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Page 427 
1 
glass of wine by the pool, stay inside. 
2 
BY MR.a: 
3 
Q. Did he ever talk to any of the girls? 
4 
A. I don't know, sir. 
5 
Q. Certainly he knew that they were there? 
6 
MR. CRrTTON: Form. 
7 
THE WITNESS: I don't know, sir. 
8 
BY MR.a: 
9 
Q. Do you know hoe 
knows Mr. 
10 Epstein? 
11 
A. No, sir. 
12 
Q. Or how long she's known him? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: She was on board two years 
15 
or itiaa 
half before I came on board. 
16 BY MR. 
17 
Q. Okay. 
18 
A. So it's probably 2003 or 2. 
19 
Q. All right. You mentioned this Citrix 
20 system. 
21 
A. Yes. 
22 
Q. Is that a system that was used to operate 
23 the phones and the computers? 
24 
A. The computers mainly. 
25 
Q. All right. But you then also described 
Page 429 
1 usually it's Yahoo dot corn or at Bellsouth dot 
2 net. 
3 
A. It was very uncommon. I don't remember, 
4 
sir. 
5 
Q. Did everybody in the -- I think you 
6 
called it the organization, did everybody have 
7 
e-mails? 
8 
A. Yes. 
9 
Q. Okay. Would that includeM? 
10 
A. Yes. 
11 
Q. All right. And did Mr. Epstein have an 
12 e-mail? 
13 
A. Yes. 
14 
Q. Did you ever correspond with Mr. Epstein 
15 
by e-mail? 
16 
A. Y 
17 
Ma: 
You can go ahead. 
18 
THE WITNESS: That's the only one that I 
19 
remember. 
20 
THE VIDEOGRAPHER: Okay, we're off the 
21 
record. 
22 
(Thereupon, a recess was had.) 
23 
THE VIDEOGRAPHER: We're back on the 
24 
pe number four. 
25 
BY MR. 
Page 428 
1 some system where someone would call on the 
2 
telephone and that would be automatically 
3 
downloaded to the computer? 
4 
A. Yeah, you can retrieve who called in a 
5 
transcript written who called, what's the message, 
6 
the time so you have it on a piece of paper, you 
7 
can print it out. 
8 
Q. Is it your understanding that is also 
9 
part of the Citrix system? 
10 
A. Yes. 
11 
Q. All right. Did you have an e-mail? 
12 
A. Right now, yes. 
13 
Q. No, when you were working at --
14 
A. Yes, I did. 
15 
Q. -- Mr. 
16 
And did 
have an e-mail? 
17 
A. Yes. 
18 
Q. And did all of the e-mails end the same 
19 
way such as Epstein's house dot corn or something? 
20 
A. Yes. 
21 
Q. Okay. What was 
e-mail? 
22 
A. I don't remember. 
23 
Q. What was your e-mail? 
24 
A. Staff house -- I don't remember, sir. 
25 
Q. Do you recall how It ended? I mean 
Page 430 
1 
Q. Mr. Rodriguez, what was Mr. Epstein's 
2 
e-mail? 
3 
A. Jeep project at something -- Jeep 
4 
project -- I can't remember it right now. 
5 
Q. Okay. In the course of this next 10 or 
6 
15 minutes --
7 
A. I can recall. 
8 
Q. -- if it comes to you just tell me. So 
9 it was Jeep project --
10 
A. Like Jeep, the brand name Jeep, Jeep 
11 project at -- I can't remember. 
12 
Q. Okay. Was that his only e-mail to your 
13 
knowledge? 
14 
A. No. 
15 
Q. He had other e-mail addresses? 
16 
A. Yes. 
17 
Q. Do you know what any of his other e-mail 
18 
addresses were? 
19 
A. No, I don't remember. 
20 
Q. Do you know who the carriers were for the 
21 other e-mail addresses owned by Jeffrey Epstein? 
22 
A. No, sir. 
23 
Q. Whether it was Yahoo or hot mail or --
24 
A. No, none of those. 
25 
Q. Okay. Was this Jeep project e-mail run 
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Page 431 
1 through the Citrix system? 
2 
A. Yes. 
3 
Q. Okay. And was there a certain company 
4 
that came out and fixed the actual Citrix system? 
5 
A. Yes. 
6 
Q. And who was that? 
7 
A. We used to have our own in-house 
8 
technician from Ohio. 
9 
Q. The same guy you were telling us about 
10 before? 
11 
A. Yes. 
12 
Q. All right. He would fix the video 
13 equipment or the --
14 
A. Computers mainly. 
15 
Q. And if the Citrix system broke down too 
16 then he would be in charge of it? 
17 
A. He was the only one dealing with this, we 
18 couldn't hire anybody else. 
19 
Q. Do you know why that is? 
20 
A. No. It was too many lines into the house 
21 from many properties. 
22 
Q. And do you know who that person is, 
23 remember his name now? 
24 
A. I don't remember, sir. 
25 
Q. I understood you to say at some point In 
Page 433 
1 at the house did any of these girls, these local 
2 
Palm Beach girls come over to the house as well? 
3 
A. They were earlier, sometimes they will 
4 
leave and he will stay for dinner. 
S 
Q. All right. Andy 
member there was 
6 
one time where maybe stayed for dinner with 
7 
David Copperfield? 
8 
A. That's correct. 
9 
Q. Was there ever a time where.. and 
10 David Copperfield were in a bedroom together? 
11 
A. I don't think Mr. Copperfield went 
12 upstairs. 
13 
Q. When the police came to the driveway with 
14 
in the car, what did you to lUlae police, if 
15 anything, that you were payingM. for? 
