gov.uscourts.nysd.447706.55.12.pdf

Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 1 of 21 EXHIBIT 7 PART 1  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 2 of 21 Page 1 Page 3 UNITED STATES DISTRICT COURT 1 On behalf of the Defendant: SOUTHERN DISTRICT 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 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, 08-80811, 08-80893, 09-80469, 9 09-80591, 09-80656, 09-80802, 09-81092 ______________________________________________________ 10 11 VIDEOTAPED DEPOSITION OF JUAN ALESSI 12 VOLUME I 13 Tuesday, 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, State of Florida 22 PROSE COURT REPORTING AGENCY 23 West Palm Beach Office 24 25 Page 2 Page 4 1 APPEARANCES: 1 - - - 2 On behalf of the Plaintiffs: 3 RICHARD WILLITS, ESQUIRE 2 EXHIBITS RICHARD H. WILLITS, P.A. 3 - - - 4 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 4 5 Phone: 561.582.7600 [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, Florida 33160 9 Phone: 305.931.2200 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 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 12 13 Phone: 954.522.3456 13 [email protected] 14 14 15 KATHERINE W. EZELL, ESQUIRE 15 PODHURST ORSECK, P.A. 16 25 West Flagler Street, Suite 800 16 Miami, Florida 33130 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 33410 21 21 Phone: 561.515.1400 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-479898cc7004  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 3 of 21 Page 5 Page 7 1 PROCEEDINGS 1 Boynton Beach, Florida, 33472. 2 --- 2 Q. All right, sir. Did you ever work for Jeffrey 3 Deposition taken before Sandra W. Townsend, Court 3 Epstein? 4 Reporter and Notary Public in and for the State of 4 A. Yes, I did. 5 Florida at Large, in the above cause. 5 Q. In what capacity? 6 - - - 6 A. Everything. I started with Jeffrey Epstein 7 VIDEOGRAPHER: Today is September 8, 2009. 7 around 19 -- please bear with the dates because I 8 The time is 12 minutes after 10:00 in the morning. 8 trying -- 9 This is the videotaped deposition of Juan 9 Q. Sure. 10 Alessi in the matter of Jane Doe number two versus 10 A. -- to remember. 1969 as a part-time 11 Jeffrey Epstein. This deposition is being held at 11 maintenance guy. 12 2139 Palm Beach Lakes Boulevard in West Palm Beach, 12 And then I become a full-time employee, I 13 Florida. 13 think it was January 1, 2 -- '91, '92, so '92. Sorry. 14 My name is Stan Sanders. I'm the videographer 14 Q. You said you started in 1969? That would 15 representing Visual Evidence, Incorporated. 15 be -- 16 Would the attorneys please announce their 16 A. No. No. No. No. No. 17 appearances for the record. 17 Q. Okay. 18 MR. WILLITS: Richard Willits, representing 18 A. '99. 19 Carolyn Andriano. 19 Q. 1999? 20 MR. BERGER: William J. Berger, representing 20 A. Yeah. 21 E.W., L.M. and Jane Doe number two. 21 Q. All right. And how did you happen to get that 22 MR. MERMELSTEIN: Stuart Mermelstein of 22 job? Was it through an employment agency -- 23 Mermelstein and Horowitz, representing Jane Does 23 A. No. 24 numbers two through eight. 24 Q. -- or an ad in the paper? 25 MR. LANGINO: Adam Langino, on behalf of B.B. 25 A. I had a company at that time used to take care Page 6 Page 8 1 MS. EZELL: Katherine Ezell from Podhurst 1 of a lot of residents in Palm Beach. And I got to know 2 Orseck, on behalf of Jane Does 101 and 102. 2 Jeffrey through Lesley Wexner. And I used to work in 3 MR. CRITTON: Bob Critton, on behalf of 3 about 20 different, 20, 25 different homes in Palm Beach 4 Jeffrey Epstein. 4 as a maintenance guy. 5 THEREUPON, 5 Q. Okay. 6 JUAN ALESSI, 6 A. And I have basically my own company and I do 7 having been first duly sworn or affirmed, was examined 7 repairs for them. I did home sit in for them. 8 and testified as follows: 8 Q. And what was -- did you work for Jeffrey 9 THE WITNESS: I do. 9 Epstein? What was your position when you started? 10 DIRECT EXAMINATION 10 A. When I started, he hire me to -- he just 11 BY MR. WILLITS: 11 bought the house. 12 Q. Good morning, sir. 12 Q. I'm sorry? 13 A. Good morning. 13 A. He just had bought the house -- 14 Q. I introduced myself through the videographer. 14 Q. Okay. 15 My name is Richard Willits. 