EFTA00157548.pdf

Page 1 UNITED STATES DISTRICT COURT 1 On behalf of the Defendant: SOUTHERN DISTRICT OF FLORIDA CASE No.08•CV.80119•CIV•MARRAIJOIINSON 2 ROBERTI. CRITTON. ESQUIRE R JANE DOE NO. 2. 3 Plaintiff. n. 4 JEFFREY EPSTEIN. 5 Defendant. 6 7 Related cases: 08.10232. 0840360. 984038108.10994. a 0640993. 0840811. 08.80893. 09.80169. 9 09.10591.09.80656.09.80802.0941092 10 11 VIDEOTAPED DEPOSITION OF JUAN ALESSI 12 VOLUME I 13 Tuesday. September 8. 2009 14 1012 am.. 3:45 pm. 15 16 2139 Palm Beach Lakes Boulevanl 17 West Palm Beach. Banda 31301 18 19 20 Reported By 21 Sandra W Townsend. FPR Now), Public. State of Flan& 22 PROSE COURT REPORTING AGENCY 23 West Palm Beach Office 24 25 Page 2 Page 4 APPEARANCES: 1 On behalf of the Plaintiffs: RICHARD WII.I.ITS. ESQUIRE 2 EXHIBITS RICHARD H. WILLITS PA 3 4 4 5 NUMBER DESCRIPTION PAGE 76 5 STUART hIERAIELS1EIN. ESQUIRE 6 Exhibit number 1 Photographs 45 7 Exhibit number 2 Transcript B0 9 B Exhibit number 3 Incident Report 137 9 Exhibit number 4 Incorporation Papers 149 10 11 10 Exhibit number 5 Incorporation Papers ISO 11 12 12 13 13 14 14 15 KATHERINE W. EZELL. ESQUIRE 15 16 16 IT 17 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 1 (Pages 1 to 4) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 FOIA Confidential Treatment Requested / Fed. R. Crim. P. 6(e) Material Electronically signed by Sandra Townsend (401-377-676-289S) GJ SUBPOENA RESPONSE 000337 Electronically signed by Sandra Townsend (401-377-676-289S) 76e15648-4alc-Odee-67ac-479898cc7004 3504-021 Pagc I of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002595 EFTA00157548  Page 5 Page 7 1 PROIEEDINGS 1 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 19 Q. 1999? 20 MR. BERGER: WilliamJ. Berger. representing 20 A. Yeah. 21 ...mg 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 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 examined7 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. re resent a young lady by the name of 17 basically what I did the most was taking walls apart. 18 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. 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 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 FOIA Confidential Treatment Requested /Fed. R. ern. P. 6(e) Material Electronically signed by Sandra Townsend (401-377-676-2895) al SUBPOENA RESPONSE 000338 Electronically signed by Sandra Townsend (401-377-676-2895) 76.1564a-4alc-4dee-87ac-479808cc7004 3504-021 Page 2 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00002596 EFTA00157549  Page 9 Page 11 _ 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. S 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 :1 company? 11 question. :2 A. It was Jeffrey Epstein and Company. 12 Would you have referred to her as your :3 Q. So you said you had that position for a couple 13 supervisor or your superior or what would you have :4 of months. 14 called Mrs. Maxwell? :5 What happened next? 15 A. I used to call her Ghislaine. :6 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 S 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 :1 Q. And how much was that. did he pay you? 11 work. :2 A. Around 445.000. I think I started with 45. 12 Q. Okay. :3 Q. Okay. And when you started to work for him as 13 A. Was doing — they were trying to remodel the :4 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 lime 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 FOIA Confidential Treatment Requested /Fed. R. Cren. P. 6(e) Material Electronically signed by Sandra Townsend (401-377-676-2895) al SUBPOENA RESPONSE 000339 Electronically signed by Sandra Townsend (401-377-676-289S) 76ef664a-ealc-edee-87ac-479898ec7004 3504-021 l'a"4e 3 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002597 EFTA00157550  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 wu 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 mute 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. :3 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 wen 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 FM Confidential Treatment Requested I Fed. R. Cren. P. 6(e) Material Electronically signed by Sandra Townsend (401-3n-67B-289S) al SUBPOENA RESPONSE 000340 Electronically signed by Sandra Townsend (401-377-67B-2895) 760564a4ato-4dee-87ao-479898ce7004 3504-021 Page 4 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00002598 EFTA00157551  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 S 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 11 again? 