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Case 1:15-cv-07433-LAP Document 55-21 Filed 03/14/16 Page 1 of 69
EXHIBIT 13
PART 1
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1 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
3 JANE DOE NO. 2, Case No: 08-CV-80119
4 Plaintiff,
5 Vs
6 JEFFREY EPSTEIN,
7 Defendant.
___________________/
8
JANE DOE NO. 3, Case NO: 08-CV-80232
9
Plaintiff,
10 Vs
11 JEFFREY EPSTEIN,
12 Defendant.
___________________/
13
JANE DOE NO. 4, Case No: 08-CV-80380
14
Plaintiff,
15
Vs.
16
JEFFREY EPSTEIN,
17
Defendant.
18 ___________________/
19 JANE DOE NO. 5, Case No: 08-CV-80381
20 Plaintiff,
21 Vs
22 JEFFREY EPSTEIN,
23 Defendant.
___________________/
24
25
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1 JANE DOE NO. 6, Case No: 08-CV-80994 1 VIDEOTAPED
2 Plaintiff, 2 DEPOSITION
3 Vs 3 of
4 JEFFREY EPSTEIN, 4 ALFREDO RODRIGUEZ
5 Defendant. 5
___________________/ 6 taken on behalf of the Plaintiffs pursuant
6 7 to a Re-Notice of Taking Deposition (Duces Tecum)
JANE DOE NO. 7, Case No. 08-CV-80993 8
7 9 ---
Plaintiff, 10 APPEARANCES:
8 11
Vs MERMELSTEIN & HOROWITZ, P.A.
9 12 BY: STUART MERMELSTEIN, ESQ.
JEFFREY EPSTEIN, 18205 Biscayne Boulevard
10
13 Suite 2218
Defendant.
Miami, Florida 33160
11 ___________________/
14 Attorney for Jane Doe 2, 3, 4, 5,
12 C.M.A., Case No: 08-CV-80811
6, and 7.
13 Plaintiff,
15
14 Vs
15 JEFFREY EPSTEIN,
16 ROTHSTEIN ROSENFELDT ADLER
16 Defendant. BY: BRAD J. EDWARDS, ESQ., and
___________________/ 17 CARA HOLMES, ESQ.
17 Las Olas City Centre
JANE DOE, Case No: 08-CV-80893 18 Suite 1650
18 401 East Las Olas Boulevard
Plaintiff, 19 Fort Lauderdale, Florida 33301
19 Attorney for Jane Doe and E.W.
Vs 20 And L.M.
20 21
JEFFREY EPSTEIN, PODHURST ORSECK
21 22 BY: KATHERINE W. EZELL
Defendant. 25 West Flagler Street
22 ___________________/ 23 Suite 800
23 Miami, Florida 33130
24 24 Attorney for Jane Doe 101 and 102.
25 25
Page 3 Page 5
1 JANE DOE NO. II, Case No: 08-CV-80469 1
2 Plaintiff, APPEARANCES:
3 Vs 2
3 LEOPOLD-KUVIN
4 JEFFREY EPSTEIN,
ADAM J. LANGINO, ESQ.
5 Defendant. 4 2925 PGA Boulevard
___________________/ Suite 200
6 5 Palm Beach Gardens, Florida 33410
JANE DOE NO. 101, Case No: 09-CV-80591 Attorney for B.B.
7 6
Plaintiff, 7 RICHARD WILLITS, ESQ.
8 2290 10th Avenue North
Vs 8 Suite 404
Lake Worth, Florida 33461
9
9 Attorney for C.M.A.
JEFFREY EPSTEIN, 10
10 BURMAN, CRITTON, LUTTIER &
Defendant. 11 COLEMAN, LLP
11 ___________________/ BY: ROBERT CRITTON, ESQ.
12 JANE DOE NO. 102, Case No: 09-CV-80656 12 515 North Flagler Drive
13 Plaintiff, Suite 400
14 Vs 13 West Palm Beach, Florida 33401
Attorney for Jeffrey Epstein.
15 JEFFREY EPSTEIN,
14
16 Defendant. 15
___________________/ 16
17 ALSO PRESENT:
18 17
19 JOE LANGSAM, VIDEOGRAPHER
20 1031 Ives Dairy Road 18
Suite 228 19
- - -
21 North Miami, Florida
20
July 29, 2009
21
22 11:00 a.m. to 5:30 p.m. 22
23 23
24 24
25 25
2 (Pages 2 to 5)
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1 INDEX OF EXAMINATION 1 Doe right here on the copy you gave me. I'm
2 2 missing which Jane Doe this is.
WITNESS DIRECT CROSS
3
3 They're all different case numbers. Do
ALFREDO RODRIGUEZ 4 you want me to go through each case number?
4 5 MR. CRITTON: I'm going to note my
(By Mr. Mermelstein) 12 6 objection. Obviously if this deposition
5 7 gets played -- not obviously, I'm going to
(By Mr. Edwards) 157
6
8 object to the litany of each one so I don't
(By Mr. Langino) 260 9 know how we can separate it out. Maybe if
7 10 and when at the time of trial and depending
8 11 on how the Court determines what comes in
9 12 and what doesn't with regard to the
10 INDEX OF EXHIBITS
11 EXHIBITS PAGE
13 consolidated aspects of this. I have no
12 1 Message pad 72 14 great idea other than just saying Jane Doe
13 2 Documents 115 15 versus Epstein, et al, or something like
14 16 that, or Jane Doe, et al.
15 17 MS. EZELL: Couldn't we just say and
16
17
18 those cases which have been consolidated
18 19 with it for Discovery purposes?
19 20 MR. EDWARDS: Although there is cases
20 21 here that have cross noticed this from state
21 22 court that haven't been consolidated so that
22
23
23 may not work. You may have to read them
24 24 all, if it works out your way that will just
25 25 get edited out, at least he will have read
Page 7 Page 9
1 Deposition taken before MICHELLE PAYNE, Court 1 that caption, every caption. Right? Is
2 Reporter and Notary Public in and for the State of 2 there a better suggestion?
3 Florida at Large, in the above cause. 3 MR. CRITTON: No. There may be a better
4 - - - 4 suggestion if he starts this is such and
5 THE VIDEOGRAPHER: This is the case of 5 such day, it's the deposition of Mr.
6 Jane Doe No. 2, plaintiff, versus Jeffrey 6 Rodriguez in the case such and such, and we
7 Epstein, defendant. Jane Doe No. 3, 7 can almost fill it in depending on which
8 plaintiff, versus Jeffrey Epstein, 8 tape it goes, how it fills in, at least
9 defendant. Jane Doe No. 4, plaintiff, 9 we'll have the context of the first and
10 versus Jeffrey Epstein, defendant. And Jane 10 depending on whether the Judge reads it in
11 Doe No. 5, plaintiff, versus Jeffrey 11 from a consolidated or they all come
12 Epstein, defendant. Jane Doe No. 6, 12 related, I have no great idea.
13 plaintiff, versus Jeffrey Epstein, 13 MR. EDWARDS: I was thinking if he read
14 defendant. Jane Doe No. 7, plaintiff, 14 every one of them and it was the seventh in
15 versus Jeffrey Epstein, defendant. CMA, 15 line then you just would edit it so you
16 plaintiff, versus Jeffrey Epstein, 16 would only read that one.
17 defendant. And Jane Doe, plaintiff, versus 17 MR. CRITTON: I'm okay with that too.
18 Jeffrey Epstein, et al, defendant. And Jane 18 THE VIDEOGRAPHER: On page number three
19 Doe -- is there a shorter thing that we can 19 there is something missing on the top here.
20 do here? It's also missing this one right 20 Do you want me to read each case number
21 here. 21 separately?
22 MR. MERMELSTEIN: Do we have a problem 22 MR. MERMELSTEIN: I don't think it's
23 with saying Jane Doe 2 and the Epstein and 23 necessary.
