gov.uscourts.nysd.447706.1328.17.pdf

Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 1 of 6 EXHIBIT 16 (Filed Under Seal)  Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 2 of 6 Page 2 Page 4 ' 1 JANE DOE NO. 6, Case No: 08-CV-80994 1 VIDEOTAPED 2 Plaintiff, 2 DEPOSITION 3 Vs 3 of 4 JEFFREY EPSTEIN, 4 ALFREDO RODRIGUEZ 5 Defendant. 5 I 6 taken on behalf of the Plaintiffs pursuant 6 7 to a Re-Notice of Taking Deposition (Duces Tecum) JANE DOE NO. 7, Case No. 08-CV-80993 8 7 9 --- Plaintiff, 10 APPEARANCES: 8 11 Vs MERMELSTEIN & HOROWITZ, P.A. 9 12 BY: STUART MERMELSTEIN, ESQ. JEFFREY EPSTEIN, 18205 Biscayne Boulevard 10 Suite 2218 13 Defendant. Miami, Florida 33160 11 I 14 Attorney for Jane Doe 2, 3, 4, 5, 12 C.M.A., Case No: 08-CV-80811 6, and 7. 13 Plaintiff, 15 14 Vs 16 ROTHSTEIN ROSENFELDT ADLER 15 JEFFREY EPSTEIN, 16 Defendant. BY: BRAD J. EDWARDS, ESQ., and I 17 CARA HOLMES, ESQ. 17 Las Olas City Centre JANE DOE, Case No: 08-CV-80893 18 Suite 1650 18 401 East Las Olas Boulevard Plaintiff, 19 Fort Lauderdale, Florida 33301 19 Attorney for Jane Doe and E.W. Vs 20 And L.M. 20 21 JEFFREY EPSTEIN, PODHURST ORSECK 21 22 BY: KATHERINE W. EZELL Defendant. 25 West Flagler Street 22 I 23 Suite 800 23 Miami, Florida 33130 24 24 Attorney for Jane Doe 101 and 102. 25 25 Page 3 Page 5 1 JANE DOE NO. 11, Case No: 08-CV-80469 1 2 Plaintiff, APPEARANCES: 3 Vs 2 3 LEOPOLD-KUVIN 4 JEFFREY EPSTEIN, ADAM J. LANGINO, ESQ. 5 Defendant. 4 2925 PGA Boulevard SUite 200 6 5 Palm Beach Gardens, Florida 33410 JANE DOE NO. 101, Case No: 09-CV-80591 Attorney for 8.8. 7 6 Plaintiff, 7 RIOiARD WILLITS, ESQ. 8 2290 10th Avenue North Vs 8 SUite 404 Lake Worth, Florida 33461 9 9 Attorney for C.M.A. JEFFREY EPSTEIN, 10 10 BURMAN, CRITTON, LUmER & Defendant. 11 COLEMAN, LLP 11 BY: ROBERT CRITTON, ESQ. 12 JANE DOE NO. 102, Case No: 09-CV-80656 12 515 North Flagler Drive 13 Plaintiff, SUite 400 14 Vs 13 West Palm Beach, Florida 33401 Attorney for Jeffrey Epstein. 15 JEFFREY EPSTEIN, 14 16 Defendant. 15 16 17 ALSO PRESENT: 18 17 19 JOE LANGSAM, VIDEOGRAPHER 20 1031 Ives Dairy Road 18 Suite 228 19 21 North Miami, Florida - - - 20 July 29, 2009 21 22 11:00 a.m. to 5:30 p.m. 22 23 23 24 24 25 25 2 (Pages 2 to 5) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141  Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 3 of 6 Page 166 Page 168 1 written down anywhere? 1 for now we'll call it a massage -- as well as 2 A. No. 2 anybody who brought that person over to the house, 3 Q. It's my understanding that C. and T. 3 they would both get paid cash. Are you familiar 4 either came to his house alone to visit with Mr. 4 with that? 5 Epstein or brought other girls in their age group 5 MR. CRITTON: Form. 6 to Mr. Epstein. 6 THE WITNESS: No. 7 Were you familiar with that type of 7 BY MR. EDWARDS: 8 recruitment process of girls bringing other girls? 8 Q. If C. brought another girl over to the 9 MR. CRITTON: Form. 9 house and C. stayed downstairs but this other girl 10 THE WITNESS: Yes. 10 went upstairs with Mr. Epstein, which one would 11 BY MR. EDWARDS: 11 you pay? 12 Q. Can you tell me more about what you know 12 A. I don't know because I was told who to 13 about girls bringing other girls that are 13 pay. 14 relatively the same age to come to Jeffrey 14 Q. And Sarah Kellen always told you? 15 Epstein's house and to use your words, have a good 15 A. Sarah told me pay so and so. 16 time? 16 Q. So if we were going to ask anybody else 17 MR. CRITTON: Form. 17 about the exact method in terms of who wou ld get 18 THE WITNESS: It's hard to know who they 18 paid and for what, who would the people be? I 19 knew. But I think that was -- they feel 19 mean, other than Mr. Epstein who else could we ask 20 better themselves when they're in a group 20 these questions? 21 than going by themselves, but I don't know 21 A. Sarah. 22 somebody recruiting. 22 Q. Sarah Kellen? 23 BY MR. EDWARDS: 23 A. Yes. 24 Q. Okay. And you've talked about, at least 24 Q. She would know this? 25 referred to yourself I believe to the police and 25 A. Yes. Page 167 Page 169 1 as well today as a human ATM machine. Right? 