EFTA01247530.pdf
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Condensed Transcript
• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
Plaintiff,
vs. CASE No.
502008CA028051XXXXMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
• VOLUME I
October, 20. 2009
10:10 a.m.
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
• Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, Ft. 33410
www.esqulresoluttons.com
3501.172-001
CONFIDENTIAL Page I of 38
EFTA_00070807
EFTA01247530
•
•
•
3501.172-001
CONFIDENTIAL Page 2 of 38
EFTA_00070808
EFTA01247531
- Volume I October 20, 2009
1 3
IR na chicory cceer OF TIM FIFTRI26111 JOICTAL CIRCUIT 1 APPEARANCES'
111 AND FOR PAlM SIAM CCM', FLORIDA
• Plaintiff,
CIVIL DIVISION
CASK No.5132COSCAOTSCD/XXX/30 AS
2
3
4
On behalf of the Defoxlant:
ROBERT 0. CRITTON, JR.. ESQUIRE
BURIMN CRITTON LIMIER & COLEMAN. LLP
303 Banyan Boulevard. Suite 400
JRFIRIT errotte. West Riatairda 33401
Phoe:
Defendant. 6
7 On behalf of PORNO :
A
DITPGItlal
vel)P1R=-
9
111044411. October. 20. 2009
10110 - 1,10 p.a. 10
11
12 00 'WS
13
%sported Sy: 14
Teresa IabaIon, RPR. PPR
Notary Public. Stab of Florida 15
Neat Palt leach Office Job
16
17 On behalf or Wanda
19
20
21 On behalf M PMaLMt in reWmd Cabe No 08-80811
22
23
24
35
2 4
1 UNITED STATES DISTRICT COURT 1 • •
• 2
3
4
SOUTHERN DISTRICT OF FLORIDA
CASE No.06-CV-60119-CIV•MARRAMOHNSON
2
3
WITNESS
INDEX
' "
DIRECT CROSS REDIRECT RECROSS
PIIe I,
6
1 JEFFREY EPSTEIN,
Deist 7
9 Related cases 0 BY MRIn i5 190
08-80232, 08-80380. 93-8038I. 08-80904. 9 BY LEL 135 208
10 08-80993. WSW 1. 004/0893. 0943469. :o BY ma= 156
09-80591. 0940656. memex.09-elos2
II 11 BY MR. 173
12
12
DEPOSITION OF
VOLUME I 13
14 II EXHIBITS
Tuesday. Ocfcbts 20. 2009
15 1010 - 3:33 p.m as
16 16
11 11 NUMBER DESCRIPTION PAGE
IS DEFENDANTS EX. I COPIES, COMPOSITE PHOTOGRAPHS 103
1
19 19 DEFENDANTS EX. 2 COMPO9TE FICNE MESSAGE BOOK 147
20 20 DEFENDANTS EX 3 COPY OF PHOTOGRAPH 162
21 Reported By:
TINOS. Whalen. APR, FPR 21
22 WINO PROC. STIDO of Fbrkla 22
West Palm Beech Office Job is116991 23
23 Phone: 800.330.6952
561 659 4155 24
24 21
25
• Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutIons.com
CONFIDENTIAL 3501.172-001
Page 3 of 38
EFTA_00070809
EFTA01247532
IMIIM MID - Volume October 20, 2009
5 7
1 PROCEEDINGS 1 0 How long have you been employed by
2
3
4
Deposition taken before Teresa Whalen:
Registered Professional Reporter, Florida
Professional Reporter, and Notary Public In and for
2
3
4
Mr. Epstein?
A It will be live years this November 17th.
0 So you started November 17th, 2004?
A Yes. sir.
•
6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein?
- - 7 A Through an agency.
8 Thereupon, 8 0 What agency?
9
10
MIS)
having been first duly sworn or affirmed. was examined
9 A It's Regal Domestics.
to 0 And what was your position that you were tired
11 and testified as knows: 11 by Mr. Epstein la?
12 THE WITNESS: I do. 12 A Housekeeper-
13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness
14 MR Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Aro you familiar with
15 record what case INS is bang taken in? I noticed 15 that name?
16 it ire. versus Epstein. I don't know if anybody 16 A Yes.
17 cares to say who your clients me, what the case 17 0 And that person. I believe he represented that
18 style is or hi else for when she types it up. 18 he was also maybe a house manager. IS that correct?
19 MR I don't have a problem with 19 A Correct.
20 that. Are we doing initials? 20 0 Would he have been, at some point in time,
21 MR Yeah. Initials. 21 your boss or your superior?
22 MRS Okay. 22 A Yes.
23 BY MR. 23 0 That's somebody who you answered to,
24 0 All right. Will you state your name for the 24 Alfredo Rodriguez?
25 record. 25 A (Nodang head). Sometimes
6
1 A
Ma
•
1 You have to say yes or no. you
2 2 card nod your hoed.
3 3 BY I.E.
4 4 0 Yes?
5 5 A Yes.
6 6 MR. CRITTON: No. no. Site said SOMNIMOS.
7 7 then yeingaijaper Muth.
8 MR. . laden put anything in her
9 9 mouth. I don't want the record -
10 10 MR. CRITTON: Let me take It back. You said
11 11 yes. but she started to say something before she
12 12 vas Interrupted.
13 13 BYMi
14 14 O That's line. You cal answer the question.
15 15 then well irettua On the deposition.
16 16 : Did you want to explain that
17 17 further?
