gov.uscourts.nysd.447706.1328.42.pdf

Case 1:15-cv-07433-LAP Document 1328-42 Filed 01/05/24 Page 1 of 5 EXHIBIT 6 (Filed Under Seal)  Case 1:15-cv-07433-LAP Document 1328-42 Filed 01/05/24 Page 2 of 5 Page 1 Page 3 UNITED STATES DISTRICT COURT 1 On behalf of the Defendant: SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80 11 9-CIV-MARRA/JOHNSON 2 ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER JANE DOE NO. 2, 3 515 North Flagler Drive, Suite 400 Plaintiff, West Palm Beach, Florida 33401 -vs- 4 Phone: 561.842 .2820 JEFFREY EPSTEIN, [email protected] 5 [email protected] Defendant. 6 7 Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 8 08-80993, 08-8081 I, 08-80893, 09-80469, 9 09-8059 1, 09-80656, 09-80802, 09-81092 10 11 VIDEOTAPED DEPOSITION OF WAN ALESS I 12 VOLUME ! 13 Tuesday, September 8, 2009 14 10:12 a.m. - 3:45 p.m. 15 16 2 139 Palm Beach Lakes Boulevard 17 West Palm Beach, Florida 3340 1 18 19 20 Reported By: 21 Sandra W. Townsend, FPR Notary Public, State of Florida 22 PROSE COURT REPORTING AGENCY 23 West Palm Beach Office 24 25 Page 2 Page 4 1 2 APPEARANCES: On behalf of the Plaintiffs: 1 - -- 3 RICHARD WILLITS, ESQUIRE 2 EXHIBITS 4 RICHARD H. WILLITS, P.A. 2290 I 0th Avenue North, Suite 404 3 - -- Lake Worth, Florida 33461 4 5 Phone: 56 1.582.7600 [email protected] NUMBER DESCRIPTION PAGE 6 5 7 STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 6 Exhibit number 1 Photographs 45 8 18205 Biscayne Boulevard, Suite 2218 7 Exhibit number 2 Transcript 130 Miami, Flo1ida 33 160 9 Phone: 305.93 1.2200 8 Exhibit number 3 Incident Report 137 [email protected] 9 Exhibit number 4 Incorporation Papers 149 10 [email protected] 11 WILLIAM J. BERGER, ESQUIRE 10 Exhibit number 5 Incorporation Papers 150 ROTHSTEIN ROSENFELDT ADLER 11 12 40 1 East Las Olas Boulevard, Suite 1650 Fo,t Lauderdale, Florida 3330 1 12 13 Phone: 954.522.3456 13 [email protected] 14 14 15 KATHERINE W. EZELL, ESQUIRE 15 PODHURST ORS ECK, P.A. 16 25 West Flagler Street, Suite 800 16 Miami, Flo1ida 33 I30 17 17 Phone: 305.358.2800 [email protected] 18 18 [email protected] 19 19 ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 20 20 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 334 10 21 21 Phone: 561.5 15.1400 22 [email protected] 22 23 23 24 24 25 25 1 (Pages 1 to 4) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4a1c-4dee-87ac-479898cc; GIUFFRE00009 l  Case 1:15-cv-07433-LAP Document 1328-42 Filed 01/05/24 Page 3 of 5 Page 45 Page 47 1 MS. EZELL: I'm going to ask -- I don't know 1 THE WITNESS: Could have been. But, you know 2 whether you've still been serially designating 2 I am not -- I don't think I am a very good judge of 3 Exhibits or whether we're doing them separately for 3 ages. If you ask me how old you are, I really 4 deposition. 4 couldn't tell you. 5 MR. CRITTON: I think we cannot trust that 5 MR. CRITTON: Kathy thinks she's 25. 6 people will do them serially. I'd do them with 6 MS. EZELL: In my dreams. 7 each one. 7 THE WITNESS: Now, again, I must tell you, I 8 MS. EZELL: Then would you mark this, please, 8 was never told to check any i.d.s on any of the 9 as Exhibit 1 to this deposition. 9 people who work at the house. 10 And I'm just going to state on the record that 1O BY MS. EZELL: 11 I will keep that original. We will not attach it 11 Q. I understand that. And, so, I think I'm just 12 to the deposition. 12 trying to establish that you didn't consider it part of 13 (Exhibit number 1 was marked for 13 your job description to worry about or consider the 14 identification purposes and retained by Counsel for the 14 ages -- 15 Plaintiffs.) 15 A. No. 16 THE WITNESS: Yes, that's -- 16 Q. -- of the young women that came there? 