15 A. -- where he live on El Brillo. And he hire me 16 A. Okay. 16 through Mr. Wexner's references to do repair works. And 17 Q. I represent a young lady by the name of 17 basically what I did the most was taking walls apart, 18 Carolyn Andriano. 18 windows and stuff that he didn't want to have it, -- 19 A. Okay. 19 Q. I see. 20 Q. Is that name familiar to you at all? 20 A. -- fix it. 21 A. Whose name? 21 Q. And when you started working for Mr. Epstein, 22 Q. Carolyn Andriano. Do you recognize that name? 22 were you still working for other people in Palm Beach? 23 A. No. 23 A. Yes, I did. 24 Q. What is your residence address, sir? 24 Q. Okay. And about how long a period of time did 25 A. My address is 6791 Fairway Lakes Drive, 25 you do this type of work for Mr. Epstein, the 2 (Pages 5 to 8) (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-479898cc7004  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 4 of 21 Page 9 Page 11 1 maintenance and taking out walls? 1 about seven months before -- after I become a full-time 2 A. It was couple months. It was couple months 2 employee. 3 before. 3 Q. Okay. And how did Ms. Maxwell come into the 4 Q. And what was the name of your company? 4 picture? 5 A. Alessi Maintenance. 5 A. It was his girlfriend, his main girlfriend. 6 Q. And how were you paid? 6 Q. Okay. Had you known her before she became -- 7 A. By him? 7 A. No. 8 Q. Yes. 8 Q. -- your -- 9 A. Usually by check or cash sometimes. 9 A. Never know her before. 10 Q. Do you know what company actually paid your 10 Q. I'm sorry. I didn't get a chance to finish my 11 company? 11 question. 12 A. It was Jeffrey Epstein and Company. 12 Would you have referred to her as your 13 Q. So you said you had that position for a couple 13 supervisor or your superior or what would you have 14 of months. 14 called Mrs. Maxwell? 15 What happened next? 15 A. I used to call her Ghislaine. 16 A. Then Mr. Epstein asked me to, if I wanted to 16 Q. Okay. And how was it explained to you that 17 be his employee, because I was going from one house to 17 you were now to deal with Ms. Maxwell, as opposed to 18 another house to another house, one hour here. I was 18 Jeffrey Epstein? 19 just running around Palm Beach all day. 19 A. She would tell me, I am going to take care of 20 So he asked me if I would just work for him, 20 the house. 21 exclusively for him. 21 Q. Okay. That was explained to you by 22 Q. Okay. 22 Ms. Maxwell? 23 A. And we agreed with the terms and I become a 23 A. Uh-huh. 24 full-time employee as a maintenance guy. And I was 24 Q. Is that a yes? 25 taking care of everything, as far as maintenance. 25 A. Yes. Page 10 Page 12 1 Then my job changed little by little to house 1 Q. And when Ms. Maxwell started assuming 2 man, estate manager, and then to a majordomo. 2 responsibility for the house, did your duties change at 3 Q. Okay. When you first agreed to terms with 3 that time? 4 Mr. Epstein and you first started working for him full 4 A. Not much. 5 time, what were those terms, do you remember? 5 Q. Okay. 6 A. The terms is basically was how much -- he 6 A. Not much. 7 asked me how much I was making in all the properties. 7 Q. And at that time when Ms. Maxwell started 8 And I says, well, I make this -- this amount 8 taking responsibility for the house, what were your 9 of money. 9 duties? 10 And he says, fine. 10 A. Basically I was still doing the maintenance 11 Q. And how much was that, did he pay you? 11 work. 12 A. Around $45,000. I think I started with 45. 12 Q. Okay. 13 Q. Okay. And when you started to work for him as 13 A. Was doing -- they were trying to remodel the 14 a full-time employee, did you have anybody that you 14 home and they would told me, okay, tear down this wall. 15 reported to or did you deal directly with Mr. Epstein? 15 We want to see how it's going to look. Or put this 16 A. At the beginning with Mr. Epstein, directly to 16 windows and tear down -- we had a fishing tank. We took 17 him. 17 it out -- I took it out. A kitchen on the second floor. 18 Q. Did that change? 18 I took it out. So it was basically dismantling the 19 A. Later on, yes. 19 house. 20 Q. And how did that change? 20 Q. Okay. And about how long a period of time did 21 A. When Ms. Maxwell, Ghislaine Maxwell came to 21 that project last? 22 the picture. 22 A. I would says, six to seven months. 23 Q. Okay. About when was it that she came into 23 Q. Okay. And after the remodeling slacked off or 24 the picture? 