18 18 THE WITNESS: Because we wore supposed towed(
19 O Have you ever lived at Jeffrey Epstein's 19 together. Nit he was bossy. he was bossy.
20 location of 358 El Brillo Way? 20 BY I.E.
21 A No, sir. 21 0 Okay. Have you ever had your deposition taken
22 0 Whore are you currently employed? 22 before Ike this?
23 A Mr. Epstein. 23 A No.
24 0 And what address do you report to work? 24 0 All right. Well, there is one oourt repater,
25 A 358 El Brae Way. 25 n very easy In casual conversation to nod your
• Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
•
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
vnvw.esquiresolutions.com
3501.172-001
CONFIDENTIAL Page 4 of 38
EFTA 00070810
EFTA01247533
- Volume I October 20, 2009
9 11
I head or shake your head, and she can't take that down. 1 that it's clean and appropriately. what's this...
• 2
3
4
5
A All right
O It's also very easy to say uh-huh or huh-uh,
but it kind of looks the same on paper, so you can't do
that either. I'm going to wait until you finish your
2
3
4
O And as I understand this property, there is a
main house and then there's also a staff house on the
property. is that right?
A Yeast
6 answer, and you have to wait until I finish my question, 6 O And when the guests would come over, would you
7 because if we talk over one another, then the court 7 stay in the main house. or would you go to the staff
8 reporter can't get it down. 8 house?
9 A Okay. Yes, sir. 9 Can we get a time frame to the
10 O All right. So if you don't understand the 10 question?
n questiOn, sell me you don't understand and I'll try to 11 BY MR.-
12 ask a better question. 12 O Over the last five yews while you worked
13 A Yes. 13 there.
14 O Okay. So you were hired in November ol 2004 14 A I usually stay in the staff house and do the
15 to be the housekeeper for Mr. Epstein? 15 laundry, then I go to the kitchen and then tidy the
16 A Yes. 16 kitchen.
17 0 And when you were hired, who exactly hired 17 O You were hired in November of 2004. and what
10 you, who — let me strike that. 18 were your hours that you worked there back in November
19 When you were hired to be the housekeeper for 19 of 2004 when you were hired?
20 Mr. Epstein, who did you interview with? 20 A Eight to five.
21 A Ms. Maxwell. 21 O How many days a week?
22 O Is that Ghislaine Maxwell or just 22 A Depends.
23 Leine Maxwell? 23 O Flow would the schedule be relayed to you?
24 A Ghislaine Maxwell. 24 A When Mr. Epstein is there, then I'm supposed
25 O And where did the interview take place? 25 to report, but usually it's live days a week.
10 12
• 1 A At 358 El Belo Way. 1 O So am I correct in understanding that there
2 O And what did Ms. Maxwell and you speak about 2 was one schedule when Mr. Epstein was in town, and the
3 prior to your being hired as the housekeeper'? 3 schedule may be a little bit different it Mr. Epstein
4 A My duties. 4 was out of town?
O And what did she tell you your duties would 5 A Yes, sir.
6 be? 6 O All right. Tell me the differences when
7 A To tidy, to make beds, do laundry 7 Mr. Epstein Is in town versus when Mr. Epstein was not
8 O Did she tell you what would take ptace in the in town.
9 house on a day-to-day basis? 9 A If he stays like three or four days, then I'm
10 A No. 10 supposed to be there. and then the house is to be
11 O So going into that position, you had no idea 11 cleaned. And then when they do not come, then I can
12 who the guests would be or who the people Coming in the 12 either go there, or I'm gven free days off.
13 house would be, or what would generally go on? 13 Cr Three days off?
14 A Can you simplify the question? 14 A No. A free day.
15 O Sure. When you talked about with 15 o Oh. okay. But typically back in 2004 when you
16 Ghlslaine Maxwell at this interview, your duties being 16 were hired, you worked an average of about five days a
17 you would make the bed and tidy up, did she also tell 17 week; is that correct?
103 you that there would be a lot of guests, there would be 18 A Yes.
19 a few guests, did she talk to you about that at all? 19 o All right. And I guess by the way that you're
20 A She mentioned Petri there are guests, we 20 explaining it, of Mr. Epstein was in town for a longer
21 have to, like, you know, prepare the room, and, what's 2L period of time, you may work more than five days. and if
22 this. attend to the guests. 22 Mr. Epstein was not in town, you may work less than five
23 O And what did you understand that to mean that 23 days?
24 you have to attend to the guests? 24 A YOS.
25 A You have to prepare the room and see to it 25 o Okay. Did you ever talk to Mr. Epstein prior
Toll Free: 866.709.8777
Facsimile: 561.394.2621
• 0
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.eSqUiresOlutiOns.com
3501.172-001
CONFIDENTIAL Page 5 of 38
EFTYL00070811
EFTA01247534
- Volume I October 20, 2009
13 15
1
•
1 to being hired? 0 Did she tea what you would be paid at that
2 A No. sir. 2 time?
3 O Where did this meeting, within the house where 3 A Not yet.
4 did the meeting with Ghislaine Maxwell take place? 4 0 Did you show up that Saturday? I guess that's
A In the living room. 5 November 17th of 2004?
6 O Aside from telling you that you were going to 6 A No, that's not.
7 be required to make the beds and just generally tidy up, 7 0 No. Was it prior to November 17th of 2004. or
did she specify anything else that you would be required 8 after?
9 to do? 9 A After.
10 A No. 10 0 Okay. The interview that you first went to
11 11 was November 17th. 2004 with Ms. Maxwell; is that the
12 12 date that you gave us?
13 13 A I cannot remember.