1 Q. What about Ghislaine Maxwell? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Something like that. I was 3 THE WITNESS: You're talking about the 4 supposed to carry cash at all times. 4 boss. I don't know. 5 BY MR. EDWARDS: 5 BY MR. EDWARDS: 6 Q. One of the primary reasons why you 6 Q. To your knowledge was Ghislaine Maxwell 7 carried cash was to pay the girls in this age 7 aware of these girls that are in the age group of 8 group of C. and T. for whatever happened at the 8 C. and T. coming to Jeffrey Epstein's house to 9 house. Right? 9 have a good time? 10 MR. CRITTON: Form. 10 MR. CRITTON: Form. 11 THE WITNESS: Yes. 11 THE WITNESS: I have to say something . 12 BY MR. EDWARDS: 12 Mrs. Maxwell called me and told me not to 13 Q. That's a fair statement. Right? 13 ever discuss or contact her again in a 14 MR. CRITTON: Form. 14 threaten way. 15 THE WITNESS: Yes. 15 BY MR. EDWARDS: 16 BY MR. EDWARDS: 16 Q. When was this? 17 Q. Okay. And when C., let's use her for 17 A. Right after I left because I call one of 18 example, would bring somebody else to the house, 18 the friends for a job and she told me this, but, 19 did you pay C. as well as whomever she brought to 19 you know, I feel intimidated and so I want to keep 20 the house, pay them both? 20 her out. 21 A. No, I pay only one person. 21 Q. What exactly did she say? First of all, 22 Q. Okay. My understanding, and tell me if 22 was this a telephone call? 23 this is wrong or you can corroborate this, is that 23 A. Yes, she was in New York. 24 Mr. Epstein would pay the girl that was actually 24 Q. She called you on your cell phone? 25 performing whatever was happening in the room -- 25 A. Yes. 43 (Pages 166 to 169) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141  Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 4 of 6 Page 170 Page 172 1 Q. Is this the cell phone that was issued to 1 precisely did she say? 2 you by Mr. Epstein? 2 A. She said I forbid you that you're going 3 A. No, it was my personal phone. I was 3 to be -- that I will be sorry if I contact any of 4 already -- 4 her friends again. 5 Q. Gone? 5 Q. Okay. Other than you will be sorry if 6 A. Yeah, this is three, four months down the 6 you contact any of my friends again did she say 7 road. 7 anything else about what you know about Mr. 8 Q. So if you left in -- 8 Epstein and/or what goes on at his house? 9 A. February, March -- it was May or June. 9 A. She said something like don't open your 10 Q. Of 2005? 10 mouth or something like that. But you have to 11 A. Yes. 11 understand, I'm a civil humble, I came as an 12 Q. And you got a call from Ghislaine Maxwell 12 immigrant to service people, and right now you 13 out of the blue? 13 feel a little -- I'm 55 and I'm afraid. First of 14 A. Yes. 14 all, I don't have a job, but I'm glad this is on 15 Q. And do you know what prompted that 15 tape because I don't want nothing to happen to me. 16 telephone call? 16 This is the way they treat you, better do this and 17 A. Because I contact somebody in New York to 17 you shut up and don't talk to nobody and -- 18 get a job. 18 Q. When you say this is the way they treat, 19 Q. Who was that person? 19 who specifically are you talking about when you 20 A. I contact Jean-Luc and I contact Eva, the 20 say the word they? 21 Swedish girl, she used to be very good friends 21 A. Maxwell. 22 with Mr. Epstein because she asked me she need 22 Q. And usually when you say the word they, 23 somebody in New York. 23 you're not only talking about one person -- 24 Q. What does Eva do? 24 A. Wealthy people. 25 A. Eva was a model many years ago and he 25 Q. Are you also putting Jeffrey Epstein in Page 171 Page 173 1 married -- Eva is the mother of the girl who was 1 that category? 2 on the wall. 2 MR. CRITTON: Form. 3 Q. Who is on the wall of Mr. Epstein's 3 THE WITNESS: I didn't talk to him 4 house? 4 directly most of the time. 5 A. Yeah. 5 BY MR. EDWARDS: 6 Q. All right. There is a younger girl model 6 Q. What's the reason why if you were his 7 that's on the wall of Mr. Epstein's house and this 7 head of security that you wouldn't have more 8 lady Eva is her mother? 