EFTA00181630.pdf

Page 81 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIV-MARRA/JOHNSQN JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME II Tuesday, September 8, 2009 10:12 a.m. - 3:45 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 300cel-c.860-091-801.banbcaelPde EFTA00181630  Page 82 1 APPEARANCES: 2 On behalf of the Plaintiffs: 3 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 4 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 5 Phone: 6 7 STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 9 Phone: 10 11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 Phone: 14 15 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 16 25 West Flagler Street, Suite 800 Miami, Florida 33130 17 Phone: 18 19 ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 20 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 21 Phone: 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01•ba20bcao87de EFTA00181631  Page 83 1 On behalf of the Defendant: 2 ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER 3 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 4 Phone: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c868-4b91-8d01-ba2Obcaerde EFTA00181632  Page 84 1 PROCEEDINGS 2 - - - 3 Deposition taken before Sandra W. Townsend, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 (Continued from Volume I.) 8 VIDEOGRAPHER: We're going back on the record 9 at 12:52. 10 CROSS EXAMINATION 11 BY MR. LANGINO: 12 Q. Hello. My name is Adam Langino and I 13 represent III. I'll have fewer questions than the rest 14 of everybody, since I'm going next in line. But one of 15 the things I wanted to ask you 16 MR. CRITTON: Before you get started, let me 17 just put on my objection. 18 Adam, your client is ., who alleges that 19 she was at Mr. Epstein's house sometime, I think, 20 on one occasion in the summer of '03. 21 This witness is neither relevant, nor 22 material, nor can it lead to the admissibility of 23 any relevant information regarding my client. So I 24 understand -- so you certainly can notice him, but 25 I'll move to strike all of the questions and PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01•ba2Obcae87de EFTA00181633  Page 85 1 answers in response to your questions. 2 MR. LANGINO: Thank you. 3 BY MR. LANGINO: 4 Q. One thing I wasn't sure about was the date of 5 your employment. When did you start with Mr. Epstein? 6 A. I am not sure, sir, but I think I started full 7 time on my salary, I was on the roll in 1991. 1991, 8 January 1, 1991. 9 Q. In 1991, you started full time with 10 Mr. Epstein? 11 A. Yes, working for him alone. I left all my 12 clients, I left -- dissolved my company. 13 Q. And in what year did you start part time at 14 his house? 15 A. 1990. '90. 16 Q. You mentioned earlier that some of the massage 17 therapists you paid with checks? 18 A. Yes. 19 Q. And some of the massage therapists you paid 20 with cash? 21 A. Sorry. Can you repeat the question? 22 Q. Sure. You mentioned earlier that you paid 23 some of the massage therapists with checks and some with 24 cash? 25 A. Yes, sir. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba20bcae87de EFTA00181634  Page 86 1 Q. Were there any general differences between 2 those massage therapists that you paid with checks and 3 those that you paid with cash? 4 A. No, sir. It was -- when I was there always 5 was a hundred dollars an hour rate. That was for 6 everybody. 7 Q. Did you ever hear Jeffrey Epstein talk about 8 his massages? 9 A. No, sir. 10 Q. At one point you said that you're not -- this 11 might be summarizing your testimony -- that you may not 12 be the best guesser of ages. Is that something that you 13 may have said earlier today? 14 MR. CRITTON: Form. 15 THE WITNESS: Yeah. Yeah. I think I -- you 16 can be thirties, twenties. I don't know. 17 BY MR. LANGINO: 18 Q. Do you have any children? 19 A. I have two. One is a doctor in psychology. 20 And one is a financial manager and he starts his own 21 company. 22 Q. Are either of your children female? 23 A. No. 24 Q. Do you have any grandchildren? 25 A. I have one granddaughter. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01•ba20bcao87do EFTA00181635  Page 87 1 Q. How old is she? 2 A. She is five. 3 Q. Do you have any relative that you had spent a 4 significant amount of time with that would be a female 5 teenager? 6 MR. CRITTON: Form. 7 THE WITNESS: No, except my daughter. 8 BY MR. LANGINO: 9 Q. Cousin? 10 A. My daughter, no. 11 Q. Before when we first started speaking with 12 you, you talked a little bit about your business. Are 13 you still working? 14 A. No. I disabled. 15 Q. You owned that business; is that correct? 