24 stopped, did your duties then change? 25 A. Exactly date, I cannot remember. But it was 25 A. Yeah. Increasingly they change. 3 (Pages 9 to 12) (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-479898cc7004  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 5 of 21 Page 13 Page 15 1 Q. Okay. Who -- 1 living on the property, but outside the house? 2 A. Periodically. It didn't change from one day 2 A. I was living in the property. No. No. No. 3 to another. 3 I was working outside the property. 4 Q. And who would tell you that your duties were 4 Q. Yes. 5 increasing? 5 A. And because it was multiple jobs that I had to 6 A. Either Mr. Epstein or Ms. Maxwell. 6 do. 7 Q. Okay. And how did your duties increase? 7 Q. Okay. 8 A. In -- I become more -- more involved in the 8 A. Had to do with the pool, the service, the 9 daily running operation of this home. This home was run 9 landscaping, taking care of that. I didn't do it 10 like a hotel basically. 10 myself, but I have people working for me. 11 Q. Okay. Were you given any manuals or rules or 11 Q. Okay. Approximately when was it in 12 procedures that you had to follow? 12 relationship to Ms. Maxwell taking over the 13 A. At the end of my stay, yes, I was. 13 responsibility of the house did you then move inside the 14 Q. Okay. At the end. And I'm going to jump to 14 house? 15 the end now and then come back. 15 A. I will says, after it was done, a big 16 What was it that you were given at the end of 16 renovation, when architects and engineers. And that was 17 your stay; what kind of papers or manuals? 17 after I did the breaking down of this renovation, they 18 A. It was a manual. I can't remember how many 18 hire architects, they hire decorators and engineers, and 19 pages, but it was quite thick manual that was -- that 19 did the -- they did the work. It was a big renovation, 20 was done by estate manager, that she will manage all -- 20 one of the renovations. 21 all the properties. And that was also to be in force in 21 And then they make our quarters. They even 22 Palm Beach. 22 built our -- my quarters in there. 23 Q. I see. Do you still have a copy of that 23 Q. When you said "our," was there someone else 24 manual? 24 who had quarters there, too? 25 A. No, I don't. 25 A. About three years later, after I start Page 14 Page 16 1 Q. Do you have any papers whatsoever that were 1 working, my wife came to help me. 2 prepared while you were working -- 2 Q. I see. And are you able to describe for me 3 A. No. 3 where the quarters were, like, what floor? 4 Q. -- for Mr. Epstein? 4 A. Yes. It was in the second floor and the -- 5 A. I left everything in there. 5 let me trying to remember -- northeast corner of the 6 Q. Did you make any diary notes yourself or any 6 property. Northeast corner, yes. 7 notes for your own private use while you worked for 7 Q. Did anyone else work for Mr. Epstein while you 8 Mr. Epstein? 8 were working for him there at the house? 9 A. No, sir. The only thing I have is my 9 A. During the whole time? 10 separation agreement. That's it. 10 Q. Yes, sir. 11 Q. Okay. Did you bring that with you today? 11 A. Yes. 12 A. No, I didn't. 12 Q. All right. When you first started there, 13 Q. Okay. Did your duties ever include taking 13 there was no one else? 14 telephone messages? 14 A. When I started there, was a -- it was a 15 A. Yes, sometimes. 15 Jamaican girl that she was doing the cooking. 16 Q. And when did that start approximately? 16 Q. Okay. Do you happen to remember her name? 17 A. When I move from the outside to the inside of 17 A. No. 18 the house. 18 Q. All right. 19 Q. All right. 19 A. She worked for couple months. 20 A. I -- when I start the position, I never had an 20 Q. I see. All right. When did any other 21 apartment in the house. And when I definite they want 21 employees begin to work for Mr. Epstein while you were 22 me inside to run the house, I had an apartment. I have 22 there? 23 a small service quarters in the house, inside the house. 23 A. They hire chefs. There was mostly European 24 Q. Okay. And when you say, outside the house, do 24 chefs. It was an English chef, but I cannot -- Rupert. 