gov.uscourts.nysd.447706.1331.11.pdf

Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 1 of 8 EXHIBITE  Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 2 of 8 Page 270 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, CASE NO: 08-CV-80119 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant . I 8 JANE DOE NO. 3 I CASE NO: 08-CV-80232 9 Pla i ntiff, 10 Vs . CONDENSED 11 JEFFREY EPSTEIN, 12 Defendant. 13 I ( , 14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. I 19 JANE DOE NO. 5, CASE NO: 08-CV-80381 20 Plaintiff, 21 VS 22 JEFFREY EPSTEIN, 23 Defendant. 24 I 25 I ' Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000315 OI UFFRE0023 14 Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 3 of 8 Page 271 Page 273 l JANE DOE NO. 6, CASE NO: 08·CV·80994 1 IN THE CIRCUIT COURT OF THE 15TH 2 Plaintiff, JUDICIAL CIRCUIT IN AND FOR l Vs. 2 PALM BEACH COUNTY, FLORIDA 4 JEFFREY EPSTEIN, 5 Defendant. 3 CASE NO. 502008CA0373l9XXXXMB AB 4 6 B.B., JANE DOE NO. 7, CASE NO: 08·CV·80993 5 7 Plaintiff, Plaintiff, 6 8 Vs. Vs. 7 9 JEFFREY EPSTHN, JEFFREY EPSTEIN. 10 8 Defendant. Defendant. ll 9 I l2 C.M.A., CASE NO: 08·CV·808I l 10 13 Plaintiff, 11 [4 Vs, 12 1031 Ives Dairy Road 15 JEFFREY EPSTEIN, Suite 228 l6 Defendant. I 13 North Miami, Florida ll August 7, 2009 JANE DOE, CASE NO: 08·lV·80893 14 1:15 p.m. to 5:30 p.m. 18 15 Plalnt~f, 16 CONTINUED 19 17 VIDEOTAPED Vs. 18 DEPOSITION 20 JEFFREY EPSTEIN, 19 of 21 20 ALFREDO RODRIGUEZ Defendant. 21 22 I 22 taken on behalf of the Plaintiffs pursuant 23 23 to a Re-Notice of Taking Continued Videotaped 24 24 Deposition (Duces Tecum) 25 25 Page 272 Page 274 1 JANE DOE NO. Ir, CASE NO: 08-CV-80469 1 APPEARANCES: 2 Plaintiff, 2 3 Vs. 3 MERMEI.SfEIN & HOROWITT, P.A. BY: ADAM HOROWITT, ESQ. 4 JEFFREY EPSTEIN, 4 18205 Biscayne Boulevard 5 Defendant. Suite 2218 I 5 Miami, Florida 33160 6 Attorney for Jane Doe 2, 3, 4, 5, 6 6, and 7. JANE DOE NO. 101 CASE NO: 08-CV-80591 7 7 8 ROTHSTclN ROSENFELDT ADlfR Plaintiff, 6Y: BRAD J. EDWARDS, ESQ., and 8 9 CARA HOLMES, f.SQ. Vs. Las Olas City Centre 9 10 Suite 1650 401 East Las Olas Boulevard JEFFREY EPSTEIN, ll Fort Lauderdale, Florida 33301 10 Attorney for Jane Doe and E.W. Defendant. 12 And LM. 11 I 13 12 JANE DOE NO. 102, CASE NO: OS·C\1·80656 14 PODtlURST ORSEO< SY: KATHERINE W. EZELL, ESQ, 13 Plaintiff, 15 25 West Flagler Street 14 Vs. Suite 800 15 JEFFREY EPSTEIN 16 Miami Florida 33130 16 Defendant. Attorney for .Jane Doe 101 and l02. 17 18 17 lfOPOLO·KWlN 18 19 BY: ADAM J. LANGINO, ESQ, 19 2925 PGA Boulevard 20 20 Suite 200 21 Palm Beach Gardens, Florida 33410 21 Attorney for 8.8, 22 22 23 23 24 24 25 25 - 2 (Pages 271 to 274) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000316 GIUF!'RE0023 J5 Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 4 of 8 Page 275 Page 277 1 APPEARANCES: 1 Deposition taken before MICHELLE PAYNE, Court 2 3 RICHARD WILLITS, ESQ. 2 Reporter and Notary Public in and for the State of 2290 10th Avenue North 3 Florida at Large, in the above cause. 4 Suite 404 4 Lake Worth, Florida 33461 Attorney for C.M.A. 5 THE VIDEOGRAPHER: This is a continuation Appeared via telephone. 6 of the deposition of Alfredo Rodriguez. 6 7 7 Today is Friday, August the 7th, the year BURMAN, CRITTON, LUTI1ER & 8 2009, starting time approximately 1: 15 p.m. 8 COLEMAN, LLP 9 WIii the court reporter please swear In BY: ROBERT CRITTON, ESQ. 9 515 North Flagler Drtve 10 the witness? Suite 400 11 Thereupon, 10 West Palm Beach, Florida 33401 12 ALFREDO RODRIGUEZ, Attorney for Jeffrey Epstein. 