24 related cases? 24 MR. EDWARDS: I don't think it's
25 THE VIDEOGRAPHER: I'm missing this Jane 25 necessary either.
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1 THE VIDEOGRAPHER: So just go through 1 Jeffrey Epstein.
2 just the names. 2 MR. WILLITS: Richard Willits on behalf
3 MR. MERMELSTEIN: That's sufficient. And 3 of plaintiff C.M.A.
4 there is a cross notice for one of the state 4 MR. EDWARDS: And Brad Edwards on behalf
5 cases? 5 of plaintiffs E.W. and L.M.
6 MR. LANGINO: That would be our case. 6 Thereupon,
7 MR. MERMELSTEIN: So he's got that 7 ALFREDO RODRIGUEZ,
8 notice? Off the record. 8 having been first duly sworn or affirmed, was
9 (Thereupon, a discussion was held off the 9 examined and testified as follows:
10 record.) 10 DIRECT EXAMINATION
11 THE VIDEOGRAPHER: This is the case of 11 BY MR. MERMELSTEIN:
12 Jane Doe No. 2, plaintiff, versus Jeffrey 12 Q. Can you state your full name for the
13 Epstein, defendant. Jane Doe No. 3, 13 record, please?
14 plaintiff, versus Jeffrey Epstein, 14 A. My name is Alfredo Rodriguez.
15 defendant. Jane Doe No. 4, plaintiff, 15 Q. And where do you live?
16 versus Jeffrey Epstein, defendant. Jane Doe 16 A. I live in Kendall, 11349 Southwest 86
17 No. 5, plaintiff, versus Jeffrey Epstein, 17 Lane, Miami, Florida 33173.
18 defendant. Jane Doe No. 6, plaintiff, 18 Q. Are you currently employed?
19 versus Jeffrey Epstein, defendant. Jane Doe 19 A. No.
20 No. 7, plaintiff, versus Jeffrey Epstein, 20 Q. Okay. When was the last time you were
21 defendant. CMA, plaintiff, versus Jeffrey 21 employed?
22 Epstein, defendant. Jane Doe, plaintiff, 22 A. December of 2008.
23 versus Jeffrey Epstein, et al, defendant. 23 Q. Was there a time you were employed in
24 Jane Doe 3, plaintiff, versus Jeffrey 24 Palm Beach, Florida?
25 Epstein, et al, defendant. Jane Doe No. 25 A. Yes, I was.
Page 11 Page 13
1 101, plaintiff, versus Jeffrey Epstein, 1 Q. When was that?
2 defendant. Jane Doe No. 102, plaintiff, 2 A. I began on September of 2004.
3 versus Jeffrey Epstein defendant. B.B., 3 Q. And where were you employed?
4 plaintiff, versus Jeffrey Epstein, 4 A. I work -- well, I have several employers
5 defendant. 5 in Palm Beach. One of them was Jeffrey Epstein.
6 This is in the Circuit Court of the 15th 6 Q. By several employers in Palm Beach you
7 Judicial Circuit in and for Palm Beach 7 mean --
8 County, Florida. 8 A. Different employers.
9 This is the deposition of Alfredo 9 Q. At the same time?
10 Rodriguez. Today is July the 29th, starting 10 A. No, different times. From 2005 to 2006 I
11 time -- the year 2009, starting time 11 was employed by Dana Hammond.
12 approximately 11:16 a.m. 12 Q. Donna Hammond?
13 Will attorneys please state their 13 A. D-A-N-A, Hammond. Or Aimes is her single
14 appearance? 14 name. Dana Aimes Hammond.
15 MR. MERMELSTEIN: Stuart Mermelstein for 15 Q. Dana Aimes Hammond?
16 plaintiffs Jane Doe 2, Jane Doe 3, Jane Doe 16 A. Yeah.
17 4, Jane Doe 5, and Jane Doe 6, and Jane Doe 17 Q. That was in Palm Beach?
18 7. 18 A. Yes.
19 MR. EDWARDS: Brad Edwards for plaintiff 19 Q. And in September 2004 you were employed
20 Jane Doe. 20 by whom?
21 MR. LANGINO: Adam Langino on behalf of 21 A. Jeffrey Epstein.
22 plaintiff, B.B. 22 Q. Did Mr. Epstein employ you as an
23 MS. EZELL: Cathy Ezell on behalf of Jane 23 individual or through any business or corporate
24 Doe 101 and 102. 24 entity?
25 MR. CRITTON: Bob Critton on behalf of 25 A. As an individual.
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1 Q. And what was your position with Jeffrey 1 A. I moved to Florida in 1996.
2 Epstein? 2 Q. Between 1996 and 2006 when you started to
3 A. I was the household manager. 3 work for Mr. Epstein did you have household
4 Q. And what does the household manager do? 4 management jobs in that period?
5 A. Oversees all aspects of the maintenance 5 A. On and off, yes, in Fisher Island,
6 of the estate, payroll of the gardeners, 6 Florida.
7 scheduling staff and security, food, coordinating 7 Q. Fisher Island?
8 activities with the chef, and pilots, etc. 8 A. Yeah.
9 Q. I'm sorry, what was the last one? 9 Q. I take it that Barbara Goldberg
10 A. Activities with the pilots. 10 specializes in placing employees for wealthy
11 Q. Oh pilots. 11 households?
12 A. Yes. 12 A. Yes.
13 Q. What kind of activities do you coordinate 13 Q. Did you know Mr. Epstein before you began
14 with the pilots? 14 to work for him?
15 A. What time Mr. Epstein will arrive, how 15 A. No.
16 many cars will I need and so on and so forth. 16 Q. Did you interview with him?
17 Q. Was there a particular place that you 17 A. Yes, I did.
18 were employed? 18 Q. And what did the interview entail?
19 A. Yeah, I was employed by 358 El Brillo 19 A. He asked me what I did before, and he
20 Way. 20 wanted to know where my capabilities of running
21 Q. Did you have any other duties other than 21 his estate, and what was my salary potentials, we
22 what you've mentioned? 22 discuss the time he was going to be in the Island,
23 A. Driving. Well, I used to prepare coffee 23 et cetera.
24 for Mr. Epstein every morning, 6:30 in the 24 Q. What did he tell you at that time as to
25 morning. Other than that is little problems 25 the time he was going to be in the Island?
Page 15 Page 17
1 arise, you know, the maintenance, the 1 A. He will say he will be traveling on and
2 electricians, I have to deal with the contractors 2 off, and like when he's in the Island he needs a
3 on a daily basis. 3 lot of attention but when he's off I will be more
4 Q. Now, what is located at 358 El Brillo Way 4 relaxed.
5 in Palm Beach? 5 MR. EDWARDS: I'm sorry, Stuart, I'm
6 A. It's called the estate section of Palm 6 missing some of this just because the noise
7 Beach. It's off North Ocean Boulevard. 7 on the other end of Richard's phone.
8 Q. So is it a single-family residence? 8 Richard, do you have a mute or anything?
9 A. Yes, it is. 9 MR. WILLITS: I'm sorry?
10 Q. When you say you were a household 10 MR. EDWARDS: Do you have a mute or
11 manager, you were managing that residence? 11 anything? We're getting a lot of noise
12 A. Yes, sir. 12 coming out of the phone.
13 Q. And how did you come about obtaining this 13 MR. WILLITS: I'm sorry.
14 position as household manager? 14 THE VIDEOGRAPHER: Do you want to go off
15 A. Through an employment agency. 15 the record?
16 Q. Do you know which employment agency it 16 MR. EDWARDS: Sure.
17 was? 17 (Thereupon, a discussion was held off the
18 A. Barbara Goldberg. She has an agency 18 record.)
19 called Regal Domestics. 19 THE VIDEOGRAPHER: We're back on the
20 Q. Had you worked in household services 20 record.
21 before September of '04? 21 BY MR. MERMELSTEIN:
22 A. Yes. 22 Q. So Mr. Epstein told you that when he
23 Q. Did you work in Palm Beach before that? 23 wasn't there you would be more relaxed but when he
24 A. Long Island. 24 was there it would be more intense, I assume?
25 Q. When did you move from Long Island? 25 A. Yes.
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1 Q. And how often did he indicate he would be 1 A. We have guests that particular day and
2 in Palm Beach? 2 arrange, coordinate with the chef if I have to go
3 A. He will say once a month, like two weeks 3 buy the groceries, gas the cars. That was a
4 out of the month, something like that. This is a 4 routine everyday. Relay instructions to the
5 long time ago so I'm trying to remember the words. 5 housekeepers and the gardeners and the pool
6 Q. That's all right. You can only answer to 6 people. Arrange meals. This was done by the chef
7 the extent that you recall the information that's 7 but I was trying to be sure Mr. Epstein was fed at
8 asked for in the question. 8 his lunch time. And then of course through the
9 By the way, have you had your deposition 9 day he will give me instructions.
10 taken before? 10 Q. So he would give you instructions himself
11 A. I was subpoena by the State Attorney in 11 personally?
12 Palm Beach but not here. 12 A. Secretary.
13 Q. Did you give a transcribed statement to 13 Q. Okay. Now, let's go through who the
14 the State Attorney? 14 household staff was at the time that you started.