14 14 0 The only reason I'm using that date is I
15 15 believe the question I asked was when did you start
16 16 working for Mr. Epstein, and I thought the date that you
17 17 gave me was November 17th. 2004.
18 18 A Yes.
39 19 0 Okay. And in the course of this whole thing.
20 20 it sounds like you interviewed with Ghislaine Maxwell.
21 21 there were other interviewees, you received a call and
22 22 you were asked to try out on a Saturday?
23 23 A Yes.
24 O And when you went to the interview. Obviously 24 0 And where does that Saturday fall in related
25 youtre going to this very big house and you talked to 25 to November 17th, 2004?
14 16
1
2
3
4
Ghislaine Maxwell. right?
A Yes.
0 And did you decide right then that you Med
this and that you were going to change professions and
2
3
4
A When I accepted the fob offer.
0 Okay. And did they tel you at that time sten
you accepted the job offer how much you WOW Going to he
paid?
•
5 you were going to be his housekeeper? s A Yes.
6 A No. 6 0 What was that?
7 0 Okay. Then walk me through that, how did you 7 A It was 32.000 per annum.
8 go about eventually accepting the position? 0 And haS your salary increased ovor time?
9 A I didn't expect to be hired. because there 9 A Yes. sir.
10 were other interviewers (sic). interview people that 10 0 And can you walk us through the increments of
11 were to be interviewed. 11 increase n your salary?
12 0 Okay. 12 A It was PronliSed yearly increase'
13 A And then I receive a call from Ms. Maxwell it 13 0 By whom?
14 I like. I can do a try-out. 14 A Ms. Maxwell
15 0 Okay. Did the tell you how long this try-out 15 0 Was that at the lime whon you wore
16 period would last? 16 interviewed, or look the job?
17 A No. 17 A Yes. sir.
18 0 And what did you tell her when sho made that 18 0 Did the promise you what your yearly Increase
19 offer for you to try out? 19 would be?
20 A I told her that I am still taking care of this 20 A No.
21 patient, so she said if you like, you can come Saturday 21 0 And have you received a yearly increase every
22 and try it. 22 year?
23 0 Okay. And what did you tell her, did you 23 A Idid.
24 accept that? 24 0 And what has that yearly increase been?
25 A Yes,Idid. 25 A Up to 42.
•
Toll Free: 866.709.8777
Facsimile: 561.394.2621
0
Suite 600
ESQUIRE
uMtGW.Cw
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquireSolutions.com
3501.172-001
CONFIDENTIAL Page 6 of 38
EFTA_00070812
EFTA01247535
- Volume I October 20, 2009
17 19
1 0 Today? 1 O Okay. So legs talk about lhat. Back in
• 2
3
S
A Yes.
0 So you're making $42,000 today. and that's the
meet that you've made over the five-year period you've
worked for Mr. Epstein?
2
3
4
5
November o12004, you were to working 8:03 a.m. to
5:00 p.m. And when Cod that schedule change from 8:00
5:00?
A When? When the house was renovated.
6 A Yes, sir. 6 O When was that, do you remember the year?
7 O At the lime when you -- when we took 7 A 2006.
8 Alfredo Rodriguez's deposition, he described you as a a O Okay.
9 very religious Catholic woman. Does that accurately 9 MR. CRITTON: I'm sorry. '06?
10 describe you? 10 THE WITNESS: '06.
11 MR. CRITTON: Let me just object to the form. 11 BY MR. -
12 You can answer the question If 12 O So from November 2004 through '06, I'm correct
13 you understood it. 13 in presumi ng that your schedule was an average cativo
14 THE WITNESS: I am a Catholic and I go to 14 days a week from 8:00 a.m. to 5:00 p.m.?
15 mass. 15 A At that time I go nine o'clock. I go to the
16 BY MR. 16 house at nine o'clock.
17 O Is that something you go to regularly? 17 O Starting in 2006?
18 A III have time. I go regularly. 18 A Yes.
19 O When do you normally go to mass? 19 O So when your schedule changed from 8:00 ti
20 A Sunday masses and weekdays. 20 5:00. in 2006 you started going to the house,
21 o How many weekdays? 21 Jeffrey Epstein's house, at nine o'clock?
22 A 111 can, every day. 22 A Yes, sir.
23 o And in the five-year period that you've worked 23 O And you would stay until what time?
24 for Mr. Epstein, have you tried to go every day it you 24 A Sometimes 5:00, sometimes later. 5:30.
25 could? 25 o Would that depend on what needed to be done?
18 20
1 A Yes.
• 1
2
3
4
A No.
0 In a typical week would you normally go on
Sunday to mass?
A Yes, sir.
2
3
4
O How have you received your money. has it been
by Check, by cash, in terms of payment from Mr. Epstein?
A It's directly deposited to my bank
5 0 And how many days during the week will you 5 O Do you know who directly deposits your money?
6 also attend mass? 6 A MP?
7 A If the schedule permits, then Igo, but if 7 O Yeah. Mother Its Ghislaine Maxwell or a
not, then I don't go. 8 corporation or Jeffrey Epstein. do you knew who the
9 0 So is there a way that you could 9-IVO me an 9 direct depositor is of your check?
10 average of how many times a week that you go during the 10 MR. CRITTON: Form.
11 week to mass? 11 THE WITNESS: Mr. Epstein.
12 A This lime? 12 BY MR.-
13 0 Right. Yeah. I guess today, these days. 13 O Okay. Over the five years that you have been
14 A I attend Sunday masses only. 14 working at Mr. Epstein's house, how many conversations
15 0 And back in 2004, vmen you first started with 15 have you had directly with Mr. Epstein?