16 
A. They asked me whose this people, and I 
17 
said they're a masseuse. 
18 
Q. Okay. Why would you tell them that 
19 they're a masseuse, that's the name you were 
20 
supposed to call them? 
21 
MR. CRITTON: Form. 
22 
SS: Yes. 
23 BY MRIMI: 
24 
Q. And for these massages you were paying 
25 
between 300 and 500 dollars each time? 
Page 432 
1 time that you saw photographs of some of the girls 
2 
that were at the house to give massages on 
3 
Ms. Maxwell's computer. 
4 
A. Yes. 
5 
Q. And --
6 
MII,TTN: Form to the last question. 
7 
BY MR. 
8 
Q. And do you know which of the girls? 
9 
A. No, sir. 
10 
Q. Was.. one of them? 
11 
MR. CRITTON: Form. 
12 
THE WITNESS: I cannot guarantee that, I 
13 
cannot say hundred percent, sir. 
14 
BY MR. 
15 
Q. Was A. one of them? 
16 
A. Could be, sir. 
17 
Q. How about..? 
18 
A. It's the same thing, I cannot say a 
19 hundred percent, sir. 
20 
Q. I think that you used the phrase there 
21 were so many girls. 
22 
A. Yes, sir. 
23 
Q. That you're not sure which ones you saw? 
24 
A. No, sir, so many names. 
25 
Q. Okay. While David Copperfield was ever 
Page 434 
1 
A. Yes, sir. 
2 
Q. And that's usually for an hour up in the 
3 
bedroom with Mr. Epstein? 
4 
A. More or less, yes. 
5 
Q. You never told your 15-year old daughter 
6 at the time that she could come over to Mr. 
7 
Epstein's for $500 an hour? 
8 
A. No, sir. 
9 
N: Form. 
10 BY MR 
11 
Q. Why is it that you never asked your 
12 daughter to come over if it's just a massage? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: My daughters are too clean 
15 
for OS 
•
16 BY MR. 
17 
Q. Too clean to give a massage? 
18 
MR. CRITTON: Form. 
19 
THE WITNESS: They are good students, 
20 
they are in another type of environment, 
21 
sir, we are poor but you know, they're good 
22 
st 
23 
BY MR.
24 
Q. It's because you knew there was more than 
25 a massage going on in the bedroom? 
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1 
MR. CRITTON: Form. 
2 
THE WITNESS: Yes, sir. 
3 
BY MR. 
4 
Q. tivW•e some of Mr. Epstein's companies, 
5 if you know the names? 
6 
A. Well, he was the Price -- Price Corn, it 
7 
was one of his companies, he had a phone company 
8 
in Palm Beach. A lot of offshore companies that 
9 I don't recall, sir. 
10 
Q. When you say Price Corn --
11 
A. Price dot Corn, he owned that for awhile. 
12 And the local phone company in Palm Beach was his 
13 
but then he sold it again. But there is too many. 
14 
Q. As house manager you're obviously at his 
15 house every single day, did you inquire as to what 
16 he did in terms of making money? 
17 
A. No, sir, I only got through the Internet 
18 
because I put his name on Google and then I find 
19 out the rest of his companies. 
20 
Q. So during the day when he would go to the 
21 cabana I think that you described last time that 
22 he would work there? 
23 
A. He would work there. 
24 
Q. Do you know what he would do in terms of 
25 
working? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 437 
telephone numbers of various girls that were 
referred to as masseuses, did that also give you 
access to the girls that were coming over to Mr. 
Epstein's house in Paris and New York and New 
Mexico? 
MR. CRITTON: Form. 
THE WITNESS: We used to have a book in 
every car, in every plane, in every boat 
that Mr. Epstein with all the names of all 
these people so it was not necessarily a 
BY IsalM: 
Q. When we're talking all these people, are 
we talking about --
A. Masseuses and, you know, chefs, the 
important people in the life of Mr. Epstein, you 
know, used to have a black book with all the 
names. 
Q. So there were many black books? 
A. Yes. 
Q. And do you know where those black books 
are now? 
A. There were tons of those in the house 
but, you know, I don't know. 
Q. Okay. And did each one of them have 
Page 436 
1 
A. No, that was very private. I would put 
2 
his coffee t 
ould shut the door. 
3 
Q. And 
had a work station or 
4 
work computer within the house? 
5 
A. Yes. 
6 
Q. What did she do in terms of work? 
7 
A. She will set appointments for comedy 
8 
shops, movies. I will get the tickets but, you 
9 
know, she was appointments for the masseuse, or 
10 travel arrangements with the pilots, that type of 
11 thing. 
12 
Q. And would she keep track of all of the 
13 girls who were coming to his house in Palm Beach 
14 or at the other houses as well? 
15 
MR. CRITTON: Form. 
16 
THE WITNESS: All of the houses. 
17 
BY MR. 
18 
Q. All right. So if he was going to be in 
19 Paris and he wanted girls over in that house she 
20 would keep track of that as well? 
21 
MR. CRITTON: Form. 
22 
23 
SS: Exactly. 
BY MR.
:
seeing-
computer and seeing the names and 
nd when you talked about 
Page 438 
1 handwritten names and numbers or were these 
2 
computer printouts so they were the same? 
3 
A. They were very organized. Once in awhile 
4 
they used to be updated, so we used to have these 
5 books with obsolete dates, you know, so we discard 
6 
them and have the new ones. 
7 
Q. By obsolete dates are you saying that 
8 there were girls that came over and then they no 
9 longer came over anymore? 
10 
A. That's correct. 
11 
N: Form. 
