gov.uscourts.nysd.447706.1328.43.pdf

Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 1 of 8 COMPOSITE EXHIBIT 8 (File Under Seal)  Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 2 of 8 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. I 8 JANE DOE NO. 3, Case NO: 08-CV-80232 9 Plaintiff, 10 Vs 11 JEFFREY EPSTEIN, 12 Defendant. I 13 JANE DOE NO. 4, Case No: 08-CV-80380 14 Plaintiff, 15 Vs. 16 JEFFREY EPSTEIN, 17 Defendant. 18 I 19 JANE DOE NO. 5, Case No: 08-CV-80381 20 Plaintiff, 21 Vs 22 JEFFREY EPSTEIN, 23 Defendant. I 24 25 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 GIUFFRE00025 l  Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 3 of 8 Page 198 Page 200 1 that tape it's going to be Assistant Attorney 1 friends, I will say, yeah. 2 Weiss and Detective Recarey asking questions? 2 Q. Then you mentioned that you typed into 3 A. Yes. 3 Google, I guess you Googled Prince Andrew and Bill 4 Q. It says, during the sworn taped statement 4 Clinton. Why would you pick those names, were 5 Mr. Rodriguez stated he was employed by Jeffrey 5 they associated with Mr. Epstein? 6 Epstein for approximately six months. 6 A. Yes. 7 I think we already talked about that. 7 Q. And what is your understanding as to how 8 I'm skipping ahead a little bit. 8 Prince Andrew is associated with Jeffrey Epstein? 9 If Rodriguez needed to relay a message to 9 A. Because there were pictures with him 10 Epstein he would have to notify Epstein's 10 together. 11 secretary Lesley in New York who would then notify 11 Q. In the house? 12 Epstein's personal assistant Sarah who would relay 12 A. Yes. 13 the message to Epstein. 13 Q. Many pictures or are we talking about 14 A. Yeah. 14 one? 15 MR. CRITTON: Form. 15 A. Many pictures. 16 BY MR. EDWARDS: 16 Q. Were these pictures that looked that 17 Q. That's pretty much the process you 17 appeared to be at social events, at Mr. Epstein's 18 described? 18 house or where? 19 A. Yes, it was normal procedure. 19 A. Mrs. Maxwell took him to England to 20 Q. Rodriguez stated Epstein did not want to 20 introduce him to the royalty. 21 see or hear the staff when he was in the 21 Q. Is it's your understanding that Ghislaine 22 residence? 22 Maxwell knew Prince Andrew and introduced -- 23 MR. CRITTON: Form. 23 A. Yes. 24 THE WITNESS: That's correct. 24 Q. Is it also your understanding that at 25 BY MR. EDWARDS: 25 some point in time Ghislaine dated or had a Page 199 Page 201 1 Q. That's something you agree with? 1 romantic relationship with Prince Andrew? 2 A. Yes. 2 MR. CRITTON: Form. 3 MR. CRITTON: Form. 3 THE WITNESS: I don't know that. 4 BY MR. EDWARDS: 4 BY MR. EDWARDS: 5 Q. Rodriguez advised Mr. Epstein had many 5 Q. Do you know around what time period it 6 guests. 6 was that Mr. Epstein was introduced to Prince 7 In addition to the girls who are roughly 7 Andrew? 8 C. and T. age who had come to the house to have a 8 A. 2003, I believe. 9 good time, who were some of the other guests that 9 Q. How do you know that? 10 you know of, if you know their name? 10 A. I've heard dates. 11 MR. CRITTON: Form. 11 Q. From people in the Epstein group? 12 THE WITNESS: I mentioned Alan 12 A. Yes. 13 Dershowitz. 13 Q. Okay. 14 BY MR. EDWARDS: 14 MR. CRITTON: Let me note my objection, 15 Q. That's a lawyer from Harvard? 15 move to strike, it's based on -- his 16 A. Yes. The magician, David Copperfield, 16 testimony is based on hearsay. 17 some other lawyers from New York, you know. There 17 BY MR. EDWARDS: 18 were some other guests. 18 Q. During the six month period of time when 19 Q. And how frequently would these other 19 you worked directly for Mr. Epstein, how often did 20 guests come over? 20 Mr. Epstein get together with or hangout with 21 A. Once a month, something like that. 21 Prince Andrew; if you know? 22 Q. Okay. So if it's only once a month and 22 A. I didn't see him once. 23 you were only there six months you're saying you 23 Q. You never saw Prince Andrew at the house? 24 only saw six guests come over in addition to -- 24 A. No, no, he called. 25 A. They have people, you know, they have 25 Q. I'm sorry, how often would he call? 51 (Pages 198 to 201) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 GIU FFRE00030 1  Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 4 of 8 Page 270 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. I 8 JANE DOE NO. 3' CASE NO: 08-CV-80232 9 Plaintiff, 10 Vs. CONDENSED 11 JEFFREY EPSTEIN, 12 Defendant. 13 I , 14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. I 19 JANE DOE NO. 5, CASE NO: 08-CV-80381 20 Plaintiff, 21 vs 22 JEFFREY EPSTEIN, 23 Defendant. 24 I 25 I " Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000315 GIUFFRE00 l 004  Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 5 of 8 Page 275 Page 277 1 APPEARANCES: 1 Deposition taken before MICHELLE PAYNE, Court 2 3 RICHARD WILLITS, ESQ. 2 Reporter and Notary Public in and for the State of 2290 10th AVenue North 3 Florida at Large, in the above cause. 4 Suite 404 4 Lake Worth, Florida 33461 5 Attorney for C.M.A. 5 THE VIDEOGRAPHER: This is a continuation Appeared via telephone. 6 of the deposition of Alfredo Rodriguez. 6 7 Today is Friday, August the 7th, the year 7 BURMAN, CRITTON, LlJTTIER & 8 2009, starting time approximately 1:15 p.m. 8 COLEMAN, LLP 9 Will the court reporter please swear in BY: ROBERT CRITTON, ESQ. 9 515 North Flagler Drive 10 the witness? Suite 400 11 Thereupon, 10 West Palm Beach, Florida 33401 12 ALFREDO RODRIGUEZ, Attorney for Jeffrey Epstein. 11 13 having been first duly sworn or affirmed, was 12 14 examined and testified as follows: 13 ALSO PRESENT: 15 MR. CRITTON: Before we get started just 14 JOE LANGSAM, VIDEOGRAPHER 16 with regard to Ms. Ezell represents Jane Doe 15 17 101 and 102, the alleged time of her 16 18 incidents as of least have been plead in the 17 19 complaint for 101 is '99 -- I'm sorry, '98 18 20 through 2002, with Jane Doe 102 the Spring 19 21 of -- Spring/Summer of 2003. Mr. Rodriguez 20 21 22 never even began employment until '04 and 22 23 '05. I think her questioning I think -- I 23 24 can't say she doesn't have standing based on 24 25 25 the court order, but I would say it's Page 276 Page 278 1 CONTINUED INDEX OF EXAMINATION 1 completely irrelevant and immaterial and has 2 WITNESS DIRECT CROSS REDIRECT RECROSS 2 no probative value with regard to this 3 3 particular witness based upon the two ALFREDO RODRIGUEZ 4 clients at least that are in suit at this 4 (By Ms. Ezell) 278 441,467 5 point in time. s 6 MS. EZELL: As Mr. Critton well knows I (By Mr. Willits) 334 453,469 7 represent a number of other clients whose 6 (By Mr. Critton) 338 464 8 cases have not been filed and I believe we 7 9 do have standing to ask questions, and I do (By Mr. Edwards) 419, 454, 468 10 intend to do that today. 8 (By Mr. Langino) 452 11 EXAMINATION 9 12 BY MS. EZELL: 10 13 Q. Mr. Rodriguez, you stated last time that 11 14 there were guests at the house, frequent guests, 12 CONTINUED INDEX OF EXHIBITS 13 PLAINTIFF'S PAGE 15 friends from Harvard. 14 3 Drawing 315 16 Do you remember that testimony? i6 5 Photo9raph 331 J./ 18 /-\ , 1'--'t IIIQQIII, Q. And was there a lawyer from Harvard named 17 6 Photograph 331 18 7 Photograph 331 19 Alan Dershowitz? 