16 A. Yeah. Yeah. It was my -- my it was me, 17 only me. 18 Q. You ntioned that one of your children is a 19 doctor? 20 A. My da ghter is a doctor in psychology. 21 Q. Are any of your children or any of your family 22 members continuing the business that you started? 23 A. No. They have their own business. 24 Q. You mentioned a few times today that you were 25 never told to check the identification of any of the PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86.1-4b91-Etd01-ba2Obcae87do EFTA00181636  Page 88 1 massage therapists that came to give massages? 2 A. That's correct. 3 Q. How come you said that a couple of times 4 today? 5 MR. CRITTON: Form. 6 THE WITNESS: You asked me. They asked me I 7 think I just answer questions. 8 BY MR. LANGINO: 9 Q. As you reflect back in your time working for 10 Mr. Epstein, today do you believe you turned a blind eye 11 to some of the ages of the women or females that worked 12 for Jeffrey Epstein with massages? 13 MR. CRITTON: Form. 14 THE WITNESS: Can you repeat the question? 15 BY MR. LANGINO: 16 Q. Sure. As you sit here today and reflect back 17 on your time working for Jeffrey Epstein, do you believe 18 you turned a blind eye or ignored, purposely ignored the 19 ages of the females that gave him massages? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know. I don't 22 cannot -- I'm not a judge. I don't know. I don't 23 know. I don't think so. Sincerely, I don't think 24 so. 25 BY MR. LANGINO: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b9f-8d0141a2Obcae87de EFTA00181637  Page 89 1 Q. When you were working for Mr. Epstein, did you 2 have any doubt that the girls who provided him massages 3 were not of the proper age or not older than 18 years 4 old? 5 MR. CRITTON: Form. 6 THE WITNESS: No. 7 BY MR. LANGINO: 8 Q. Did you keep up with Mr. Epstein's -- keep 9 informed of Mr. Epstein's criminal case while it was in 10 the paper? 11 A. Only what was on tv. What it was on tv, 12 that's how I found out. 13 Q. How do you feel about Mr. Epstein today? 14 A. I feel bad, sincerely I feel bad, because he 15 was -- with me, with my family, with my wife, he was a 16 very generous guy, extremely -- I don't know what the 17 word is in English -- but he would press for perfection. 18 I mean, and that was a very stressful job. But, 19 otherwise, I have no problems with him at all. _And I 20 feel bad about it, what's happened in his life. 21 Q. Have you had any contact with Mr. Epstein 22 after you ended working there? 23 A. After I work -- after I end working with him? 24 Yes, I did. 25 When this case, when this criminal case PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e.4b91-Bd01-ba20bcae87de EFTA00181638  Page 90 1 started, I got home and I had a card, a business card 2 from a police officer. I think it was Paul from the 3 Palm Beach Department. 4 And -- and I got scared. And I was trying to 5 find out what it's all about. Because it was an 6 occasion with Mr. Epstein that we had a disagreement. 7 We settled that. Everything was well and we went our 8 friendly ways and never heard from him again. 9 And I received this from the police department 10 that we need to talk to you. And, so, I got scared. 11 And I called the office in New York. 12 I says, I would like to speak to Mr. Epstein. 13 And he come on, and I said, I told him, I 14 says, Jeffrey, what's going on? What's happening? I 15 thought it was related to the problem that I had 16 personally with him settled. 17 And I says -- no, he says. And he says to me, 18 no, John, it's nothing to do with that, has nothing to 19 do with it. I've been I don't know if he told me I 20 been sued or I been -- it's a problem with me, they're 21 investigating something and I cannot talk to you. That 22 was the end. And that's it. 23 Q. Any other conversations with Mr. Epstein -- 24 A. No. 25 Q. -- since that conversation? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0c86e-4b91-8d01-ba20bcae87de EFTA00181639  Page 91 1 A. No. 2 Q. At some points you were caught stealing from 3 Mr. Epstein; is that true? 4 A. We settled with him as a borrowing money from 5 him. Okay? 6 MR. BERGER: As what? 7 THE WITNESS: Borrowing. 8 MR. LANGINO: Borrowing. 9 BY MR. LANGINO: 10 Q. When you took the money from Mr. Epstein, -- 11 A. Yes, sir. 12 Q. -- did he give you permission to take that 13 money? 14 A. No. 15 Q. At any point did you take a firearm from 16 Mr. Epstein? 17 A. No. 18 Q. At any point did you enter Mr. Epstein's 19 property when you were not allowed to be there? 20 A. Yes. 21 Q. And was that the incident where you took some 22 money from him? 23 A. Yes. 24 Q. Can you explain to me how you and Mr. Epstein 25 came to an agreement that the cops would not be called? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0-c868-4b9f4d01-ba2Obcae87de EFTA00181640  Page 92 1 A. He called me and he say, John, we need to 2 talk. 3 I says, okay. Where? 4 And -- and we met at a luncheonette in Palm 5 Beach and we have a friendly conversation. He asked 6 about my kids, about my family. 7 Then -- is this related to Mr. Epstein's case? 8 Q. It is. 9 A. Because I prefer to keep this -- this -- I was 10 not incriminated. I was not -- I went to the police 11 department. I made my statement and there was no 12 charges filed. 13 I don't think I would like to continue with 14 this. 15 MR. CRITTON: Let me just put on the record as 16 I think it's completely irrelevant, immaterial, 17 it's not calculated to lead to the -- 18 THE WITNESS: And it was after -- 19 MR. CRITTON: Let me just finish putting my 20 objection on. 21 As I understand it, it occurred long before he 22 ever got the card from the police. I think you're 23 harassing him. I think you're trying to intimidate 24 him and I think it's inappropriate. 25 BY MR. LANGINO: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b91-Bd01-ba20bcae87de EFTA00181641  Page 93 1 Q. How did you feel about Mr. Epstein being loyal 2 to you as an employee for him by not getting you into 3 further trouble with the police? 4 MR. CRITTON: Form. 5 THE WITNESS: I feel that it was part of a 6 relationship over 422=that I did a lot of 7 extra work. And I was more or less says, hey, 8 John, you did it for me, I do it for you. And that 9 was it. And we end up as _f riends. We did not 10 break it apart. 11 BY MR. LANGINO: 12 Q. As you sit here today, do you have a sense of 13 personal loyalty to Mr. Epstein? 14 A. No. No. Matter of fact, that job has Laft me 15 a lot of sequels, psychological problems. It was 16 extremely damaging to my mar Right after I left 17 we broke up with my wife. I walk away. I left my 1 house. I left my family. I end up with a woman that 1 she need the money and that's why I went in there and 2 got the money. 21 And that's what I think you wanted to hear. 22 And I want to end it there. 23 I have no -- nothing -- I think my stay there, 24 in reflecting the job, I was not paid well enough for 25 what we did. And too late now. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba20bcae87de EFTA00181642  Page 94 1 Q. The overall theme of my question is: The fact 2 that Mr. Epstein chose not to get you in trouble with 3 the police further, trouble with the police -- 4 A. Uh-huh. 5 Q. -- so many years ago, has today that caused 6 you or pressed upon you to maybe soften your testimony 7 or change your testimony at all? 8 A. Absolutely not. 9 Q. Have you ever spoken with any independent 10 investigators regarding the actions, the criminal 11 actions that occurred at Jeffrey Epstein's home? 12 A. Yes. 13 Q. When did that occur? 14 A. Right after I receive a card from the police 15 department, when I call Jeffrey and I ask him, what's 16 going on? 17 He says, I cannot talk to you. Somebody will 18 talk to you. 19 And then I got a call from this guy that I 20 cannot recall his name now. Talked to me and we met at 21 Carabbas. And we talked -- what? -- about 15 minutes. And he asked me questions just like you guys are asking ,3 3 me and I says exactly the same answers. 24 And he says, well, there's an investigation 25 against Jeffrey. You has nothing to do with it. You PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3alc3ca0-O36e-4b91-6d01-ba20bcadade EFTA00181643  Page 95 1 have nothing to do, nothing to worry about it, but if 2 you want to hire a lawyer to protect yourself. 3 And I asked -- my question to him was, _I don't 4 want to get incriminated into something that, you know, 5 somebody trying to incriminate me for -- for my job. 6 And he says, no, no, no. But if you want to 7 get a lawyer, that's fine. 8 And that's where I got Mr lancl 'ust 9 came to us, to sign this, to -- that was d of it. 10 Q. Who got Mr. Murrell for you? 11 A. Who got it? Mr. Epstein. ✓ 12 Q. When you met with this investigator at 13 Carabbas, 14 A. Yes. 15 Q. -- did he record your conversation 16 A. No. 17 Q. -- in any way? 18 After this meeting at Carabbas, did you meet 19 with any other investigators? 20 A. No. 21 Q. After -- during your inspection of the massage 22 room after these massages had been completed with 23 Mr. Epstein, -- 24 A. Uh-huh. 25 Q. -- do you remember seeing any -- anything that PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba2ObcaeB7de EFTA00181644  Page 96 1 you would describe as blood? 2 A. No, never. 3 Q. Do you remember seeing anything that you would 4 describe as a sexual fluid? 