12 BY 
13 
Q. Okay. So if a girl that was coming over 
14 for a period of time got too old and was no longer 
15 able to come over and somebody else took her place 
16 then her page would disappear from that book? 
17 
MR. CRITTON: Form. 
18 
SS: I believe so, sir. 
19 BY 
20 
Q. You were asked about other homes that you 
21 worked at for other wealthy people and asked If 
22 these other homes had a massage table. 
23 
A. Yes. 
24 
Q. And you said that they did? 
25 
A. Yes. 
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1 
Q. And you said that that was -- the massage 
2 
table was similar in kind to that used by Mr. 
3 Epstein? 
4 
A. That's correct. 
5 
Q. And others had massage oils and that was 
6 
similar in kind to Mr. Epstein's as well? 
7 
A. Yes. 
8 
Q. And you didn't think that the massage 
9 table at a home was unusual? 
10 
A. No. 
11 
Q. All right. Did any of the other houses 
12 where you worked have masseuses that were 14, 15, 
13 and 16 years old? 
14 
MR. CRITTON: Form. 
15
WITN SS: No, sir. 
16 BY MR.
17 
Q. And did any of the other homes where you 
18 worked have different girls of that age coming 
19 every single day? 
20 
A. Yes. 
21 
MR. 
N: Form. 
22 BY MR. 
23 
Q. They had different girls? 
24 
A. Yes. 
25 
Q. Okay. And how old were the girls that 
Page 441 
1 
MR. E. 
I don't have anything else. 
2 
MS. 
. I ave a few. 
3 
EXAMINATION 
4 
BY MS. 
5 
Q. Mr. Rodriguez, I may have missed 
6 
something. Did you say that there weren't any 
7 
wild parties ever at El Brillo Way? 
8 
A. I never saw what was going on inside the 
9 
house, Ma'am. 
10 
Q. So you don't know wether there were or 
11 were not? 
12 
A. No, ma'am. 
13 
Q. There wasn't just one massage table 
14 there; was there? 
15 
A. We used to have two and we have an extra 
16 
reserve, I think there were three in the house. 
17 
Excuse me, I'll take that back. All the bedrooms 
18 used to have one. 
19 
Q. Okay. Thank 
u. Did you ever hear 
20 about a girl named 
.? 
21 
A. No, no, ma'am. 
22 
Q. And those pictures on Ms. Maxwell's 
23 computer, did you ever see one of a girl naked in 
24 
a hammock? 
25 
MR. CRITTON: Form. Asked and answered. 
Page 440 
1 would come to these other homes? 
2 
A. They seem older. 
3 
Q. Older than the ones that would come to 
4 
Mr. Epstein's home? 
5 
A. Yes. 
6 
Q. And did you ever work at a place where 
7 
there would be girls calling up on the phone to 
8 
say I have girls to bring him and --
9 
A. No, sir. 
10 
Q. -- coming over in teams --
11 
A. No. 
12 
Q. -- or pairs? 
13 
A. No. 
14 
Q. So there were a lot of things about Mr. 
15 Epstein's house and his arrangement that were very 
16 unusual compared to the other places where you 
17 
worked? 
18 
MR. CRITTON: Form. 
19 
liaSS: 
Yes. 
20 
BY MR. 
21 
Q. And there were no drugs and alcohol or no 
22 
wild parties at Mr. Epstein's house, that is 
23 
somewhat different from some of the other places 
24 
where you worked? 
25 
A. Yes. 
Page 442 
1 
THE WITNESS: I saw on a book not on a 
2 
co 
3 
BY MS.iii 
4 
Q. You saw a picture of a girl naked in a 
5 
book or on a book? 
6 
A. The book was done for 
and she was 
7 
on the hammodc, that's the only one 
8 
Q. I'm sorry, the book was done for
? 
9 
A. She was on the cover. 
10 
Q. Then there were other people inside the 
11 book? 
12 
A. Yes, ma'am. 
13 
Q. And in that book there was a picture of a 
14 girl naked in a hammock? 
15 
A. Yes. 
16 
Q. Where did 
keep that book? 
17 
A. There were a few of those examples but I 
18 don't know where she kept It. 
19 
Q. Was it laying around the house somewhere? 
20 
A. Yes. 
21 
Q. Downstairs? 
22 
A. Dowailas, yes, ma'am. 
23 
Q. Did 
keep scrapbooks or photograph 
24 
books --
25 
A. Yes. 
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Page 443 
1 
Q. -- of friends, girls? 
1 
2 
A. Yes, ma'am. 
2 
3 
MR. CRITTON: Form. 
3 
4 
BY MS. 
•
4 
5 
Q. 
you remember there being a young man 
5 
6 
who would bring girls to the house named Tony 
6 
7 
Figueroa? 
7 
8 
A. No, ma'am. The only person that I saw 
8 
9 
that night 
was at the house, she was driving 
9 
10 the car, but I didn't see any males. 
10 
11 
MR. CRITTON: You said he, he being whom? 11 
12 
BY MS. 
12 
13 
Q. I 
ir t quite understand that either. 
13 
14 Tony Figueroa was driving. 
14 
15 
A. She was with this girl that nightM I 
15 
16 
think that's the only time I saw a male at the 
16 
17 
house, ma'am. 
17 
18 
Q. And you're talking about the night when 
18 
19 
you came and found the old car in the driveway? 
19 
20 
A. Exactly, yes, with the police, yes. 
20 
21 
Q. How did you remember that it was Tony 
21 
22 
Figueroa? 
22 
23 
A. It's the only person, mate that I 
23 
24 
remember. 