11 13 having been first duly sworn or affirmed, was 12 14 examined and testified as follows: 13 ALSO PRESENT: 15 MR. CRITTON: Before we get started just 14 JOE LANGSAM, VIDEOGRAPHER 16 with regard to Ms. Ezell represents Jane Doe 15 17 101 and 102, the alleged time of her 16 18 incidents as of least have been plead in the 17 19 complaint for 101 is '99 -- I'm sorry, '98 18 20 through 2002, with Jane Doe 102 the Spring 19 21 of -- Spring/Summer of 2003. Mr. Rodriguez 20 21 22 never even began employment until '04 and 22 23 '05. I think her questioning I think -- I 23 24 24 can't say she doesn't have standing based on 25 25 the court order, but I would say it's Page 276 Page 278 l CONTINUED INDEX OF EXAMINATION 1 completely irrelevant and immaterial and has 2 WITNESS DIRECf CROSS REDIRECT RECROSS 2 no probative value with regard to this 3 particular witness based upon the two ALFREDO RODRIGUEZ 4 clients at least that are in suit at this 4 (Dy Ms. Ezell) 278 441, 467 5 point in time, 5 6 MS. EZELL: As Mr. Critton well knows I (By Mr. Willits) 334 453, 459 7 represent a number of other clients whose 6 ( By Mr. Critton) 338 454 8 cases have not been filed and I believe we 7 9 do have standing to ask questions, and I do (By Mr. Edwards) 419, 454, 468 10 intend to do that today. 8 (By Mr. Langi no) 452 11 EXAMINATION 9 12 BY MS. EZELL: 10 13 Q, Mr. Rodriguez, you stated last time that 11 14 there were guests at the house, frequent guests, 12 CONTINUED INDEX OF EXHIBITS 13 PLAINTIFPS PAGE 15 friends from Harvard. 14 3 ~-•awing 315 16 Do you remember that testimony? ._J , • - - :;, • -F • J./ A, 11:;;;;,1 ,.uQIII, 16 5 Photograph 331 17 6 Photograph 331 18 Q. And was there a lawyer from Harvard named 18 7 Photograph 331 19 Alan Dershowitz? 19 8 Photograph 331 20 A. Yes, ma'am, 20 9 Report 446 21 (Exhibits 4, 5, 5, 7, and 8 were reta ined by Ms. 21 Q. And are you famillar with the fact that Ezell .) 22 he's a famous author and famous lawyer? 22 23 A. Yes, ma'am. 23 24 24 Q. How often during the six months or so 25 25 that you were there was Mr. Dershowitz there? 3 (Pages 275 to 278) Kress Court Reporting, Inc. 305·866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000317 (JllJFFRE0023 lG  Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 5 of 8 Page '139 Page 4'11 l Q. And you said that that was -- the massage 1 MR. EDWARDS: I don't have anything else. 2 table was similar in kind to that used by Mr. 2 MS. EZELL: I have a few. 3 Epstein? 3 EXAMINATION 4 A. That's correct. 4 BY MS. EZELL: 5 Q. And others had massage oils and that was 5 Q. Mr. Rodriguez, I may have missed 6 similar in kind to Mr. Epstein's as well? 6 something. Did you say that there weren't any 7 A. Yes. 7 wild parties ever at El Brillo Way? 8 Q. And you didn't think that the massage 8 A. I never saw what was going on inside the 9 table at a home was unusual? 9 house, Ma'am. 10 A. No. 10 Q. So you don't know wether there were or 11 Q. All right. Did any of the other houses 11 were not? 12 where you worked have masseuses that were 14, 15, 12 A. No, ma'am. 13 and 16 years old? 13 Q. There wasn't just one massage table 14 MR. CRITTON: Form. 14 there; was there? 15 THE WITNESS: No, sir. 15 A. We used to have two and we have an extra 16 BY MR. EDWARDS: 16 reserve, I think there were three in the house. 17 Q. And did any of the other homes where you 17 Excuse me, I'll take that back. All the bedrooms 18 worked have different girls of that age coming 18 used to have one. 19 every single day? 19 Q. Okay. Thank you. Did you ever hear 20 A. Yes. 20 about a girl named V.R.? 21 MR. CRITTON: Form. 21 A. No, no, ma'am. 22 BY MR. EDWARDS: 22 Q. And those pictures on Ms. Maxwell's 23 Q. They had different girls? 