5 A. No, never. 6 Q. When you worked for Jeffrey Epstein, the woman 7 that you were married to, what is her name or -- what is 8 her name? 9 A. The woman that I was married to? 10 Q. I think -- the reason I'm asking is because 11 earlier today when you first spoke, I thought I 12 remembered you saying that you -- both you and your 13 wife -- 14 A. That's my 15 Q. -- worked for Mr. Epstein? 16 A. It's still my wife. It's still my wife. We 17 didn't -- we got two ways away from a divorce and the 18 lawyers were taking my money by pipeline. 19 Q. And what is her name? 20 A. And we decide not to divorce and we still 21 together. 22 Q. Sorry. I missed that. But what is her name? 23 A. Maria Alessi. 24 Q. Let me just look through my notes to see if I 25 have any other questions. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c868-4b9f-Eld01-ba2Obcae87de EFTA00181645  Page 97 1 A. Okay. 2 Q. Thank you very much. 3 A. Welcome. 4 CROSS EXAMINATION 5 BY MR. MERMELSTEIN: 6 Q. Good afternoon, Mr. Alessi. 7 A. Yes, sir. 8 Q. My name is Stuart Mermelstein. I represent a 9 group of the Plaintiffs in these cases and I have some 10 questions for you as well. 11 Your wife, Maria, does she live at the same 12 address as you now? 13 A. Yes, she does. 14 Q. Now, when you began working full time for 15 Mr. Epstein, I believe you said that was around 1991; is 16 that correct? 17 A. Yes. 18 Q. Was your wife, was she hired at the same time 19 as you? 20 A. No. She was hired three years after. 21 Q. And how did that come about that your wife was 22 hired? 23 A. My wife was hired because we had a housekeeper 24 that she was doing the cleaning and she left. Then we 25 had another housekeeper, Polish girl, and she left. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-c860-4b91-8d01-ba2Obcae87de EFTA00181646  Page 98 1 And then by that time my kids went to college 2 and my wife was at home. And I suggest my wife to come 3 to work with me, to help me. 4 Q. So you recommended to Mr. Epstein that he hire 5 your wife? 6 A. Yes. 7 Q. And he did? 8 A. Yes, he did. 9 Q. And what were her job duties there? 10 A. Her only job duties were shopping, basically 11 the shopping, getting movie tickets, show tickets, buy 12 books, bring the food to Mrs. Epstein's -- Mr. Epstein's 13 mother, sometimes drive Mrs. Epstein to the doctors. 14 She was not involved -- and sometimes she did 15 some cleaning for me. 16 Q. Did she live with you in the upstairs 17 apartment? 18 A. Most of the nights we had an apartment right 19 across the bridge on Flagler that it was my -- my 20 property. And we had an apartment there. 21 So she went home. She didn't like to stay 22 there. But I had to stay there because my job starts 23 from 5:00 in the morning to 10:00 night 24 Q. And did Maria leave her employment the same 25 time as you? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0c860-4b91-8d01-ba20bcae87de EFTA00181647  Page 99 1 A. Yes, we did at the same time. 2 Q. You testified that you would come into the 3 bedroom and clean up after massages; is that correct? 4 A. That's correct. 5 Q. Did you -- were there occasions where you had 6 your wife help you with that? 7 A. No. No. 8 Q. Were there -- did she have occasion to go into 9 the master bedroom? 10 A. It was occasions before that she will help to 11 set up the tables once in a while, set up the oils and 12 the tables. But I will do the clean up after. 13 Q. Is there a reason for that? 14 A. I was more involved into the final appearance 15 of the house. And it was my responsibility to make sure 16 that every room was perfect after they left and before 17 they went to bed. 18 Q. Was there anyone else who assigned your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy some stuff, go get this and go get that. 22 She was mostly -- my wife was mostly out of the house. 23 She was -- this house was Mr. Epstein would says, go get 24 me this book, go get me this magazine, go get me 25 tickets, movie tickets for this show and this show and PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3cae-c86e-4b91-Eld01-ba2Obcae87de EFTA00181648  Page 100 1 this show. And she would have to travel -- and I was on 2 the phone with my wife constantly, buy this, get this, 3 get this -- and the food, and the food because it was a 4 five-star hotel. 5 Q. Did Ms. Maxwell or Mr. Epstein ever instruct 6 your wife to do housecleaning tasks? 7 A. No. I was blamed for everything. 8 Q. You were blamed for everything? 9 A. I was blamed for the good and the bad. 10 Q. Did you -- during the time your wife was 11 there, did you also have a hired housekeeper? 