24 
25 
Q. But you don't know his name? 
25 
Page 445 
ag
 
me, I guess. 
was to help 
in 
was like ip she was between 
A. Puties. 
Q. And is that what your understanding was 
so.ry; 
as to what 
did? 
A. I'm 
Q. Was it our understanding that- 
was 
there to hel 
with erduties? 
. 
A. No 
was. 
Q. 
was. Okay. 
Have you spoken to any lawyers or 
investigators about this case since you were 
deposed last? 
A. No, ma'am. 
Q. I believe Mr. Critton was asking ou 
i
questions relating to the incident when 
was 
in a car in the driveway and you went an got the 
police and he was speaking of that time as being 
in January of '05. Do you remember when it was? 
A. I will put that in that month, ma'am, but 
I cannot guarantee. 
Q. Let me just show you something that we 
can mark as the next exhibit. 
I would just ask that if — yes, the name 
is in here that we redact it to show just the 
Page 444 
1 
A. No, no, no, Ma'am. 
2 
Q. Got you. Thank you. 
3 
MR. CRITTON: Can I ask one quick? 
4 
There was a man with M., you don't know 
5 
who it was? 
6 
THE WITNESS: That's the only male that's 
7 
been to the house, so when she asked me the 
8 
question I assume, you know. 
9 
MR. CRITTON: Do you know who Tony 
10 
Figueroa is? 
11 
THE WITNESS: No, sir. 
12 
MR. CRITTON: Okay. Now I think I 
13 
unders n . Thank you. Sorry, Cathy. 
14 
MS. 
That's okay. 
15 
BY MS. 
16 
Q. I asked you earlier if the chefs name 
17 
could have been 
and I was wrong, I 
18 
wanted to ask you a diff 
19 
Could it have 
beei 
20 
A. I don't remembe 
21 
Q. Do you remember an assistant of some sort 
22 
who worked there for awhile when you were there 
23 named 
24 
A. Yes. 
25 
Q. What did she do? 
Page 446 
1 initials. 
2 
MR. 
We're going to attach this; 
3 
right? 
4 
MS. 
Yes. 
5 
MR. CRITTON: You're going to let us have 
6 
this one? 
7 
MS. IM 
Yes. With initials. 
8 
(Exhibit No. 9 was marked for 
9 
Identification.) 
10 BY MS. 
11 
Q. Have you ever seen this report? 
12 
A. I saw It typed, not handwritten like 
13 this. 
14 
Q. Did the police bring you one that was 
15 typed? 
16 
A. No, the only time I saw my own report was 
17 on the intemet because my daughter told me do you 
18 know that you're in Palm RParh and this and that, 
19 so I was in New York on vacation and that's why I 
20 read it but this is the first time I'm looking at 
21 this. 
22 
Q. Oka 
23 
MR. 
Do you have extra copies? 
24 
MS. 
I do, I don't want to give 
25 
them out, I'd rather -- I don't mind them 
Kress Court Reporting, Inc. 
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1 
attaching it to the deposition as long as it 
2 
has just the initials. 
3 
THE WITNESS: This is the report when I 
4 
called to the police to the house? 
5 
BY MS. 
6 
Q. Let me let you look at it, I'd rather you 
7 
tell us if it is. 
8 
A. This is why I was fired. This is the 
9 
reason I was let go. 
10 
MR. CRITTON: There is no question right 
11 
now. I'm sure there will be. 
12 
MR. 
I'll ask it if you want. 
13 
THE WITNESS: I'm thinking out loud. 
14 
BY MS. IM 
15 
Q. Did you notice the date on this report? 
16 
A. November 28th, yes, ma'am. 
17 
Q. And do you have any reason to believe 
18 that that's not accurate? 
19 
A. No, that's it, yeah. 
20 
Q. And as you look at other information on 
21 the report do you see anything else that's not 
22 
accurate? 
23 
A. Let me finish reading this, please. 
24 
Q. Sure. 
25 
MR. CRITTON: Let me just object to the 
Page 449 
1 
Q. Can you tell me what you mean by that? 
2 
A. Mr. Epstein used to give a lot of gifts 
3 
to the police department, so we used to have 
4 
certain leeway in terms of speeding or some other 
5 
things. So he used to put a baseball cap Palm 
6 
Beach Police Department on the dashboard. 
7 
So when he saw I called the police for my 
8 
own safety because I was carrying cash, I 
9 
explained that to him, and he say why you called 
10 the police, and I said because I saw a clunker in 
11 the driveway and it's dark. In Palm Beach there 
12 
is no nights. So I called for my own safety. I 
13 
was coming from Publix buying my groceries and I 
14 
had cash in my pocket. And I said I called the 
15 
police because I was concerned about my own 
16 safety. 
17 
And I recognized the girl and I figured 
18 
because I remember 
told me earlier that day 
19 -- it was a hectic day,i.st 
left Palm Beach 
20 and I was catching up with my breath, you know, I 
21 went to buy my groceries, and I explained that 
22 
So he was upset that this will spill, you know, to 
23 
the public or the street. But I didn't realize 
24 
this was written or something, you know. 
25 
Q. You were not fired though until sometime 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 448 
form. Can I look at your copy, please? 
THE WITNESS: This Is the first time I 
saw.
BY MS. 
Q. Have you had a chance now to read it? 
A. Yes, ma'am. 
Q. Okay. Does this report accurately 
describe what occurred that evening? 
A. Yes, ma'am. 
MR. CRITTON: Form. 
BY MS. a 
Did you overhear the conversation between 
M. and the policeman? 
A. Yes, ma'am. 
Q. And is that part accurate as well? 
A. Yes. 
O. And then 
r conversation with Mr. --
A. Yes, ma'am. 
Q. -- is that accurately reported here as 
well? 
