gov.uscourts.nysd.447706.1331.15.pdf

Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 1 of 27 EXHIBIT 3 (File Under Seal)  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 2 of 27 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 V::; 22 JEFFREY EPSTE I N, 23 Defendant. 24 I 25 { • ' Kress Court Reporting, Inc. 305-866·7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR)0003 15 OIUFFREOO I004  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 3 of 27 Page 271 Page 273 I JANE DOE NO. 6, CASE NO: 08·CV·80994 1 IN lliE ORCUTT COURT OF THE lSTli 2 P!aintrff, JUDICIAL CIRCUIT IN AND FOR 3 Vs. 2 PALM BEACH COUNTY, FLORIDA 4 JEFFREY EPSTEIN, 3 CASE NO. 502008CA037319XXXXMB AB s Defendant. 4 I 6 B.B., JANE OOE NO. 7, CASE NO: 08·CV·80993 5 Plaintiff, ' 8 Plaintiff, 6 Vs. Vs. 7 9 JEFFREY EPSTEIN, JEFFREY EPSTclN. to 8 Defendant. Defendant. II 9 12 C.M.A., CASE NO: 08-CV-8081 I 10 13 Plaintiff, 11 14 Vs. 12 1031 Ives Dairy Road IS JEFFREY EPSTEIN, Suite 228 16 Defendant. 13 North Miami, Florida 17 August 7, 2009 JANE DOE, CASE NO: 08·CV·80893 14 1: 15 p.m. to 5:30 p.m. 18 15 Plaintiff, 16 CONTINUED 19 17 VIDEOTAPED vs. 18 DEPOSITION 20 JEFFREY EPSTEIN, 19 of 21 20 ALFREDO RODRJGUEZ Defendant. 21 22 I 22 taken on behalf of the Plaintiffs pursuant 23 23 to a Re-Notice of Taking Continued Videotaped 24 24 Deposition ( Duces Tecum) 25 25 ... Page 272 Page 274 i 1 JANE DOE NO. II, CASE NO: 08·CV·80469 I APPEARANCES: 2 Plaintiff, 2 3 MERMEI.Sll:IN &. HOROWITZ, P.A. 3 Vs. BY: ADAM HOROWITZ, ESQ. 4 JEFFREY EPSTl:IN, 4 18205 Biscayne Boulevard 5 Defendant. Solle 2218 s Miami, Flor1cla 33 l60 6 Attorney for Mne Doe 21 3, 4, S, 6 6, and 7. JANE DOE NO. 101 CASE NO: 08·CV·80591 7 7 8 R0111STEIN ROSENFELDT ADl.fR Plaintiff, BY: BAAD J. EOW.AROS, ESQ., and 8 9 CAAA HOLMES, ESQ. Vs. Las Olas Oty Centre 9 10 Suite 1650 40I East lM Olas Boulevard JEFFREY EPSTEIN, II Fort Lauderdale, Florida 33301 10 Attorney for Jane Doe and E.W. Defendant. 12 And LM. 11 I 13 12 JANE DOE NO. 102, CASE NO: 08·CV·80656 14 PODHURST ORSOCK BY: KATHERINE W. EZEU, ESQ. 13 Plaintiff, 15 25 West Flagler Street 14 Vs. SUite BOO 15 JEFFREY EPSTEIN 16 Miami fiorida 33130 16 Defendant. Attorney for Jane Doe IOI and 102. I 17 18 17 1£0POI.O-KlMN 18 19 BY: ADAM J. LANGINO, ESQ. 19 2925 PGA Boulevard 20 20 Suite 200 21 Palm Beach Garoens, Florida 33410 21 Attorney for B.B. 22 22 23 23 24 24 25 25 r ' 2 (Pages 271 to 274) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 00031 6 GIUFFRE001005  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 4 of 27 Page 299 Page 301 1 A. I don't remember, Ma'am. He came from 1 video, even phones. 2 New l\'bany, Ohio. 2 Q. Would he also repair the televisions if 3 Q. From New - 3 they needed work? 4 A. New Albany, Ohio. 4 A. No. 5 Q. New Albany, Ohio. Did he have his own 5 Q. No. Did you have any kind of intercom 6 business? 6 system in the house? 7 A. No, he worked for Mr. Epstein. He will 7 A. Yes, ma'am. 8 maintain all the computers. 8 Q. And what kind of system was that? 9 Q. Was he there everyday? 9 A. It was standard office equipment, Lucid 10 A. No, ma'am. 10 Technologies maybe, but it was an intercom like we 11 Q. Do you know whether at that time Mr. 11 using rig ht now. 12 Epstein had an office in Palm Beach? 12 MS. EZELL: Just let the record reflect 13 A. Not outside the house, no. 13 that the witness pointed to the telephone on 14 Q. Do you have any knowledge of whether or 14 the table that has a speaker phone. 15 not the video equipment was -- and I don't know 15 THE WITNESS: Yes, ma'am. 16 the technical term, forgive me, but was it the 16 BY MS. EZELL; 17 kind of equipment that would record for a certain 17 Q. And did you use that in your work? 18 amount of time and then record over that film? 18 A. Yes, ma'am. 19 A. I don't know. 19 Q. And what did you use it for? 20 MR. CRITTON: Form. 20 A. Mr. Epstein used to page me when he 21 BY MS. EZELL: 21 needed me. 22 Q. You don't know? 22 Q. Did you have one of those phones in the 23 A. No, ma'am. 23 kitchen? 