12 A. We have a crew of housecleaners. We have a 13 crew of people that would come to the house and do a 14 serial -- I mean, deep cleaning, you know, to the house. 15 Q. Was that every day? 16 A. Once a week -- no, it was twice a week. It 17 was Tuesday and Fridays. 18 It depends on Mr. Epstein's schedule because 19 he didn't -- he didn't want nobody at the house while he _ •-- 20 was at the house. So we have to rearrange days for the 21 clean-up crew to come in. And I usually did that. As 22 soon as they left I bring the cleaning crew, get the 23 house ready and -- and get set for them for the next 24 trip. 25 Q. Did you have a housekeeper who did PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3alc3ca0-c86o-4b9f-8d01-ba20bcae87de EFTA00181649  Page 101 1 housekeeping tasks on an everyday basis while you were 2 employed there? 3 A. No. 4 Before my wife went in? 5 Q. No. After your wife. 6 A. No. No. Not a full-time housekeeper. 7 Q. But you said your wife was hired after the 6 housekeeper left? 9 A. Yes. 10 Q. But -- so the person who left before your wife 11 came, was she doing housekeeping chores? 12 A. Yes, she was doing the housekeeping chores. 13 Q. Well, who did it then after your wife became 14 employed there, because she wasn't doing the 15 housekeeping? 16 A. I was. I was doing it and then we hire people 17 for to help us. 18 Q. So you were the main person doing the 19 housecleaning? 20 A. Yeah. 21 Q. And during -- between that time that your wife 22 started and when you left the employment, was there a 23 separate housekeeper employed during that time? 24 A. No. Full time? No. 25 Q. Full-time housekeeper? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b9f-4(101-ba2Obcae87de EFTA00181650  Page 102 1 A. No. 2 Q. What about a part-time housekeeper? 3 A. No. Like I told you, daily basis we call this 4 company. And then they will come in with four or five 5 girls and clean the whole house. 6 Q. This is the crew you were talking about? 7 A. The crew. 8 Q. But the crew didn't come when Mr. Epstein was 9 there? 10 A. Right. 11 Q. So on an everyday basis when Mr. Epstein was 12 there, you were the only person who was cleaning? 13 A. Me -- yeah, or my wife will help. 14 Q. At your instruction? 15 A. That's right. 16 Q. But you don't ever remember her cleaning up 17 after massages? 18 A. No. No. 19 Q. Is it possible that you instructed her to 20 clean up? 21 A. It's possible, but -- 22 MR. CRITTON: Form. Asking him to speculate. 23 BY MR. MERMELSTEIN: 24 Q. You can answer. 25 A. It's possible. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0c86e-4b9110101-ba2Obcae87do EFTA00181651  Page 103 1 Q. When girls would come to give a massage, where 2 would they come in the house? Would they come to the 3 front door? 4 A. Mostly came to the back kitchen door. 5 Q. The back kitchen door? 6 A. Uh-huh. 7 Q. Okay. And is there a bell there? Would they 8 knock or how would they -- 9 A. There's a door bell. 10 Q. A door bell? They would ring the door bell? 11 A. Uh-huh. 12 Q. And who generally would answer the door? 13 A. Me or my wife. 14 Q. So you would let them in? 15 A. Uh-huh. 16 MR. CRITTON: Stuart, can I just ask you? You 17 use the term, girls. I assume you just mean, that 16 means female woman. It can mean anything? It has 19 no age bracket to it? 20 MR. MERMELSTEIN: That's correct. I'm not 21 referring specifically to ages right now. 22 THE WITNESS: No. 23 BY MR. MERMELSTEIN: 24 Q. So as I understand it, the girl would come to 25 the kitchen entrance, which is the service entrance, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c96o-4b9f-6d01-ba20bcae67de EFTA00181652  Page 104 1 correct? 2 A. Uh-huh. 3 Q. You have to say yes or no. 4 A. Yes, sir. 5 Q. If you answer uh-huh, that's not clear, so you 6 have to answer yes or no. 7 A. Okay. 8 Q. And you would typically open the door? 9 A. Yes, sir. 10 Q. And what would happen then? 11 A. Then I will keep her in the kitchen and go to 12 Mr. Epstein and find out where they want to have the 13 massage, or if it was for him or for Ms. Maxwell. And I 14 immediately, if they were reReat gl.jj.s—that are -- they 15 will know exactly where to go. And I will go up with 16 them, set the tables, and they will wait for him or her 17 to go in the room and they sit there until they come up. 18 Q. So did you generally already know that they 19 were coming at the time that they knocked on the door? 20 A. Yes, uh-huh. 21 Q. So you had an appointment schedule? 22 A. Yeah. Because most of the times I was doing 23 1/ the calling, you know. I called J., come in at 3:00 24 this afternoon. And she will told me, no, I cannot, get 25 somebody else. And I knew it the time they were coming. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed