gov.uscourts.nysd.447706.1328.37
gov.uscourts.nysd.447706.1328.38 giuffre-maxwell
gov.uscourts.nysd.447706.1328.39

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Case 1:15-cv-07433-LAP Document 1328-38 Filed 01/05/24 Page 1 of 5 EXHIBIT E Case 1:15-cv-07433-LAP Document 1328-38 Filed 01/05/24 Page 2 of 5 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 1, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of JOHN ALESSI, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-38 Filed 01/05/24 Page 3 of 5 Page 165 1 JOHN ALESSI 2 at 358 El Brillo Way; is that correct? 3 A. Yes. 4 Q. Now, when counsel for the Plaintiff was 5 asking you questions, he kept referring to females 6 as girls, okay? 7 A. Yes. 8 9 10 - Q. Jane Doe 2 , you understood at the time that any of the massage therapists that were being -- giving - So is it fair to say that other than Jane Doe 2 11 massages at 358 El Brillo Way were over the age of 12 18; is that correct? 13 MR. EDWARDS: Objection, argumentative, 14 counsel testifying. 15 THE WITNESS: Most of them. 16 BY MR. PAGLIUSCA: 17 Q. Okay. And you talked a little bit about 18 paying for massages. Now, as I understand it, 19 people who were getting massages at 358 El Brillo 20 Way were paid $100 per massage; is that right? 21 A. That was -- everybody got $100 an hour. 22 Q. Okay. And you never paid more than $100 23 to anyone who gave a massage, correct? 24 A. Not for one, but I paid more if they were 25 four massages; I would pay $400, $500. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-38 Filed 01/05/24 Page 4 of 5 Page 182 1 JOHN ALESSI 2 his equipment for yoga and exercising there. They 3 have a treadmill, exercise equipment. They have a 4 bathroom. And there was the pool. 5 And behind the pool was the lake, the 6 Intracoastal lake, and we had a boat, a couple -- we 7 had -- at one time we had those jet -- jet flows. 8 Q. Jet skis? 9 A. Jet skis. We had a couple of those. And 10 that was it. 11 Q. Was the pool private? 12 A. Very much, yeah. It was no access to the 13 street. There was no access -- no view from any 14 neighbors or anything like that. 15 Q. Okay. You were asked some questions by 16 Mr. Edwards about Jane Doe 2 ; is that right? 17 A. Yes. 18 Q. To your knowledge, she was the only person 19 at El Brillo that was under the age of 18? 20 A. To my knowledge, yes. 21 Q. Okay. And you recall seeing her with her 22 mother at the house, correct? 23 A. The first couple of times, after, she came 24 with her mother. 25 Q. And you don't ever recall her spending the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-38 Filed 01/05/24 Page 5 of 5 Page 188 1 JOHN ALESSI 2 person; I recommend her to you? 3 A. Yes, he would give to me the number. 4 Q. And most of the people, I take it, were 5 from these spas or clubs; is that right? Most of 6 the massage people? 7 A. Yes. 8 Q. And do you know, did they have what I'll 9 call regular day jobs at the spas, and then they 10 would come into Mr. Epstein's after? 11 MR. EDWARDS: Objection, speculation. 12 THE WITNESS: I think so. 13 BY MR. PAGLIUSCA: 14 Q. Okay. And why do you think so? 15 A. Because they were working at the Breakers, 16 and sometimes I have to get in touch with these 17 people. I used to call -- have to call the Breakers 18 or the Mar-a-Lago or the -- all the clubs. There be 19 clubs, even in Boca Raton, the Boca Raton Resort and 20 Hotel. They have a great spa. I had to call these 21 people, Can you come in at 10:00 tonight? 22 Q. You would know they were working there 23 because you would talk to them there? 24 A. Yes. 25 Q. I'm going to have you take a look at MAGNA9 LEGAL SERVICES
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