24 MR. CRITTON; Just for clarification, I 24 A. Yes, ma'am. 25 may have misunderstood, but I thought he 25 Q. And was there one out in the staff house Page 300 Page 302 ( 1 said he didn't even know the video equipment 1 as well? 2 existed until he read the FBI report. 2 A. Yes, ma'am. 3 MS. EZELL: He said he didn't know that 3 Q. Do you know where others were in the 4 it was upstairs and downstairs, I believe. 4 house? 5 MR. CRITTON: I thought he said he didn't 5 A. Probably have like 15 phones. We used to 6 know that It even existed. 6 have three In the staff house, one In the cabana, 7 MS. EZELL: I may be wrong. 7 two In the master bedroom, one in each room, 8 BY MS. EZELL: 8 kitchen, dining room, Mrs. Maxwell's office, the 9 Q. Did you know it existed before you read 9 garage. 10 the FBI report? 10 Q. Where was Mrs. Maxwell's office? 11 A. No, ma'am. 11 A. Under the stairs next to the kitchen. 12 Q. I'm sorry, then I was wrong. 12 Q. can you give me some idea of what size 13 How did you know then that the young 13 space that was? 14 technician from Ohio maintained the computers and 14 A. It was probably -- we change the floor. 15 the video equipment? 15 Twelve by five, something like that. 16 A. Because we used to request -- there were 16 Q. And was the computer equipment in that 17 always problems with the computers so he came to 11 space1 18 the house and he was the programmer. It was very 18 A. Yes, ma'am. 19 sophisticated. 19 Q. Do you know whether Ms. Maxwell kept the 20 MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came 21 move to strike the answer as nonresponsive. 21 to do massages? 22 BY MS. EZELL: 22 A. Yes, ma'am. 23 Q. How did you know then that he maintained 23 MR. CRITTON: Form. 24 the video equipment as well? 24 BY MS. EZELL: 25 A. Because he was in charge of computers, 25 Q. Do you know that because you saw the 9 (Pages 299 to 302) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000323 GIUFFRE00 10 13  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 5 of 27 Page 303 Page 305 1 names and phone numbers? 1 computer? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 5 Q. And did she generally have phone numbers 6 girls on the computer? 6 for those girls? 7 A. Yes, she did. 7 A. Yes, ma'am. 8 Q. And you know that as well because you 8 Q. And were they generally pictures of the 9 happen to see them? 9 girls? 10 A. Yes, ma'am. 10 MR. CRITTON: Form. 11 MR. CRITTON: Form to the last two 11 THE WITNESS: No, ma'am. 12 questions. 12 BY MS. EZELL: 13 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 Q. Were they similar to the pictures that 14 girls who came to give massages? 15 Ms. Kellen had on her computer? 15 MR. CRITTON: Form. 16 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 Q. Did the pictures that they kept there 19 A. Yes, ma'am. 20 look like pictures that were posed? 20 MR. CRITTON: Form. 21 A. They were more casual. 21 BY MS. EZELL: 22 Q. Did they look as though the person being 22 Q. Were there pictures on her computer of 23 photographed knew that they were being 23 the girls who came to give massages? 24 photographed? 24 MR. CRITTON: Form. 25 MR. CRITTON: Form. 25 BY MS. EZELL: Page 304 Page 306 . 1 THE WITNESS: No, ma'am. 1 Q. Ms. Maxwell I'm talking about. 2 BY MS. EZELL: 2 A. Yes, ma'am. 3 Q. And what can you tell me about that, what 3 Q. And were those pictures the more casual 4 lead you to draw that conclusion? 4 ones that you described when I asked whether or 5 A. They were probably taken in parties in 5 not the subject looked as though she knew she was 6 big reception or banquet. 6 being photographed? 7 MR. CRITTON: Let me offer as a 7 MR. CRITTON: Form. 8 suggestion, not that you have to accept or 8 THE WITNESS: I'm sorry, can you repeat? 9 that you would, you're using the term young 9 BY MS. EZELL: 10 girls generically, he has probably seen 10 Q. Yeah. The pictures of the young girls 11 many, many young girls, there was no •· 11 who came to the house to give massages that were 12 you've used it interchangeably with just 12 on Ms. Maxwell's computer, did they appear to have 13 young girls versus young girls who may have 13 been taken when the girls knew they were being 14 come to·· purported to give a massage and, 14 photographed? 