16 Mr. Epstein? 16 A What's this, what year?
17 A I filed to go it I have the time. sir. 17 O Wel. in the last five years, how many
18 O Was there ever a time that you went every day? 18 conversations have you had &cc* with Mr. Epstein?
19 A No. 19 MR. CRITTON: Form.
20 0 But your testimony is that if time permitted, 20 THE WITNESS: The past year it's just good
21 you tried to Go every day? 21 morning, how aro you. you're doing a good job.
22 A Yes. 22 BY MR. -
23 0 Is there a reason why now these days you only 23 O Okay. How was it prior to that, did you talk
24 attend on Sundays? 24 to him more?
25 A Because my time schedule has changed. 25 A This time more.
• 0
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 31410
www.esquiresolutions.com
CONFIDENTIAL 3501.172-001
Page 7 of 38
EFTA_00070813
EFTA01247536
- Volume I October 20, 2009
21 23
1
•
O Now you talk to him more? 1 A Yes.
2 A Because I serve him breakfast. so... 2 O When did you talk to Lyn Fontanilla about
3 O And is that an additional responsibility that 3
4 you didn't have before? 4 A It was just through the conversation.
A Yes. 5 O What would cause you to be in a conversation
6 O In the live-year penod that you've worked 6 with this person in New York?
7 there, can you name for me all of the other employees 7 MR. CRITTON: Form.
8 who have worked at the Jeffrey Epstein house? 8 THE WITNESS: She calls me, I call her.
9 A After Alfredo Rodriguez left, there was 9 BY MR.
10 Jerome. the gardener, and now it's Yanusz. 10 O You're friends?
11 O And those are the house managers'? 11 A Yes.
12 A Yes. 12 O Do you still talk to her today?
13 O And then you work there? 13 A Yes.
14 A Right. 14 O And does she work for Mr. Epstein as well, to
15 O Aside from yourself. Jerome. and Janusz. was 15 your knowledge?
16 there anybody else that you can remember working at the 16 A She does.
17 house in the past live years in any position? 17 O And does Jojo, her husband, also work for
18 A Yes. 18 Mr. Epstein as well?
19 O Who else? 19 A Yes, sir.
20 A 20 O Where do they work?
21 O That's 21 A In New York.
22 A Yes. 22 O At Mr. Epstein's house in New York?
23 O What does she do there? 23 A Yes, sir.
24 A She's the personal assistant. 24 O And have you talked with them about your
25 O Personal assistant to whom? 25 duties and has she talked to you about her duties?
22 24
•
1 A Mr. Epstein. 1 A YeSi sir.
2 O And as his personal assistant, what have you 2 O Arid your duties are similar to Lyn's duties in
3 observed her to do for him? 3 New York?
4 A Can you rephrase your question? 4 A No. Because that's a bigger house than...
5 O I can try. You sad that she's his personal 5 O Palm Beach?
6 assistant. What does that mean, what does she do? 6 A Yes, sir.
7 A Order things that I need. Ordi whats this. 7 O IS It your understanding that you know,
8 O So it's your testimony that has 8 we're going to gel into the past two years where
9 been. tor the past the years that you ve worked there. 9 Mr. Epstein has either been in jail or he's been on
10 has been somebody that you have observed to order things 10 house arrest in Palm Beach, so I'm going to ask you
11 that you reed? 11 first for the first three years that you worked there
12 A If I need something. than I go to ask 12 and Mr. Epstein was traveling, was Mr. Epstein spending
MI
13 O Oka . What other things have you seen 13 the majority of his time in Palm Beach or in New Yolk or
16 do for Mr. Epstein? 14 elsewhere. il you know?
15 A I have not, that's the any thing I know. 15 A He comes we don't know the schedule, we
16 O Who told you that is 16 receive a call, then we prepare, he's coming.
17 Mr. Epste,rts personal assistant? 17 O You say we receive a call. Who receives the
18 A Coworker. 18 calf?
19 O Who is that? 19 A Esther Alfredo or Janusz.
20 A In New York. 20 O Depending on who the house manager is at the
21 O What's that person's rerne? 21 time?
22 A Lyn. 22 A Yes.
23 O Lyn who? 23 O And the call comes from whom, from Dhislaine
24 A Fcetanala. 24 or from Jeffrey Epstein?
25 O Is that Jojo's wife? 25 A I don't know.
•
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE •••Insw•erGaloCeeptay
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
3501.172-001
CONFIDENTIAL Page 8 of 38
EFTA_00070814
EFTA01247537
- Volume I October 20, 200c;
25 27
1 O Okay. What's your understanding of Lyn's role 1 MR. CRITTON Form.
• 2
3
4
5
In Jeffrey Epstein's life up in New York?
A She's housekeeper, too.
O And your understanding of Jojo's role'
A A driver.
2
3
4
5
BY MR.
O
BY MR.-
Do you understand his question?
6 O Does he also serve as a house manager, similar 6 O Do you understand my question?
7 to the way Alfredo Rodriguez was in Palm Beach? 7 Do you know that is whim he's
A No. 8 asking you?
9 O Whon you say a driver, who does he drive. it 9 THE WITNESS: Yes.
10 you know? 10 I think the question was do you
11 A Mr. Epstein. 11 know whether or not Mr. Epstein pled guilty to
12 O All right. Mr. Epstein obviously hasn't been 12 comes.
13 in New York for quite some time: isn't that your 13 Was Mal the Ion?