25 you mean outside the property or were you -- or were you 25 I know his name was Rupert. A french chef that was 4 (Pages 13 to 16) (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-479898cc7004  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 6 of 21 Page 17 Page 19 1 Didier. A kid from New York who was a chef, also. But 1 Q. Were there any photographs of nude females in 2 they were one after another one. They were hiring chefs 2 the house while you were there? 3 when I doing -- sometimes I did most of the cooking. 3 MR. CRITTON: Form. 4 When they wanted to bring their chef, they bring their 4 MR. WILLITS: What's the matter with that 5 chef in their plane. And the chef will stay, will work 5 form? 6 there and then will travel with them. 6 MR. CRITTON: Overly broad. Nude? You mean, 7 Q. Were there any other employees that worked for 7 completely naked? 8 Mr. Epstein while you were worked for him, that you know 8 MR. WILLITS: However you want to interpret 9 of? 9 it. 10 A. No, except my wife. 10 THE WITNESS: Excuse me. Can you repeat that 11 Q. Did you know a lady by the name of Sarah 11 again? 12 Kellen? 12 MR. CRITTON: Form. 13 A. Sarah, yes, I do. Sarah Kellen came at the 13 BY MR. WILLITS: 14 end of my stay there, probably two or three months 14 Q. Yes. Were there any photographs of nude 15 before I left. 15 females in the house while you worked for Mr. Epstein? 16 Q. Okay. Did she do any work for Mr. Epstein, 16 A. Yes. Sometimes I saw nude photographs. 17 that you know of? 17 Q. Are you able to describe where you saw those, 18 A. Yes. She was a -- I don't know her deterrent, 18 where in the house? 19 but she was an assistant to him or to her. I don't 19 A. Most of the times those photographs were taken 20 know. 20 by Ms. Maxwell. And they usually are her desk. And she 21 Q. All right. There is a -- I've seen a 21 kept a big album. 22 reference in -- and the spelling has changed in my 22 Q. Do you remember any pictures of nude or 23 various references -- is there a N. or N.? Do you 23 partially unclothed females on the walls at 24 recognize that name? 24 Mr. Epstein's house? 25 A. N. 25 MR. CRITTON: Form. Page 18 Page 20 1 Q. N. 1 BY MR. WILLITS: 2 A. N. Yes, I know N.B. 2 Q. He's just making objections for the record 3 Q. Want to take a chance at spelling that last 3 that he can take -- he will take it up with the Judge 4 name? 4 later on. 5 A. I think it was B. But she was not an 5 A. Okay. 6 employee. She was a guest. 6 Q. You don't need to worry about -- 7 Q. Was she a full-time guest? 7 A. Yes, it was. It was pictures of partially 8 A. No. 8 nude. 9 Q. When would she visit? 9 Q. And where were they? 10 A. She was a girl that was very, very talented. 10 A. Most of the times they were in the pool. 11 Mr. Epstein help her become an actress. Now she's a 11 Q. How about on the stairway? 12 movie actress and she's in a soap opera. She came with 12 A. No. On the stairway there were no pictures 13 her mother to the house. And she -- he help her come up 13 when I was there. 14 with her career. 14 Q. How many stairways were there? 15 Q. Okay. Do you -- are you familiar with any 15 A. It was the service stairway that is very 16 other individuals by the name of N. or N. who worked for 16 narrow coming from the service quarters to the kitchen. 17 Mr. Epstein? 17 And the main stairway, that it was quite wide 18 A. No. 18 and to the second floor. 19 Q. After the renovations were complete, did you 19 Just those two. 20 have access to the entire house while you worked for 20 And also there was a stairway outside through 21 Mr. Epstein? 21 the pool to the balcony upstairs. 22 A. Absolutely, yeah. 22 Q. And do you have a recollection of pictures of 23 Q. Was there any particular portion of the house 23 any females whatsoever on either of the inside 24 that was denied access by -- to you? 24 stairways? 25 A. No. 25 A. No, I don't. 5 (Pages 17 to 20) (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-479898cc7004  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 7 of 21 Page 21 Page 23 1 Q. What is your understanding, sir, of the -- a 1 Q. Okay. Do you remember any other females being 2 reference to a girl, as opposed to a woman? Are you 2 present at the house, other than the females that you've 3 familiar with the term, girl? 3 mentioned, which were N., her mother, Sarah Kellen, V. 4 A. Of course. 4 Were there any others that you -- 5 Q. Are you familiar with the term, woman? 5 A. Many, many, many, many, many. 6 A. I interpret most a woman, a married woman, a 6 Q. When did you first -- 7 married person. 