EFTA00310278.pdf

Page 270 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, CONDENSED 7 Defendant. 8 JANE DOE NO. 3, CASE NO: 08-CV-80232 9 Plaintiff, 10 Vs. 11 JEFFREY EPSTEIN, 12 Defendant. 13 ,14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. 19 JANE DOE NO. 5, CASE NO: 08-CV-80381 20 Plaintiff, 21 Vs 22 JEFFREY EPSTEIN, 23 Defendant. 24 25 EFTA00310278  Page 271 Page 2/3 1 JANE DOE ea 6, USE NO: 08-CV-80994 1 IN THE CIRCUIT COURT OF THE 15TH 2 Plaintiff, JUDICIAL CIRCUIT IN AND FOR 3 Vs. 2 PALM BEACH COUNTY, FLORIDA JEFFREY tpSie81, 3 CASE NO. 502008CA0373199000<MB AB Defendant. 4 B.B., 6 5 WE DOE NO. 7, CASE NO: 08-CV-80993 7 Plaintiff, Plaintiff, 6 8 Vs. vs. 7 9 JEFFREY EPSTEIN. JEFFREY EPSIEIN, B 10 Defendant. Defendant. 11 9 12 C.N.A., CASE NO: 08.CV-80811 10 13 Plaintiff, 11 14 Vs. 12 1031 Ives Dairy Road 15 JEFFREY EPSTEIN, 16 Defendant. 13 17 14 JANE DOE, CASE NO: 08.07-80893 18 :5 Plaintiff, 16 CONTINUED 19 17 VIDEOTAPED Vs. 18 DEPOSITION 20 19 of JEFFREY EPSTEIN, 20 ALFREDO RODRIGUEZ 21 21. Defendant. taken on behalf of the Plainbffs pursuant 22 22 23 23 to a Re-Notice of Taking Continued Videotaped 24 24 Depo9tlon (Duals Tatum) 25 25 --- Page 272 Pa4e 274 1 JANE DOE NO. Ii, CASE NO: 08-CV.80469 1 APPEARANCES: 2 2 Plaintiff, 3 TERVELSTEIN & liOROWIT2, P.A. 3 Vs. BY: ADAI4HORownt ESQ. l 4 JEFFREY EPSTEIN, 4 5 Defendant. a y , .,„ 6 6 6, and 7. JANE DOE NO. 101 CASE NO: 08-CV-80591 7 7 8 ROTHSTEIN ROSENfELOT ADLER Plaintiff, BY: BRAD J. EDWARDS, ESQ., and 8 9 VS. 10 9 JEFFREY EPSTEIN, 11 10 Defendant. 12 13 11 14 PODHURST ORSECK 12 JANE DOE NO. 102, CASE NO: 08-0/-80656 SQ. 13 Plaintiff, 15 14 VS. 15 JEFFREY EPSTEIN, 16 Attorney for lane Doe 101 and 102. 16 Defendant. 12 18 17 18 19 19 20 20 Palm Bead, Gardens, Florida 33410 21 21 Attorney for B.B. 22 22 23 23 24 24 25 25 2 (Pages 271 to 274 Kress Court Reporting, Inc. EFTA00310279  Page 275 Page 277 1 APPEARANCES: 1 Deposition taken before MICHELLE PAYNE, Court 2 2 Reporter and Notary Public in and for the State of 3 RICHARD WILLITS, ESQ. 2290 10th AVenue North 3 Florida at Large, in the above cause. 4 Suite 404 4 Lake Worth, Florida 33461 5 THE VIDEOGRAPHER: This is a continuation S Attorney for C.MA. speared via telephone. 6 of the deposition of Alfredo Rodriguez. 6 7 Today is Friday, August the 7th, the year 7 BURMAN, CRITTON, CURTER 8 2009, starting time approximately 1:15 p.m. 8 COLEMAN, LLP 9 Will the court reporter please swear in BY: ROBERT CRITTON, ESQ. 10 the witness? 9 515 North Rapier Drive Suite 400 11 Thereupon, 10 West Palm Beach, Florida 33401 12 ALFREDO RODRIGUEZ, Attorney for Jeffrey Epstein. 13 having been first duly sworn or affirmed, was 11 12 14 examined and testified as follows: 13 ALSO PRESENT: 15 MR. CRITTON: Before we get started just 14 16 with regard to Ms. Ezell represents Jane Doe 30E LANGSAM, VIDEOGRAPHER 15 17 101 and 102, the alleged time of her 16 18 incidents as of least have been plead in the 19 complaint for 101 is '99 -- I'm sorry, '98 17 18 20 through 2002, with Jane Doe 102 the Spring 19 21 of -- Spring/Summer of 2003. Mr. Rodriguez 20 22 never even began employment until '04 and 21 22 23 '05. I think her questioning I think -- I 23 24 can't say she doesn't have standing based on 24 the court order, but I would say it's 25 25 Page 276 Page 278 1 CONTINUED INDEX OF EXAMINATION 1 completely irrelevant and immaterial and has 2 2 no probative value with regard to this WITNESS DIRECT CROSS REDIRECT RECROSS 3 3 particular witness based upon the two ALFREDO RODRIGUEZ 4 clients at least that are in suit at this 4 5 point in time. (By Ms. Ezell) 278 441, 467 5 6 MS. EZELL: As Mr. Critton well knows I (By Mr. Willits) 334 453, 469 7 represent a number of other dients whose 6 8 cases have not been filed and I believe we (By Mr. Crkton) 338 464 7 9 do have standing to ask questions, and I do (By Mr. Edwards) 419, 454, 468 10 intend to do that today. 