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UNITED STMES DISTRICT COURT 1 APPEARANCES:
SOMMRN DISTRICT Or FLOOIDA
CUE IM.08-CV-80119-GIV4PARA/J01135031 2 On behalf of the Tliantilfs:
3 RIONARD WILLITS. ESQUIRE
JAKE DOC NO. 2.
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6
JEFFREY EPSTEIN.
STUART MERNELIMIN, ZMUIRE
Defendant. mou•elelit 4 ennwsres •
Related mew
08-80234 0840180, 98.80381, 0840994, 1
0840993, 08-8081I, 0840993, 0940469,
09-50591, 09-80446, 0940102, 0941092 10
It WILLIAM J. ROOM, ESQUIRE
RORISTEIN RIMENFELDT ADM*
VIDEOTAPED DEPOSITION Or JUAN ALESSI 12
MIME If
13
Tuesday, September 8. 2009
10i12 a.n. - 3:45 p.n. 16
15 YATNERIWZ EZELL,
POI:WORST CREECH. P.A.
16
2139 Pals beech Letts Boulevard 17
West Palm Mech. flor IN 33401
le
If ADM J. LAM010. ESQ000,
LEOPOLD MNIN
20
Reported ny:
Sandra W. Townsend. flit 21
Votary Public. state of Florida
PROSE COURT REPORTING AGENCY 22
Went Fels Mack Or flee
23
26
25
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1 On behalf of the Defendant: PROCEEDINGS
2 ROBERT J. GRITION. ESQUIRE 2
Wimp. rsirm: !Pain"
3 Dep0sitiOn taker: before Sandra M. TO.M5Oted. Court
4 Reporter end Notary Public. In and for the State et
5 FlOride at large, in the above Cause.
5
6
6
(Continued tron VOluse 1.1
VIDCOGRATIMIO we'te going beet On the record
e
• at 12:52.
10 10 CRASS EXAMMTIO11
11 BY PR. MMINO:
11
12 O. Rolle. My maw le Mae Langan., and I
12
13
11 represent el 1.11 have fewer questions than the rot
14 ll of everybody. since I's: going next in line. nut one of
15 15 the thing. 1 vented to tak you
14 16 lat. GRIMM: before you get .,tart ed. let m
IT Just put on fry objection.
18 Is Ma, your client le who allege. that
19 19 she vas at Wr. Met•in's house raset W. 1 think..
20 20 On One occasion in the ban of '03.
21 21 This Mtn's, Is neither relevant, nor
22 22 material, nor Can It lead to the adnisalhil ay 0
21 2) any relevant infonutIM regardlng ny client. So I
26 24 nnrh, ilt•nd *0 you ce rtainly can notice Mu, Du:
25 25 .•:. 7ove to •trike 4711 of the question and
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1 enviers in response to yobs question.. 1 Were there any general difference, between
2 le. lANGINO: Thank you. those message theraplet• that you pall with check. and
3 BT MR. LANGIMO: 3 ' h. " that You paid with canal?
4 O. One thine I won't sure about was the dote Of R. Mo. ear. It seas ... when I vas then savoys
5 your enploynent. When did you start with Nr. Cpolein? 5 was a hundred dollar. an hour rat*. root was ler
6 A. : as not sure. air. but I think I started lull 6 everybody.
7 tine ea ay salary. I was on the roll In 1591. 1551. O. Dad you ever hear Jeffrey Epstein talk about
January 1, 1951. S hie lea...apes?
0. In 1551. you started full time with 9
10 Nr. Epstein? 10 O. At one point you wild that you're not -- this
11 A. Yea, wafting for hin alone. 1 left all ny 11 night be aunNarazing your terettoony -- that you way not
)2 Clients. I left -- dissolved ny ~Pan?. 12 be the beat guesser or ages. Is that sornhInq that you
1) 0. And in what year did you start past tine at 1) nay hove said earl er today?
14 his house? 14 AIR. CRITIC«, Fora.
IS A. 1590. '90. 15 INC INTIMSS: Yeah. Yeah. 1 think I -- you
16 Q. lea rentlored earlier that sole of the snap. 14 can be thirtieth twentleS. I don't kn0w.
1? therapist. you pald with check.? It BY MR. ?AMINO:
19 A. Yes. le
19 0. And acne Of the aaaaapa therapist. you paid it
20 with cash? 20
It A. Sorry. can you repeat the au/ration, SI
22 O. Sure. You wintiored earlier that you paid 22
2) .ore of the passel. therapist. with chock. and song with SI
21 cash? 24
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2 2 That's Correct.
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4 today?
5 KR. CRITTOM: Fern.
6 TNN 11:TMESS: You caked se. They asked no. 2
7 • think 1 Just answer question...
S • by IS. IAMGINO:
As you reflect back in your ties 'sorting for
10 10 Nr. Epstein. today de you believe you turned a bland eye
11 ll to sona Of the apes Of the *Peen Or finales that worked
12 12 for Jeffrey Cpetelri with ma»&OOe1?
I) I) M. CRITTCW: Porn.
14 14 TNN INTOOSS: Can you repeat the question?
IS IS BY is. LANCING:
14 16 Q. Sure. A. you fat here today and reflect back
17 On your time waking for Jeffrey Epstein. do you believe
14 19 You turned a bl lad ay* Or ignored. pryO'41Y Ignored the
19 It epee Of the females that gave hin swages?
20 20 MR. CROFTON: 4Om.
21 Si nirret5S: I don•t [new. I den •t -- I
22 22 cannot -- not a judo.. I don't know. I don't
23 21 knew. I don't think so. Sincerely. I don't think
24 0. you Penn:Intl a few tines today that you were 24
25 never told to chock the 1OantifiCatIOn of any of the 25 BY MR. LANG1MO:
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when you were working for Mr. Epstein. did you 1 started. I got hone and I had • ca rd, a business card
2 have any doubt that the girls who prOvlded bin masstwes • teen a collo& derider. I think it wepilli Iron n.e
3 were not of the proper age or not older than 18 years • Pain Beach Police Denartnent.
4 old? 4 And -- and : got scared. And I was trying to
M. CRITTON: dorm. • find Out what It's all about. Because It wee an
6 TUE WOMESS: alb. oceanic., with Mr. Epstein that we had a disagmmonnt.
in MR. IPAGINO: 1 Ye settled that. Everything watt well and we went our
8 O. Did you keep up with Mr. Epotein's -- keep 4 friendly ways and never heard iron his &gain.
9 Informed of Mr. Eptiteln'S Criminal COS* while it we in 9 And I received this free the police department
10 the paper? 10 that we need to talk to you. And. 00. I got seared.
11 A. Only whet was On Iv. What it was On tr. Ii And .1 called the office In New York.
12 that's how I found Out. 12 I says. I would like to speak to Mr. Epstein.
13 O. sow Os you feel about Mr. Epstein today? II And he come on. end I said, I told him. I
14 A. : feel bed, sincerely 1 fool bed, because he 14 say. . Jeffrey, what's going one What's happening? I
15 was -- with me, with my family, with my wife, he was • 15 thought it was related to the problem that I had
16 waxy generous guy. extremely -- I don't Now whet the 16 petsonaily with him settled.
It used Is in Erml Leh -- but he would press for perfection. 17 And I says -- no, he says. And he says to me.
28 I smart. and that was • very stmeesful job. but, IS nO, John. It's nothing to do with that, has nothing 10
19 Otherelse, I have no emblem, with him at all. And 1 L9 do with it. I've been -- I don't know if he told me I
20 feel had about it. what'. haveened it, his life. 20 been sued or I been -- It's • ptoblen with ne. they're
21 Q. nave you had any contact with Mr. Epetein 21 Investigating sOmething and 1 cannot talk to you. That
22 you ended working there? 22 wAs the *net And tbat'e it.
23 A. After I work -- after I end working with tint 2) My Other COnvereatiOn, with Kr. Epstein --
24 Y . I did. 24 ne.
25 when 'him can, when this criminal came 25 -- circa that conversation?
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Page 91 Page 92
NO Called AO and he nay. John. we need to
2 Q. At Bono points you were caught stealing fro. 2 talk.
Mr. Epstein; is that true? I Pays. Okay. Where?
A. We settled with him as • borrowing money trot 4 And -- and we net At a luncheonette in Palm
him. Okay? 5 POE% and we have • friendly conversation. Me soled
M. PIKAORR: As whet? 6 about my kids, about ny fealty.
TtlE WITIiCT: Rolrowing. Then -- Is this related to Mr. Epstein', Gee?
M. LANCING: Borrowing. O. It Se.
by M. LANCING: 9 A. Because I prefer to keep this -- this -- I was
10 0. When you took the money (too Mr. Epstein, -- 10 not IncrieMnated. 1 watt not -- I went to the police
11 A. Yes. sir. 11 deportment. 1 mode ny statement and there was no
12 0. -- did he give yea petwiselon to take that 12 charges filed.
13 money? 13 X don't think I would like to continue with
14 14 this.
15 At any point Old you take a firearm from IS IS. CRITTOW: Let no just put on the second as
16 Kr. Epstein? 16 think ms conplllll y irrelevant, immaterial,
1? it's not calculated to lead to the --
le O. At any point Old you enter Kr. Epstein', 1$ THE 14111413$: And it less often --
19 property when you mere mot allowed to he thorn? 19 MR. ER:210M: Let me just finish putting my
20 A. Yen. 20 Objection on.
21 O. And was that the Incident when you took •0/. 21 As I understand it. It occurred long before he
22 normy from him? 22 ever got the Card Iron the polite. I think you're
23 21 hereptlIng his. I think you're trying tO IntiRlditte
24 v. Can you explain to on how you and Mi. Epstein 24 his and 1 think it's inapptstos4t..
2n agreement that the cops would not be called: 111 wt. Lancing:
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I How di0 you feel about Mr. Epstein being loyal The overall theme of ay question Is: The feet
2 t0 you as en employe* (or his by net getting you into 2 that Hr. Epstein Cho,e not to get you In trouble with
further trouble with the pollee? the pollee further, trouble with the p01100 --
4 IN. CRIMP: Pone. 4 A. Uh-huh.
5 1NE WITNESS: I feel that it was part of a 0. -- DO luny years age. has today that Caused
6 relationship over le veer. that I did a lot ol 6 you or pressed upon you to snybe soften your testimony
1 extra work. And I was lore or less says. he y. or Change your testlnony at ell?
6 John. you did it for no, I do it for you. Md that A. Absolutely net.
see It. And w0 end an al ', lends. NO did not 9 O. Neve you ever spoken with any independent
10 break It apart. 10 .....tigators regarding the actions, the criminal
11 BY XR. LANOINO: 11 act lone that occurred at Jeffrey Epetein's home?
12 Q. As you alt here today. do you have a sense of 12 Yes.
13 personal loyalty to Mx. Epstein? 13 than did that occur?
14 A. Mo. Natter of fact, that lot has .alt en 14 A. Right after I receive e card from the pollee
IS a lot of se 1 avenological pro/game. 15 depertemot, when I call Jeffrey and : ask him, ehst's
16 16 going on?
11 17 No says. I cannot talk to you. Somebody we.:
It IS use en you,
IS 19 And titer, I got a call frees this. guy that I
2C 20 gannet recall his nee. new. talked to sae arg at set at
21 nes rhea •• whet i onet you 444444 to end. II, Grabbed. And we talked -- what? -- about 15 minutes.
22 And I went to end it there. 22 Md he asked ma (betetIOne gust Ilk& IOU guy* axe aerie,
23 have .. not herd think ny stay thene. 21 ma and I says a: Melly the ears. answers.
24 In r•flecting tho 'ob. I was not paid eoll onowah for 24 And he sage. 'will. there's on investigation
25 ght we did. And too late new. 25 against eel'l tag. You has nothirq to do with it. you
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Page 95 ?age 96
here nothing to do, nothing to worry about At• but if you would describe as blood)
2 you went to hire a govern to protect yoares II. No. never.
And I finked -- r. thatIon to hits ••••, I don• t Cio you renomber seeing anything that you would
eh, to net .....wing ad see,. ..neetning yen en. describe as • sexual fluid?
5 sialsocdv trvino to inert...... se (or -- tor Sr lob. A. No, never.
And he says, no, no. no. Out If you want to 6 0. When you worked for Jeffrey Spoleto. the wosan
get a lawyer, that's fin*. that you were married to. what Is her nen. Or -- what le
And that'. where I got Mr. Myrna, and he..)at 6 her name?
9 cans to um. to akin thin. to -- that Wee the one nf 9 A. The noun that I was neer led tol
10 Q. Mho got Kr. Nuriell for you? 10 Q. I think -- the reason 'a eating la because
11 A. Win got it/ Mr. English.. 11 earlier today mean you first spoke, I thought I
)2 Q. Shen you not with this investigator at )2 reseaborod you saying that you -- both you and your
)3 Carabba•, -- 13
IS A. Yee. 14
IS Q. -- dld he record your convered.un -- 15 Q. -- Worked (or Ht. Epstein?
16 A. 16 A. It's still my wife. It's still icy wife. We
I? 0. -- In Any way? 11 didn't -- loo got Leeway* away fro.* divorce and the
Is After %hie needing et Carabbas. 0id you meet IS lawyers were toting ny nerdy by pipeline.
19 with any other Investigators? 19 O. And what is her nano?
20 20 A. And we decide not to diver** gad we 'hill
21 -- dories your inspection of the tosser* 2: together.
22 rove alter thew! massages had been completed with 22 Sorry. I Missed that. But what is her ramie'
2) Mr. Epstein. -- 23 A. wee..
24 24 O. bet es bah look through dry notes to see If I
2$ Q. -- do you [saber seeing any -- anything that 2$ have any other questions.