15 A. I believe it was recorded. I don't know 15 Who would you say worked under your
16 with this method but it was recorded. 16 supervision as the household manager?
17 Q. With a tape machine? 17 A. It was a Filipino lady by the name of
18 A. Yeah. 18 Louella. I don't recall her last name.
19 Q. Now, after you were interviewed did he 19 Q. Louella Rabuyo?
20 give you the job on the spot or did he call you 20 A. Yes, exactly, yes.
21 afterward? 21 Q. What did she do?
22 A. He hired me on the spot. 22 A. She would be the housekeeper in charge of
23 Q. What was your salary? 23 the laundry, cleaning the household, everything
24 A. 55,000. 24 inside the house.
25 Q. And when did you start to work for him? 25 Q. And who else?
Page 19 Page 21
1 A. I believe it was the last week of August 1 A. Jerome. Jerome Pierre was the gardener.
2 of 2004. 2 Q. And he was full-time?
3 Q. Now, I take it your day to day job duties 3 A. Full-time, yes.
4 were different from when he was there to when he 4 Q. Who else?
5 wasn't there. Correct? 5 A. And then we have a young lady who used to
6 A. Yes. 6 take care of the pool but I don't recall her name
7 Q. Let's take a day when he's there. What 7 right now. She used to come three times a week,
8 would your -- what would be your routine, what 8 sometimes four times. Most every day we used to
9 would your day entail? 9 have John Cassidy air conditioner came to the
10 A. Well, coffee at 6:30 in the morning. 10 house because it's hot and it's humid. What
11 Check the cars, you know, see -- he like the 11 contractor that's almost on a daily basis there.
12 cabana to be in his computer, I would be sure that 12 Q. Because there was problems with the air
13 the cabana was clean and, you know, tidy. 13 conditioner?
14 Q. I'm sorry, what does that have to do with 14 A. Well, the house is big, and all the house
15 the computer? 15 in Palm Beach need constant attention.
16 A. He would like to work in the cabana so I 16 Q. Okay.
17 would pay attention to that. 17 A. That's the full -- and the chef, David, I
18 Q. So he would go to the computer in the 18 can't remember his last name.
19 cabana and you would make sure that the cabana was 19 Q. Was it Mullen?
20 clean? 20 A. I don't recall, sir, right now.
21 A. Yes, sir. 21 Q. Muller. But his first name was David?
22 Q. So he had coffee at 6:30 a.m. Did he 22 A. David, yes.
23 start working immediately after that? 23 Q. Was there a butler as well?
24 A. Yes. 24 A. Well, I used to double as household
25 Q. Continue. What did you do then? 25 manager slash butler.
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1 Q. Was there a Michael Liffman that was 1 garlic, maybe something like that, you know,
2 hired as a butler at some point? 2 personal things.
3 A. That was before me. 3 Q. You mentioned Ms. Maxwell?
4 Q. Okay. Who was the household manager 4 A. Yes.
5 before you? 5 Q. Who is she?
6 A. I understand there were several in one 6 A. She was her companion.
7 year. There was Mike Friedman, there is Joe 7 Q. Whose companion?
8 Alessi. There was a couple of Filipino girls -- 8 A. Mr. Epstein.
9 no, they were from Bangladesh. I can't remember. 9 Q. By companion what do you mean?
10 I used to send his -- I used to forward his mail 10 A. Well, in the beginning I assume they were
11 to Maryland but I can't recall right now, sir. 11 husband and wife but, you know, they were not
12 Q. Okay. And at the time you took the job 12 married, but I treated her as such. Mrs. Maxwell
13 it was open, he didn't have anyone in that 13 was like the lady of the house.
14 position. Is that correct? 14 Q. Okay. So it was your understanding they
15 A. What I find is the staff from his house 15 were in a romantic relationship?
16 in Manhattan they gave me the briefing on what he 16 MR. CRITTON: Form.
17 likes and what he doesn't like. Belinda Retta 17 THE WITNESS: Something like that.
18 from Mrs. Maxwell, they were due to give me an 18 BY MR. MERMELSTEIN:
19 inside look because it was too much to learn in 19 Q. But they just weren't married?
20 48 hours so they were there handling the house 20 A. No, sir.
21 before me, so there were two couples. 21 Q. So you took instructions from Ms. Maxwell
22 Q. Two couples. All right. Let's walk 22 as well as Mr. Epstein?
23 through that. So the first day you come to work 23 A. She gave me the instructions of how to
24 you're basically you received some training? 24 run the household directly. In other words, she
25 A. Exactly. 25 likes the towels, the sheets and all that so I
Page 23 Page 25
1 Q. And tell us who provided that training? 1 give the instructions to Louella how to proceed
2 A. Joe-Joe is his nickname but he runs Mr. 2 with the cleaning and the upkeep of the house.
3 Epstein's estate in Manhattan as well as his wife. 3 Q. You went through the employees who worked
4 They were very nice people telling me because you 4 under you as household manager. Who would you say
5 have to understand, there is a lot of specifics, 5 was your direct supervisor, was it both
6 where to park the car, here and there, if the 6 Ms. Maxwell and Mr. Epstein?
7 plane lands here you have to park the Mercedes, 7 A. Mrs. Maxwell.
8 you know, very specific details, and he gave me an 8 Q. Was your supervisor?
9 inside of all of that. 9 A. Yes, sir.
10 Q. Okay. So you would pick up Mr. Epstein 10 Q. I think I interrupted you. You were
11 at the airport? 11 going through the daily routine, and I'm not sure
12 A. Yes. 12 you had completed going through what you would do
13 Q. And how long did this training last? 13 in a day.
14 A. Two or three days. 14 A. Until noon we have all the -- we knew
15 Q. Okay. And it was Joe-Joe and his wife? 15 that the food that was going to be served for
16 A. Joe-Joe, yes. 16 lunch and dinner. And then in the afternoon it
17 Q. You don't remember the last name or full 17 was open to shopping, maybe have to drive him to
18 names? 18 the airport to pick up somebody, or answering the
19 A. No, sir. 19 phones.
20 Q. Anything else you can remember that you 20 Q. Was there a procedure or protocol for
21 were told specifically regarding his preferences? 21 answering the phones?
22 A. He likes Columbian coffee, that's the 22 A. Yes, there was.
23 only type of coffee he drinks, and it was shipped 23 Q. And what was that?
24 from New York from Balducci's, stuff like that. 24 A. I couldn't relay the message directly to
25 Where to buy the groceries. And he's allergic to 25 Mr. Epstein but take message on a piece of paper
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1 with a copy. 1 A. Yes. Sometimes very short notice but,
2 Q. Were you the only one who was allowed to 2 yes, I was.
3 answer the phone? 3 Q. So that varied?