15 therefore, that may be a different answer, 15 MR. CRITTON: Form. 16 so that's part of my form objection. 16 THE WITNESS: I don't think they knew ll ,·,~. C:£.CLL, Ul\ay, ,11dfll<. yuu. lt \1•~1 •~•,;; v~•",I JJl,vw':',vl""~v, 18 BY MS. EZELL: 18 BY MS. EZELL: 19 Q. When I asked you about Ms. Kellen whether 19 Q. I believe you said they were more casual 20 she had a list of the girls and telephone numbers, 20 pictures. 21 I think I asked about those girls that came to 21 A. Yes, ma'am. 22 give massages, but let me go back and just ask it 22 Q. Did you notice any nude photographs in 23 that way. 23 those pictures? 24 Did you notice that Ms. Kellen had a list 24 A. Yes, ma'am. 25 of the girls that came to give massages on her 25 MR. CRITTON: Form for the last question. I. 10 (Pages 303 to 306) Kress Court Reporting, Inc. 305-866·7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000324 GIUFFRE00 1014  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 6 of 27 Page 335 Page 337 1 Q. Do you remember whether she came to the 1 A. I give him a list of notes that I used to 2 house on more than one occasion? 2 take from frequent people -- I mean, people who 3 A. I heard her name several times from 3 used to frequent the house and -- I'm sorry, it's 4 Sarah, sir, but beyond that I cannot say anything 4 been a few years, I don't remember, but it was 5 else. 5 those years, like it was a file with my personal 6 Q. Okay. Who have you talked to about your 6 notes because he told me it was very important and 7 knowledge of Mr. Epstein in the last year? 7 he kind of said can I borrow this from you, and he 8 A. My wife. 8 still has those documents, sir. 9 Q. Anyone else? 9 Q. So even though they pertain to Mr. 10 A. No, sir. 10 Epstein you kept those notes at your residence? 11 Q. Well, you talked to Mr. Critton. 11 A. Yes, sir. 12 A. We have a conversation in West Palm 12 Q. Okay. Where in your residence did you 13 Beach. 13 keep those notes before you gave them to the 14 Q. Yes. So you talked to your wife, you 14 Detective? 15 talked to Mr. Critton? 15 A. In my bedroom. 16 A. Yes. 16 Q. Did you have a file cabinet or -- 17 Q. Had you talked to anyone else in the last 17 A. No. 18 year about Epstein? 18 Q. -- chester drawers or something? 19 A. No. 19 A. No, they were laying next to some other 20 Q. Did you talk to Mr. Goldberger? 20 papers that I have. 21 A. Yeah, I called Mr. Goldberger first 21 Q. Did the other papers pertain to Mr. 22 before I talked to Mr. Critton. 22 Epstein? 23 Q. Okay. So we have your wife, we have Mr. 23 A. No, no, nothing else related to Mr. 24 Critton, and we have Mr. Goldberger. 24 Epstein. 25 Do we have anyone else that you talked to 25 Q. I'm just confused as to why you told us Page 336 Page 338 ( 1 in the last year? 1 before that you had a journal at home and today 2 A. No, sir. 2 you say that you gave everything to the Detective. 3 Q. How about Mr. Epstein of course? 3 MR. CRITTON: Form. You also may have 4 A. No. 4 missed a portion of his earlier testimony if 5 Q. Where did you usually keep the journal 5 you couldn't hear something, but go ahead. 6 with the names of the girls, in what part of the 6 MR. WI LLITS: Most likely. 7 house? 7 THE WITNESS: What I said was I thought I 8 A. In the staff house. 8 had some information, and then I look with 9 Q. Sorry? 9 my daughter and we couldn't find anything, 10 A. The staff house, the guest house. 10 and I remember now that I put everything in 11 Q. Right. But you said you had a journal at 11 the file that I give to Detective Recarey. 12 your own residence with the names of the girls. 12 BY MR. WI LLITS: 13 A. I give the whole journal and all the 13 Q. Did anyone help you assemble those papers 14 information regarding this case, sir, to Detective 14 to give to the Detective? 