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A. Okay. 1 And then by that tine so kids wont to College
2 Q Thank you very suet,. 2 and nur wife was at hOme. And I suggest my wife to Cede
A. Velame. 3 to work wIth a. to help a.
CROSS EXAMINATION 4 Q. so you secessended to Kr. Epstein that he litre
5 BY KW. NEAKELSIKIM: S your wife)
• 0. Good afternoon, Kr. Alessi. 6 Yes.
A. Yeti. s1r. And he did?
O O. fly name is Stuart deteelstein. I represent a 6 A. Yes. he did.
9 group of the Plaintiffs in thee* Cases and I have posse 9 0. And what were her 100 Outlet' there?
10 questions for you as well. 10 A. Nor only job duties were SlApplog. basically
11 Your wife). Maria. does she live at the ear* 11 the shopping. getting movie tickets, show tickets. bay
12 address a0 you h0e? 12 books, blind the food to Kis. EtAteln'S -- Kr. Epstein's
A. Yes. she does. 13 mother. sometimes drive Mrs. Spaeth to the doctors.
14 O. New, when you began sorting lull time for 16 She was not involved -- and wart she did
15 Mr. Spoleto. I believe you said that was around 1921. Or IS sons cleaning for me.
16 that correct? 16 0. did she live with you in the upstairs
I? Yea. 17 apartment?
IP O. Was your wife, was she hired at the nee tore lb
19 its you? 19
20 A. No. She was hired three years after. 20
21 O. And NA did that come about that your wife sr) 21
22 hired? 22 there. Out I had to stay these beanie 9y Job starts
2) A. My wife was hired because we had a housekeeper 23 from 5:00 in the sins nn to 10:00 et Binh'
24 that one was doing the cleaning and she left. Then we 24 O. Mid did Maria leave her employment the sea
25 had another housekeeper. Polish girl. and she lett. 25 tins as you?
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1 Yea. ise did at the ars time. 1 this show. And she would have to travel -- and I was on
2 O. you testified that you would come into the 2 the phone with so wife constantly, buy this, get this.
bedroom and clean up after that correct? 3 get this -- and the food, and the food because it was •
4 A. That's correct. 4 five-star hotel.
5 O. Old you -- were there occasions Were you had 5 Q. Old Its. 'Unwell or Ms. [patio over instruct
6 your wife help you with that? 6 your wife to do housecleaning tasks)
7 7 No. : was blamed for everything.
0. mere there -- did she hove occasion to go into O Q. You were blamed for everything,
the easter bedroom? 9 A. : was blamed for the gad and the bad.
10 A. It was occasions before that she will help to 10 O. Old you -- during the time your wife wet
Il set up the tables once in a while, set up the oils and II there, did you also have a hired housekeeper?
12 the tables. But I will do the clean up 12 A. Ma have a crew of house/Cleaners. we have •
13 Q. Is there • reason for that? I) crew of peOple that would Cone t0 the rouse and do a
14 A. I was non) involved into the final appearance 14 -- 1 Keane 0eep cleaning. you know, to the house.
15 Of the house. And It wee my responsibility to mate sure If Mae that every day?
16 that every coo. was perfect after they Nit and before 16 A. Once • week -- 0m it watt type a *AA. It
I, they went to bed. )7 was ',weedily and friday..
II 0. was there anyone else who assigned your wire 16 It depends on Mr. Epritein't eche/Ade because
IS work other than you? 19 he didn't -- he didn't want nobody at the house while he
20 A. MO. KS. Maxwell. etOmetliniS She would tell my 20 use at the house. So we have to rearrange cloys for the
21 wife. 00 buy >Coe stuff. 00 get this and go get that. 21 clean-tp crew to cone in. And r usually did that. As
22 She was mostly -- my wife was scatty out of the house. 22 soon as they left 1 bring the cleaning clew, get the
13 She was -- this house was Mr. Spetein would pays. go get 23 hOuse reedy and -- end get set for then for the next
14 a* this book. go get lie this eaqaxinot 9a get en 24 trip.
25 tickets, nevie tiCket• for this Sheet and (hie shoe and 25 O. Old you have a hefeekeeper Ntip did
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housekeeping tasks en an everyday bests while you were
2 employed 2 Moot about a part -tram housekeeper?
3 Like I told you, deity baste ea cell this
4 Motore cry vile wont In? company. and then they will cow* In with four or five
S O. Mo. After your wife. 5 girls and clean the whole house.
6 A. Mo. Not a full-Ilea housekeeper. 6 This is the crew you were taping about?
7 O. Skit you said your wife was hired &&&&& the 7 The crew.
housekeeper left? Q. but the crew didn't cone when Mr. Epstein wee
9 9 there?
10 0. Out -- so the pencil who left befor• your wit. 10 A. Ri
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908842e58b5617dcfc08d20d821e90cf9dbdeb725e512cf81f14411689ddf2fd
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