. 
You recall now; is that correct? 
11 
A. 
Yes. Yes. 
12 
Q. 
And I think you described her, I think your 
13 
recollection was, is that you remember her being at the 
14 
house the last few months that you worked for 
15 
Mr. Epstein? 
16 
A. 
Yeah. The last few months. 
17 
Q. 
And that's the only time that you remember her 
18 
actually being there? 
19 
A. 
Yeah. 
20 
Q. 
Because you actually recall when she used to 
21 
work at Mar-a-lago, and then you recall her starting to 
22 
come to --
23 
A. 
To the house. 
24 
Q. 
-- Mr. Epstein's home? 
25 
A. 
Right. 
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Q. 
And I think you testified that at one time you 
2 
had to pick her up and she lived at her house or she was 
3 
living with her boyfriend at some house out in Royal 
4 
Palm Beach; is that correct? 
5 
A. 
That's right. 
6 
Q. 
Did you know anything about 
.? 
7 
A. 
Not necessarily. Not that I can remember. I 
8 
knew the one time either Ms. Maxwell or Mr. Epstein told 
9 
me that she was arrested because she was working in --
10 
in the restaurant and she took her -- the tips, her tips 
11 
for that day. And the next day she was arrested and the 
12 
money have to be returned and -- it was something about 
13 
that, but that's it. That's all I know. 
14 
Q. 
Okay. Was it -- let me ask you this: Do you 
15 
remember her stealing some money from the Roadhouse 
16 
Restaurant where she was working? 
17 
A. 
That's what I heard, that it was a report, 
18 
there was a police report. 
19 
Q. 
All right. And, so, at least you understood 
20 
from Mr. Epstein or Ms. Maxwell that she had stolen 
21 
money from her employment? 
22 
A. 
Yeah. 
23 
Q. 
Again, you never saw the police report? 
24 
A. 
No. 
25 
Q. 
Nor the date of it? 
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A. 
No. 
2 
Q. 
That's correct? 
3 
A. 
That's correct. 
4 
Q. 
And as to whether she repaid the money or what 
5 
happened with that criminal charge, do you know? 
6 
A. 
No, I don't. 
7 
Q. 
Do you know whether there's an arrest out for 
8 
her -- a warrant out for her arrest at the current time? 
9 
A. 
No, sir. 
10 
Q. 
Were you aware of any of her other background; 
11 
that is, before she ever met Mr. Epstein, were you aware 
12 
that she, back in, say, 1997, that she was involved in a 
13 
sexual battery between with her and three girls and 
14 
three boys that were engaged in sexual or lewd acts and 
15 
they were found by some individuals in, as was 
16 
described, compromising positions with the males on top 
17 
of the females, including her, and she was intoxicated? 
18 
Did she ever talk about that with you? 
19 
A. 
No. 
20 
MR. BERGER: Objection. Compound question. 
21 
And Counsel is testifying. 
22 
MR. WILLITS: Object to the form. 
23 
MS. EZELL: Join. 
24 
BY MR. CRITTON: 
25 
Q. 
Were you aware that she had, prior to the time 
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she ever met Mr. Epstein, that she had -- her mother 
2 
described her as having significant drug problems? 
3 
MR. BERGER: Objection. Counsel is 
4 
testifying. 
5 
THE WITNESS: No. 
6 
BY MR. CRITTON: 
7 
Q. 
Mrs. Ezell used -- she referred to a 
8 
MS. EZELL: Santiago. 
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THE WITNESS: Santiago. 
10 
BY MR. CRITTON: 
11 
Q. 
Have you ever heard of a 
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MS. EZELL: Thank you. You're right. 
13 
THE WITNESS: I know that his name was 
14 
but I don't know if it was Santiago or 
15 
don't remember the last name. I never spoke to 
16 
him, except ask him to move his car one time. 
17 
BY MR. CRITTON: 
18 
Q. 
And did Mr. -- got it wrong -- did 
19 
Mr. 
bring III. to the Epstein house on more 
20 
than one occasion? 
21 
A. 
Yes. 
22 
Q. 
And did you consider her, at least from your 
23 
viewpoint, was she one of the individuals who came to 
24 
give massages? 
25 
A. 
She was supposed to be a massage therapist. 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
3afc3ca0c860-4b91-8d01-ba2Obcao87de 
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Q. 
And, so, Mr. -- at least Mr. 
2 
assuming, if I asked you to assume his name was 
3 
, was he aware that his live-in girlfriend was 
4 
coming to Mr. Epstein's house to give him a massage? 
5 
A. 
I don't know if he was aware of it. He was 
6 
waiting outside. 
7 
Q. 
All right. And you understood that she, that 
8 
is, III. and Mr. 
or 
, a 
lived together 
9 
out in Royal Palm Beach? 
10 
A. 
Yes. 
11 
Q. 
And as to what their relationship was and as 
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to what -- that is, their internal relationship was and 
13 
whether there was abuse, either physical or verbal, 
14 
associated with that, do you have any personal 
15 
knowledge? 
16 
A. 
Not except that that time that I went to pick 
17 
her up and she was crying and she told me the furniture, 
18 
the couch was slit with like a razor blade or a knife, 
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and also the screen porch at the entrance, it was cut. 
20 
And I ask, I said, what happened here? 
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She says, well, my boyfriend got mad and he 
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did it. 
23 
Q. 
And she indicate -- she, III., told you it was 
24 
her boyfriend that caused all that damage? 
25 
A. 
Yeah. 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Sandra Townsend (401 
Electronically signed by Sandra Townsend (401 
3afc3ca0-c860-4b91-8d01-ba2Obcaellido 
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