23 computer, did you ever see one of a girl naked in ~ A~~ ~ a hammock? 1 25 Q. Okay. And how old were the girls that 25 MR. CRITTON: Form. Asked and answered. Page 440 Page 442 1 would come to these other homes? 1 THE WITNESS: I saw on a book not on a 2 A. They seem older. 2 computer. 3 Q. Older than the ones that would come to 3 BY MS. EZELL: 4 Mr. Epstein's home? 4 Q. You saw a picture of a girl naked in a S A. Yes. 5 book or on a book? 6 Q. And did you ever work at a place where 6 A. The book was done for i i . and she was 7 there would be girls calllng up on the phone to 7 on the hammock, that's the only one t saw. 8 say I have girls to bring him and •· 8 Q. I'm sorry, the book was done for - 9 A. No, sir. 9 A. She was on the cover. 10 Q. •• coming over in teams •· 10 Q. Then there were other people inside the 11 A. No. 11 book? 12 Q. -- or pairs? 12 A. Yes, ma'am. 13 A. No. 13 Q. And in that book there was a picture of a 14 Q. So there were a lot of things about Mr. 14 girl naked in a hammock? 15 Epstein's house and his arrangement that were very 15 A. Yes, ,.,.., UI ,_.,.. __ , · r- ·- ~""' "'' • - - -· ,..,., ,-- - - - - - ..... ,.., - -· 17 worked? - - 1 17 A. There were a few of those examples but I 18 MR. CRITTON: Form. 18 don't know where she kept it. 19 THE WITNESS: Yes. 19 Q. Was it laying around the house somewhere? 20 BY MR. EDWARDS: 20 A. Yes. 21 Q. And there were no drugs and alcohol or no 21 Q. Downstairs? 22 wild parties at Mr. Epstein's house, that is 22 A. Downstairs, yes, ma'am. 23 somewhat different from some of the other places 23 Q. Did Nadia keep scrapbooks or photograph 24 where you worked? 24 books -- 25 A. Yes. 25 A. Yes. 44 (Pages 439 to 442) Kress Court Reporting, Inc. 305-866-7668 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000358 GIUFFREO02357  Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 6 of 8 Page 463 Page 465 1 Q. -· to sexually please Mr. Epstein. l Q, And as to -- it was read to you by Mr. 2 Right? 2 Edwards and he then asked you a number of 3 MR. CRITTON: Form. 3 questions whether you remembered something. 4 THE WITNESS: Yes. 4 Correct? 5 BY MR. EDWARDS: 5 A. Yes. 6 Q. r mean, that's what you were telling the 6 Q. Okay. Just so I'm clear, he's asking you 7 police officer. 7 to speculate on what may or may not have occurred 8 MR. CRITTON: Form. 8 upstairs in the bedroom. I want to be very clear. 9 THE WITNESS: Yes. 9 Mr. Rodriguez, were you ever up in the 10 BY MR. EDWARDS: 10 bedroom to observe whatever went on between a 11 Q. Okay. There's always a different girl at 11 masseuse and Mr. Epstein or anyone else for that 12 the pool or inside with him when he's here. 12 matter at any time? 13 MR. CRITTON: Form . 13 MR. HOROWITT: Form. 14 THE WITNESS: Yes. 14 THE WITNESS: No, sir. 15 MS. EZELL: You left out a word, young. 15 BY MR. CRITTON: 16 BY MR. EDWARDS: 16 Q, And so when Mr. Edwards asked you, you 17 Q. Sorry, I'll read the last sentence again. 17 were aware that sexual activity or may have been 18 There's always a different young girl at 18 sexual activity occurring upstairs, you have no 19 the pool or Inside with him when he's here. 19 personal knowledge, you're just speculating; 20 Do you remember telling the police 20 aren't you, sir? 21 officer that? 21 MR. HOROWITT: Form. 22 A. Yes. 22 MR. EDWARDS: Object to the form. 23 MR. CRITTON: Form. 23 THE WITNESS: I never saw them. 24 BY MR. EDWARDS: 24 BY MR. WILLITS: 25 Q. And that's true. Right? 