8 direct contact with him? Why is that? 9 A. Yes. 9 MR. CRITTON: Form. 10 Q. And at some point in time you called her 10 THE WITNESS: He wanted that way, you 11 in New York to get a job? 11 know, so, yeah, I have to talk to Sarah, 12 A. That's right. 12 Sarah is not available talk to Lesley in New 13 Q. And you also called Jean-Luc Bernell? 13 York. He didn't want to be disturbed. 14 That's his name. Right? 14 BY MR. EDWARDS: 15 A. Jean-Luc, yeah, I don't remember his last 15 Q. Even while you were in the same house 16 name. 16 with him he still had other people you could talk 17 Q. Does that sound familiar to you, Jean-Luc 17 to directly but he was not one of them? 18 Bernell? 18 A. Yeah. 19 A. Yeah. 19 Q. When you were fired you were not fired 20 Q. What did Eva and/or Jean-Luc say about 20 directly by him? 21 employing you? 21 A. No. 22 A. No, they said they're going to find out 22 Q. It was through somebody else? 23 and obviously the first thing they did was talk to 23 A. Ms. Maxwell. 24 Mrs. Maxwell. 24 Q. Okay. But it was for upsetting him for 25 Q. She made a telephone call to you and what 25 taking the wrong car? - 44 (Pages 170 to 173) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141  Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 5 of 6 Page 174 Page 176 1 A. Yes. 1 this. Because I went through -- the first 2 Q. Okay. Ever since this communication that 2 time I went to the deposition I was in Palm 3 Ms. Maxwell made to you where she called you 3 Beach and I did my duty, I mean, I tell what 4 sometime in May or June of 2005, and have you felt 4 I know, but now I know there is more 5 threatened? 5 digging, all I want is this to be to get on 6 A. Yes. 6 with my normal life and stuff. 7 MR. CRITTON: Form . 7 BY MR. EDWARDS: 8 BY MR. EDWARDS: 8 Q. So when you come here today to testify, 9 Q. Have you felt reluctant to come forward 9 your main objective is to get back to your normal 10 and give truthful, honest, and full disclosure of 10 life and get out of the spotlight of this case. 11 all information that you know about this case? 11 Yes? 12 MR. CRITTON : Form. 12 A. Yes. 13 THE WITNESS: I said this off the record 13 Q. And in doing so have you held back some 14 but I will say it on the record, being in 14 of the details that you know about that happened 15 the Epstein case for me resulted in two 15 in this case to remove yourself from the 16 years I have -- I won't bring the names but 16 spotlight? 17 I was in the third interview to get hired as 17 MR. CRITTON: Form. 18 a household manager in Palm Beach and they 18 THE WITNESS: No, sir. 19 told me you are the Jeffrey Epstein guy. 19 BY MR. EDWARDS: 20 Not in the sense I did something wrong 20 Q. Okay. Have you ever talked to Ghislaine 21 because of the scandal, so they shun the job 21 Maxwell after that telephone call where she called 22 away from me. And so I was afraid that -- 22 you and you felt threatened? 23 this is very powerful people and one phone 23 A. No. 24 call and you finish, so I'm the little guy. 24 Q. Okay. So going back to where we started 25 Even I'm wearing a tie I'm a -- I'm talking 25 here was, does Ghislaine Maxwell have knowledge of Page 175 Page 177 1 from my heart. This is the way it is. 1 the girls that would come over to Jeffrey 2 BY MR. EDWARDS: 2 Epstein's house that are in roughly the same age 3 Q. I feel for you, I'm sorry that you have 3 group as C. and T. and to have a good time as you 4 to be in this position. 