12 =I 12 MR. CRITTON: Form. 13 A. • yes. I do. --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 sin. 21 Q. All right. There is a -- I've seen a 21 kept a big album. 22 23 24 various references -- is there recognize that name? a reference in -- and the spelling has changed in my or.?Do you 22 23 24 Q. Do you remember any pictures of nude or partially unclothed females on the walls at Mr. Epstein's house? 25 A. 25 MR. CRITTON: Form. Page 18 Page 20 1 Q. 1 BY MR. WILLITS: 2 A. Yes. I know 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. S A. I think it was 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. Most of the times they were in the pool. 11 Q. How about on the stairway? Ill 12 A. No. On the stairway there were no pictures 13 when I was there. re. i 14 Q. How many stairways were there? 15 16 17 other individuals by the name ME Mr. Epstein? on Q. Okay. Do you — are you familiar with any 15 who worked fo- 16 17 A. It was the service stairway that is very narrow coming from the service quarters to the kitchen. 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 FOIA Confidential Treatment Requested /Fed. R. Cren. P. 6(e) Material Electronically signed by Sandra Townsend (401.377478-2895) al SUBPOENA RESPONSE 000341 Electronically signed by Sandra Townsend (401.377476-2895) 76M5648.4atc-Odee-87ac479898ce7004 3504-021 Page 5 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002599 EFTA00157552  Page 21 Page 23 1 Q. What is your understanding. sir, of the -- a 1 Q. Okay. Do you remember any other females beitq 2 reference to a girl. as opposed to a woman? Are you 2 present at the house, other than the females that ou'vc 3 familiar with the term. girl? 3 mentioned. which were 4 A. Of course. 4 Were them 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. :0 A. A girl. of course. 10 MR. CRITTON: Please. :1 Q. How would you describe a 16 year old. a womar 11 MR. WILLITS: But only once. :2 or a girl? 12 MR. CRITTON: That's all I need. :3 A. Again. I don't know. I am not -- I don't 13 MR. WILLITS: You sure. :4 think I can tell you exactly she is 14 or 16. 14 Go ahead. :5 Q. But if you knew -- 15 (Previous question was read.) :6 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? Arc you going to use -- if 18 house that you considered to be girls. as opposed to 18 you use the word woman, am 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 its 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 M. was very young because she was in hi w school. Ant 1 females. sometimes either l •ick he 2 MR. CRITTON: Okay. I 3 MR. WILLITS: And ask -- I 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 it 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. 12 Q. When did you first become aware of female:, 13 Her name I cant remember her last name, but I 13 visiting the Epstein house? 19 think it w• 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 brio them back to their house. 18 A. Before the -- before Ms. Maxwell. 19 Q. Did you conside 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 29 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 wan 25 Anderson. And I really liked this girl. She was veil. 6 (Pages 21 to 24) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 FOIA Confidential Treatment Requested /Fed. R. ern. P. 6(e) Material Electronically signed by Sandra Townsend (901-377.676-2895) al SUBPOENA RESPONSE 000342 Electronically signed by Sandra Townsend (40f-377-676-2895) 7601564a-4a Ic-4dee-87ac-479898cc7004 3504-021 Page 6 of 20 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002600 EFTA00157553  Page 25 Page 27 1 nice, nice person. 1 A. Because they were local. Sonic people. they 2 Q. Did you say Anderson or Underson? 2 live in Palm Beach. Sonic 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 them 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 M.. 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 14 responsibility for the house, do you recall any female 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 responsibilit