4 A. Yes. 4 A. Yes.
5 Q. I'm sorry, what would you do -- 5 Q. Who would give you that notice?
6 A. I would leave it on the counter next to 6 A. Mrs. Maxwell or Sarah or Larry, the
7 the kitchen so when I find that piece all crumbled 7 pilot.
8 I knew that Mr. Epstein saw the message, so we 8 Q. And then you would drive to pick them up
9 communicated like that. 9 at the airport?
10 Q. Now, you mentioned Mr. Epstein would give 10 A. Yes.
11 you instructions during the course of the day. 11 Q. And who traveled with him?
12 A. Through his assistant. 12 A. The three pilots and some guests.
13 Q. And his assistant was whom? 13 Q. What do you mean by guests?
14 A. Sarah Kellen. 14 A. He will have some friends from Harvard,
15 Q. But you didn't view her as your 15 he will have -- well, very important people that,
16 supervisor? 16 you know, friends, acquaintances from New York or
17 A. She take orders from Mrs. Maxwell but she 17 Europe because I was just told the number of
18 will tell me, Alfredo, we need to buy this, we 18 people was coming on the plane.
19 need to do this, and so and so was coming. I 19 Q. Were there people who were employed by
20 couldn't talk directly to Mr. Epstein. 20 him who came regularly?
21 Q. Okay. So any communications from Mr. 21 A. Yes.
22 Epstein always came through Ms. Kellen? 22 Q. And who would they be?
23 A. Or from the office in New York. Lesley, 23 A. Like I said, they were the pilots, Larry
24 his secretary, or somebody else, the comptroller, 24 Bisosky, George, and I don't remember the flight
25 the architect, any lawyer. 25 engineer, and he will have two girlfriends.
Page 27 Page 29
1 Q. Lawyer, what kind of instructions would 1 Q. The pilot would have two girlfriends?
2 you get from lawyers? 2 A. Mr. Epstein. This is all people coming
3 A. We used to have a lot of time, for 3 in the plane together.
4 instance, the dock construction, you need to have 4 Q. Right. What do you mean by girlfriends?
5 a lot of permits in Palm Beach so they were there 5 A. Friends, you know, that he was always
6 for that reason. 6 having friends that he will befriend in New York,
7 Q. Okay. Now, so you would interact with 7 I don't know, or some other places.
8 the staff from New York and that would include I 8 But I was just told -- my concern was how
9 think you said Lesley? 9 many people I have to feed, how many cars do I
10 A. Lesley, Bella. 10 need to transport these people from the airport to
11 Q. What was Lesley's position? 11 the house, and to arrange accommodations in the
12 A. Lesley is the secretary, secretary to Mr. 12 house.
13 Epstein. 13 Q. What about Sarah Kellen, did she travel
14 Q. Okay. Is that Lesley Groff? 14 with him?
15 A. I believe it was, I don't remember the 15 A. Yes.
16 last name. 16 Q. So she was on the plane?
17 Q. Bella, who was Bella? 17 A. Yes.
18 A. Bella was the assistant comptroller. 18 MR. CRITTON: Form.
19 Q. Anyone else that you dealt with in New 19 BY MR. MERMELSTEIN:
20 York? 20 Q. And Ms. Maxwell?
21 A. Doug Shadow was the architect and he used 21 MR. CRITTON: Form.
22 to come to the house in a regular basis because we 22 THE WITNESS: No, she will have different
23 used to have a lot of projects going on. 23 plane.
24 Q. Okay. Would you get advance notice when 24 BY MR. MERMELSTEIN:
25 Mr. Epstein was going to arrive in Palm Beach? 25 Q. Okay.
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1 A. She will rent and Mr. Epstein will fly 1 movies.
2 his own plane. 2 BY MR. MERMELSTEIN:
3 Q. Did you also go to the airport to pick up 3 Q. Did you drive them to the movies?
4 Ms. Maxwell? 4 A. Yes. Or sometimes they would take one of
5 A. Yes. 5 the cars. Comedy clubs.
6 Q. Did she travel with anyone on a regular 6 Q. Comedy clubs?
7 basis when she came in? 7 A. In Palm Beach, West Palm Beach.
8 A. No. 8 Q. What did they do in the house?
9 Q. She was usually alone? 9 A. They will be on the internet most of the
10 A. (Shakes head.) 10 time, by the pool. I think they were having a
11 Q. Now, going back to Mr. Epstein when he 11 good time.
12 traveled, these girlfriends that Mr. Epstein had, 12 Q. Could they use any of the computers in
13 you said there were usually two? 13 the house?
14 A. Two, three, you know. 14 A. Yes.
15 Q. And did you know who they were or did you 15 Q. About how many computers did he have?
16 ever talk to them? 16 MR. CRITTON: Form.
17 A. No, I never seen them before. 17 THE WITNESS: Five or six and plus
18 Q. So each time he came it would be 18 laptops, you know, more or less.
19 different girls? 19 BY MR. MERMELSTEIN:
20 MR. CRITTON: Form. 20 Q. What about Sarah Kellen, did she stay in
21 THE WITNESS: Yes, sometimes it's the 21 the house during that two week period as well?
22 same. 22 A. Yes.
23 BY MR. MERMELSTEIN: 23 Q. And they all had their own bedroom?
24 Q. Do you remember any of their names? 24 A. Yes.
25 A. No, sir. 25 Q. How many bedrooms were in the house?
Page 31 Page 33
1 Q. And would they stay at the El Brillo Way 1 A. Master bedroom plus I think it was four
2 residence until he left? 2 extra bedrooms.
3 A. Yes. 3 Q. And when Ms. Maxwell, she would arrive at
4 Q. So they were given a bedroom? 4 some point during this two week period?
5 A. Yes. 5 MR. CRITTON: Form.
6 Q. Did you know how old these girls were? 6 THE WITNESS: Yes.
7 A. No, sir. 7 BY MR. MERMELSTEIN:
8 Q. Did they appear to be young to you? 8 Q. But she would come and leave at different
9 MR. CRITTON: Form. 9 times?
10 THE WITNESS: They were young but, you 10 A. Yes.
11 know, I have two daughters so I believe they 11 Q. And where would she sleep?
12 were over 20. 12 A. Sometimes in the master bedroom,
13 BY MR. MERMELSTEIN: 13 sometimes in the yellow room.
14 Q. Did you at any point get to know how Mr. 14 Q. Other room?
15 Epstein came to know any of these girls? 15 A. Yellow room.
16 A. No, sir. 16 Q. What's the yellow room?
17 Q. You had no idea? 17 A. We used to give them colors because they
18 A. No. 18 will all have different bathrooms so we need to
19 Q. And so Mr. Epstein would typically stay 19 take care of towels and stuff like that.
20 for two weeks or so? 20 Q. So each of the four other bedrooms had a
21 A. I will say that. 21 color?
22 Q. And what did these girls who came with 22 A. Yes. Blue room, yellow room, pink room,
23 him, what did they do during that two week period? 23 some other, I don't remember.
24 MR. CRITTON: Form. 24 Q. Now, were there individuals who didn't
25 THE WITNESS: They would go to the 25 stay in the house but came to the house during the
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1 course of the day? 1 leave.
2 MR. CRITTON: Form. 2 Q. How far in advance would she tell you so
3 THE WITNESS: Yes. 3 and so is coming?
4 BY MR. MERMELSTEIN: 4 A. One hour, sometimes half an hour.
5 Q. And who would these be? 5 Q. Okay. And would she tell you the
6 A. The architect, Doug Shadow, some lawyer 6 person's name or would she just say a masseuse?
7 like I said for some business, masseuse, sometimes 7 A. She will say Johanna is coming, so I will
8 we have masseuse. We have guests, you know, 8 meet Johanna at the door and I will show her
9 sometimes David Copperfield would go to the house 9 inside the house because we used to have a code to
10 and have dinner. 10 get inside the house and I would leave and go to
11 Q. David Copperfield. So David Copperfield 11 the staff house or do my duties.
12 obviously is a famous person. Right? 12 Q. Is Johan
EXHIBIT 13
PART 1
Case 1:15-cv-07433-LAP Document 55-21 Filed 03/14/16 Page 2 of 69
Page 1
1 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
3 JANE DOE NO. 2, Case No: 08-CV-80119
4 Plaintiff,
5 Vs
6 JEFFREY EPSTEIN,
7 Defendant.
___________________/
8
JANE DOE NO. 3, Case NO: 08-CV-80232
9
Plaintiff,
10 Vs
11 JEFFREY EPSTEIN,
12 Defendant.
___________________/
13
JANE DOE NO. 4, Case No: 08-CV-80380
14
Plaintiff,
15
Vs.
