EFTA00158250.pdf
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
-•
Plaintiff,
- vs -
JEFFREY EPSTEIN
AND
Defendants.
DEPOSITION OF JANUSZ BANASIAK
Tuesday, February 16, 2010
10:09 - 2:30 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1317
(561) 832.7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by cynthla hopkins (601461-976-2934)
Electronically signed by cynthla hopkins (601-051-976-2934)
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1 APPEARANCES:
2 On behalf of the Plaintiff, III and Jane Doe:
3 BRADLEY J. EDWARDS, ESQUIRE
FARMER, JAFFE, WEISSING, EDWARDS
4 FISTOS & LEHRMAN, P.L.
7
8 On behalf of the Plaintiff Jane Does No.'s 1
through 8.
9
10 STUART MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
11
13
14
15 On behalf of the Defendant, Jeffrey Epstein and the
Witness:
16
17 JACK ALAN GOLDBERGER, ESQUIRE
ATTERBURY GOLDBERGER & WEISS, P.A.
18
20
21
22
23
24
25
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1 - - -
2 INDEX VOLUME I
3 - - -
4
5 WITNESS: DIRECT CROSS REDIRECT
6 JANUSZ BANASIAK
7 BY MR. EDWARDS 4
8
9
10
11 EXHIBITS
12
13
14 EXHIBITS DESCRIPTION PAGE
15 PLAINTIFFS' NO. 1 PHOTO 123
16 PLAINTIFFS' NO. 2 PHOTO 123
17 PLAINTIFFS' NO. 3 PHOTO 124
18 PLAINTIFFS' NO. 4 PHOTO 124
19 PLAINTIFFS' NO. 5 PHOTO 124
20
21
22
23
24
25
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1 PROCEEDINGS
2
3 Deposition taken before Cynthia Hopkins,
4 Registered Professional Reporter and Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
7
8 Thereupon,
9 (JANUSZ BANASIAK)
10 Having been first duly sworn or affirmed, was
11 examined and testified as follows:
12 THE WITNESS: Yes, ma'am.
13 DIRECT EXAMINATION
14 BY MR. EDWARDS:
15 Q. Would you tell us your full name.
16 A. Janusz Banasiak.
17 Q. Could you spell that for us.
18 A. J-a-n-u-s-z, Banasiak, B like boy,
19 B-a-n-a-s-i-a-k.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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8 Q. And where are you currently employed?
9 A. With Jeffrey Epstein.
10 Q. How long have you been employed with
11 Jeffrey Epstein?
12 A. Since February 2005.
13 Q. What do you do for him?
14 A. My position is called a house manager. So,
15 basically my duties is to make sure that house is in
16 good order when he is around visiting.
17 Q. And have your duties always been the same
18 since February, 2005 through --
19 A. Yes.
20 Q. -- the present?
21 A. Yes.
22 Q. Okay. Have you ever had your deposition
23 taken before?
24 A. No. This is my first time.
25 Q. All right. The rules are pretty simple.
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1 We only have one court Reporter, so it's important
2 that we don't talk over one another. I will wait
3 until you finish your answer. You wait for me to
4 finish my question.
5 A. Okay.
6 Q. Give us an answer similar to what you are
7 doing that we all understand. It's easy when we get
8 into a casual conversation and nod your head or
9 shake your head, but the court reporter can't take
10 it down so just something verbal.
11 A. Okay.
12 Q. If I ask a question you don't understand,
13 tell me you don't understand.
14 A. Okay.
15 Q. So, who hired you to work with Jeffrey
16 Epstein in February of 2005?
17 A. Who hired me?
18 Q. Right.
19 A. I got the phone call from my agency because I
20 signed with agency that Jeffrey Epstein looking for the
21 position in Palm Beach.
22 Q. And what agency was that?
23 A. This was Regal Domestic, Regal Domestic. I .37
24 not sure but something with the Domestic. The office
25 was in Maryland. I signed to the Internet.
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1 Q. Okay.
2 A. I signed a few of them. Then one of them, the
3 one who called me they were the one from Maryland.
4 Q. And what was your
5 A. They told me that they had an opening position
6 in Palm Beach, Florida.
7 Q. And did you know Jeffrey Epstein before
8 working with him?