8 11 EXAMINATION (By Mr. Langlno) 452 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 PLAINTIFFS PAGE 15 friends from Harvard. 13 14 3 Drawing 315 16 Do you remember that testimony? 15 4 Photograph 327 17 A. Yes, ma'am. 16 5 Photograph 331 331 18 Q. And was there a lawyer from Harvard named 17 6 Photograph 18 7 Photograph 331 19 Alan Dershowitz? 19 8 Photograph 331 20 A. Yes, ma'am. 20 9 Report 446 Q. And are you familiar with the fact that 21 21 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. Ezell.) 22 he's a famous author and famous lawyer? 22 23 A. Yes, ma'am. 23 24 Q. How often during the six months or so 24 25 25 that you were there was Mr. Dershowitz there? I 3 (Pages 275 to 278 Kress Court Reporting, Inc. EFTA00310280  Page 279 Page 281 1 A. Two or three times. 1 Q. Can you tell me where those were? 2 Q. And did you have any knowledge of why he 2 A. One in the kitchen, and the one in the 3 was visiting there? 3 formal -- the main entrance. And there was one 4 A. No, ma'am. 4 more added later on, but there is two when I was 5 Q. You don't know whether or not he was a 5 working there. 6 lawyer -- acting as a lawyer or whether he was 6 Q. Could you just give me a rough sketch of 7 there as a friend? 7 the house of where the main entrance was and where 8 A. I believe as a friend. 8 the kitchen was? 9 Q. Were there also young ladies in the house 9 A. I'm not an architect but it's something 10 at the time he was there? 10 like this. This is the kitchen, this is the main 11 MR. CRITTON: Form. 11 entrance. 12 THE WITNESS: Yes, ma'am. 12 Q. Will you mark the kitchen with a K, 13 BY MS. EZELL: 13 please, and the main entrance with ME? 14 Q. av in ded for 14 A. This is the pool. 15 instan 15 Q. The pool? 16 A. Yes, ma'am. 16 A. Yes, ma'am. 17 Q. Were there other young ladies there when 17 Q. And in the upper left? 18 Mr. Dershowitz was there? 18 A. In the terrace, yeah, there was a balcony 19 MR. CRITTON: Form. 19 here. 20 THE WITNESS: Yes, ma'am. 20 Q. And where were the staircases? 21 BY MS. EZELL: 21 A. This is one, the kitchen, one in the 22 Q. Do you have any idea who those young 22 foyer, and the pool. 23 women were? 23 Q. Okay. And would you just put an F where 24 A. No, ma'am. 24 the foyer staircase began? And KS where the 25 Q. Were any of those the young women that 25 kitchen staircase began. Page 280 Page 282 1 you have said came to give massages? 1 And you said that later another staircase 2 A. Yes, ma'am. 2 was added? 3 Q. And do you have any Idea whether or not 3 A. Yeah, we rehabilitated this, you know, 4 Mr. Dershowitz was also receiving massages? 4 but you asked me how many stairs there were, to 5 A. I don't know, Ma'am. 5 answer your question there were three. 6 Q. I want to ask you to take this piece of 6 Q. Three. So where was the third one? 7 paper, please, and a pencil -- 7 A. The pool, this leads to the pool. 8 MR. WILLITS: Can anybody hear me? 8 Through the outside master bedroom you could go 9 MS. EZELL: Yes. Can you hear me? 9 downstairs to the pool. 10 MR. WILLITS: I've heard nothing for 10 Q. Okay. A stairway then from the outside, 11 about a minute or so. 11 from outside the master bedroom? 12 MR. CRITTON: Can you hear me now? 12 A. Yes, ma'am. 13 MR. WILLITS: Yes. 13 Q. Down to the pool? 14 MS. EZELL: I'm asking questions, I'm 14 A. Yes, ma'am. 15 sorry. 15 Q. One of your duties was to answer the 16 MR. CRITTON: Why don't we go off the 16 door. Is that correct? 