25 Q. And therefore you can only speculate ·- ' Page '164 Page 466 ,, 1 A. Yes. 1 MR. WILLITS: Object to the Form. 2 Q. When he's at the house there is always a 2 MR. CRITTON : I need to ask the question 3 young girl inside with him. 3 first. 4 MR. CRITTON: Form. 4 MR. WILLITS: It was the earlier 5 BY MR. EDWARDS: 5 question. 6 Q. Right? 6 BY MR. CRITTON : 7 A. That's right. 7 Q, All right. If you did not see what was 8 Q. Okay. And whether the company line is to 8 going on you can have no personal knowledge. 9 call them a masseuse, you knew that these girls 9 True? 10 were young and were up in the bedroom with Mr. 10 MR. HOROWITT: Object to the form. 11 Epstein to sexually please Mr. Epstein. 11 MR. EDWARDS: Object to the form. 12 MR. CRITTON: Form. 12 THE WITNESS: Yes. 13 THE WITNESS: That's right. 13 BY MR. CRITTON: 14 MR. EDWARDS: I don't have anything else. 14 Q. And, therefore, what you're doing is 15 - !U We've already attached this; right? Here is ll It: UI I~ \.I u...,1,, ..,...., ...,.._. ..... ., _ _ , • - - • .15 ,, •v ~--- speculating or guessing what may have been ... .,. _.... 17 MR. WILLITS: Who is next? 17 MR. HOROWITT: Form. 18 MR. CRITTON: Me. 18 MR. EDWARDS: Form . 19 RECROSS EXAMINATION 19 MR. WILLITS: Form. 20 BY MR. CRITTON: 20 THE WITNESS : I use my age together. 21 Q. Mr. Rodriguez, looking at Exhibit 9 which 21 BY MR. CRITTON: 22 is the police report that was prepared on November 22 Q. I'm not saying that you don't, but 23 28, 2004, this is the first time you've seen it. 23 without having personal knowledge you're best 24 Correct? 24 guessing what may have occurred up there between 25 A. That's correct. 25 Mr. Epstein and one of the massage women, or for SO (Pages 463 to 466) Kress Court Reporting, Inc. 305·866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000364 GIUFFRE0Cl2363  Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 7 of 8 Page 467 Page 469 1 that matter anyone else who was upstairs? 1 A. Yes. 2 A. Yes. 2 MR. EDWARDS: Nothing else. 3 MR. HOROWm: Form. 3 MR. WILLITS: Is it my tum? 4 MR. EDWARDS: Form. 4 MR. EDWARDS: Yes. 5 MR. WILLITS: Object to the form. 5 EXAMINATION 6 MR. CRITTON: Thank you. 6 BY MR. WILLITS: 7 MS. EZELL: I just have a couple of 7 Q. Mr. Rodriguez, you mentioned the last 8 questions. 8 time about a lady who was an obvious professional 9 EXAMINATION 9 masseuse by the name of Johanna. Do you remember 10 BY MS. EZELL: 10 that? 11 Q. Following up on that, you did however see 11 A. Yes, I do remember. 12 this same young woman asleep naked in the sauna? 12 Q. Did you ever pay her? 13 A. Yes, ma'am. 13 A. Yes, sir. 14 Q. And you did along with Louella find and 14 Q. Okay. How much did you pay her? 15 -- and you did also find sex toys and rnassagers of 15 A. It was between 200 and S00, sir, but 16 various kinds and creams scattered around on 16 somewhere in that -- between those two amounts. 17 several occasions after these young women had been 17 Q. For Johanna? 18 upstairs with Mr. Epstein? 18 A. Yes, sir. 19 MR. CRITTON: Object to form, asked and 19 MR. WILLITS: Okay. I don't have any 20 answered about six times. 20 other questions. 21 THE WITNESS: Yes. 21 MR. CRITTON: You have a right to read 22 MS. EZELL: No other questions. 22 this deposition when the other part is typed 23 MR. EDWARDS: Sorry, last one. It has 23 and make any changes that you want. Would 24 nothing to do with this report. 