14 understanding? 14 MR. Sure.
15 A Yes. 15 MR. CRITTON: That was not his question.
16 O So Jcicts still employed up In New York as a 16 BY MR. -
17 driver for Mr. Epstein, right? 17 O Okay. Well, do you realize that Mr. Epstein
18 A He also does housework, helps Lyn. 18 pled guilty to crimes?
19 O Have you discussed with Lyn whether or not 19 A Plead guilty? From the news.
20 young girls visit the house in New York? 20 O Okay. So when you say you saw the news, which
21 MR. CRITTON: Form. 21 is whore this portion or our discussion began, aro you
22 You can answer that. 22 referring to the news related to Mr. Epstein and the
23 BY MR. 23 charges, the criminal charges or criminal investigation
24 O He didn't lik
Condensed Transcript
• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
Plaintiff,
vs. CASE No.
502008CA028051XXXXMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
• VOLUME I
October, 20. 2009
10:10 a.m.
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
• Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, Ft. 33410
www.esqulresoluttons.com
3501.172-001
CONFIDENTIAL Page I of 38
EFTA_00070807
EFTA01247530
•
•
•
3501.172-001
CONFIDENTIAL Page 2 of 38
EFTA_00070808
EFTA01247531
- Volume I October 20, 2009
1 3
IR na chicory cceer OF TIM FIFTRI26111 JOICTAL CIRCUIT 1 APPEARANCES'
111 AND FOR PAlM SIAM CCM', FLORIDA
• Plaintiff,
CIVIL DIVISION
CASK No.5132COSCAOTSCD/XXX/30 AS
2
3
4
On behalf of the Defoxlant:
ROBERT 0. CRITTON, JR.. ESQUIRE
BURIMN CRITTON LIMIER & COLEMAN. LLP
303 Banyan Boulevard. Suite 400
JRFIRIT errotte. West Riatairda 33401
Phoe:
Defendant. 6
7 On behalf of PORNO :
A
DITPGItlal
vel)P1R=-
9
111044411. October. 20. 2009
10110 - 1,10 p.a. 10
11
12 00 'WS
13
%sported Sy: 14
Teresa IabaIon, RPR. PPR
Notary Public. Stab of Florida 15
Neat Palt leach Office Job
16
17 On behalf or Wanda
19
20
21 On behalf M PMaLMt in reWmd Cabe No 08-80811
22
23
24
35
2 4
1 UNITED STATES DISTRICT COURT 1 • •
• 2
3
4
SOUTHERN DISTRICT OF FLORIDA
CASE No.06-CV-60119-CIV•MARRAMOHNSON
2
3
WITNESS
INDEX
' "
DIRECT CROSS REDIRECT RECROSS
PIIe I,
6
1 JEFFREY EPSTEIN,
Deist 7
9 Related cases 0 BY MRIn i5 190
08-80232, 08-80380. 93-8038I. 08-80904. 9 BY LEL 135 208
10 08-80993. WSW 1. 004/0893. 0943469. :o BY ma= 156
09-80591. 0940656. memex.09-elos2
II 11 BY MR. 173
12
12
DEPOSITION OF
VOLUME I 13
14 II EXHIBITS
Tuesday. Ocfcbts 20. 2009
15 1010 - 3:33 p.m as
16 16
11 11 NUMBER DESCRIPTION PAGE
IS DEFENDANTS EX. I COPIES, COMPOSITE PHOTOGRAPHS 103
1
19 19 DEFENDANTS EX. 2 COMPO9TE FICNE MESSAGE BOOK 147
20 20 DEFENDANTS EX 3 COPY OF PHOTOGRAPH 162
21 Reported By:
TINOS. Whalen. APR, FPR 21
22 WINO PROC. STIDO of Fbrkla 22
West Palm Beech Office Job is116991 23
23 Phone: 800.330.6952
561 659 4155 24
24 21
25
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IMIIM MID - Volume October 20, 2009
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1 PROCEEDINGS 1 0 How long have you been employed by
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Deposition taken before Teresa Whalen:
Registered Professional Reporter, Florida
Professional Reporter, and Notary Public In and for
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Mr. Epstein?
A It will be live years this November 17th.
0 So you started November 17th, 2004?
A Yes. sir.
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6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein?
- - 7 A Through an agency.
8 Thereupon, 8 0 What agency?
9
10
MIS)
having been first duly sworn or affirmed. was examined
9 A It's Regal Domestics.
to 0 And what was your position that you were tired
11 and testified as knows: 11 by Mr. Epstein la?
12 THE WITNESS: I do. 12 A Housekeeper-
13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness
14 MR Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Aro you familiar with
15 record what case INS is bang taken in? I noticed 15 that name?
16 it ire. versus Epstein. I don't know if anybody 16 A Yes.
17 cares to say who your clients me, what the case 17 0 And that person. I believe he represented that
18 style is or hi else for when she types it up. 18 he was also maybe a house manager. IS that correct?
19 MR I don't have a problem with 19 A Correct.
20 that. Are we doing initials? 20 0 Would he have been, at some point in time,
21 MR Yeah. Initials. 21 your boss or your superior?
22 MRS Okay. 22 A Yes.
23 BY MR. 23 0 That's somebody who you answered to,
24 0 All right. Will you state your name for the 24 Alfredo Rodriguez?
25 record. 25 A (Nodang head). Sometimes
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1 A
Ma
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1 You have to say yes or no. you
2 2 card nod your hoed.
3 3 BY I.E.
4 4 0 Yes?
5 5 A Yes.