9 A. No, no.
10
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17 Q. And when you started in 2005 when you
18 heard that there was a job position with Jeffrey
19 Epstein, did you interview for that position?
20 A. Yes.
21 Q. Who did you interview with?
22 A. First I got interviewed with Ghislaine
23 Maxwell.
24 Q. And that's G-h-i-s-l-a-i-n-e, Maxwell?
25 A. Right, right.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 Q. Where did that interview take place?
2 A. In New York.
3 Q. And it was for the position as house
4 manager in the Palm Beach house, correct?
5 A. Right.
6 Q. That's at 358 Albrillo way?
7 A. Correct.
8 Q. Why were you interviewed in New York, if
9 you know?
10 A. Because at that time I was living in New York
11 with my friends and so --
12 Q. Where did the interview take place in New
13 York?
14 A. In her house on 65th Street.
15 Q. Whose house, do you know?
16 A. Ghislaine Maxwell.
17 Q. So, Ghislaine Maxwell interviewed you back
18 in 2005 at her house in New York for a position at
19 Jeffrey Epstein's house in Palm Beach?
20 A. Right.
21 Q. And what did the interview consist of?
22 What did she ask you?
23 A. She asked me basic questions, you know, what's
24 my previous employer, how long I work for them and
25 basically she was checking my resume.
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1 Q. Okay. And did she ask you about a
2 starting salary?
3 A. No, not yet. We just was a preliminary
4 interview, checking.
5 Q. How long was the interview?
6 A. How long?
7 Q. Yes.
8 A. How long did it last?
9 Q. Yeah. How long did the interview last?
10 A. Maybe 20 minutes, half an hour.
11 Q. All right. After that interview, what's
12 your next contact with either Ghislaine Maxwell,
13 Jeffrey Epstein or anybody else associated with that_
14 job?
15 A. My second interview with Jeffrey Epstein after
16 a few days.
17 Q. And where did that take place?
18 A. In his office on Madison Avenue.
19 Q. What's the address there?
20 A. I don't remember physical address. It was 27,
21 51st Street. Madison and 51st Street, corner. I don't
22 remember physical address.
23 Q. Okay. And what did you speak with
24 Mr. Epstein about during that interview?
25 A. Same thing. He ask me how long I work for III
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 what was my duty, basically the same
2 thing.
3 Q. Did you talk about salary with him?
4 A. No.
5 Q. All right. So, what happened in that
6 interview to further your position with Jeffrey
7 Epstein?
8 A. After I finish interview with him I, I waiting
9 for a few days. And I got the phone call from secretary
10 that I had been accepted and offered the job.
11 Q. Okay. Who made that phone call to you?
12 A. One of the secretary. I don't remember her
13 name right now. She told me that they agreed to hire
14 me.
15 Q. Is this a secretary that is located in the
16 New York office?
17 A. Yes, yes. It was a call from the New York
18 office.
19 Q. And she told you that you were being
20 offered the job?
21 A. Right.
22 Q. And at that point in time were you offered
23 a salary?
24 A. Yes.
25 Q• Okay. So up to that point, you had made
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 it clear to them that you wanted a job but not
2 necessarily how much you wanted to be paid?
3 A. Yes.
4 Q. All right. And what was your starting
5 salary?
6 A. It was $58,000, I think, yeah.
7 Q. Did Jeffrey Epstein or anybody else during
8 this interview process tell you why the house
9 manager position had become available, meaning
10 somebody quit or why it was vacant?
11 A. No, no, he didn't. Nobody mention it.
12 Q. Okay. Do you know who the house manager
13 was prior to you being the house manager?
14 A. When I get to Palm Beach, one of the people
15 who work over there they told me that this guy working
16 currently for him Alfredo Rodriguez.
17 Q. Alfredo Rodriguez?
18 A. Yes.
19 Q. And who told you that Alfredo Rodriguez
20 was the previous house manager, do you remember who?
21 A. I think it was . She is
22 currently employed with him.
23 Q. is still employed by him,
24 right?
25 A. Yes.
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1 Q. And she's a housekeeper or something?
2 A. Right.
3 Q. All right. So, when this secretary of New
4 York calls and offers you the job at $58,000, you
5 accept the job?
6 A. Yes.
7 Q. And do you remember about what month that
8 was that January 2005 or so?
