gov.uscourts.nysd.447706.1218.29.pdf

Case 1:15-cv-07433-LAP Document 1218-29 Filed 07/15/21 Page 1 of 5 McCAWLEY DECLARATION EXHIBIT 6 (Filed Under Seal)  Case 1:15-cv-07433-LAP Document 1218-29 Filed 07/15/21 Page 2 of 5 Page 1 Page 3 UNITED STATES DJSTRJCT COURT 1 On behaJf of the Defendant: SOUTI~ERN DISTRJCT OF FLORIDA CASE No.08-CV-80119-CIV-MARRA/JOHNSON 2 ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER JANE DOE NO. 2, 3 515 North Flagler Drive, Suite 400 PlaintiIT, West Palm Beach, Florida 33401 ·VS• 4 Phone: 561.842.2820 JEFFREY EPSTE IN. [email protected] 5 mpike@bclclaw .corn Defendant. 6 7 Related cases: 08-80232. 08-80380, 98-80381. 08-80994, 8 08-80993, 08-8081 I, 08-80893, 09-80469, 9 09-80591. 09-80656, 09-80802, 09-81092 10 11 VIDEOTAPED DEPOSITION OF JUAN ALESS I 12 VOLUME I 13 Tuesd.1y, September 8, 2009 14 10: 12 a.m. - 3:45 p.m. 15 16 2139 Palm Beach Lakes Boulevard 17 West Palm Beach, Florida 33401 18 19 20 Reported By: 21 Sandra W. Townsend, FPR Notary Public, Stare of Florida 22 PROSE COURT REPORTING AGENCY 23 West Palm Bl~1ch Office 24 25 Page 2 Page 4 1 2 APPEARANCES: On behalf of the Plaimiffs: 1 --- 3 RJCHARD WlLUTS, ESQUIRE 2 EXHIB I TS 4 RICHARD H. Wll.LffS, P.A. 2290 IOlh Avenue North, Suite 404 3 -- - Lake Wo11h, Florida 33461 4 5 Phone: 561.582.7600 [email protected] NUMBER DESCRIPTION PAGE 6 5 7 STUART MERMELSTEIN. ESQUIRE MERMELS11:1N & HOROWITZ, P.A. 6 Exhibit number I Photographs 45 8 I8205 Biscayne Boulevard, Suite 2218 7 Exhibit number 2 Transcript 130 l'-1iami, Florida 33160 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] ll WILLIAM J. BERGER, ESQUIRE 10 Exhibit number 5 Incorporation Papers 150 ROTI-ISTECN ROSENFELDT ADLER 11 12 40 I Eas1 Las Olas Boulevard, Suite J650 Fon Lauderdale, Florida 33301 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 l'-1iami, Florida 33130 17 l7 Phone: 305.358.2800 rjosefsberg@J)Qdhurst.com 18 18 [email protected] 19 19 ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 20 20 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 21 21 Phone: 561.515.l~OO 22 [email protected] 22 23 23 24 24 25 25 - - 1 (Pages 1 to 4) (561) 832-7500 PROSE COU RT REPORT ING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401 -377-676-2895) Electronically signed by Sandra Townsend (401 -377-676-2895) 76ef564a-4a1 c-4dee-87ac-479898cc: GllJFFRE00009 I  Case 1:15-cv-07433-LAP Document 1218-29 Filed 07/15/21 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 1 am not -- I don't think I am a very good judge of 3 Exhibits or whether we're doing tJ1em separately for 3 ages. If you ask me how old you are, I really 4 deposition. 4 couldn't tell you. 5 MR. CRITTON: T think we cannot trust that s 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, s was never told to check any i.d.s on any of the 9 as Exhibit l 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 wilJ keep that original. We will not attach it 11 Q. I understand that. And, so, 1 think l'm just 12 to the deposition. 12 trying to establish that you didu'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 mid retained by Counsel for the 14 ages -- 15 Plaintiffs.) 1s A. No. 16 THE WITNESS: Yes, that's -- 16 Q. -- of the young women that came there? 17 BYMS. EZELL: 17 A. Absolutely not. Absolutely not. 18 Q. Can you identify that -- t11e yow1g woman i11 18 Q. And, so, you never really focused on that or 19 tJ1ose pictures? 19 particularly thought about it if they seemed young? 20 A. Yes. 20 MR. CRITTON: Fon11. 21 Q. \Vbo is it? 21 THE WITNESS: l 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 T 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, lbat 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 tJ1i11k I should be allowed to have a copy of 3 She's an actress and she has done movies. And he 4 ExJ1ibits that are being used in deposition. Bul 4 help her in her career. I 5 I'll file a motion with the Court so we don't get 5 That's the only girl that l 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 U1e court 7 up from high school sometimes. But she was not a 8 reporter initial tJiat. 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 sung 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 -- T would says, underage. 14 MR. CRITTON: She's nodding that sbe did 14 BY MS. EZELL: 15 everytJ1ing that she usually does, which means, 15 Q. Okay. Did -- who told you that V.R. was a 16 initials, date and number. 16 massage therapist? 17 MR. MERMELSTEIN: You can 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. l assumed she was a massage therapy 22 began coming to Mr. Epstein's home? 22 because l was - l drove Ms. Maxwell to Mar-a-Jago, 23 A. Shecouldbavebeenl7, 18, 19. 23 Donald Tmmp'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. CRlTTON: 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 -7 506 Electronically signed by Sandra Townsend (401 -377-676-2895) Electronically signed by Sandra Townsend (401 -377.676.2895) 76ef564a-4a1c-4dee.87ac-479898cc: GI lJFFREOOO I02  Case 1:15-cv-07433-LAP Document 1218-29 Filed 07/15/21 Page 4 of 5 Page 69 Page 7 1 1 MR. C RITI"ON: Fonn. 1 , sbe stay there for a week with ber 2 THE WITNESS: No, not that I can remember. 2 kids and we took care of her. 3 BY MS. EZELL: 3 Who else? . That's a celebrity. 4 Q. Do yo u know if he and Mr. Epste in were 4 . 5 involved in any businesses together? 5 Q. Who is that? 6 A. Mr. Epstein, l never knew what businesses he 6 A. 7 was involved. He will ·· I was completely shut olI of 7 . Who else? I don't think I can remember 8 all of the business, except for the office, transfer of 8 anymore. 9 commu11ications or faxes. But I have no idea of the 9 Q. ? 10 relationship wi th other business partners. 10 A. No, I never saw him. 11 Q. Did you ever have to deal witl1 his -- the 11 Q. You never saw him. 12 office in New York with someone named in Nev 12 Now, would t11ese -- the people tha t 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 , the -- I 15 Q. Yes. 15 can't remember his name. It was an old gentleman. He 16 A. Yeah. I would ca 11 -- I would call 16 was a , l t11iuk, or 17 almost every day o r 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. Epste in 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 . But I don't k11ow. They're 20 Mr. Epstein. But he was on the phone or busy or 20 not famous, l guess. r 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 cal1 me or -- it was a 22 Q. Was that a dinner or a reception? 23 constant repo1t with the office in New York. 23 A. I think it was a lunch. 24 Q. And did you in rum sometimes call New York tc 24 Q. A lunch. 25 get a message to Mr. Epstein? 25 , did you ever -- Page 70 Page 72 1 A. Yes. 1 A. I met 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, (met 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 l.isten to his conversations. But I saw guests at the 10 A. No. I was already out. 11 house that were celebrities. 11 Q. And , did you ever meet him? 12 Q. Wbo d id you sec at house? 12 A. No. r hear about it on the uews, but l uever 13 A. Many. It was . It was 13 met him. 14 . It was . It 14 Q. Were friends 15 was . 15 of Ms. Maxwell? 16 Q. 16 A. Both of them. 17 A. . 17 Q. Both Ms. Maxwell and Mr. Epstein? 18 Q. 18 A. Yeah. 19 A. . 19 Q. Did -- did they ever have massages when they 20 Alld 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. did. I think was rhere 22 were a lot of queens alld other famous people that I 22 onl y once and for a short time. l don't think she slept 23 can't remember. It was a very famous lawyers that I'm 23 in there. I cannot remember. Tthi nk she was visiting 24 sure you lmow, Alan Dershowitz, who spend at the house 24 Wellington and she came to the house and we met her. 25 couple times. And he slepl there. He - 25 But , yes, spent weeks will 18 ( Pages 69 to 72) (561) 832 - 7500 PROSE COURT REPORTING AGENCY , INC . (561) 832 -7 506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676.2895) 76ef564a-4a1c-4dee.87ac-479898cc: GllJFFREOOO 108  Case 1:15-cv-07433-LAP Document 1218-29 Filed 07/15/21 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. Ill Lhe main room, Lhe 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 WJTNESS: I would says, daily massages. 8 MR. CRITTON: Fonn. 9 They have a daily massage. 9 THE WITNESS: That's correct. There was a 10 BY MS. EZELL: 10 tremendous amow1t of work in the house, especially 11 Q. Was it sometimes more tlJau one a day? 11 lauudry rowels, because they were -- we have 12 A. I can't remember if he 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 alld there 14 rabies 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 was t11ere? 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 cleall up after the massages? 20 A. Uh-huh. 20 A. Yeah, uh-huh. 21 Q. -- how often did be come? 21 Q. Did yon ever find any vibrators in that area? 22 A. He came pretty -- pretty often. l 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 SOil)'. ' 24 Q. And how long would be stay typically? 24 MR. CRITTON: Yes. 25 A. Two, three days. 25 MS. EZELL: I don't know how 1 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, Jet me 3 A . Yes. A massage was like a rreat for 3 just ask you again. 4 everybody. lf 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, , 6 A. I'm not fami liar -- not too familiar with the 7 ~re~ 7 names, but they were big dildos, what they call tl1e big 8 A. Uh-huh. 8 rubber t11ings like that (indicating). And J 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 the 10 A. No, never. 10 sink, rinse it off and put it in Ms. Maxwell -- 11 Q. He would come for a meal? 11 Ms. MaxweU had in ber closet, she had, like, a laundry 12 A. He would come, bave dinner. He never sat at 12 basket, one of those laundry basket that you put Jaundr) 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 be ever have massages while be was there? 14 that was me being profossional, leaving the room ready 15 A. No. . 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. lliat happened a few times, few times. 18 right now. J'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. LANGlNO: It is noon, so I don't know wha 20 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. 1 9 ( Pa ge s 7 3 to 76) ( 561 ) 832 - 7 500 PROSE COURT REPORTI NG AGENCY, I NC . (561 ) 832 -7 506 Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a-4a1c-4dee-87ac-479898cc: GllJFFREOOO 109