19 8 Photograph 331 20 A. Yes, ma'am. 20 9 Report 446 21 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. 21 Q. And are you familiar with the fact that Ezell.) 22 he's a famous author and famous lawyer? 22 23 A. Yes, ma'am. 23 24 24 Q. How often during the six months or so 25 25 that you were there was Mr. Dershowitz there? 3 (Pages 275 to 278) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000317 GIUFFRE00 1006  Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 6 of 8 Page 279 Page 281 1 A. Two or three times. 1 Q. Can you tell me where those were? 2 Q. And did you have any knowledge of why he 2 A. One in the kitchen, and the one in the / 3 was visiting there? 3 formal -- the main entrance. And there was one 4 A. No, ma'am. 4 more added later on, but there is two when I was 5 Q. You don't know whether or not he was a 5 working there . 6 lawyer -- acting as a lawyer or whether he was 6 Q. Could you just give me a rough sketch of 7 there as a friend? 7 the house of where the main entrance was and where 8 A. I believe as a friend. 8 the kitchen was? 9 Q. Were there also young ladies in the house 9 A. I'm not an architect but it's something 10 at the time he was there? 10 like this. This is the kitchen, this is the main 11 MR. CRITTON : Form . 11 entrance. 12 THE WITNESS: Yes, ma'am. 12 Q. Will you mark the kitchen with a K, 13 BY MS. EZELL: 13 please, and the main entrance with ME? 14 Q. And would those have included, for 14 A. This is the pool. 15 instance, Sarah Kellen and Nadia Marcenacova? 15 Q. The pool? 16 A. Yes, ma'am. 16 A. Yes, ma'am. 17 Q. Were there other young ladies there when 17 Q. And in the upper left? 18 Mr. Dershowitz was there? 18 A. In the terrace, yeah, there was a balcony 19 MR. CRITTON: Form. 19 here. 20 THE WITNESS: Yes, ma'am. 20 Q. And where were the staircases? 21 BY MS. EZELL: 21 A. This is one, the kitchen, one in the 22 Q. Do you have any idea who those young 22 foyer, and the pool. 23 women were? 23 Q. Okay. And would you just put an F where 24 A. No, ma'am. 24 the foyer staircase began? And KS where the 25 Q. Were any of those the young women that 25 kitchen staircase began. Page 280 Page 282 1 you have said came to give massages? 1 And you said that later another staircase --- 2 A. Yes, ma'am. 2 was added? 3 Q. And do you have any idea whether or not 3 A. Yeah, we rehabilitated this, you know, 4 Mr. Dershowitz was also receiving massages? 4 but you asked me how many stairs there were, to 5 A. I don't know, Ma'am. 5 answer your question there were three. 6 Q. I want to ask you to take this piece of 6 Q. Three. So where was the third one? 7 paper, please, and a pencil -- 7 A. The pool, this leads to the pool. 8 MR. WILLITS: Can anybody hear me? 8 Through the outside master bedroom you could go 9 MS. EZELL: Yes. Can you hear me? 9 downstairs to the pool. 10 MR. WILLITS: I've heard nothing for 10 Q. Okay. A stairway then from the outside, 11 about a minute or so. 11 from outside the master bedroom? 12 MR. CRITTON: Can you hear me now? 12 A. Yes, ma'am. 13 MR. WILLITS: Yes. 13 Q. Down to the pool? 14 MS. EZELL: I'm asking questions, I'm 14 A. Yes, ma'am. 15 sorry. 15 Q. One of your duties was to answer the 16 MR. CRITTON: Why don't we go off the 16 door. Is that correct? 17 recora ror a secona. 1/ 1-\, ic:,1 11 1aa111. 18 (Thereupon, a discussion was held off the 18 Q. Which door would you answer? 19 record.) 19 A. Mainly the kitchen. 20 THE VIDEOGRAPHER: We're back on the 20 Q. And why was that, why would people mainly 21 record. 