15 Joe Recarey, sir. 15 A. No, sir. 16 Q. Okay. And the materials that you gave to 16 MR. WILLITS: I don't have any other ll lfle Uete1..UVC1 VVCI C U 1<:::y l\t::}Jl -- VV<:;I <::: cl11y Qf lll<:11 I lt '"IY~J"v,I:>. 18 kept at your own personal residence? 18 CROSS EXAMINATION 19 A. Yes, they were with me, sir. 19 BY MR. CRITTON: 20 Q. Okay. When you gave the materials to the 20 Q. Mr. Rodriguez, my name is Bob Critton and 21 Detective, did all of the materials you gave to 21 I represent Mr. Epstein as you're aware, I have a 22 him come from your residence? 22 few questions for you. 23 A. Yes. 23 What I would like to remind you at the 24 Q. Do you remember exactly what you gave to 24 start of this is if you know something, tell us, 25 him? 25 if you don't know something tell us that. ' 18 (Pages 335 to 338) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000332 GIUFFRE00 1022  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 7 of 27 Page 339 Page 341 1 You're not required to speculate, you're 1 marked up, no, you can't. 2 not required to guess, you're not required to 2 MR. CRITTON: I just want to show him. 3 assume because some lawyers ask you a leading 3 Thank you, (athy. 4 question or suggested in a report or like the 4 BY MR. CRITTON: 5 police report like Mr. Mermelstein and Mr. Edwards 5 Q. This is the first what Ms. Ezell was kind 5 did, that did you tell the police officers X, Y, 6 enough to provide is the first part of your 7 or Z without showing you the statement. You're 7 deposition, it was transcribed by the court 8 not required to guess, I want personal knowledge, 8 reporter and provided by all counsel. 9 not speculation. Do you understand? 9 Do you understand that? 10 A. Yes, I do. 10 A. Yes, I understand that. 11 Q. All right. Now, when Mr. Edwards and -- 11 Q. And no one has provided that to you yet 12 Mr. Horowitz is here today for Mr. Mermelstein, 12 today; have they? 13 but you remember a lawyer asked you some questions 13 A. No. 14 last time you were here? 14 Q. Now, I think you told us that with the 15 A. Yes. 15 police officers you gave a taped statement. 15 Q. That is he started and he went on for a 16 Did I understand you correctly? 17 few hours. Do you recall that? 17 A. Yes. 18 A. Yes, I remember. 18 Q. And the only conversation that you had 19 Q. He asked you do you remember telling the 19 with the police officers, and it may have been a 20 police officer Y, X, or Z. 20 state attorney, it was somebody named Ms. Weiss 21 Do you remember that? Do you remember 21 who I think was referenced in the questions, the 22 that's how he phrased his question? 22 only time that you talked with at least Officer 23 A. Yes, yes. 23 Recarey and the State Attorney's Office from Palm 24 Q. He never showed you a statement that you 24 Beach County was in a taped statement. 25 made to the police department; did he? 25 Is that correct? 1 Page 340 Page 342 ( 1 A. I'm sorry? 1 A. No. 2 Q. He didn't show you a document that said, 2 Q. Did you talk with them separate and apart 3 question, you know, what is your name; answer, my 3 from that? 4 name is Alfredo Rodriguez -- 4 A. Yes, I did. 5 MR. WILLITS: Object to the form of the 5 Q. Okay. Did they tape that statement? 6 question. 6 A. No. 7 MR. CRITTON: You need to let me finish 7 Q. You told us you also spoke with 8 it first. 8 representatives of the FBI? 9 MR. WILLITS: I'm sorry, I thought you 9 A. Yes. 10 were. 10 Q. Okay. And you distinguished between the 11 BY MR. CRITTON: 11 FBI and between Officer Recarey? 12 Q. He never showed you a statement of what 12 A. Yes. 13 the question was and the answer that you gave. 13 Q. So how many times did Officer Recarey, or 14 True? 14 Detective Recarey, I think he's from the Palm 15 16 17 MR. WILLITS: Object to the form of the question. 1HE WITNESS: I don t exact1y unoerstana 15 16 1/ Beach Police Department speak with you? A. Like three or four times. l,!. tlUt ne on,y lOOK one srn,cn,cmr I 18 your question. 18 A. One taped. 19 BY MR. CRITTON: 19 Q. I'm sorry, one taped statement? 