7 MR. CRITTON: Can I just have the last 8 Q. Are you -- how would you describe a 14 year 8 question read back? 9 old, a woman or a girl? 9 MR. WILLITS: Of course you can. 10 A. A girl, of course. 10 MR. CRITTON: Please. 11 Q. How would you describe a 16 year old, a woman 11 MR. WILLITS: But only once. 12 or a girl? 12 MR. CRITTON: That's all I need. 13 A. Again, I don't know. I am not -- I don't 13 MR. WILLITS: You sure. 14 think I can tell you exactly she is 14 or 16. 14 Go ahead. 15 Q. But if you knew -- 15 (Previous question was read.) 16 A. Sixteen, I would think is a girl, of course. 16 MR. CRITTON: And can I just ask for a 17 Q. Were there ever any visitors to the Epstein 17 clarification from you? Are you going to use -- if 18 house that you considered to be girls, as opposed to 18 you use the word woman, are you -- 19 women? 19 MR. WILLITS: I said, females. 20 A. Yes. Yes. I think I would says, I never 20 MR. CRITTON: No, no, I understand. But in 21 check her i.d. 21 the future if you use woman, does that mean, at 22 Q. Right. 22 least to Mr. Alessi, that that's married, and if 23 A. Or I was not told to check i.d.s. -- 23 it's a girl she has to be 14 or 16? Because that's 24 Q. Of course. 24 how you asked the question. 25 A. -- on these girls. But one, I would says, 25 MR. WILLITS: All I'm going to talk about is Page 22 Page 24 1 N.B. was very young because she was in high school. And 1 females. 2 sometimes either I pick her mother and herself from her 2 MR. CRITTON: Okay. 3 house or I pick her from The School of the Arts or the 3 MR. WILLITS: And ask -- 4 ballet place, ballet in West Palm Beach. I can't 4 MR. CRITTON: I'll be alert to the questions 5 remember exactly what that place is, the name of the 5 then. 6 place. 6 MR. WILLITS: All right. So you don't need to 7 Q. Did you give -- provide transportation for any 7 sleep through the next few questions. 8 other females while you worked for Mr. Epstein? 8 MR. CRITTON: I don't sleep at all. 9 A. Occasionally, yes, I did. 9 MR. WILLITS: All right. Now I'm totally 10 Q. Do you happen to remember the names of any of 10 confused. 11 those females? 11 BY MR. WILLITS: 12 A. I remember one, specifically one. It was V. 12 Q. When did you first become aware of females 13 Her name was V. I can't remember her last name, but I 13 visiting the Epstein house? 14 think it was P. I'm not sure. I can be wrong on that. 14 A. Since I know him. 15 Q. And how many times did you provide 15 Q. During the renovations? 16 transportation services for this female? 16 A. Yeah. 17 A. Whenever I had -- I been told. Whenever I was 17 Q. Were there -- 18 told to go get them or bring them back to their house. 18 A. Before the -- before Ms. Maxwell. 19 Q. Did you consider V. to be a girl or a woman? 19 Q. Okay. All right. Let's use that as a 20 A. Again, I think it was a woman, from myself, 20 milepost. 21 her dressing and her -- I think it was -- again, I don't 21 Before Ms. Maxwell -- 22 know if she was 16, 17 or 18 or 19, could have been. 22 A. Before it was Ms. Maxwell, it was only one 23 But she was not -- I never pick her up from a school or 23 woman that it was Mr. Epstein's girlfriend. And her 24 anything like that. The only girl that I picked up from 24 name was Dr. -- she was a doctor of medicine -- Eva 25 the school was N. 25 Anderson. And I really liked this girl. She was very 6 (Pages 21 to 24) (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-479898cc7004  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 8 of 21 Page 25 Page 27 1 nice, nice person. 1 A. Because they were local. Some people, they 2 Q. Did you say Anderson or Underson? 2 live in Palm Beach. Some of these girls, they live in 3 A. Anderson, A-N. 3 Palm Beach. 4 Q. A-N-D-E-R-S-O-N? 4 Q. How did you know that? 5 A. Yeah. 5 A. They become friends. 6 MR. BERGER: What was her first name? 6 Q. Okay. Do you happen to remember the names of 7 THE WITNESS: Eva. 7 any of those friends? 8 BY MR. WILLITS 8 A. I remember there were some girls that come 9 Q. Before Ms. Maxwell assumed responsibilities 9 multiple times and they're usually there for dinners or 10 for the house, were there any other female visitors to 10 lunches. One was G.B., G.B. 11 the house, except for Dr. Eva Anderson? 