24 you like to do that? It's your right a 25 EXAMINATION 25 hundred percent. The court reporter can Page 468 Page 470 1 BY MR. EDWARDS: 1 provide you or whoever set your 2 Q. During Mr. Critton's questioning he asked 2 deposition -- 3 you about whether or not we had ever shown you a 3 THE WITNESS: I tried to be truthful. 4 previous taped statement that you had given to a 4 MR. CRITTON: All you have to do is tell 5 police officer, and we did not do that; did we? 5 her you would like to waive. Do you waive 6 A. No. 6 the reading and signing? 7 Q. We can represent to you that we don't 7 MR. EDWARDS: You can either read or you 8 have it to show it to you otherwise we would like 8 can waive reading? 9 to do that. 9 THE WITNESS: I don't understand what I 10 However, he asked you did you tell the 10 have to do. 11 police officers at that time that the girls 11 MR. CRITTON: Why don't we go off the 12 appeared to be 18 years or older, and I believe 12 record and you can explain it to him. 13 that you said when you gave the statement to the 13 MR. EDWARDS: We can go off the record. 14 police that you did; right, say that? 14 THE VIDEOGRAPHER: Off the record. 15 A. Yes. 15 (Thereupon, a discussion was held off the .. .- - ,. 'T .... :J... - --· it:. ..... '-(;• >IIV ~ 'f'II_,.,.._./ ,......., .. I\." f I .,...,..,..,.. -- ·-- -·, • ..J \ 17 that because you were fearful of reprise from 17 THE WITNESS: Waive. 18 Ms. Maxwell and Mr. Epstein. 18 (Thereupon, the deposition was concluded 19 A. That's correct. 19 at 5:30 p.rn.) 20 MR. CRITTON: Form. 20 21 BY MR. EDWARDS: 21 22 Q. Okay. Is everything that you've said 22 23 today and told us today, is it true? 23 24 A. Yes. 24 25 Q. To the best of your knowledge? 25 51 (Pages 467 to 470) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000365 GIUFFRE002364  Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 8 of 8 Page 471 l THE STATE OF FLORIDA, ) 2 COUNTY OF DADE. ) 3 4 S I, the undersigned authority, certify 6 that ,\LFREDO RODRIGUEZ personally appeared before 7 me on the 7th day of August, 2009 and was duly 8 sworn. 9 10 WITNESS my hand and official seal this 11 18th day of August, 2009. 12 13 14 15 MICHELLE PAYNE, Court Reporter 16 Notary Public• State of Florida 17 18 19 20 21 22 23 24 25 Page 472 l CERTrFICAJ'f. l lho Stato Of Florida, J county or Dade. 4 s I, MICHEll.l' PAYNE, Cou<t Reporter a!Xl Nota,y Pub!<: in and for !he State of Florida at 6 large, do hereby certify that I was. avlhoriled to and did stenographically repo,t lhe dc'j)OSiti<;,n of 7 All'REDO RODRIGUEZ; that a review of the transcript was not re-quested; and that the forf.'lloinQ pages, 8 nvmbered from 270 to 472, lnciusi11e, are :,- true and com,ct tr;,nso;plion of my s«moqraphlc notes 9 or said deposition. 10 l further certify that ,aid deposition was tak.cn at the time and ptace hereiflabove set forth 11 31\d that the taking of said der,osilioo was i.:ommencnct and cornptetcd as hereinaOOve set out. 12 i furthC!r certify that l am no! an 13 atto~y or counsel of any of the parties, nor arn l a relative or empfoyce of any attorney or 14 counsel of party connected with the actloo, nor am J flac,r.c:!ally interestl!d In the ilct.lOfl. 15 1ne rorego11,y wrw ........ ,.,.. ...,, , .. ~ I G transcnpt does not •Pill>' to any reproduction of the ~me by any me-,ns unfes.s under the direct 17 i.:ontrol and/Or direction of the certlfyin9 reporter. DAlED this 18!!\ dav of August, 2009. 19 20 21 -MfCHfLLE PAYlff, Cou•t Reporter 22 ZJ 24 25 52 (Pages 471 to 472) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000366 GIUFFRE002365