9 A. No. I think I start February 2005, but I, I
10 got a phone call I think it was end of December, 2004.
11 Q. Okay. So, the previous interview with
12 Ghislaine Maxwell and Jeffrey Epstein happened
13 sometime in late 2004?
14 A. Right.
15 Q. Okay. And when you say you got the job in
16 February 2005, is that when you came down to Palm
17 Beach to start working?
18 A. Yes.
19 Q. So, you had a month or so to gather your
20 stuff and get down?
21 A. Correct.
22 Q. And did you move down with anybody?
23 A. No, just myself.
I
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8 Q. So, you came down in February 2005 and
9 began working. What did you, what did you first
10 start doing for Jeffrey Epstein?
11 A. First I doing? I don't remember nothing
12 special.
13 Q. Okay. Well, were you working I will
14 rephrase it. Were you working only for Jeffrey
15 Epstein or were you working also for Ghislaine
16 Maxwell, the other person who interviewed you, or
17 anybody else in the house?
18 A. I guess only for him because she was visiting
19 a few times house, but I am employed by him.
20 Q. Okay. What was your understanding at that
21 time as to the relationship between Ghislaine
22 Maxwell and Jeffrey Epstein?
23 A. They were like partners in business.
24 Q. Okay. What business was that, if you
25 know?
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1 A. I don't know what kind of business but she was
2 the one who organized I would say employment with this
3 organization. So, whatever I need, if I have some kind
4 of problem, I contact her. She was the one who decided
5 what I have to answer my problems with, what I was
6 supposed to do.
7 Q. How many times did you have problems where
8 you had to go through her?
9 A. Well, not big problems. Just a question of
10 what certain, how to do certain things. For example,
11 what kind of flowers I have to buy, what kind of things
12 he likes, what time I supposed to serve him coffee in
13 the mornings, sort of organizing things.
14 Q. Those are things that you wouldn't ask
15 Jeffrey Epstein directly?
16 A. No, no. He doesn't like those things to ask
17 him directly. He would like to prefer either through
18 his assistant or like I say, Ghislaine Maxwell.
19 Q. Is that still the same today?
20 A. Yes, still the same. Unless, something happen
21 that I need to, nobody is around and I need to urgently
22 contact him, I go to him directly.
23 Q. So, for the most part if you have a
24 question or at least -- let's go back to 2005, you
25 had a question about what needed to be done in the
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1 house, day-to-day stuff, you would ask Ghislaine
2 Maxwell?
3 A. Right.
4 Q. And would she normally, back in 2005, be
5 at the house in Palm Beach for you to ask her or
6 would you have to call her in New York?
7 A. To the phone up in New York. She was visiting
8 the house but most of the time I spoke with her on the
9 phone.
10 Q. Okay. Let's talk specifically about that
11 year in 2005. How often would Ghislaine Maxwell be
12 at the Palm Beach house when Jeffrey Epstein was at
13 the Palm Beach house?
14 A. I would say about once a month since I started
15 work.
16 Q. All right. Well, it was a bad question
17 because I understand that Mr. Epstein has several
18 homes, right?
19 A. Right.
20 Q. And he is sometimes in New Mexico or New
21 York or Florida or the Island or somewhere, right?
22 A. Right.
23 Q. So, I guess the first question is in 2005,
24 how often was Jeffrey Epstein at the Palm Beach
25 house on a weekly basis?
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1 A. Probably like two, three times a month.
2 Q. And when he would come to the Palm Beach
3 house two or three times a month, how long would he
4 stay typically?
5 A. Three days, sometimes two, sometimes four,
6 depends, you know, but it was no regular -- but no more
7 than four days I would say.
8 Q. Okay. And of those two or three trips to
9 Palm Beach, are you telling me that Ghislaine
10 Maxwell would usually come for one of them per
11 month?
12 A. Not usually, sometimes. Not every time but
13 sometimes they, she comes.
14 Q. Okay. But at that point in time in 2005
15 you understood that Ghislaine Maxwell and Jeffrey
16 Epstein were business partners?
17 A. Right.
18 Q. Did you know at the time what Jeffrey
19 Epstein did for a living?
20 A. Yes. He was one, I overheard invest money
21 with other people.
22 Q. Okay. Who told you that or who did you
23 overhear?