A. Yes, ma'am. 
Q. Now you stated that this is why you got 
fired. 
A. Yes, ma'am. 
- 13162=1=19.1SIC
. 
Page 450 
1 in March? 
2 
A. Exactly, yes. But he gave me -- Mr. 
3 
Epstein used the word I'm going to give you -- he 
4 
make fun of my Spanish and he said (speaking in 
5 
Spanish). 
6 
And I said, yes, Mr. Epstein. Okay, I'll 
7 
give you one more chance. And I said what's going 
8 
on. But, you know, it meant a few words, I 
9 
couldn't talk to him too much, but this was it. 
10 
Because, you know, I have to say this for 
11 myself, you know, I never did something illegal, I 
12 
was working hard to please him and sometimes more 
13 than I was supposed to, many hours beyond my 
14 
duties, and so -- but he was concerned about this. 
15 
And I say, Mr. Epstein, you told me 
16 safety is the paramount of this house, In this 
17 case it was me, but obviously he didn't care about 
18 me, it was his safety. 
19 
MR. CRITTON: Form. Move to strike. 
20 
BY MS. 
21 
Q. Can you translate for me what you said a 
22 moment ago In -- I don't know --
23 
A. In Spanish he said "conose" amnesty, but 
24 he used the word "conose amnistia", I'll give you 
25 
amnesty so you have a chance to continue working 
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Page 451 
1 with me. 
2 
But I didn't ask him why. He just came 
3 
fast. You're always in the run, you have to be on 
4 
your toes, and the next thing he said I took the 
5 
wrong Suburban and they let me go. 
6 
But I never find out what happened 
7 
because I have to say this. Being so many people 
8 in the house I didn't know if 1 displease one of 
9 the girls, or something I said or I did, I don't 
10 think so. So they let me go very mysteriously. 
11 But this is it. 
12 
Q. I understood you to say that Mr. Epstein 
13 gave lots of gifts to the police department. 
14 
A. Yes, ma'am. 
15 
Q. And you said something about a baseball 
16 cap. 
17 
A. Well, the police department used to give 
18 us in retribution dozens of baseball caps with the 
19 Palm Beach Police Department, you put one of those 
20 on the dashboard you don't get a ticket. 
21 
Q. Oh. 
22 
A. Stuff like that. Key rings and so on and 
23 so forth. There is -- everybody knows this, I 
24 don't think it's a secret. Mr. Epstein give 
25 $85,000 simulator for the police to shoot, you 
1 
2 
3 
4 
5 
6 
7 
B 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 453 
her do you believe under the influence of drugs? 
A. No. 
Q. Did you ever see steroids in the house? 
A. No. 
MR. 
• Thank you. 
: Do you have anything, 
MR. 
• Yes. 
MR. 
: Okay, shoot. 
BY 
MR.S1AMINATION 
Q. Mr. Critton asked you several questions 
about the females who you were told to refer to as 
masseuses. And when he asked you those questions 
he referred to them often as women. 
Did you think of those masseuses as 
women? 
MR. CRITTON: Form. 
BY 
MR.i:ESS: Yes. 
Q. Why? 
A. Because I saw them, they were females. 
Q. What is your definition of a woman? 
A. Person of the opposite sex, I'm a male. 
Q. Is a three-year old a woman? 
Page 452 
I. 
know, and it was returned after the scandal broke 
1 
2 
out. 
2 
3 
MR. CRITTON: Move as nonresponsive to 
3 
4 
any q 1/2:
in. 
Move to strike. 
4 
S 
MS. M: 
I don't have any other 
5 
6 
questions. 
6 
7 
EXAMINATION 
7 
8 
BY MR. 
8 
9 
Q. Mr. Rodriguez, do you know where the main 
9 
10 server, the main computer server was located 
10 
11 inside the house? 
11 
12 
A. In the garage. 
12 
13 
Q. Do you know the names of any of the 
13 
14 
programs -.ler 
programs --
14 
15 
MR. 
: I am missing something. 
15 
16
Whose uestionin 
MR. 
16 
17 
17 
18 
BY MR. 
18 
19 
Q. Do you know the names of some of the main 19 
20 computer programs that are used as part of your 
20 
21 routine as the house manager of the house? 
21 
22 
A. The main computers? 
22 
23 
Q. Programs. 
23 
24 
A. Besides 
24
Cilt 
25 
Q. Regarding 
did you ever see 
I 
25 
Page 454 
A. Yes. 
Q. O 
MRk.liM: 
I don't have any other 
questiga 
MR. MEI: 
I do but only just to 
follow-up with this police report that we've 
just been provided which I'm not sure if it 
has a designation. 
MR. ou
ill
alL Exhibit 9. 
MR. 
Okay. 
EXAMINATION 
BY MR. 
Q. You were asked by Macritton about.. 
who we were referring to as M. in this 
deposition, and her date of birth is 
And Mr. Clifton was indicating to you earlier that 
at the time that you had this dealing with her in 
the driveway that she was 18 years old. It 
appears that this occurred November 28, 2004, 
which would indicate that she i 
years old. 
I think the question that w g asked of 
you Is, are you surprised by that, so I'll ask you 
the same question? 
A. No, sir. 
Q. All right. This report that you have 
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1 indicated is accurate or accurately reflects the 
2 
events of that night, I want to make sure that Mr. 
3 
ahears and that we go through it and you 
4 
can e borate on any part of it. Okay. 