16
JEFFREY EPSTEIN,
17
Defendant.
18 ___________________/
19 JANE DOE NO. 5, Case No: 08-CV-80381
20 Plaintiff,
21 Vs
22 JEFFREY EPSTEIN,
23 Defendant.
___________________/
24
25
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1 JANE DOE NO. 6, Case No: 08-CV-80994 1 VIDEOTAPED
2 Plaintiff, 2 DEPOSITION
3 Vs 3 of
4 JEFFREY EPSTEIN, 4 ALFREDO RODRIGUEZ
5 Defendant. 5
___________________/ 6 taken on behalf of the Plaintiffs pursuant
6 7 to a Re-Notice of Taking Deposition (Duces Tecum)
JANE DOE NO. 7, Case No. 08-CV-80993 8
7 9 ---
Plaintiff, 10 APPEARANCES:
8 11
Vs MERMELSTEIN & HOROWITZ, P.A.
9 12 BY: STUART MERMELSTEIN, ESQ.
JEFFREY EPSTEIN, 18205 Biscayne Boulevard
10
13 Suite 2218
Defendant.
Miami, Florida 33160
11 ___________________/
14 Attorney for Jane Doe 2, 3, 4, 5,
12 C.M.A., Case No: 08-CV-80811
6, and 7.
13 Plaintiff,
15
14 Vs
15 JEFFREY EPSTEIN,
16 ROTHSTEIN ROSENFELDT ADLER
16 Defendant. BY: BRAD J. EDWARDS, ESQ., and
___________________/ 17 CARA HOLMES, ESQ.
17 Las Olas City Centre
JANE DOE, Case No: 08-CV-80893 18 Suite 1650
18 401 East Las Olas Boulevard
Plaintiff, 19 Fort Lauderdale, Florida 33301
19 Attorney for Jane Doe and E.W.
Vs 20 And L.M.
20 21
JEFFREY EPSTEIN, PODHURST ORSECK
21 22 BY: KATHERINE W. EZELL
Defendant. 25 West Flagler Street
22 ___________________/ 23 Suite 800
23 Miami, Florida 33130
24 24 Attorney for Jane Doe 101 and 102.
25 25
Page 3 Page 5
1 JANE DOE NO. II, Case No: 08-CV-80469 1
2 Plaintiff, APPEARANCES:
3 Vs 2
3 LEOPOLD-KUVIN
4 JEFFREY EPSTEIN,
ADAM J. LANGINO, ESQ.
5 Defendant. 4 2925 PGA Boulevard
___________________/ Suite 200
6 5 Palm Beach Gardens, Florida 33410
JANE DOE NO. 101, Case No: 09-CV-80591 Attorney for B.B.
7 6
Plaintiff, 7 RICHARD WILLITS, ESQ.
8 2290 10th Avenue North
Vs 8 Suite 404
Lake Worth, Florida 33461
9
9 Attorney for C.M.A.
JEFFREY EPSTEIN, 10
10 BURMAN, CRITTON, LUTTIER &
Defendant. 11 COLEMAN, LLP
11 ___________________/ BY: ROBERT CRITTON, ESQ.
12 JANE DOE NO. 102, Case No: 09-CV-80656 12 515 North Flagler Drive
13 Plaintiff, Suite 400
14 Vs 13 West Palm Beach, Florida 33401
Attorney for Jeffrey Epstein.
15 JEFFREY EPSTEIN,
14
16 Defendant. 15
___________________/ 16
17 ALSO PRESENT:
18 17
19 JOE LANGSAM, VIDEOGRAPHER
20 1031 Ives Dairy Road 18
Suite 228 19
- - -
21 North Miami, Florida
20
July 29, 2009
21
22 11:00 a.m. to 5:30 p.m. 22
23 23
24 24
25 25
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1 INDEX OF EXAMINATION 1 Doe right here on the copy you gave me. I'm
2 2 missing which Jane Doe this is.
WITNESS DIRECT CROSS
3
3 They're all different case numbers. Do
ALFREDO RODRIGUEZ 4 you want me to go through each case number?
4 5 MR. CRITTON: I'm going to note my
(By Mr. Mermelstein) 12 6 objection. Obviously if this deposition
5 7 gets played -- not obviously, I'm going to
(By Mr. Edwards) 157
6
8 object to the litany of each one so I don't
(By Mr. Langino) 260 9 know how we can separate it out. Maybe if
7 10 and when at the time of trial and depending
8 11 on how the Court determines what comes in
9 12 and what doesn't with regard to the
10 INDEX OF EXHIBITS
11 EXHIBITS PAGE
13 consolidated aspects of this. I have no
12 1 Message pad 72 14 great idea other than just saying Jane Doe
13 2 Documents 115 15 versus Epstein, et al, or something like
14 16 that, or Jane Doe, et al.
15 17 MS. EZELL: Couldn't we just say and
16
17
18 those cases which have been consolidated
18 19 with it for Discovery purposes?
19 20 MR. EDWARDS: Although there is cases
20 21 here that have cross noticed this from state
21 22 court that haven't been consolidated so that
22
23
23 may not work. You may have to read them
24 24 all, if it works out your way that will just
25 25 get edited out, at least he will have read
Page 7 Page 9
1 Deposition taken before MICHELLE PAYNE, Court 1 that caption, every caption. Right? Is
2 Reporter and Notary Public in and for the State of 2 there a better suggestion?
3 Florida at Large, in the above cause. 3 MR. CRITTON: No. There may be a better
4 - - - 4 suggestion if he starts this is such and
5 THE VIDEOGRAPHER: This is the case of 5 such day, it's the deposition of Mr.
6 Jane Doe No. 2, plaintiff, versus Jeffrey 6 Rodriguez in the case such and such, and we
7 Epstein, defendant. Jane Doe No. 3, 7 can almost fill it in depending on which
8 plaintiff, versus Jeffrey Epstein, 8 tape it goes, how it fills in, at least
9 defendant. Jane Doe No. 4, plaintiff, 9 we'll have the context of the first and
10 versus Jeffrey Epstein, defendant. And Jane 10 depending on whether the Judge reads it in
11 Doe No. 5, plaintiff, versus Jeffrey 11 from a consolidated or they all come
12 Epstein, defendant. Jane Doe No. 6, 12 related, I have no great idea.
13 plaintiff, versus Jeffrey Epstein, 13 MR. EDWARDS: I was thinking if he read
14 defendant. Jane Doe No. 7, plaintiff, 14 every one of them and it was the seventh in
15 versus Jeffrey Epstein, defendant. CMA, 15 line then you just would edit it so you
16 plaintiff, versus Jeffrey Epstein, 16 would only read that one.
17 defendant. And Jane Doe, plaintiff, versus 17 MR. CRITTON: I'm okay with that too.
18 Jeffrey Epstein, et al, defendant. And Jane 18 THE VIDEOGRAPHER: On page number three
19 Doe -- is there a shorter thing that we can 19 there is something missing on the top here.
20 do here? It's also missing this one right 20 Do you want me to read each case number
21 here. 21 separately?
22 MR. MERMELSTEIN: Do we have a problem 22 MR. MERMELSTEIN: I don't think it's
23 with saying Jane Doe 2 and the Epstein and 23 necessary.