24 A. I think I read in the paper or something.
25 Nobody --
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1 Q. So, you don't actually think you overheard
2 it. You think you read it?
3 A. Right. It's hard to say right now. I don't
4 remember but probably most, yeah, I think I read in the
5 paper.
6 Q. Did you understand in 2005 that Ghislaine
7 Maxwell and Jeffrey Epstein had an intimate
8 relationship with one another?
9 A. No.
10 Q. You only believed them to have a business
11 relationship?
12 A. Right.
13 Q. Okay. And when Ghislaine Maxwell would
14 come to Florida, what did you or what did you
15 observe her and Mr. Epstein do back in 2005?
16 MR. GOLDBERGER: Form.
17 THE WITNESS: What would they do? I mean
18 what?
19 BY MR. EDWARDS:
20 Q. What was a typical day for Jeffrey Epstein
21 and Ghislaine Maxwell when she was in town at the
22 same time he was in town.
23 A. I would say that they have breakfast in the
24 morning. They spend time reading, talking on the phone,
25 meeting people, go to the movies sometimes. They did
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1 entertain a lot. They did go out for dinners I would
2 say.
3 BY MR. EDWARDS:
4 Q. Did you know at that time what Ghislaine
5 Maxwell did for a living?
6 A. No.
7 Q. Do you know today even what she did?
8 A. No.
9 Q. No. Back in 2005 to your knowledge, did
10 Jeffrey Epstein have a girlfriend or female
11 companion that was more than just a business partner
12 to your knowledge?
13 A. No, I didn't know.
14 Q. And for the most part I am going to try to
15 go chronological from 2005 to the present, but for
16 this question for that entire period of time that
17 you have known Jeffrey Epstein, 2005 through today,
18 have you ever known Jeffrey Epstein to have somebody
19 who you would observe to be a female companion or
20 girlfriend?
21 A. Yes.
22 Q. Okay. When is the
23 first time that you believe you recognized
24 as a girlfriend to Jeffrey Epstein?
25 A. At one point, I don't remember exactly what
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1 year was it, he told us that will take some part
2 of the organization, organizing, scheduling. And she
3 would decide, you know, which way household supposed to
4 work, and if you have any questions or problems, we
5 could contact her. So, since then I figure out that
6 she's the person who, wh
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
-•
Plaintiff,
- vs -
JEFFREY EPSTEIN
AND
Defendants.
DEPOSITION OF JANUSZ BANASIAK
Tuesday, February 16, 2010
10:09 - 2:30 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1317
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1 APPEARANCES:
2 On behalf of the Plaintiff, III and Jane Doe:
3 BRADLEY J. EDWARDS, ESQUIRE
FARMER, JAFFE, WEISSING, EDWARDS
4 FISTOS & LEHRMAN, P.L.
7
8 On behalf of the Plaintiff Jane Does No.'s 1
through 8.
9
10 STUART MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
11
13
14
15 On behalf of the Defendant, Jeffrey Epstein and the
Witness:
16
17 JACK ALAN GOLDBERGER, ESQUIRE
ATTERBURY GOLDBERGER & WEISS, P.A.
18
20
21
22
23
24
25
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1 - - -
2 INDEX VOLUME I
3 - - -
4
5 WITNESS: DIRECT CROSS REDIRECT
6 JANUSZ BANASIAK
7 BY MR. EDWARDS 4
8
9
10
11 EXHIBITS
12
13
14 EXHIBITS DESCRIPTION PAGE
15 PLAINTIFFS' NO. 1 PHOTO 123
16 PLAINTIFFS' NO. 2 PHOTO 123
17 PLAINTIFFS' NO. 3 PHOTO 124
18 PLAINTIFFS' NO. 4 PHOTO 124
19 PLAINTIFFS' NO. 5 PHOTO 124
20
21
22
23
24
25
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1 PROCEEDINGS
2
3 Deposition taken before Cynthia Hopkins,
4 Registered Professional Reporter and Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
7
8 Thereupon,
9 (JANUSZ BANASIAK)
10 Having been first duly sworn or affirmed, was
11 examined and testified as follows:
12 THE WITNESS: Yes, ma'am.
13 DIRECT EXAMINATION
14 BY MR. EDWARDS:
15 Q. Would you tell us your full name.
16 A. Janusz Banasiak.
17 Q. Could you spell that for us.
18 A. J-a-n-u-s-z, Banasiak, B like boy,
19 B-a-n-a-s-i-a-k.
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8 Q. And where are you currently employed?