5 
On Sunday, 11/28/2004, at approximately 
6 19:00 hours, so we're talking about 7:00 at night, 
7 
the property manager of 358 El Brillo Way, Alfredo 
8 
Rodriguez, came to the station to complain there 
9 
was a strange vehicle parked in the driveway. 
10 
A. Yes. 
11 
Q. That's true? 
12 
A. Yes. 
13 
Q. When Officer 
and I, this is 
14 
Officer 
talking, arrived at 358 El Brillo, 
15 
we local .hite female later Identified as 
16 
, date of birth 12/30/86 waiting in the 
17 geway. 
18 
A. That's correct. 
19 
Q. Okay. 
20 
MR. CRITTON: Form. Are you asking him 
21 
whether the statement is correct or that 
22 
you're readin it correctly? 
23 
BY MR. 
24 
Q. No, the statement is correct. 
25 
A. Yes. 
Page 457 
1 
Did you get that impression thaaas 
2 
very nervous in her car when the police showed up? 
3 
A. Yes. 
4 
Q. Was that an indication to you that she 
5 
realized that there were police there and that 
6 
there was some form of illegal activity that she 
7 
was involved in at Jeffrey Epstein's house? 
8 
MR. CRITTON: Form. 
9 
THE WITNESS: Yes. 
10 
BY M 
11 
Q. 
p ne rang, she answered it 
12 
quickly, said, in quotes, "I can't talk, I can't 
13 
talk, I'm at school, I got to go." 
14 
Did you hear that part of it? 
15 
A. Yeah. 
16 
Q. Okay. That's obviously a lie. Right? 
17 
MR. CRITTON: Form. 
18 
BY MR. 
19 
Q. Sg•whg she's at school when really 
20 
she's right in front of Jeffrey Epstein's house? 
21 
A. Yes. 
22 
Q. And again, another indication that she's 
23 
doing something she shouldn't be doing. Right? 
24 
MR. CRITTON: Form. 
25 
MS. I= 
Object to the form. 
Page 456 
1 
Q. That's what you understood me to ask you? 
1 
2 
A. Yes. 
2 
3 
Q. Okay. Rodriguez arrived at that time and 
3 
4 
stated he did rememberMas there to pick up -- 
4 
5 
was coming there to pickup an envelope the 
5 
6 
homeowner, Jeffrey Epstein, left for her. 
6 
7 
And that's correct as well. Right? 
7 
8 
A. Yes. 
8 
9 
MR. CRITTON: Form. 
9 
10 
BY MR. 
10 
11 
Q. This document right here, is it 
11 
12 refreshing your recollection as to that night? 
12 
13 
A. Yes. 
13 
14 
MR. CRITTON: Form. 
14 
15 
BY MR. 
15 
16 
Q. Rodriguez quickly entered the house then 
16 
17 
returned with a sealed envelope with. first 
17 
18 name on it. 
18 
19 
A. Yes. 
19 
20 
Q. Do you remember who wrote her first name 
20 
21 on that envelope? 
21 
22 
A. I did. 
22 
23 
Q. Okay. The envelope appeared to have 
23 
24 
money in it, in my opinion. 
was very nervous 
24 
25 
with us standing there. 
25 
BY MR. 
Q. II she was a masseuse and was at 
someone's house in relation to pick up money from 
a massage she had given, that's not the typical 
answer that you would expect. Right? 
MR. CRITTON: Form. 
THE WITNESS: That's right. 
BY MR. 
Q. Okay. It didn't shock you or surprise 
you as Mr. Critton asked you earlier that she 
would make up a tale or a lie about her 
whereabouts considering what she was doing. 
Right? 
A. No. 
MR. CRITTON: Form. 
BY MR. 
Q. Then hung up, talking about ft.. 
I 
asked her who it was on the phone, she stated it 
was her mom. I asked her how she 
the 
in th 
Mall, s e met 
Epstein throug a ema e nen at work, Epstein 
allows them to come over any time and use the 
house and pool. Then she quickly left. 
Did you hear that conversation? 
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1 
A. Yes, they were next to me. 
2 
Q. Okay. Is that the entire substance of 
3 
that conversation between Ms. Nand the police 
4 
officer? 
5 
A. Yes. 
6 
Q. She didn't mention that she comes over to 
7 
his house and goes into a bedroom with Mr. 
8 
Epstein. Right? 
9 
MR. CRITTON: Form. 
10 
THE WITNESS: No. 
11 BY MR. 
12 
Q. An 
In't tell the police officer 
13 that she is a masseuse; did she? 
14 
A. No. 
15 
Q. And that didn't surprise you either; did 
16 it? 
17 
A. No. 
18 
MR. CRITTON: Form. 
19 
BY MR. 
20 
Q. I then as
 Rodriguez what was in the 
21 envelope, Rodriguez was hesitant but -- what is 
22 that word? 
23 
A. But then. 
24 
Q. But then I said it was drugs and he 
25 
quickly said it was money. Is that accurate? 
Page 461 
1 
Q. I asked what kind of job Serforms, 
2 
Rodriguez smiled and says she is a massage 
3 
therapist. 
4 
A. Yeah. 
5 
Q. Why did you tell him that? 
6 
MR. CRITTON: Form. 
7 
THE WITNESS: Because I understood she 
8 
came to ive massage. 
9 
BY MR. 
10 
Q. 
e,t a s what somebody had told you? 
11 
A. Yes. 
12 
Q. At this point in time though you knew 
13 
that more was going on than a massage? 
14 
MR. CRITTON: Form. 
15 
BY MR. IIIIIII 
16 
Q. Right? 
17 
MR. CRITTON: Form. 
18 
THE WITNESS: That's right. 
19 BY 
20 
Q. I asked -- this is the police officer 
21 talking, I asked which musde she rubbed. 