6 6 MR. CRITTON: No. no. Site said SOMNIMOS.
7 7 then yeingaijaper Muth.
8 MR. . laden put anything in her
9 9 mouth. I don't want the record -
10 10 MR. CRITTON: Let me take It back. You said
11 11 yes. but she started to say something before she
12 12 vas Interrupted.
13 13 BYMi
14 14 O That's line. You cal answer the question.
15 15 then well irettua On the deposition.
16 16 : Did you want to explain that
17 17 further?
18 18 THE WITNESS: Because we wore supposed towed(
19 O Have you ever lived at Jeffrey Epstein's 19 together. Nit he was bossy. he was bossy.
20 location of 358 El Brillo Way? 20 BY I.E.
21 A No, sir. 21 0 Okay. Have you ever had your deposition taken
22 0 Whore are you currently employed? 22 before Ike this?
23 A Mr. Epstein. 23 A No.
24 0 And what address do you report to work? 24 0 All right. Well, there is one oourt repater,
25 A 358 El Brae Way. 25 n very easy In casual conversation to nod your
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I head or shake your head, and she can't take that down. 1 that it's clean and appropriately. what's this...
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A All right
O It's also very easy to say uh-huh or huh-uh,
but it kind of looks the same on paper, so you can't do
that either. I'm going to wait until you finish your
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O And as I understand this property, there is a
main house and then there's also a staff house on the
property. is that right?
A Yeast
6 answer, and you have to wait until I finish my question, 6 O And when the guests would come over, would you
7 because if we talk over one another, then the court 7 stay in the main house. or would you go to the staff
8 reporter can't get it down. 8 house?
9 A Okay. Yes, sir. 9 Can we get a time frame to the
10 O All right. So if you don't understand the 10 question?
n questiOn, sell me you don't understand and I'll try to 11 BY MR.-
12 ask a better question. 12 O Over the last five yews while you worked
13 A Yes. 13 there.
14 O Okay. So you were hired in November ol 2004 14 A I usually stay in the staff house and do the
15 to be the housekeeper for Mr. Epstein? 15 laundry, then I go to the kitchen and then tidy the
16 A Yes. 16 kitchen.
17 0 And when you were hired, who exactly hired 17 O You were hired in November of 2004. and what
10 you, who — let me strike that. 18 were your hours that you worked there back in November
19 When you were hired to be the housekeeper for 19 of 2004 when you were hired?
20 Mr. Epstein, who did you interview with? 20 A Eight to five.
21 A Ms. Maxwell. 21 O How many days a week?
22 O Is that Ghislaine Maxwell or just 22 A Depends.
23 Leine Maxwell? 23 O Flow would the schedule be relayed to you?
24 A Ghislaine Maxwell. 24 A When Mr. Epstein is there, then I'm supposed
25 O And where did the interview take place? 25 to report, but usually it's live days a week.
10 12
• 1 A At 358 El Belo Way. 1 O So am I correct in understanding that there
2 O And what did Ms. Maxwell and you speak about 2 was one schedule when Mr. Epstein was in town, and the
3 prior to your being hired as the housekeeper'? 3 schedule may be a little bit different it Mr. Epstein
4 A My duties. 4 was out of town?
O And what did she tell you your duties would 5 A Yes, sir.
6 be? 6 O All right. Tell me the differences when
7 A To tidy, to make beds, do laundry 7 Mr. Epstein Is in town versus when Mr. Epstein was not
8 O Did she tell you what would take ptace in the in town.
9 house on a day-to-day basis? 9 A If he stays like three or four days, then I'm
10 A No. 10 supposed to be there. and then the house is to be
11 O So going into that position, you had no idea 11 cleaned. And then when they do not come, then I can
12 who the guests would be or who the people Coming in the 12 either go there, or I'm gven free days off.
13 house would be, or what would generally go on? 13 Cr Three days off?
14 A Can you simplify the question? 14 A No. A free day.
15 O Sure. When you talked about with 15 o Oh. okay. But typically back in 2004 when you
16 Ghlslaine Maxwell at this interview, your duties being 16 were hired, you worked an average of about five days a
17 you would make the bed and tidy up, did she also tell 17 week; is that correct?
103 you that there would be a lot of guests, there would be 18 A Yes.
19 a few guests, did she talk to you about that at all? 19 o All right. And I guess by the way that you're
20 A She mentioned Petri there are guests, we 20 explaining it, of Mr. Epstein was in town for a longer
21 have to, like, you know, prepare the room, and, what's 2L period of time, you may work more than five days. and if
22 this. attend to the guests. 22 Mr. Epstein was not in town, you may work less than five
23 O And what did you understand that to mean that 23 days?
24 you have to attend to the guests? 24 A YOS.
25 A You have to prepare the room and see to it 25 o Okay. Did you ever talk to Mr. Epstein prior
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1 to being hired? 0 Did she tea what you would be paid at that
2 A No. sir. 2 time?
3 O Where did this meeting, within the house where 3 A Not yet.
4 did the meeting with Ghislaine Maxwell take place? 4 0 Did you show up that Saturday? I guess that's
A In the living room. 5 November 17th of 2004?
6 O Aside from telling you that you were going to 6 A No, that's not.
7 be required to make the beds and just generally tidy up, 7 0 No. Was it prior to November 17th of 2004. or
did she specify anything else that you would be required 8 after?
9 to do? 9 A After.
10 A No. 10 0 Okay. The interview that you first went to
11 11 was November 17th. 2004 with Ms. Maxwell; is that the
12 12 date that you gave us?