24 related cases? 24 MR. EDWARDS: I don't think it's
25 THE VIDEOGRAPHER: I'm missing this Jane 25 necessary either.
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1 THE VIDEOGRAPHER: So just go through 1 Jeffrey Epstein.
2 just the names. 2 MR. WILLITS: Richard Willits on behalf
3 MR. MERMELSTEIN: That's sufficient. And 3 of plaintiff C.M.A.
4 there is a cross notice for one of the state 4 MR. EDWARDS: And Brad Edwards on behalf
5 cases? 5 of plaintiffs E.W. and L.M.
6 MR. LANGINO: That would be our case. 6 Thereupon,
7 MR. MERMELSTEIN: So he's got that 7 ALFREDO RODRIGUEZ,
8 notice? Off the record. 8 having been first duly sworn or affirmed, was
9 (Thereupon, a discussion was held off the 9 examined and testified as follows:
10 record.) 10 DIRECT EXAMINATION
11 THE VIDEOGRAPHER: This is the case of 11 BY MR. MERMELSTEIN:
12 Jane Doe No. 2, plaintiff, versus Jeffrey 12 Q. Can you state your full name for the
13 Epstein, defendant. Jane Doe No. 3, 13 record, please?
14 plaintiff, versus Jeffrey Epstein, 14 A. My name is Alfredo Rodriguez.
15 defendant. Jane Doe No. 4, plaintiff, 15 Q. And where do you live?
16 versus Jeffrey Epstein, defendant. Jane Doe 16 A. I live in Kendall, 11349 Southwest 86
17 No. 5, plaintiff, versus Jeffrey Epstein, 17 Lane, Miami, Florida 33173.
18 defendant. Jane Doe No. 6, plaintiff, 18 Q. Are you currently employed?
19 versus Jeffrey Epstein, defendant. Jane Doe 19 A. No.
20 No. 7, plaintiff, versus Jeffrey Epstein, 20 Q. Okay. When was the last time you were
21 defendant. CMA, plaintiff, versus Jeffrey 21 employed?
22 Epstein, defendant. Jane Doe, plaintiff, 22 A. December of 2008.
23 versus Jeffrey Epstein, et al, defendant. 23 Q. Was there a time you were employed in
24 Jane Doe 3, plaintiff, versus Jeffrey 24 Palm Beach, Florida?
25 Epstein, et al, defendant. Jane Doe No. 25 A. Yes, I was.
Page 11 Page 13
1 101, plaintiff, versus Jeffrey Epstein, 1 Q. When was that?
2 defendant. Jane Doe No. 102, plaintiff, 2 A. I began on September of 2004.
3 versus Jeffrey Epstein defendant. B.B., 3 Q. And where were you employed?
4 plaintiff, versus Jeffrey Epstein, 4 A. I work -- well, I have several employers
5 defendant. 5 in Palm Beach. One of them was Jeffrey Epstein.
6 This is in the Circuit Court of the 15th 6 Q. By several employers in Palm Beach you
7 Judicial Circuit in and for Palm Beach 7 mean --
8 County, Florida. 8 A. Different employers.
9 This is the deposition of Alfredo 9 Q. At the same time?
10 Rodriguez. Today is July the 29th, starting 10 A. No, different times. From 2005 to 2006 I
11 time -- the year 2009, starting time 11 was employed by Dana Hammond.
12 approximately 11:16 a.m. 12 Q. Donna Hammond?
13 Will attorneys please state their 13 A. D-A-N-A, Hammond. Or Aimes is her single
14 appearance? 14 name. Dana Aimes Hammond.
15 MR. MERMELSTEIN: Stuart Mermelstein for 15 Q. Dana Aimes Hammond?
16 plaintiffs Jane Doe 2, Jane Doe 3, Jane Doe 16 A. Yeah.
17 4, Jane Doe 5, and Jane Doe 6, and Jane Doe 17 Q. That was in Palm Beach?
18 7. 18 A. Yes.
19 MR. EDWARDS: Brad Edwards for plaintiff 19 Q. And in September 2004 you were employed
20 Jane Doe. 20 by whom?
21 MR. LANGINO: Adam Langino on behalf of 21 A. Jeffrey Epstein.
22 plaintiff, B.B. 22 Q. Did Mr. Epstein employ you as an
23 MS. EZELL: Cathy Ezell on behalf of Jane 23 individual or through any business or corporate
24 Doe 101 and 102. 24 entity?
25 MR. CRITTON: Bob Critton on behalf of 25 A. As an individual.
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1 Q. And what was your position with Jeffrey 1 A. I moved to Florida in 1996.
2 Epstein? 2 Q. Between 1996 and 2006 when you started to
3 A. I was the household manager. 3 work for Mr. Epstein did you have household
4 Q. And what does the household manager do? 4 management jobs in that period?
5 A. Oversees all aspects of the maintenance 5 A. On and off, yes, in Fisher Island,
6 of the estate, payroll of the gardeners, 6 Florida.
7 scheduling staff and security, food, coordinating 7 Q. Fisher Island?
8 activities with the chef, and pilots, etc. 8 A. Yeah.
9 Q. I'm sorry, what was the last one? 9 Q. I take it that Barbara Goldberg
10 A. Activities with the pilots. 10 specializes in placing employees for wealthy
11 Q. Oh pilots. 11 households?
12 A. Yes. 12 A. Yes.
13 Q. What kind of activities do you coordinate 13 Q. Did you know Mr. Epstein before you began
14 with the pilots? 14 to work for him?
15 A. What time Mr. Epstein will arrive, how 15 A. No.
16 many cars will I need and so on and so forth. 16 Q. Did you interview with him?
17 Q. Was there a particular place that you 17 A. Yes, I did.
18 were employed? 18 Q. And what did the interview entail?
19 A. Yeah, I was employed by 358 El Brillo 19 A. He asked me what I did before, and he
20 Way. 20 wanted to know where my capabilities of running
21 Q. Did you have any other duties other than 21 his estate, and what was my salary potentials, we
22 what you've mentioned? 22 discuss the time he was going to be in the Island,
23 A. Driving. Well, I used to prepare coffee 23 et cetera.
24 for Mr. Epstein every morning, 6:30 in the 24 Q. What did he tell you at that time as to
25 morning. Other than that is little problems 25 the time he was going to be in the Island?
Page 15 Page 17
1 arise, you know, the maintenance, the 1 A. He will say he will be traveling on and
2 electricians, I have to deal with the contractors 2 off, and like when he's in the Island he needs a
3 on a daily basis. 3 lot of attention but when he's off I will be more
4 Q. Now, what is located at 358 El Brillo Way 4 relaxed.
5 in Palm Beach? 5 MR. EDWARDS: I'm sorry, Stuart, I'm
6 A. It's called the estate section of Palm 6 missing some of this just because the noise
7 Beach. It's off North Ocean Boulevard. 7 on the other end of Richard's phone.
8 Q. So is it a single-family residence? 8 Richard, do you have a mute or anything?
9 A. Yes, it is. 9 MR. WILLITS: I'm sorry?
10 Q. When you say you were a household 10 MR. EDWARDS: Do you have a mute or
11 manager, you were managing that residence? 11 anything? We're getting a lot of noise
12 A. Yes, sir. 12 coming out of the phone.
13 Q. And how did you come about obtaining this 13 MR. WILLITS: I'm sorry.
14 position as household manager? 14 THE VIDEOGRAPHER: Do you want to go off
15 A. Through an employment agency. 15 the record?
16 Q. Do you know which employment agency it 16 MR. EDWARDS: Sure.
17 was? 17 (Thereupon, a discussion was held off the
18 A. Barbara Goldberg. She has an agency 18 record.)
19 called Regal Domestics. 19 THE VIDEOGRAPHER: We're back on the
20 Q. Had you worked in household services 20 record.
21 before September of '04? 21 BY MR. MERMELSTEIN:
22 A. Yes. 22 Q. So Mr. Epstein told you that when he
23 Q. Did you work in Palm Beach before that? 23 wasn't there you would be more relaxed but when he
24 A. Long Island. 24 was there it would be more intense, I assume?
25 Q. When did you move from Long Island? 25 A. Yes.
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1 Q. And how often did he indicate he would be 1 A. We have guests that particular day and
2 in Palm Beach? 2 arrange, coordinate with the chef if I have to go
3 A. He will say once a month, like two weeks 3 buy the groceries, gas the cars. That was a
4 out of the month, something like that. This is a 4 routine everyday. Relay instructions to the
5 long time ago so I'm trying to remember the words. 5 housekeepers and the gardeners and the pool
6 Q. That's all right. You can only answer to 6 people. Arrange meals. This was done by the chef
7 the extent that you recall the information that's 7 but I was trying to be sure Mr. Epstein was fed at
8 asked for in the question. 8 his lunch time. And then of course through the
9 By the way, have you had your deposition 9 day he will give me instructions.
10 taken before? 10 Q. So he would give you instructions himself
11 A. I was subpoena by the State Attorney in 11 personally?
12 Palm Beach but not here. 12 A. Secretary.
13 Q. Did you give a transcribed statement to 13 Q. Okay. Now, let's go through who the
14 the State Attorney? 14 household staff was at the time that you started.
15 A. I believe it was recorded. I don't know 15 Who would you say worked under your
16 with this method but it was recorded. 16 supervision as the household manager?
17 Q. With a tape machine? 17 A. It was a Filipino lady by the name of
18 A. Yeah. 18 Louella. I don't recall her last name.
19 Q. Now, after you were interviewed did he 19 Q. Louella Rabuyo?
20 give you the job on the spot or did he call you 20 A. Yes, exactly, yes.
21 afterward? 21 Q. What did she do?
22 A. He hired me on the spot. 22 A. She would be the housekeeper in charge of
23 Q. What was your salary? 23 the laundry, cleaning the household, everything
24 A. 55,000. 24 inside the house.
25 Q. And when did you start to work for him? 25 Q. And who else?
Page 19 Page 21
1 A. I believe it was the last week of August 1 A. Jerome. Jerome Pierre was the gardener.
2 of 2004. 2 Q. And he was full-time?
3 Q. Now, I take it your day to day job duties 3 A. Full-time, yes.
4 were different from when he was there to when he 4 Q. Who else?
5 wasn't there. Correct? 5 A. And then we have a young lady who used to
6 A. Yes. 6 take care of the pool but I don't recall her name
7 Q. Let's take a day when he's there. What 7 right now. She used to come three times a week,
8 would your -- what would be your routine, what 8 sometimes four times. Most every day we used to
9 would your day entail? 9 have John Cassidy air conditioner came to the
10 A. Well, coffee at 6:30 in the morning. 10 house because it's hot and it's humid. What
11 Check the cars, you know, see -- he like the 11 contractor that's almost on a daily basis there.
12 cabana to be in his computer, I would be sure that 12 Q. Because there was problems with the air
13 the cabana was clean and, you know, tidy. 13 conditioner?
14 Q. I'm sorry, what does that have to do with 14 A. Well, the house is big, and all the house
15 the computer? 15 in Palm Beach need constant attention.
16 A. He would like to work in the cabana so I 16 Q. Okay.
17 would pay attention to that. 17 A. That's the full -- and the chef, David, I
18 Q. So he would go to the computer in the 18 can't remember his last name.
19 cabana and you would make sure that the cabana was 19 Q. Was it Mullen?
20 clean? 20 A. I don't recall, sir, right now.
21 A. Yes, sir. 21 Q. Muller. But his first name was David?
22 Q. So he had coffee at 6:30 a.m. Did he 22 A. David, yes.
23 start working immediately after that? 23 Q. Was there a butler as well?
24 A. Yes. 24 A. Well, I used to double as household
25 Q. Continue. What did you do then? 25 manager slash butler.
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1 Q. Was there a Michael Liffman that was 1 garlic, maybe something like that, you know,
2 hired as a butler at some point? 2 personal things.
3 A. That was before me. 3 Q. You mentioned Ms. Maxwell?
4 Q. Okay. Who was the household manager 4 A. Yes.
5 before you? 5 Q. Who is she?
6 A. I understand there were several in one 6 A. She was her companion.
7 year. There was Mike Friedman, there is Joe 7 Q. Whose companion?
8 Alessi. There was a couple of Filipino girls -- 8 A. Mr. Epstein.
9 no, they were from Bangladesh. I can't remember. 9 Q. By companion what do you mean?
10 I used to send his -- I used to forward his mail 10 A. Well, in the beginning I assume they were
11 to Maryland but I can't recall right now, sir. 11 husband and wife but, you know, they were not
12 Q. Okay. And at the time you took the job 12 married, but I treated her as such. Mrs. Maxwell
13 it was open, he didn't have anyone in that 13 was like the lady of the house.
14 position. Is that correct? 14 Q. Okay. So it was your understanding they
15 A. What I find is the staff from his house 15 were in a romantic relationship?
16 in Manhattan they gave me the briefing on what he 16 MR. CRITTON: Form.
17 likes and what he doesn't like. Belinda Retta 17 THE WITNESS: Something like that.
18 from Mrs. Maxwell, they were due to give me an 18 BY MR. MERMELSTEIN:
19 inside look because it was too much to learn in 19 Q. But they just weren't married?
20 48 hours so they were there handling the house 20 A. No, sir.
21 before me, so there were two couples. 21 Q. So you took instructions from Ms. Maxwell
22 Q. Two couples. All right. Let's walk 22 as well as Mr. Epstein?
23 through that. So the first day you come to work 23 A. She gave me the instructions of how to
24 you're basically you received some training? 24 run the household directly. In other words, she
25 A. Exactly. 25 likes the towels, the sheets and all that so I
Page 23 Page 25
1 Q. And tell us who provided that training? 1 give the instructions to Louella how to proceed
2 A. Joe-Joe is his nickname but he runs Mr. 2 with the cleaning and the upkeep of the house.
3 Epstein's estate in Manhattan as well as his wife. 3 Q. You went through the employees who worked
4 They were very nice people telling me because you 4 under you as household manager. Who would you say
5 have to understand, there is a lot of specifics, 5 was your direct supervisor, was it both
6 where to park the car, here and there, if the 6 Ms. Maxwell and Mr. Epstein?
7 plane lands here you have to park the Mercedes, 7 A. Mrs. Maxwell.
8 you know, very specific details, and he gave me an 8 Q. Was your supervisor?
9 inside of all of that. 9 A. Yes, sir.
10 Q. Okay. So you would pick up Mr. Epstein 10 Q. I think I interrupted you. You were
11 at the airport? 11 going through the daily routine, and I'm not sure
12 A. Yes. 12 you had completed going through what you would do
13 Q. And how long did this training last? 13 in a day.
14 A. Two or three days. 14 A. Until noon we have all the -- we knew
15 Q. Okay. And it was Joe-Joe and his wife? 15 that the food that was going to be served for
16 A. Joe-Joe, yes. 16 lunch and dinner. And then in the afternoon it
17 Q. You don't remember the last name or full 17 was open to shopping, maybe have to drive him to
18 names? 18 the airport to pick up somebody, or answering the
19 A. No, sir. 19 phones.
20 Q. Anything else you can remember that you 20 Q. Was there a procedure or protocol for
21 were told specifically regarding his preferences? 21 answering the phones?
22 A. He likes Columbian coffee, that's the 22 A. Yes, there was.
23 only type of coffee he drinks, and it was shipped 23 Q. And what was that?
24 from New York from Balducci's, stuff like that. 24 A. I couldn't relay the message directly to
25 Where to buy the groceries. And he's allergic to 25 Mr. Epstein but take message on a piece of paper
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1 with a copy. 1 A. Yes. Sometimes very short notice but,
2 Q. Were you the only one who was allowed to 2 yes, I was.
3 answer the phone? 3 Q. So that varied?