22 
Do you remember the police officer asking 
23 
that? 
24 
A. Yes. 
25 
Q. And you knew what he was implying. 
Page 460 
1 
A. That's correct. 
1 
2 
Q. When he first asked you what was in the 
2 
3 
envelope were you nervous? 
4 
A. No, because I was trying to -- I didn't 
' 4 
5 
want to disclose these private things with the 
5 
6 
police so that's why I was concerned about that. 
6 
7 
Q. When you're talking about private things, 
7 
8 
the fact that there are young girls coming over? 
8 
9 
MR. CRITTON: Form. 
9 
10 
THE WITNESS: It was late, you know, 
10 
11 
exact 
11 
12 
BY MR. 
12 
13 
Q. I'll let you answer. What are the 
13 
14 
private things that you were nervous to tell the 
14 
15 
police? 
15 
16 
A. This was inside the compound, the 
16 
17 
property itself, so you have to keep 
17 
18 
confidentiality, and the police was there, that's 
18 
19 
why. Not that I was doing something wrong but I 
19 
20 
was trying to keep them -- 
20 
21 
Q. I'm not suggesting that you were doing 
21 
22 something wrong. 
22 
23 
A. Exactly. So he asked me is there any 
23 
24 
drugs there, and I said, no, it's just money. 
24 
25 That's all I said. 
25 
3
Page 462 
Right? 
MR. CRITTON: Form. 
THE WITNESS: Yeah. 
BY MR. 
Q. That it was obvious to him that she was 
over there to sexually please Mr. Epstein. Right? 
MR. CRITTON: Form. 
SS: That's correct. 
BY MR. 
Q. And that's coming from a police officer 
who's not the house manager. Right? 
MR. CRITTON: Form. 
SS: That's right. 
BY MR. 
Q. You knew right away what he was asking 
and you say, Rodriguez laughed said, in quotes, 
"off the record, he, Epstein, has many young girls 
come over for that," end quote. 
Do you remember telling him that? 
MR. CRITTON: Form. 
TiaSS: 
Yes. 
BY MR. 
Q. And when you were saying come over for 
that, it was --
A. Massage or something. 
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1 
Q. -- to sexually please Mr. Epstein. 
2 
Right? 
3 
MR. CRITTON: Form. 
4 
THE WITNESS: Yes. 
S 
BY MR. 
6 
Q. I mean, that's what you were telling the 
7 
police officer. 
8 
MR. CRITTON: Form. 
9 
THE WITNESS: Yes. 
10 BY MR. 
11 
Q. ir
illre's always a different girl at 
12 the pool or inside with him when he's here. 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Yes. 
15 
MiaiYou 
left out a word, young. 
16 
BY MR. 
17 
Q. Sorry, I'll read the last sentence again. 
18 
There's always a different young girl at 
19 the pool or inside with him when he's here. 
20 
Do you remember telling the police 
21 officer that? 
22 
A. Yes. 
23 
MitITTN: Form. 
24 
BY MR. 
25 
Q. And that's true. Right? 
Page 465 
1 
And as to -- it was read to you by Mr. 
2 
and he then asked you a number of 
3 
questions whether you remembered something. 
4 
Correct? 
5 
A. Yes. 
6 
Q. Okay. lust so I'm dear, he's asking you 
7 
to speculate on what may or may not have occurred 
8 
upstairs in the bedroom. I want to be very clear. 
9 
Mr. Rodriguez, were you ever up in the 
10 bedroom to observe whatever went on between a 
11 masseuse and Mr. Epstein or anyone else for that 
12 matter at an time? 
13 
MR. 
: Form. 
14 
THE WITNESS: No, sir. 
15 BY MR. CRITTON: 
16 
Q. And so when Mr. 
asked you, you 
17 
were aware that sexual activity or may have been 
18 
sexual activity occurring upstairs, you have no 
19 
personal knowledge, you're just speculating; 
20 aren't you, Jr? 
21 
MR. 
: Form. 
22 
MR. 
Object to the form. 
23 
THE WITNESS: I never saw them. 
24 
BY MR. 
25 
Q. And therefore you can only speculate --
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 464 
A. Yes. 
Q. When he's at the house there is always a 
young girl inside with him. 
MR CRITTON: Form. 
BY MR. 
Q. Right? 
A. That's right. 
Q. Okay. And whether the company line is to 
call them a masseuse, you knew that these girls 
were young and were up in the bedroom with Mr. 
Epstein to sexually please Mr. Epstein. 
MR. CRITTON: Form. 
THE 
That's right. 
MR. 
: I don't have anything else. 
We've already attached this; right? Here Is 
the on 
n be attached. 
MR. 
: Who is next? 
MR. CRITTON: Me. 
RECROSS EXAMINATION 
BY MR. CRITTON: 
Q. Mr. Rodriguez, looking at Exhibit 9 which 
is the police report that was prepared on November 
28, 2004, this is the first time you've seen it. 
Correct? 
A. That's correct. 
Page 466 
1 
MR. 
: Object to the form. 
2 
MR. CRITTON: I need to ask the question 
3 
first. 
4 
MR. 
: It was the earlier 
5 
question. 
6 
BY MR. CRITTON: 
7 
Q. All right. If you did not see what was 
8 
going on you can have no personal knowledge. 
9 True? 
10 
MR. 
: Object to the form. 
11 
MR. 
Object to the form. 
12 
THE WITNESS: Yes. 
13 
BY MR. CRITTON: 
14 
Q. And, therefore, what you're doing is 
15 
speculating or guessing what may have been 
16 occurring. Ti 
17 
MR. 