9 A. With Jeffrey Epstein.
10 Q. How long have you been employed with
11 Jeffrey Epstein?
12 A. Since February 2005.
13 Q. What do you do for him?
14 A. My position is called a house manager. So,
15 basically my duties is to make sure that house is in
16 good order when he is around visiting.
17 Q. And have your duties always been the same
18 since February, 2005 through --
19 A. Yes.
20 Q. -- the present?
21 A. Yes.
22 Q. Okay. Have you ever had your deposition
23 taken before?
24 A. No. This is my first time.
25 Q. All right. The rules are pretty simple.
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1 We only have one court Reporter, so it's important
2 that we don't talk over one another. I will wait
3 until you finish your answer. You wait for me to
4 finish my question.
5 A. Okay.
6 Q. Give us an answer similar to what you are
7 doing that we all understand. It's easy when we get
8 into a casual conversation and nod your head or
9 shake your head, but the court reporter can't take
10 it down so just something verbal.
11 A. Okay.
12 Q. If I ask a question you don't understand,
13 tell me you don't understand.
14 A. Okay.
15 Q. So, who hired you to work with Jeffrey
16 Epstein in February of 2005?
17 A. Who hired me?
18 Q. Right.
19 A. I got the phone call from my agency because I
20 signed with agency that Jeffrey Epstein looking for the
21 position in Palm Beach.
22 Q. And what agency was that?
23 A. This was Regal Domestic, Regal Domestic. I .37
24 not sure but something with the Domestic. The office
25 was in Maryland. I signed to the Internet.
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1 Q. Okay.
2 A. I signed a few of them. Then one of them, the
3 one who called me they were the one from Maryland.
4 Q. And what was your
5 A. They told me that they had an opening position
6 in Palm Beach, Florida.
7 Q. And did you know Jeffrey Epstein before
8 working with him?
9 A. No, no.
10
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17 Q. And when you started in 2005 when you
18 heard that there was a job position with Jeffrey
19 Epstein, did you interview for that position?
20 A. Yes.
21 Q. Who did you interview with?
22 A. First I got interviewed with Ghislaine
23 Maxwell.
24 Q. And that's G-h-i-s-l-a-i-n-e, Maxwell?
25 A. Right, right.
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1 Q. Where did that interview take place?
2 A. In New York.
3 Q. And it was for the position as house
4 manager in the Palm Beach house, correct?
5 A. Right.
6 Q. That's at 358 Albrillo way?
7 A. Correct.
8 Q. Why were you interviewed in New York, if
9 you know?
10 A. Because at that time I was living in New York
11 with my friends and so --
12 Q. Where did the interview take place in New
13 York?
14 A. In her house on 65th Street.
15 Q. Whose house, do you know?
16 A. Ghislaine Maxwell.
17 Q. So, Ghislaine Maxwell interviewed you back
18 in 2005 at her house in New York for a position at
19 Jeffrey Epstein's house in Palm Beach?
20 A. Right.
21 Q. And what did the interview consist of?
22 What did she ask you?
23 A. She asked me basic questions, you know, what's
24 my previous employer, how long I work for them and
25 basically she was checking my resume.
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1 Q. Okay. And did she ask you about a
2 starting salary?
3 A. No, not yet. We just was a preliminary
4 interview, checking.
5 Q. How long was the interview?
6 A. How long?
7 Q. Yes.
8 A. How long did it last?
9 Q. Yeah. How long did the interview last?
10 A. Maybe 20 minutes, half an hour.
11 Q. All right. After that interview, what's
12 your next contact with either Ghislaine Maxwell,
13 Jeffrey Epstein or anybody else associated with that_
14 job?
15 A. My second interview with Jeffrey Epstein after
16 a few days.
17 Q. And where did that take place?
18 A. In his office on Madison Avenue.
19 Q. What's the address there?
20 A. I don't remember physical address. It was 27,
21 51st Street. Madison and 51st Street, corner. I don't
22 remember physical address.
23 Q. Okay. And what did you speak with
24 Mr. Epstein about during that interview?
25 A. Same thing. He ask me how long I work for III
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1 what was my duty, basically the same
2 thing.