13 13 A I cannot remember.
14 14 0 The only reason I'm using that date is I
15 15 believe the question I asked was when did you start
16 16 working for Mr. Epstein, and I thought the date that you
17 17 gave me was November 17th. 2004.
18 18 A Yes.
39 19 0 Okay. And in the course of this whole thing.
20 20 it sounds like you interviewed with Ghislaine Maxwell.
21 21 there were other interviewees, you received a call and
22 22 you were asked to try out on a Saturday?
23 23 A Yes.
24 O And when you went to the interview. Obviously 24 0 And where does that Saturday fall in related
25 youtre going to this very big house and you talked to 25 to November 17th, 2004?
14 16
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Ghislaine Maxwell. right?
A Yes.
0 And did you decide right then that you Med
this and that you were going to change professions and
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A When I accepted the fob offer.
0 Okay. And did they tel you at that time sten
you accepted the job offer how much you WOW Going to he
paid?
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5 you were going to be his housekeeper? s A Yes.
6 A No. 6 0 What was that?
7 0 Okay. Then walk me through that, how did you 7 A It was 32.000 per annum.
8 go about eventually accepting the position? 0 And haS your salary increased ovor time?
9 A I didn't expect to be hired. because there 9 A Yes. sir.
10 were other interviewers (sic). interview people that 10 0 And can you walk us through the increments of
11 were to be interviewed. 11 increase n your salary?
12 0 Okay. 12 A It was PronliSed yearly increase'
13 A And then I receive a call from Ms. Maxwell it 13 0 By whom?
14 I like. I can do a try-out. 14 A Ms. Maxwell
15 0 Okay. Did the tell you how long this try-out 15 0 Was that at the lime whon you wore
16 period would last? 16 interviewed, or look the job?
17 A No. 17 A Yes. sir.
18 0 And what did you tell her when sho made that 18 0 Did the promise you what your yearly Increase
19 offer for you to try out? 19 would be?
20 A I told her that I am still taking care of this 20 A No.
21 patient, so she said if you like, you can come Saturday 21 0 And have you received a yearly increase every
22 and try it. 22 year?
23 0 Okay. And what did you tell her, did you 23 A Idid.
24 accept that? 24 0 And what has that yearly increase been?
25 A Yes,Idid. 25 A Up to 42.
•
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1 0 Today? 1 O Okay. So legs talk about lhat. Back in
• 2
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S
A Yes.
0 So you're making $42,000 today. and that's the
meet that you've made over the five-year period you've
worked for Mr. Epstein?
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5
November o12004, you were to working 8:03 a.m. to
5:00 p.m. And when Cod that schedule change from 8:00
5:00?
A When? When the house was renovated.
6 A Yes, sir. 6 O When was that, do you remember the year?
7 O At the lime when you -- when we took 7 A 2006.
8 Alfredo Rodriguez's deposition, he described you as a a O Okay.
9 very religious Catholic woman. Does that accurately 9 MR. CRITTON: I'm sorry. '06?
10 describe you? 10 THE WITNESS: '06.
11 MR. CRITTON: Let me just object to the form. 11 BY MR. -
12 You can answer the question If 12 O So from November 2004 through '06, I'm correct
13 you understood it. 13 in presumi ng that your schedule was an average cativo
14 THE WITNESS: I am a Catholic and I go to 14 days a week from 8:00 a.m. to 5:00 p.m.?
15 mass. 15 A At that time I go nine o'clock. I go to the
16 BY MR. 16 house at nine o'clock.
17 O Is that something you go to regularly? 17 O Starting in 2006?
18 A III have time. I go regularly. 18 A Yes.
19 O When do you normally go to mass? 19 O So when your schedule changed from 8:00 ti
20 A Sunday masses and weekdays. 20 5:00. in 2006 you started going to the house,
21 o How many weekdays? 21 Jeffrey Epstein's house, at nine o'clock?
22 A 111 can, every day. 22 A Yes, sir.
23 o And in the five-year period that you've worked 23 O And you would stay until what time?
24 for Mr. Epstein, have you tried to go every day it you 24 A Sometimes 5:00, sometimes later. 5:30.
25 could? 25 o Would that depend on what needed to be done?
18 20
1 A Yes.
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A No.
0 In a typical week would you normally go on
Sunday to mass?
A Yes, sir.
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O How have you received your money. has it been
by Check, by cash, in terms of payment from Mr. Epstein?
A It's directly deposited to my bank
5 0 And how many days during the week will you 5 O Do you know who directly deposits your money?
6 also attend mass? 6 A MP?
7 A If the schedule permits, then Igo, but if 7 O Yeah. Mother Its Ghislaine Maxwell or a
not, then I don't go. 8 corporation or Jeffrey Epstein. do you knew who the
9 0 So is there a way that you could 9-IVO me an 9 direct depositor is of your check?
10 average of how many times a week that you go during the 10 MR. CRITTON: Form.
11 week to mass? 11 THE WITNESS: Mr. Epstein.
12 A This lime? 12 BY MR.-
13 0 Right. Yeah. I guess today, these days. 13 O Okay. Over the five years that you have been
14 A I attend Sunday masses only. 14 working at Mr. Epstein's house, how many conversations
15 0 And back in 2004, vmen you first started with 15 have you had directly with Mr. Epstein?