18 
MR. 
19 
MR. 
: Form. 
20 
THE WITNESS: I use my age together. 
21 BY MR. CRITTON: 
22 
Q. I'm not saying that you don't, but 
23 without having personal knowledge you're best 
24 
guessing what may have occurred up there between 
25 Mr. Epstein and one of the massage women, or for 
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1 
2 
3 
4 
S 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
that matter anyone else who was upstairs? 
A. Yes. 
MR. 
MR. 
MR. 
Form. 
Form. 
Object to the form. 
MR. CRITTON: Thank you. 
MS. 
I just have a couple of 
questions. 
EXAMINATION 
BY MS. 
Q. Meng up on that, you did however see 
this same young woman asleep naked in the sauna? 
A. Yes, ma'am. 
Q. And you did along with 
find and 
-- and you did also find sex toys an massagers of 
various kinds and creams scattered around on 
several occasions after these young women had been 17 
upstairs with Mr. Epstein? 
18 
MR. CRITTON: Object to form, asked and 
19 
answered about six times. 
20 
THE WITNESS: Yes. 
21 
MS. 
No other questions. 
22 
MR. 
Sorry, last one. It has 
23 
nothing to do with this report. 
24 
EXAMINATION 
25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
A. Yes. 
MR. 
MR. 
MR. 
Nothing else. 
Is it my turn? 
Yes. 
EXAMINATION 
BY MR. 
Q. Mr. Rodriguez, you mentioned the last 
time about a lady who was an obvious professional 
masseuse by the name caDo 
you remember 
that? 
A. Yes, I do remember. 
Q. Did you ever pay her? 
A. Yes, sir. 
Q. Okay. How much did you pay her? 
A. It was between 200 and 500, sir, but 
somewheriMbetween those two amounts. 
Q. Fo 
A. Yes sir. 
MR. 
Okay. I don't have any 
other questions. 
MR. CRITTON: You have a right to read 
this deposition when the other part is typed 
and make any changes that you want. Would 
you like to do that? It's your right a 
hundred percent. The court reporter can 
Page 468 
1 
BY MR. 
2 
Q. During Mr. Critton's questioning he asked 
3 
you about whether or not we had ever shown you a 
4 
previous taped statement that you had given to a 
5 
police officer, and we did not do that; did we? 
6 
A. No. 
7 
Q. We can represent to you that we don't 
8 
have it to show it to you otherwise we would like 
9 
to do that. 
10 
However, he asked you did you tell the 
11 police officers at that time that the girls 
12 
appeared to be 18 years or older, and I believe 
13 
that you said when you gave the statement to the 
14 police that you did; right, say that? 
15 
A. Yes. 
16 
Q. And I wrote, I put it in quotes, you said 
17 that because you were fearful of reprise from 
18 
Ms. Maxwell and Mr. Epstein. 
19 
A. That's correct. 
20 
MR. CRITTON: Form. 
21 BY MR. 
22 
Q. Okay. Is everything that you've said 
23 
today and told us today, Is it true? 
24 
A. Yes. 
25 
Q. To the best of your knowledge? 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 470 
provide you or whoever set your 
deposition --
THE WITNESS: I tried to be truthful. 
MR. CRITTON: All you have to do is tell 
her you would like to waive. Do you waive 
the 
ignIng? 
MR. 
You can either read or you 
can waive reading? 
THE WITNESS: I don't understand what I 
have to do. 
MR. CRITTON: Why don't we go off the 
record jjAasyspn explain it to hlm. 
MR. 
We can go off the record. 
THE VIDEOGRAPHER: Off the record. 
(Thereupon, a discussion was held off the 
record.) 
THE WITNESS: Waive. 
(Thereupon, the deposition was concluded 
at 5:30 p.m.) 
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1 THE STATE OF FLORIDA, 
) 
2 
COUNTY OF DADE. 
3 
4 
S 
I, the undersigned authority, certify 
6 
that ALFREDO RODRIGUEZ personally appeared before 
7 
me on the 7th day of August, 2009 and was duly 
B 
sworn. 
9 
10 
WITNESS my hand and official seal this 
11 18th day of August, 2009. 
12 
13 
14 
15 
MICHELLE PAYNE, Court Reporter 
16 
Notary Public - State of Florida 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 472 
1 
CERTIFICATE 
2 
The Sato Of Ronda. 
) 
3 County O1 Dade. 
4 
5 
I, MICHELLE PAYNE, Cent Reinter and 
Mabry Public h and for the State of Morn at 
6 woe, do hereby ants that' was autharnd to 
and del stencgrenkaPirepst the donsition of 
7 
ALFREDO ROC/MGM; Int a Ines Oahe banana% 
rays rpt requested; air that the k..,.4., Penh, 
0 metered from 270 to 472, has h% we a true 
an crowd transcrinco of my stinopephk notes 
9 at tad dentram. 
10 
Inter certify that sad denotes was 
taken at the time and Mime herenabost sat forth 
11 and that the InAng cf said &dads, was 
commenced and cOrriCiebol as hereinatove set out. 
12 
I niter wiry that I sin not an 
13 Werra a manna any of the PIMPS, nor am 
Ian:lathe or ennoree of am Monty or 
14 cared of Piety conned with the Winn, nor all 
I Mend* interested h the mint 
15 
flat keep® onnicadon of the 
16 
transcript don not awy to any inifinsma‘m 
be erne by any means unless uner the direct 
17 
control andIce dIrectbn of the cativna 
10 
DATED this leth day of Asst. 2009. 
19 
20 
21 
MIOIELLE PAYNE, Cast Reporter 
22 
23
24 
25 
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