11 Q. Okay. 12 A. No, not that I remember. She was one. 12 A. I think she was a -- she used to work for 13 Q. All right. After Ms. Maxwell assumed 13 Stanley, Morgan Stanley. My son work at that time same 14 responsibility for the house, do you recall any female 14 person. 15 visitors? 15 Q. Okay. 16 A. Many. 16 A. Try to remember names, but there were a lot of 17 Q. When did that start in relationship to when 17 visitors in the house, a lot of female visitors. 18 Ms. Maxwell assumed responsibilities? 18 Q. Are you aware of female visitors to the house 19 A. Immediately. 19 who were there to perform massage services? 20 Q. Were there visitors who came back more than 20 A. Yes. 21 once? 21 Q. Do you recall the first time that you observed 22 A. Yes. 22 a female come into the Epstein house for the purposes of 23 Q. And when I say, "visitors," I mean, female? 23 massage? 24 A. And males. 24 A. I don't recall that. 25 Q. I'm only interested in females. Mr. Critton 25 Q. How many different individuals came to the Page 26 Page 28 1 may be interested in the males. I'm not sure. 1 Epstein house for the purpose of massage, as far as you 2 Did you have any information as to where these 2 understood it? 3 visitors came from? 3 A. In the -- I would says, between 50 and a 4 A. They were mostly European girls. 4 hundred different persons. 5 Q. And when you say, "girls," do you mean 14 to 5 Q. Do you happen to know any of those names? 6 16, -- 6 A. I remember couple names. 7 A. No. 7 Q. Okay. 8 Q. -- or do you mean females? 8 A. And the last name I asked -- I going to tell 9 A. They all were, I would says, under -- over 20 9 you there were girls that come multiple times and there 10 years old. 10 are girls who come one times and that was it. 11 Q. Okay. And it has been explained to us in 11 Of the multiple time the girl -- the girls 12 another deposition that sometimes females travelled with 12 come to the house -- "girls," again, mean -- I'm going 13 Mr. Epstein. 13 to refer everybody as girls. 14 A. Yes, they did. 14 Q. Okay. But you don't necessarily mean under 15 Q. Are these females that you are referring to, 15 the age of 18 when you say -- 16 did they travel with Mr. Epstein or did they get to the 16 A. None of these girls were under the age of 18. 17 house in other ways? 17 Then again, I don't know. They could have been 18 or 19 18 MR. CRITTON: Form. 18 or 20 or 25. I don't know. But they were all masseuses 19 THE WITNESS: Both. 19 and they came to the house. 20 BY MR. WILLITS: 20 One of the names that I remember was D.D. 21 Q. Both. Okay. Were you aware of any female 21 Q. That's D.? 22 visitors to the Epstein house from the local area of 22 A. Uh-huh. D. I think it was. 23 Palm Beach County? 23 So many. J., A., C., J. 24 A. Yes. 24 There were also massage therapists from 25 Q. How -- and why did you become aware of that? 25 Europe. They sometimes travel with him in the plane. 7 (Pages 25 to 28) (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-479898cc7004  Case 1:15-cv-07433-LAP Document 55-12 Filed 03/14/16 Page 9 of 21 Page 29 Page 31 1 And some just names that I cannot -- I cannot go on. 1 Royal Palm Beach. 2 Q. Sure. How did you know that D. or J. were 2 She had -- she was living with a boyfriend and 3 there for purposes of a massage? 3 another person in this apartment complex in Royal Palm 4 A. Because I was told to either Ms. Maxwell will 4 Beach. 5 call, I will call or Mr. Epstein will told me, call this 5 Q. Okay. Do you happen to remember any other 6 girl at that time. Sometimes it was 1:00 in the 6 areas of the county where you transported any of the 7 morning. Sometimes it was within the afternoon. 7 females? 8 Sometimes it was after the movies. They usually go into 8 A. I transport her -- one back to a house in 9 a movie every night after dinner. And sometimes were 9 Jupiter. 10 girls that come at 10:00, 10:30. 10 Q. Okay. 11 Q. How would you know what number to call? 11 A. That's what I can remember now. 12 A. I had a list. 12 Q. Did you ever speak to any of these females 13 Q. Okay. Was this a list that you prepared or 13 that you have mentioned -- let's talk specifically about 14 was given to you? 14 the ones that you have named, D., J., A., C., J. -- 15 A. I had a list that it was in my Roladex. 15 about what they did there at the Epstein house? 16 Q. Okay. So as part of your job there was a 16 A. No. They did massage therapy. 17 Roladex? 17 Q. And how did you know they were actually