20 Q. Do you know what a deposition is? 20 A. Yes. 21 A. Yes, I am. 21 Q. All right. So as to whether or not if 22 Q. That's what you're doing here. 22 you said something to Officer Recarey or not that 23 MR. CRITTON: Could I borrow your 23 you would be able to confirm, that would only have 24 deposition for just a minute? 24 been in a taped statement, one taped statement out 25 MR. HOROWm: The transcript? It's 25 of the three, approximately three times he spoke l 19 (Pages 339 to 342) Kress Court Reporting, Inc. 305·866·7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000333 GIUFFRE00 1023  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 8 of 27 Page 343 Page 345 1 with you. 1 Q. When Officer Recarey took -- spoke with 2 MR. EDWARDS: Form. 2 you on those approximately two times when he did 3 MR. HOROWITZ: Form. 3 not take a taped statement, did he ever present 4 BY MR. CRITTON: 4 anything ror you, anything in writing that he had 5 Q. Is that correct? 5 written to say, Mr. Rodriguez, I would like you to 6 A. Yes, correct. 6 review this to make certain that I took down 7 MR. WILLITS: Obj ect to the form. 7 correctly what you said? 8 MR. HOROWITZ: Join. 8 A. No, sir. 9 BY MR. CRITTON: 9 Q. If he had offered to do that would you 10 Q. And when we were here, I think it was 10 have read what he wrote down to determine whether 11 last week or the last ten days anyway -- I could 11 or not he took down that which you had said or 12 tell you. On July 29th of this year, and Mr. 12 told him? 13 Mermelstein started with your deposition and then 13 MR. EDWARDS: Object to the form. 14 others asked questions, when Mr. Mermelstein and I 14 THE WITNESS: Probably I will read It 15 think Mr. Edwards asked questions about did you 15 first. 16 tell Officer Recarey X, Y, or Z, they didn't show 16 BY MR. CRITTON: 17 you a statement, they didn't give you like a 17 Q. All right. And if In fact he had 18 transcript like this and say see what the question 18 recorded something incorrectly or recorded in a 19 and see what the answer is? 19 particular way that he wanted it phrased and it 20 A. No. 20 was not accurate, would you have told him that? 21 MR. EDWARDS: Form. 21 MR. EDWARDS: Object to the form. 22 MR. WILLITS: Object to the form of the 22 THE WITNESS: No, I never told him that. 23 question. 23 BY MR. CRITTON: 24 BY MR. CRITTON: 24 Q. Listen to my question. 25 Q. And you haven't had an opportunity to see 25 If he, Officer Recarey, had taken down Page 344 Page 346 1 your taped statement since you gave it many years 1 what you said and it was not accurate, that is, he 2 ago? 2 put his interpretation of what you said, would you 3 4 5 A. No, sir. Q. Would you agree that your taped statement would probably be a little more accurate than your 3 4 5 have told him that's not accurate, Officer Recarey? MR. HOROWITT: Form. . l 6 testimony today because of the time period that 6 MR. EDWARDS: Object to the form. 7 has transpired? 7 THE WITNESS: I will tell him. 8 A. That's correct. 8 MR. CRITTON: Go ahead and change. We're 9 MR. HOROWITZ: Object to the form. 9 going to change the tape. We do have time. 10 MR. WILLITS: Object to the form of the 10 Cathy, could I borrow back the 11 question. 11 photographs, please? 12 BY MR. CRITTON: 12 While you're giving me those back, would 13 Q. When you spoke with the FBI over at 13 it be correct that you're going to keep -- 14 Greens -- I think it was Greens Pharmacy? 1<1 you took as you did with photograph 15 A. Yes. 15 number four you took back five, six, seven, 16 Q. Did they take a statement from you, that 16 and eight, and you're going to keep those 17 is, did they have a tape recorder or did they just 17 ana not allow me or anyone e1se to nave a 18 make notes? 18 copy of them? 19 A. They took notes. 19 MS. EZELL: Yes. 20 Q. All right. Did you sign anything? 20 MR. CRITTON: You're going to be equally 21 A. No, sir. 21 restrictive; right? 22 Q. That Is like did they take notes of what 22 MS. EZELL: Right. 23 you said and then you signed it to say yep, that 23 MR. CRITTON: All right. Thank you. 24 accurately reflects what I said? 24 BY MR. CRITTON: 25 A. No, I didn't sign anything. 