4 A. Yes. 4 A. Yes.
5 Q. I'm sorry, what would you do -- 5 Q. Who would give you that notice?
6 A. I would leave it on the counter next to 6 A. Mrs. Maxwell or Sarah or Larry, the
7 the kitchen so when I find that piece all crumbled 7 pilot.
8 I knew that Mr. Epstein saw the message, so we 8 Q. And then you would drive to pick them up
9 communicated like that. 9 at the airport?
10 Q. Now, you mentioned Mr. Epstein would give 10 A. Yes.
11 you instructions during the course of the day. 11 Q. And who traveled with him?
12 A. Through his assistant. 12 A. The three pilots and some guests.
13 Q. And his assistant was whom? 13 Q. What do you mean by guests?
14 A. Sarah Kellen. 14 A. He will have some friends from Harvard,
15 Q. But you didn't view her as your 15 he will have -- well, very important people that,
16 supervisor? 16 you know, friends, acquaintances from New York or
17 A. She take orders from Mrs. Maxwell but she 17 Europe because I was just told the number of
18 will tell me, Alfredo, we need to buy this, we 18 people was coming on the plane.
19 need to do this, and so and so was coming. I 19 Q. Were there people who were employed by
20 couldn't talk directly to Mr. Epstein. 20 him who came regularly?
21 Q. Okay. So any communications from Mr. 21 A. Yes.
22 Epstein always came through Ms. Kellen? 22 Q. And who would they be?
23 A. Or from the office in New York. Lesley, 23 A. Like I said, they were the pilots, Larry
24 his secretary, or somebody else, the comptroller, 24 Bisosky, George, and I don't remember the flight
25 the architect, any lawyer. 25 engineer, and he will have two girlfriends.
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1 Q. Lawyer, what kind of instructions would 1 Q. The pilot would have two girlfriends?
2 you get from lawyers? 2 A. Mr. Epstein. This is all people coming
3 A. We used to have a lot of time, for 3 in the plane together.
4 instance, the dock construction, you need to have 4 Q. Right. What do you mean by girlfriends?
5 a lot of permits in Palm Beach so they were there 5 A. Friends, you know, that he was always
6 for that reason. 6 having friends that he will befriend in New York,
7 Q. Okay. Now, so you would interact with 7 I don't know, or some other places.
8 the staff from New York and that would include I 8 But I was just told -- my concern was how
9 think you said Lesley? 9 many people I have to feed, how many cars do I
10 A. Lesley, Bella. 10 need to transport these people from the airport to
11 Q. What was Lesley's position? 11 the house, and to arrange accommodations in the
12 A. Lesley is the secretary, secretary to Mr. 12 house.
13 Epstein. 13 Q. What about Sarah Kellen, did she travel
14 Q. Okay. Is that Lesley Groff? 14 with him?
15 A. I believe it was, I don't remember the 15 A. Yes.
16 last name. 16 Q. So she was on the plane?
17 Q. Bella, who was Bella? 17 A. Yes.
18 A. Bella was the assistant comptroller. 18 MR. CRITTON: Form.
19 Q. Anyone else that you dealt with in New 19 BY MR. MERMELSTEIN:
20 York? 20 Q. And Ms. Maxwell?
21 A. Doug Shadow was the architect and he used 21 MR. CRITTON: Form.
22 to come to the house in a regular basis because we 22 THE WITNESS: No, she will have different
23 used to have a lot of projects going on. 23 plane.
24 Q. Okay. Would you get advance notice when 24 BY MR. MERMELSTEIN:
25 Mr. Epstein was going to arrive in Palm Beach? 25 Q. Okay.
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1 A. She will rent and Mr. Epstein will fly 1 movies.
2 his own plane. 2 BY MR. MERMELSTEIN:
3 Q. Did you also go to the airport to pick up 3 Q. Did you drive them to the movies?
4 Ms. Maxwell? 4 A. Yes. Or sometimes they would take one of
5 A. Yes. 5 the cars. Comedy clubs.
6 Q. Did she travel with anyone on a regular 6 Q. Comedy clubs?
7 basis when she came in? 7 A. In Palm Beach, West Palm Beach.
8 A. No. 8 Q. What did they do in the house?
9 Q. She was usually alone? 9 A. They will be on the internet most of the
10 A. (Shakes head.) 10 time, by the pool. I think they were having a
11 Q. Now, going back to Mr. Epstein when he 11 good time.
12 traveled, these girlfriends that Mr. Epstein had, 12 Q. Could they use any of the computers in
13 you said there were usually two? 13 the house?
14 A. Two, three, you know. 14 A. Yes.
15 Q. And did you know who they were or did you 15 Q. About how many computers did he have?
16 ever talk to them? 16 MR. CRITTON: Form.
17 A. No, I never seen them before. 17 THE WITNESS: Five or six and plus
18 Q. So each time he came it would be 18 laptops, you know, more or less.
19 different girls? 19 BY MR. MERMELSTEIN:
20 MR. CRITTON: Form. 20 Q. What about Sarah Kellen, did she stay in
21 THE WITNESS: Yes, sometimes it's the 21 the house during that two week period as well?
22 same. 22 A. Yes.
23 BY MR. MERMELSTEIN: 23 Q. And they all had their own bedroom?
24 Q. Do you remember any of their names? 24 A. Yes.
25 A. No, sir. 25 Q. How many bedrooms were in the house?
Page 31 Page 33
1 Q. And would they stay at the El Brillo Way 1 A. Master bedroom plus I think it was four
2 residence until he left? 2 extra bedrooms.
3 A. Yes. 3 Q. And when Ms. Maxwell, she would arrive at
4 Q. So they were given a bedroom? 4 some point during this two week period?
5 A. Yes. 5 MR. CRITTON: Form.
6 Q. Did you know how old these girls were? 6 THE WITNESS: Yes.
7 A. No, sir. 7 BY MR. MERMELSTEIN:
8 Q. Did they appear to be young to you? 8 Q. But she would come and leave at different
9 MR. CRITTON: Form. 9 times?
10 THE WITNESS: They were young but, you 10 A. Yes.
11 know, I have two daughters so I believe they 11 Q. And where would she sleep?
12 were over 20. 12 A. Sometimes in the master bedroom,
13 BY MR. MERMELSTEIN: 13 sometimes in the yellow room.
14 Q. Did you at any point get to know how Mr. 14 Q. Other room?
15 Epstein came to know any of these girls? 15 A. Yellow room.
16 A. No, sir. 16 Q. What's the yellow room?
17 Q. You had no idea? 17 A. We used to give them colors because they
18 A. No. 18 will all have different bathrooms so we need to
19 Q. And so Mr. Epstein would typically stay 19 take care of towels and stuff like that.
20 for two weeks or so? 20 Q. So each of the four other bedrooms had a
21 A. I will say that. 21 color?
22 Q. And what did these girls who came with 22 A. Yes. Blue room, yellow room, pink room,
23 him, what did they do during that two week period? 23 some other, I don't remember.
24 MR. CRITTON: Form. 24 Q. Now, were there individuals who didn't
25 THE WITNESS: They would go to the 25 stay in the house but came to the house during the
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1 course of the day? 1 leave.
2 MR. CRITTON: Form. 2 Q. How far in advance would she tell you so
3 THE WITNESS: Yes. 3 and so is coming?
4 BY MR. MERMELSTEIN: 4 A. One hour, sometimes half an hour.
5 Q. And who would these be? 5 Q. Okay. And would she tell you the
6 A. The architect, Doug Shadow, some lawyer 6 person's name or would she just say a masseuse?
7 like I said for some business, masseuse, sometimes 7 A. She will say Johanna is coming, so I will
8 we have masseuse. We have guests, you know, 8 meet Johanna at the door and I will show her
9 sometimes David Copperfield would go to the house 9 inside the house because we used to have a code to
10 and have dinner. 10 get inside the house and I would leave and go to
11 Q. David Copperfield. So David Copperfield 11 the staff house or do my duties.
12 obviously is a famous person. Right? 12 Q. Is Johan