16 Mr. Epstein? 16 A What's this, what year?
17 A I filed to go it I have the time. sir. 17 O Wel. in the last five years, how many
18 O Was there ever a time that you went every day? 18 conversations have you had &cc* with Mr. Epstein?
19 A No. 19 MR. CRITTON: Form.
20 0 But your testimony is that if time permitted, 20 THE WITNESS: The past year it's just good
21 you tried to Go every day? 21 morning, how aro you. you're doing a good job.
22 A Yes. 22 BY MR. -
23 0 Is there a reason why now these days you only 23 O Okay. How was it prior to that, did you talk
24 attend on Sundays? 24 to him more?
25 A Because my time schedule has changed. 25 A This time more.
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1
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O Now you talk to him more? 1 A Yes.
2 A Because I serve him breakfast. so... 2 O When did you talk to Lyn Fontanilla about
3 O And is that an additional responsibility that 3
4 you didn't have before? 4 A It was just through the conversation.
A Yes. 5 O What would cause you to be in a conversation
6 O In the live-year penod that you've worked 6 with this person in New York?
7 there, can you name for me all of the other employees 7 MR. CRITTON: Form.
8 who have worked at the Jeffrey Epstein house? 8 THE WITNESS: She calls me, I call her.
9 A After Alfredo Rodriguez left, there was 9 BY MR.
10 Jerome. the gardener, and now it's Yanusz. 10 O You're friends?
11 O And those are the house managers'? 11 A Yes.
12 A Yes. 12 O Do you still talk to her today?
13 O And then you work there? 13 A Yes.
14 A Right. 14 O And does she work for Mr. Epstein as well, to
15 O Aside from yourself. Jerome. and Janusz. was 15 your knowledge?
16 there anybody else that you can remember working at the 16 A She does.
17 house in the past live years in any position? 17 O And does Jojo, her husband, also work for
18 A Yes. 18 Mr. Epstein as well?
19 O Who else? 19 A Yes, sir.
20 A 20 O Where do they work?
21 O That's 21 A In New York.
22 A Yes. 22 O At Mr. Epstein's house in New York?
23 O What does she do there? 23 A Yes, sir.
24 A She's the personal assistant. 24 O And have you talked with them about your
25 O Personal assistant to whom? 25 duties and has she talked to you about her duties?
22 24
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1 A Mr. Epstein. 1 A YeSi sir.
2 O And as his personal assistant, what have you 2 O Arid your duties are similar to Lyn's duties in
3 observed her to do for him? 3 New York?
4 A Can you rephrase your question? 4 A No. Because that's a bigger house than...
5 O I can try. You sad that she's his personal 5 O Palm Beach?
6 assistant. What does that mean, what does she do? 6 A Yes, sir.
7 A Order things that I need. Ordi whats this. 7 O IS It your understanding that you know,
8 O So it's your testimony that has 8 we're going to gel into the past two years where
9 been. tor the past the years that you ve worked there. 9 Mr. Epstein has either been in jail or he's been on
10 has been somebody that you have observed to order things 10 house arrest in Palm Beach, so I'm going to ask you
11 that you reed? 11 first for the first three years that you worked there
12 A If I need something. than I go to ask 12 and Mr. Epstein was traveling, was Mr. Epstein spending
MI
13 O Oka . What other things have you seen 13 the majority of his time in Palm Beach or in New Yolk or
16 do for Mr. Epstein? 14 elsewhere. il you know?
15 A I have not, that's the any thing I know. 15 A He comes we don't know the schedule, we
16 O Who told you that is 16 receive a call, then we prepare, he's coming.
17 Mr. Epste,rts personal assistant? 17 O You say we receive a call. Who receives the
18 A Coworker. 18 calf?
19 O Who is that? 19 A Esther Alfredo or Janusz.
20 A In New York. 20 O Depending on who the house manager is at the
21 O What's that person's rerne? 21 time?
22 A Lyn. 22 A Yes.
23 O Lyn who? 23 O And the call comes from whom, from Dhislaine
24 A Fcetanala. 24 or from Jeffrey Epstein?
25 O Is that Jojo's wife? 25 A I don't know.
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1 O Okay. What's your understanding of Lyn's role 1 MR. CRITTON Form.
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In Jeffrey Epstein's life up in New York?
A She's housekeeper, too.
O And your understanding of Jojo's role'
A A driver.
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BY MR.
O
BY MR.-
Do you understand his question?
6 O Does he also serve as a house manager, similar 6 O Do you understand my question?
7 to the way Alfredo Rodriguez was in Palm Beach? 7 Do you know that is whim he's
A No. 8 asking you?
9 O Whon you say a driver, who does he drive. it 9 THE WITNESS: Yes.
10 you know? 10 I think the question was do you
11 A Mr. Epstein. 11 know whether or not Mr. Epstein pled guilty to
12 O All right. Mr. Epstein obviously hasn't been 12 comes.
13 in New York for quite some time: isn't that your 13 Was Mal the Ion?
14 understanding? 14 MR. Sure.
15 A Yes. 15 MR. CRITTON: That was not his question.
16 O So Jcicts still employed up In New York as a 16 BY MR. -
17 driver for Mr. Epstein, right? 17 O Okay. Well, do you realize that Mr. Epstein
18 A He also does housework, helps Lyn. 18 pled guilty to crimes?
19 O Have you discussed with Lyn whether or not 19 A Plead guilty? From the news.
20 young girls visit the house in New York? 20 O Okay. So when you say you saw the news, which
21 MR. CRITTON: Form. 21 is whore this portion or our discussion began, aro you
22 You can answer that. 22 referring to the news related to Mr. Epstein and the
23 BY MR. 23 charges, the criminal charges or criminal investigation
24 O He didn't lik