25 Q. You were shown photograph five of a lady, 20 (Pages 343 to 346) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000334 GIUFFRE00 I024  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 9 of 27 Page 3'¼7 Page 3'19 1 F.E., and I think you told us that you had seen 1 Q. I'm sorry? 2 her, you recognized her photograph. 2 A. Yes, I did, I told the police. 3 A. Yes, I did. 3 Q. And at the time that you spoke with the 4 Q. On how many occasions did you ever see 4 police and gave them a statement, isn't it true, 5 her at the Epstein home? 5 Mr. Rodriguez, that you were no longer employed by 6 A. More than three times. 6 Mr. Epstein? 7 Q. More than three? 7 A. Yes. 8 A. Yes, sir. 8 Q. And you understood that you were required 9 Q. That's as accurate as you can be? 9 to tell the police officers the truth at that 10 A. Yes. 10 time? 11 Q. More than three? 11 A. Yes. 12 A. More than three. 12 Q. And if I understood your testimony I 13 Q. Whether it was four or five you don't 13 believe from July 29th through today, you at no 14 know, but more than three? 14 time asked any of these girls how old they were. 15 A. More than three, sir. 15 True? 16 Q. In terms of F.E.'s age, did you ever ask 16 A. No. 17 her what her age was? 17 Q. And as to whether the girls were under 18 18 A. No, sir. 18 or 18 or over 18, you really didn't know one way 19 Q. Did she appear to you to be someone at 19 or the other at the time. Would that be a fair 20 least from seeing her and recalling her that she 20 statement? 21 appeared at least to you to be while a young woman 21 A. Yes. 22 appeared to be someone who was 18 or older? 22 MR. WILLITS: Object to the form of the 23 A. No, sir. 23 question. 24 Q. Okay. Well, did you ever say anything to 24 BY MR. CRITTON; 25 the police or did you ever -- were you ever 25 Q. On Exhibit 6 there is a person who's Page 348 Page 3S0 / I I 1 concerned about that such that you told someone? 1 covered, the lady that Ms. Ezell asked you about I 2 A. No, sir. 2 believe was on the right-hand side of the 3 Q. Haven't you told the police, sir -- let 3 photograph. There is a young lady on the 4 me strike that, let me ask it this way. 4 left-hand side with a black hat on. 5 In your taped statement that you gave to 5 Do you recognize her at all? 6 the police did you not tell them that all of the 6 A. No, I don't recognize her. 7 girls appeared to you to be 18 or above? 7 Q. Okay. Thank you. With regard to the 8 A. Sir, as far as when all these actions 8 photograph four that you saw that you think g that were taking place I was under an environment g possibly might b ~ I think you told us that 10 that I thought I was going to be -- in other 10 you recall seeing that woman in the sauna at Mr. 11 words, I was afraid of any reprisal Mr. Epstein 11 Epstein's house on one occasion and she was naked. 12 and Mrs. Maxwell if I say something that is any 12 A. Yes. 13 idea of me because I have this confidentiality 13 Q. Was that near the end of your employment 14 agreement. What I saw that they were very young, 14 or the middle or the front end? 15 but I cannot say that they were 18 ard old. 15 A. I saw her on January 2005, sir, and I was 16 Q. Right. Let me just take you back to my 16 terminated in March, so that was two months prior. 17 question aga,n and see 1t you can answer my ll l,!. Ano 010 you ever ce11 anyone ",a, yuu , ,u u 18 question. 18 seen her naked in the sauna? 19 MR. CRITTON; Could you please read it 19 A. I told Louella. 20 back? 20 Q. Okay. And what did Louella say? 21 (Thereupon, a portion of the record was 21 A. She was surprised. 22 read by the reporter.) 22 Q. Okay. Did you wake the young lady up in 23 THE WITNESS: I think I told the police 23 the sauna? 24 that. 24 A. No. ,· 25 BY MR. CRITTON: 25 Q. And do you know how old t he young lady ( 21 (Pages 347 to 350) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, A_ 33141 NON PARTY (VR) 000335 GIUFFREOO I 025  Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 10 of 27 Page 351 Page 353 1 wa