17 BY MS. EZELL: 17 A. Absolutely not. Absolutely not. 18 Q. Cm1 you identify that -- the young woman in 18 Q. And, so, you never really focused on that or 19 those pictures? 19 particularly thought about it if they seemed young? 20 A. Yes. 20 MR. CRITTON: Form. 21 Q. Who is it? 21 THE WITNESS: I don't-- I didn't see that 22 A. That's V. -- V. Now that you says R., that 22 many young girls, you know, young, underage girls 23 is V.R. definite, a hundred percent. 23 at the house. I never saw except the two girls 24 MR. CRITTON: Let me just note my objection, 24 that I mentioned that I think it was underage was 25 as I did in A. Rod's deposition or Mr. Rodriguez's 25 N. for sure because she was still in high school. Page 46 Page 48 1 deposition, that I know you're going to confiscate 1 And she -- she had dinner with her mother, a couple 2 Exhibit number 1. I think it's inappropriate. I 2 times with her mother. And she become an actress. 3 think I should be allowed to have a copy of 3 She's an actress and she has done movies. And he 4 Exhibits that are being used in deposition. But 4 help her in her career. 5 I'll file a motion with the Court so we don't get 5 That's the only girl that I knew she was young 6 into a pulling match over your Exhibits. 6 because she was going to high school and I pick her 7 MR. BERGER: I would ask that the court 7 up from high school sometimes. But she was not a 8 repo1ter initial that. 8 massage therapist. She will go for dinner. And 9 MS. EZELL: Sure. 9 they will go for the movies and she sang sometimes 10 Oh, you did? 10 because she was a singer. So she sw1g at the 11 MR. WILLITS: She marked it. 11 house. Beautiful girl . Very talented. 12 MR. BERGER: Did she put her initials or did 12 That's the only girl that I know that it 13 she just put a number or a letter? 13 was -- I would says, underage. 14 MR. CRITTON: She's nodding that she did 14 BY MS . EZELL: 15 everything that she usually does, which mem1s, 15 Q. Okay. Did -- who told you that V.R. was a 16 initials, date m1d number. 16 massage therapist? 17 MR. MERMELSTEIN: You cm1 talk. 17 A. Nobody. 18 MR. WILLITS: But when you talk, use your 18 Q. Did you assume that she was a massage 19 initials. 19 therapist because you were told she was coming to give 20 BY MS. EZELL: 20 massage? 21 Q. How old did you think V.R. was at the time she 21 A. No. I assumed she was a massage therapy 22 begm1 coming to Mr. Epstein's home? 22 because I was -- I drove Ms. Maxwell to Mar-a-Iago, 23 A. She could have been 17, 18, 19. 23 Donald Trump's residence. And I wait in the car while 24 Q. Could she have also been 15? 24 Ms. Maxwell got a -- I think it was a facial or massage. 25 MR. CRITTON: Form. 25 I don't know. But that day I remember this girl, V., 12 (Pages 45 to 48) (561) 832-7500 PROSE COURT REPORTING AGENCY , INC . (561) 832 - 7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4a1c-4dee-87ac-479898cc; GIUFFRE000 l 02  Case 1:15-cv-07433-LAP Document 1328-42 Filed 01/05/24 Page 4 of 5 Page 69 Page 71 1 MR. CRITTON: Form. 1 Diane's secretary, she stay there for a week with her 2 THE WITNESS: No, not that I can remember. 2 kids and we took care of her. 3 BY MS. EZELL: 3 Who else? Mr. Trump. That's a celebrity. 4 Q. Do you know ifhe and Mr. Epstein were 4 Mr. Robert Kem1edy, Junior. Mr. Frederick Fekkai. 5 involved in any businesses together? 5 Q. Who is that? 6 A. Mr. Epstein, I never knew what businesses he 6 A. Fekkai, Frederick Fekkai, the famous 7 was involved. He will -- I was completely shut off of 7 hairstylist. Who else? I don't think I can remember 8 all of the business, except for the office, transfer of 8 anymore. 9 communications or faxes. But I have no idea of the 9 Q. David Copperfield, the magician? 10 relationship with other business partners. 1O A. No, I never saw him. 11 Q. Did you ever have to deal with his -- the 11 Q. You never saw him. 12 office in New York with someone named Lesley in Nev 12 Now, would these -- the people that you named 13 York? 13 were all people that you saw visiting in the home? 14 A. The secretary? 14 A. Yes. Also was a Noble Prize winners, the -- I 15 Q. Yes. 15 can't remember his name. It was an old gentleman. He 16 A. Yeah. I would call -- I would call Lesley 16 was a Noble Prize, chemistry, I think, or mathematics. 17 almost every day or other secretaries, they live in New 17 There was a couple -- a couple of those, very -- also, 18 York. Basically it came a point when Mr. Epstein will 18 we had at one time at the house, it was a reunion of 19 call New York and New York call me to do things for 19 very Noble Prize winners. But I don't know. They're 20 Mr. Epstein. But he was on the phone or busy or 2O not famous, I guess. I can't remember their names. 21 something and he would call the office and the office 21 Very important people. 22 will send me an e-mail or call me or -- it was a 22 Q. Was that a dim1er or a reception? 23 constant report with the office in New York. 23 A. I think it was a lllllch. 24 Q. And did you in turn sometimes call New York t, 24 Q. A lunch. 25 get a message to Mr. Epstein? 25 President Clinton, did you ever -- Page 70 Page 72 1 A. Yes. 1 A. I met President Clinton on Mr. Epstein's plane 2 Q. Did you ever overhear Mr. Epstein talking to 2 in the last, I think it was the last month or just 3 any people that you would consider celebrities? 3 before I left -- I left, I met President Clinton in 4 A. Yes. I knew some -- many celebrities. 4 Miami at his plane. We drove him to Miami. 5 Q. Who -- what celebrities did you understand 5 Q. And do you know, was that a trip -- were they 6 that he spoke with? 6 going on a trip to Africa? 7 A. He spoke to it? 7 A. I hear about it, but it was not when I was 8 Q. Yes. 8 there. 9 A. I don't know who he spoke to because I never 9 Q. So that was not the time that you drove -- 10 listen to his conversations. But I saw guests at the 10 A. No, I was already out. 11 house that were celebrities. 11 Q. And Kevin Spacey, did you ever meet him? 12 Q. Who did you see at house? 12 A. No. I hear about it on the news, but I never 13 A. Many. !twas !twas- 13 met him. 14 It was Prince Andrew. It 14 Q. Were Prince Andrew and Princess Sarah friends 15 was Princess Sarah. 15 of Ms. Maxwell? 16 Q. Princess? 16 A. Both of them. 17 A. Sarah, the wife of Andrew. 17 Q. Both Ms. Maxwell and Mr. Epstein? 18 Q. SarahFerguson? 18 A. Yeah. 19 A. Ferguson. 19 Q. Did -- did they ever have massages when they 20 And it was a couple Misses, Misses Yugoslavia, 20 were there? 21 Miss Germany that I don't even know the names. But the) 21 A. Prince Andrew did. I think Sarah was there 22 were a lot of queens and other famous people that I 22 only once and for a short time. I don't think she slept 23 can't remember. It was a very famous lawyers that I'm 23 in there. I cannot remember. I think she was visiting 24 sure you know, Alan Dershowitz, who spend at tl1e house 24 Wellington and she came to the house and we met her. 25 couple times. And he slept tl1ere. He -- Princess 25 But Prince Andrew, yes, Prince Andrew spent weeks witr 18 (Pages 69 to 72) (561) 832 - 7500 PROSE COURT REPORTING AGENCY, INC . ( 561) 832 - 7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4a1c-4dee-87ac-479898cc; GIUFFRE000108  Case 1:15-cv-07433-LAP Document 1328-42 Filed 01/05/24 Page 5 of 5 Page 73 Page 75 1 us. 1 MR. LANGINO: Go ahead. Sure. 2 Q. Where would he sleep? 2 BY MS. EZELL: 3 A. In the main room, the main guest bedroom. 3 Q. You said that you set up the massage tables. 4 That was the blue room. 4 And would you also set up the oils and the towels? 