4 put it? 5 MR. CRITTON: Move to strike this. 5 MR. CRITTON: Form. 6 BY MR. EDWARDS: 6 THE WITNESS: Yes. 7 Q. Well, when you applied for these jobs and 7 BY MR. EDWARDS: 8 they turned you down and gave you the reason that 8 Q. And what was her involvement and/or 9 you're the person involved in the Jeffrey Epstein 9 knowledge about that? 10 scandal, was it that they are associated or 10 MR. CRITTON: Form. 11 friends with Jeffrey Epstein or is it that you 11 THE WITNESS: She knew what was going on. 12 have information and you have this confidentiality 12 BY MR. EDWARDS: 13 but you're revealing some certain information that 13 Q. You referred to her at one point in time 14 Mr. Epstein would not like? 14 as Jeffrey Epstein's companion. But then later on 15 MR. CRITTON: Form. 15 you said that if she flew she flew on a different 16 THE WITNESS: Both. 16 airplane and oftentimes or sometimes she slept in 17 BY MR. EDWARDS: 17 a different bed from Mr. Epstein. Did that seem 18 Q. Both? 18 unusual to you? 19 A. Both. 19 MR. CRITTON: Form . 20 Q. And since then given what you just told 20 THE WITNESS: It was odd but, I mean, and 21 us about these people being very powerful, are you 21 again, everything is odd in Palm Beach. 22 afraid for your life given the fact that you're 22 BY MR. EDWARDS: 23 involved to some extent in this case? 23 Q. Okay, I don't mean to laugh. 24 MR. CRITTON : Form. 24 A. Mr. Epstein fly to Jet Aviation, she fly 25 THE WITNESS: I just start thinking about 25 to Galaxy Aviation, but they never flew the same 45 (Pages 174 to 177) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141  Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 6 of 6 Page 266 Page 268 1 BY MR. LANGINO: 1 THE STATE OF FLORIDA, ) 2 Q. Are you currently in fear of Mr. Epstein? 2 COUNTY OF DADE. ) 3 A. Not at this particular moment but it's 3 4 something I have to be worry about, yes. 4 5 Q. Are you personally afraid of criminal 5 I, the undersigned authority, certify 6 prosecution? 6 that ALFREDO RODRIGUEZ personally appeared before 7 A. No. 7 me on the 29th day of July, 2009 and was duly 8 Q. Do you believe that you did anything 8 sworn. 9 illegal? 9 10 WITNESS my hand and official seal this 10 A. Illegal, no. 11 31st day of July, 2009. 11 MR. LANGINO: I have no further 12 12 questions. Thank you. 13 13 MR. CRITTON: We're going to break in 14 14 about 15 minutes. Do you want to start and 15 15 go for 15 minutes or do you want to -- it's MICHELLE PAYNE, Court Reporter 16 up to you. 16 Notary Public - State of Florida 17 MS. EZELL: I'll start. 17 18 MR. WILLITS: When are we going to quit, 18 19 folks? 19 20 MR. CRITTON: In 15 minutes. 20 21 THE VIDEOGRAPHER: Might as well change 21 22 tapes. 22 23 MR. EDWARDS: Bob has to get back so 23 24 we've agreed we're going to come back some 24 25 other time. 25 Page 267 Page 269 1 MR. WILLITS: Why don't we just stop now? 1 CERTIFICATE 2 2 MS. EZELL: Okay. The State Of Florida, MR. EDWARDS: Rather than you start. 3 County Of Dade. 3 4 4 MS. EZELL: Yeah, I won't get very far. 5 I, MICHELLE PAYNE, Court Reporter and 5 MR. EDWARDS: Sorry to do this with you, Notary Public In and for the State of Florida at 6 large, do hereby certify that I was authorized to 6 we didn't finish. and did stenographically report the videotaped 7 MR. CRITTON: So we're stopped? 7 deposition of ALFREDO RODRIGUEZ; that a review of the transcript was requested; and that the 8 MR. EDWARDS: We're stopped. 8 foregoing pages, numbered from 1 to 269, 9 THE VIDEOGRAPHER: Off the record. inclusive, are a true and correct transcription of 9 my stenographic notes of said deposition. 10 (Thereupon, the videotaped deposition was 10 I further certify that said videotaped 11 adjourned at 5:30 p.m.) deposition was taken at the time and place 11 hereinabove set forth and that the taking of said 12 videotaped deposition was commenced and completed 13 12 as hereinabove set out. 13 I further certify that I am not an 14 attorney or counsel of any of the parties, nor am 15 14 I a relative or employee of any attorney or counsel of party connected with the action, nor am 16 15 I financially interested In the action . 17 16 The foregoing certification of this transcript does not apply to any reproduction of 18 17 the same by any means unless under the direct 19 control and/or direction of the certifying 18 reporter. 20 19 DATED this 31st day of July, 2009. 21 20 21 22 MICHELLE PAYNE, Court Reporter 23 22 23 24 24 25 25 68 (Pages 266 to 269) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141