21 come to the kitchen? 22 BY MS. EZELL: 22 A. I'll say it was for practicable reasons 23 Q. Mr. Rodriguez, you indicated that there 23 because not to go to the main -- it was shorter 24 were several staircases in the house? 24 because the entrance was here, so this was the 25 A. Yes, ma'am. 25 driveway and we used to take into the back door of 4 (Pages 279 to 282) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000318 GIUFFRE00 1007  Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 7 of 8 Page 423 Page 425 1 York house? 1 Q.And is your understanding that Mr. 2 A. He will have massages. 2 Epstein was intimate with any of those girls? ; 3 MR. CRITTON: Form. 3 MR. CRITTON: Form. 4 BY MR. EDWARDS: 4 THE WITNESS: Yes. 5 Q. And are we still talking about a habit of 5 BY MR. EDWARDS : 6 two a day? 6 Q. With all of them? 7 MR. CRITTON: Form. 7 MR. CRITTON: Form. 8 THE WITNESS: I don't know that. 8 THE WITNESS: Yes. 9 BY MR. EDWARDS: 9 BY MR. EDWARDS: 10 Q. Okay. So for the time period when you 10 Q. With Sarah as well? 11 have been familiar with Mr. Epstein and known his 11 A. Yes. 12 habits, is it fair to say that he would have 12 MR. CRITTON: Form. 13 roughly two girls a day in that same age group 13 BY MR. EDWARDS: Jane Doe 2 14 wherever he was? 14 Q. With-? 15 A. Yes. 15 A. Yes. 16 MR. CRITTON : Form. 16 MR. CRITTON: Form. 17 BY MR. EDWARDS: 17 BY MR. EDWARDS: 18 Q. All right. And have you talked to 18 Q. And the girls who would come over on the 19 20 21 anybody that has given you similar information from his Island home? A. No. 19 20 21 airplane? MR. CRITTON: Form. THE WITNESS: Yes. I 22 Q. Do you know any of the girls that have 22 BY MR. EDWARDS: 23 been over to his Island? 23 Q. Did you ever have occasion to go into the 24 25 A. Yes. Q. And who are they? 24 25 bedroom and find the vibrators or back massagers out after Mr. Epstein was in the room with any of I Page 424 Page 426 1 ( 1 A. Nadia, the girls who used to stay at the 1 the girls that came over on the plane? 2 home in El Brillo used to go over there to the 2 MR. CRITTON: Form . 3 Island. 3 THE WITNESS: Yes. 4 Q. When he would have these girls -- I guess 4 BY MR. EDWARDS: 5 we've kind of categorized them as the girls who 5 Q. So that's something that would be out 6 would come over with him on an airplane and stay 6 after the girls that came over on the plane or the 7 at the house. 7 girls that came over for the massages? 8 A. Yes. 8 A. Yes. 9 Q. When they would be staying at the house 9 MR. CRITTON : Form . 10 would he also have the local Palm Beach girls 10 BY MR. EDWARDS : 11 coming over that you were told to call masseuses? 11 Q. And at the time when you were house 12 A. Yes. 12 manager you had a 15-year old daughter? 13 Q. So these girls that came on the airplane 13 A. Yes. 14 with him, were they also -- did they also have 14 Q. Did she live down here? 15 knowledge that these young girls were coming over 15 A. In New Jersey. 16 it to give massages? ·11, . _ ,,.a. I 1 - • - V 11,, 16 ·~ ,., , .... w ... "" . Q. Okay. When Alan Dershowitz was at the .l u1, .... _,.., ....... "" .... , ..................... , ............ , - 18 THE WITNESS: Yes, sir. 18 Palm Beach girls would come over to the house 19 BY MR. EDWARDS: 19 while he was there but you're not sure if he had a 20 Q. Okay. Who are the girls from the 20 massage from any of those girls. Jane Doe 2 21 airplane other than - that you remember? 21 A. Exactly. 22 A. Sarah . There were so many, sir, I don't 22 Q. And what would he do while those girls Jane Doe 2 23 recall right now. But Sarah is for sure, - 23 were at the house? 