3 Q. Did you talk about salary with him?
4 A. No.
5 Q. All right. So, what happened in that
6 interview to further your position with Jeffrey
7 Epstein?
8 A. After I finish interview with him I, I waiting
9 for a few days. And I got the phone call from secretary
10 that I had been accepted and offered the job.
11 Q. Okay. Who made that phone call to you?
12 A. One of the secretary. I don't remember her
13 name right now. She told me that they agreed to hire
14 me.
15 Q. Is this a secretary that is located in the
16 New York office?
17 A. Yes, yes. It was a call from the New York
18 office.
19 Q. And she told you that you were being
20 offered the job?
21 A. Right.
22 Q. And at that point in time were you offered
23 a salary?
24 A. Yes.
25 Q• Okay. So up to that point, you had made
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1 it clear to them that you wanted a job but not
2 necessarily how much you wanted to be paid?
3 A. Yes.
4 Q. All right. And what was your starting
5 salary?
6 A. It was $58,000, I think, yeah.
7 Q. Did Jeffrey Epstein or anybody else during
8 this interview process tell you why the house
9 manager position had become available, meaning
10 somebody quit or why it was vacant?
11 A. No, no, he didn't. Nobody mention it.
12 Q. Okay. Do you know who the house manager
13 was prior to you being the house manager?
14 A. When I get to Palm Beach, one of the people
15 who work over there they told me that this guy working
16 currently for him Alfredo Rodriguez.
17 Q. Alfredo Rodriguez?
18 A. Yes.
19 Q. And who told you that Alfredo Rodriguez
20 was the previous house manager, do you remember who?
21 A. I think it was . She is
22 currently employed with him.
23 Q. is still employed by him,
24 right?
25 A. Yes.
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1 Q. And she's a housekeeper or something?
2 A. Right.
3 Q. All right. So, when this secretary of New
4 York calls and offers you the job at $58,000, you
5 accept the job?
6 A. Yes.
7 Q. And do you remember about what month that
8 was that January 2005 or so?
9 A. No. I think I start February 2005, but I, I
10 got a phone call I think it was end of December, 2004.
11 Q. Okay. So, the previous interview with
12 Ghislaine Maxwell and Jeffrey Epstein happened
13 sometime in late 2004?
14 A. Right.
15 Q. Okay. And when you say you got the job in
16 February 2005, is that when you came down to Palm
17 Beach to start working?
18 A. Yes.
19 Q. So, you had a month or so to gather your
20 stuff and get down?
21 A. Correct.
22 Q. And did you move down with anybody?
23 A. No, just myself.
I
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8 Q. So, you came down in February 2005 and
9 began working. What did you, what did you first
10 start doing for Jeffrey Epstein?
11 A. First I doing? I don't remember nothing
12 special.
13 Q. Okay. Well, were you working I will
14 rephrase it. Were you working only for Jeffrey
15 Epstein or were you working also for Ghislaine
16 Maxwell, the other person who interviewed you, or
17 anybody else in the house?
18 A. I guess only for him because she was visiting
19 a few times house, but I am employed by him.
20 Q. Okay. What was your understanding at that
21 time as to the relationship between Ghislaine
22 Maxwell and Jeffrey Epstein?
23 A. They were like partners in business.
24 Q. Okay. What business was that, if you
25 know?
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1 A. I don't know what kind of business but she was
2 the one who organized I would say employment with this
3 organization. So, whatever I need, if I have some kind
4 of problem, I contact her. She was the one who decided
5 what I have to answer my problems with, what I was
6 supposed to do.
7 Q. How many times did you have problems where
8 you had to go through her?
9 A. Well, not big problems. Just a question of
10 what certain, how to do certain things. For example,
11 what kind of flowers I have to buy, what kind of things
12 he likes, what time I supposed to serve him coffee in
13 the mornings, sort of organizing things.
14 Q. Those are things that you wouldn't ask
15 Jeffrey Epstein directly?
16 A. No, no. He doesn't like those things to ask
17 him directly. He would like to prefer either through
18 his assistant or like I say, Ghislaine Maxwell.
19 Q. Is that still the same today?
20 A. Yes, still the same. Unless, something happen
21 that I need to, nobody is around and I need to urgently
22 contact him, I go to him directly.