17 record for a second. 17 A. Yes, ma'am. 18 (Thereupon, a discussion was held off the 18 Q. Which door would you answer? 19 record.) 19 A. Mainly the kitchen. 20 THE VIDEOGRAPHER: We're back on the 20 Q. And why was that, why would people mainly 21 record 21 come to the kitchen? 22 BY MS. EZELL: 22 A. I'll say it was for practicable reasons 23 Q. Mr. Rodriguez, you indicated that there 23 because not to go to the main -- it was shorter 24 were several staircases in the house? 24 because the entrance was here, so this was the 25 A. Yes, ma'am. 25 driveway and we used to take Into the back door of 4 (Pages 279 to 282 Kress Court Re ortin Inc EFTA00310281  Page 283 Page 285 1 the kitchen and they will wait there. 1 A. You're welcome. 2 Q. All right. Would you just put BD where 2 Q. Could you see the pool from the staff 3 the back door of the kitchen was, please? 3 house? 4 Now, these young women that came to give 4 A. No, ma'am. 5 Mr. Epstein massages, would they usually come to 5 Q. How would you know, or would you know 6 the kitchen door? 6 when the young women were brought downstairs after 7 A. Yes, ma'am. 7 giving the massages? 8 MR. CRITTON: Form. 8 MR. CRITTON: Form. 9 BY MS. EZELL: 9 THE WITNESS: I will hear the commotion, 10 Q. Did any ever come to the front door? 10 some voices, but I was not told they were 11 A. Very rarely. 11 leaving. 12 Q. And you would let them in the kitchen? 12 BY MS. EZELL: 13 A. Yes, ma'am. 13 Q. And so did you have any duties that had 14 A h n how did you then turn them over 14 anything to do with their leaving? 15 to 7 15 A. Check the security and see if the gate 16 MR. CRITTON: Form. 16 was closed, that the cars were locked because the 17 THE WITNESS: I will call her. 17 garage were here. 18 BY MS. EZELL: 18 Q. Would you put a G where the garage was? 19 Q. How would you call her? 19 I believe you testified that you were 20 A. On her cell phone and she will know they 20 required to have on your person $2,000 everyday? 21 were waiting in the kitchen. 21 A. More or less, Ma'am. 22 Q. And would you bring them in the kitchen 22 Q. And if you open the door and a young 23 and then just leave? 23 there to give a massage you would call 24 A. Yes, ma'am. 24 and go back to the staff house? 25 Q. And where would you go? 25 . es, ma'am. Page 284 Page 286 1 A. To my -- to the staff house that was 1 Q. And then you believ would 2 here. 2 come In and lead the young woman upstairs. 3 Q. Good, I was going to ask you to show me 3 Correct? 4 where the staff house is. Just put SH. 4 MR. CRITTON: Form. 5 A. It was just maybe five feet, I used to 5 THE WITNESS: I'm sorry, can you repeat 6 stay here. 6 your question? 7 Q. Okay. So what you're saying, it's about 7 BY MS. EZELL: 8 five feet from the kitchen? 8 Q. I'll try to, yes. 9 A. More or less, yes. 9 When you would answer the door and there 10 Q. Was it connected to the house? 10 would be a young lady there to give a massage. 11 A. No, it's detached but it's very dose 11 A. Yes, ma'am. 12 proximity. 12 Q. I believe you testified you would let her 13 Q. Okay. So to get to the staff house would 13 in the kitchen. 14 you come out the kitchen door? 14 A. Yes, ma'am. 15 A. Yes, ma'am. And I came through my -- 15 Q. And you called a 16 there was two entrances, one through the laundry 16 A. Yes, ma'am. 17 here and one to the main entrance to the staff 17 Q. And you then left her in the kitchen 18 house. 18 alone? 19 Q. All right. And what was your usual 19 A. Yes. 20 pathway if you left the kitchen to enter the staff 20 Q. And went to the staff house? 