24 was one of the main girlfriends, but I don't 24 MR. CRITTON : Form. 25 remember that. 25 THE WITNESS : He will read a book with a I 40 (Pages 423 to 426) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000354 GIUFFRE00 1044  Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 8 of 8 Page 427 Page 429 1 glass of wine by the pool, stay inside. 1 usually it's Yahoo dot com or at Bellsouth dot 2 BY MR. EDWARDS: 2 net. 3 Q. Did he ever talk to any of the girls' 3 A. It was very uncommon. I don't remember, 4 A. I don't know, sir. 4 sir. 5 Q. Certainly he knew that they were there? 5 Q. Did everybody in the -· I think you 6 MR. CRITTON: Form. 6 called it the organization, did everybody have 7 THE WITNESS: I don't know, sir. 7 e-mails? 8 BY MR. EDWARDS: 8 A. Yes. 9 Q. Do you know how Sarah Kellen knows Mr. 9 Q. Okay. Would that include Nadia? 10 Epstein? 10 A.. Yes. 11 A. No, sir. 11 Q. All right. And did Mr. Epstein have an 12 Q. Or how long she's known him? 12 e-mail? 13 MR. CRITTON: Form. 13 A. Yes. 14 THE WITNESS: She was on board two years 14 Q. Did you ever correspond with Mr. Epstein 15 or a year and a half before I came on board. 15 by e-mail? 16 BY MR. EDWARDS: 16 A. Yes. 17 Q. Okay. 17 MR. EDWARDS: You can go ahead. 18 A. So it's probably 2003 or 2. 18 THE WITNESS: That's the only one that I 19 Q. All right. You mentioned this Citrix 19 remember. 20 system. 20 THE VIDEOGRAPHER: Okay, we're off the 21 A. Yes. 21 record. 22 Q. Is that a system that was used to operate 22 (Thereupon, a recess was had.) 23 the phones and the computers? 23 THE VIDEOGRAPHER: We're back on the 24 A. The computers mainly. 24 record with tape number four. 25 Q. All right. But you then also described 25 BY MR. EDWARDS: Page 428 Page 430 l ( 1 some system where someone would call on the 1 Q. Mr. Rodriguez, what was Mr. Epstein's 2 telephone and that would be automatically 2 e-mail? 3 downloaded to the computer? 3 A. Jeep project at something -- Jeep 4 A. Yeah, you can retrieve who called in a 4 project •· I can't remember it right now. 5 transcript written who called, what's the message, 5 Q. Okay. In the course of this next 10 or 6 the time so you have it on a piece of paper, you 6 15 minutes •• 7 can print it out. 7 A. I can recall. 8 Q. Is it your understanding that is also 8 Q. -- if it comes to you just tell me. So 9 part of the Cltrix system? 9 it was Jeep project •• 10 A. Yes. 10 A. Like Jeep, the brand name Jeep, Jeep 11 Q. AH right. Did you have an e-maif? 11 project at -· I can't remember. 12 A. Right now, yes. 12 Q. Okay. Was that his only e-mail to your 13 Q. No, when you were working at · · 13 knowledge? 14 A. Yes, I did. 14 A. No. 15 Q. ·- Mr. Epstein? 15 Q. He had other e-mail addresses? A '\.,I _ _ J.O 17 A. Yes. 17 Q. Do you know what any of his other e-mail 18 Q. And did all of the e-mails end the same 18 addresses were? 19 way such as Epstein's house dot com or something? 19 A. No, I don't remember. 20 A. Yes. 20 Q. Do you know who the carriers were for the 21 Q. Okay. What was Sarah Kellen's e-mail? 21 other e-mail addresses owned by Jeffrey Epstein? 22 A. I don't remember. 22 A. No, sir. 23 Q. What was your e-mail? 23 Q. Whether it was Yahoo or hot mail or -· 24 A. Staff house •• I don't remember, sir. 24 A. No, none of those. 25 Q. Do you recall how it ended? I mean 25 Q. Okay. Was this Jeep project e-mail run 41 (Pages 427 to 430) Kress Court Reporting, Inc. 305-866·7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000355 GIUFFRE00 1045