23 Q. So, for the most part if you have a
24 question or at least -- let's go back to 2005, you
25 had a question about what needed to be done in the
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1 house, day-to-day stuff, you would ask Ghislaine
2 Maxwell?
3 A. Right.
4 Q. And would she normally, back in 2005, be
5 at the house in Palm Beach for you to ask her or
6 would you have to call her in New York?
7 A. To the phone up in New York. She was visiting
8 the house but most of the time I spoke with her on the
9 phone.
10 Q. Okay. Let's talk specifically about that
11 year in 2005. How often would Ghislaine Maxwell be
12 at the Palm Beach house when Jeffrey Epstein was at
13 the Palm Beach house?
14 A. I would say about once a month since I started
15 work.
16 Q. All right. Well, it was a bad question
17 because I understand that Mr. Epstein has several
18 homes, right?
19 A. Right.
20 Q. And he is sometimes in New Mexico or New
21 York or Florida or the Island or somewhere, right?
22 A. Right.
23 Q. So, I guess the first question is in 2005,
24 how often was Jeffrey Epstein at the Palm Beach
25 house on a weekly basis?
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1 A. Probably like two, three times a month.
2 Q. And when he would come to the Palm Beach
3 house two or three times a month, how long would he
4 stay typically?
5 A. Three days, sometimes two, sometimes four,
6 depends, you know, but it was no regular -- but no more
7 than four days I would say.
8 Q. Okay. And of those two or three trips to
9 Palm Beach, are you telling me that Ghislaine
10 Maxwell would usually come for one of them per
11 month?
12 A. Not usually, sometimes. Not every time but
13 sometimes they, she comes.
14 Q. Okay. But at that point in time in 2005
15 you understood that Ghislaine Maxwell and Jeffrey
16 Epstein were business partners?
17 A. Right.
18 Q. Did you know at the time what Jeffrey
19 Epstein did for a living?
20 A. Yes. He was one, I overheard invest money
21 with other people.
22 Q. Okay. Who told you that or who did you
23 overhear?
24 A. I think I read in the paper or something.
25 Nobody --
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1 Q. So, you don't actually think you overheard
2 it. You think you read it?
3 A. Right. It's hard to say right now. I don't
4 remember but probably most, yeah, I think I read in the
5 paper.
6 Q. Did you understand in 2005 that Ghislaine
7 Maxwell and Jeffrey Epstein had an intimate
8 relationship with one another?
9 A. No.
10 Q. You only believed them to have a business
11 relationship?
12 A. Right.
13 Q. Okay. And when Ghislaine Maxwell would
14 come to Florida, what did you or what did you
15 observe her and Mr. Epstein do back in 2005?
16 MR. GOLDBERGER: Form.
17 THE WITNESS: What would they do? I mean
18 what?
19 BY MR. EDWARDS:
20 Q. What was a typical day for Jeffrey Epstein
21 and Ghislaine Maxwell when she was in town at the
22 same time he was in town.
23 A. I would say that they have breakfast in the
24 morning. They spend time reading, talking on the phone,
25 meeting people, go to the movies sometimes. They did
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1 entertain a lot. They did go out for dinners I would
2 say.
3 BY MR. EDWARDS:
4 Q. Did you know at that time what Ghislaine
5 Maxwell did for a living?
6 A. No.
7 Q. Do you know today even what she did?
8 A. No.
9 Q. No. Back in 2005 to your knowledge, did
10 Jeffrey Epstein have a girlfriend or female
11 companion that was more than just a business partner
12 to your knowledge?
13 A. No, I didn't know.
14 Q. And for the most part I am going to try to
15 go chronological from 2005 to the present, but for
16 this question for that entire period of time that
17 you have known Jeffrey Epstein, 2005 through today,
18 have you ever known Jeffrey Epstein to have somebody
19 who you would observe to be a female companion or
20 girlfriend?
21 A. Yes.
22 Q. Okay. When is the
23 first time that you believe you recognized
24 as a girlfriend to Jeffrey Epstein?
25 A. At one point, I don't remember exactly what
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1 year was it, he told us that will take some part
2 of the organization, organizing, scheduling. And she
3 would decide, you know, which way household supposed to
4 work, and if you have any questions or problems, we
5 could contact her. So, since then I figure out that
6 she's the person who, wh