5 Q. And, so, when he would come and stay, during 5 A. Yes, ma'am. 6 that time would he frequently have massages? 6 Q. And I think I read one time you said they used 7 MR. CRITTON: Form. 7 40 or 50 towels a day? 8 THE WITNESS: I would says, daily massages. 8 MR. CRITTON: Fom1. 9 They have a daily massage. 9 THE WITNESS: That's correct. There was a 10 BY MS. EZELL: 10 tremendous amount of work in the house, especially 11 Q. Was it sometimes more than one a day? 11 laundry towels, because they were -- we have 12 A. I can't remember ifhe had more than one, but 12 towels, piles of towels. And they use in the pool. 13 I think it was just a massage for him. We set up the 13 There was a lot of people in the pool and there 14 tables and -- 14 were a towel that went in the floor, we have to go 15 Q. Do you have any recollection ofV.R. coming to 15 and pick it up, wash it. So it was -- it was a lot 16 the house when Prince Andrew was there? 16 of towels, yes. 17 A. It could have been, but I'm not sure. 17 BY MS. EZELL: 18 Q. Not sure. When Mr. Dershowitz was 18 Q. And did you ever have occasion to go upstairs 19 visiting, -- 19 and clean up after the massages? 20 A. Uh-huh. 20 A. Yeah, uh-huh. 21 Q. -- how often did he come? 21 Q. Did you ever find any vibrators in that area? 22 A. He came pretty -- pretty often. I would says, 22 A. Yes. I told him, yes. 23 at least four or five times a year. 23 MS. EZELL: And did you ask that? I'm son-y. 24 Q. And how long would he stay typically? 24 MR. CRITTON: Yes. 25 A. Two, three days. 25 MS. EZELL: I don't know how I missed that. Page 74 Page 76 1 Q. Did he have massages sometimes when he was 1 BY MS. EZELL: 2 there? 2 Q. Since I did miss it, if you don't mind, let me 3 A. Yes. A massage was like a treat for 3 just ask you again. 4 everybody. If they want it, we call the massage and 4 Would you describe for me what kinds of 5 they have a massage. 5 vibrators you found? 6 Q. Now, Mr. Trump had a home in Palm Beach, 6 A I'm not familiar -- not too familiar with the 7 correct? 7 names, but they were big dildos, what they call the big 8 A. Uh-huh. 8 rubber things like that (indicating). And I used to go 9 Q. So he didn't come and stay there, did he? 9 and put my gloves on and pick them up, put them in tht 10 A. No, never. 1O sink, rinse it off and put it in Ms. Maxwell -- 11 Q. He would come for a meal? 11 Ms. Maxwell had in her closet, she had, like, a laundry 12 A. He would come, have dinner. He never sat at 12 basket, one of those laundry basket that you put laundn 13 the table. He eat with me in the kitchen. 13 in. She have full of those toys. And that was -- and 14 Q. Did he ever have massages while he was there? 14 that was me being professional, leaving the room ready 15 A. No. Because he's got his own spa. 15 for bed when he would come back to the room again. 16 Q. Sure. 16 Q. Okay . 17 MS. EZELL: I don't have any other questions 17 A That happened a few times, few times. 18 right now. I'd just like to reserve if something 18 Q. Were there other sex toys that you found in 19 comes up to ask. But, otherwise, you may go ahead. 19 the area -- 20 MR. LANGINO: It is noon, so I don't know wha 2O A. No. 21 everybody else's schedule is. I don't know how 21 Q. -- sometimes? You mentioned she kept them in 22 you're feeling. 22 a basket in her closet? 23 THE WITNESS: I am fine. 23 A She kept them in her basket. She had some 24 MS. EZELL: I do have another question. May I 24 videos there and she have a costume there. I know that 25 ask it? 25 she bought it, that she brought it with her. 19 (Pages 73 to 76) (561) 832-7500 PROSE COURT REPORTING AGENCY , INC . (561) 832 - 7506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4a1c-4dee-87ac-479898cc; GIUFFRE000 l 09