21 house, how would you generally do it? 21 A. Yes, ma'am. 22 A. Normally I will came to the laundry, the 22 Q. And sometimes you heard the commotion 23 laundry was here and my office was next to the 23 when the young woman was leaving -- 24 laundry. 24 A. Yes, ma'am. 25 Q. Okay. Thank you. 25 Q. -- but you didn't necessarily see them 5 (Pages 283 to 286 Kress Court Reporting, Inc EFTA00310282  Page 287 Page 289 1 leave. Is that correct? 1 A. Yes. le south face of the house, 2 A. Exactly, yes, ma'am. 2 but this was . 3 Q. How did the money that you .3 Q. All rig . nd so did she usually work 4 were keeping t to pay those young 4 with her laptop on the dining room table? 5 women? ' 5 A. She will have all over the house but she 6 A. =would tell me who to pay and how 6 will sit down here to work on the desk. 7 much, that's the way we work. 7 Q. Do you know whether she kept any lists of 8 Q. And when would she tell you that? 8 names of girls to come and give massages? 9 A. She will call me by phone and say I'll 9 A. She did, Ma'am. 10 give so much to so on and so forth. 10 MR. CRITTON: Form. 11 Q. Okay. Was that at the condusion of the 11 BY MS. EZELL: 12 massage? 12 Q. And do you know in what form she kept 13 MR. CRITTON: Form. 13 those? 14 THE WITNESS: Yes, ma'am. 14 A. She had notes, you know, she always have 15 BY MS. EZELL: 15 papers, but I don't know. 16 Q. Okay. Then I'm a little confused because 16 Q. Do you recall seeing the papers with 17 I thought you said that you didn't see them when 17 telephone numbers on them? 18 they left from giving the massage. 18 A. A couple of times. 19 A. She will call me and she will say pay X, 19 Q. Do you know whether she also kept records 20 Y, or Z, and that's the way I knew how much and to 20 on the computer relating to the girls? 21 whom. But sometimes they would leave and I didn't 21 MR. CRITTON: Form. 22 pay those, I don't know who paid them. 22 THE WITNESS: Yes, ma'am. 23 Q. Okay. So if she calls you and told you 23 BY MS. EZELL: 24 to pay X, Y, and Z $200, would you then go back 24 Q. And how do you know that? 25 into the kitchen and give X, Y, and Z $200 each? 25 A. Everything was recorded in -- everything Page 288 Page 291 1 A. Sometimes in the kitchen, sometimes in 1 we did as employees we used to record and kept in 2 the driveway I will pay them in an envelope, you 2 the internal circuit we used to have among the 3 know. 3 employees. 4 Q. Okay. And she would tell you how much to 4 Q. And so would it be, if I understand you 5 pay them? 5 correctly then, was there some sort of a program 6 A. Yes, ma'am. 6 solil could access Information that 7 Q. Where was Ms. when you would call 7 Ms as putting into that program and she 8 her to tell her that there was someone at the 8 co information you put in? 9 kitchen door to give a massage? 9 A. Yes, ma'am. 10 A. She was inside the house so I call her on 10 Q. And did you also send each other e-mails 11 her cell and say, Alfredo, leave them in the 11 that way or did you use a different program for 12 kitchen, but I don't know where she was. 12 e-mail`., 13 Q. Okay. Did she have an office? 13 A. didn't send direct e-malls to me 14 A. No, ma'am. 14 but she will call me on her cell. But I was 15 Q. Did she have a computer In the house? 15 supposed to send through Citrix to other 16 A. Yes. 16 employees. 17 Q. Where was her computer? 17 Q. E-mail them through Citrix? 18 A. She had a laptop but she usually work in 18 A. Yes, ma'am. 19 the dining room. 19 Q. Okay. And who would those other 20 Q. And where was the dining room? 20 employees be, have been, I mean, while you were 21 A. All this area facing the garde 21 there? 22 north -- I'm sorry, facing south, a 22 A. Mrs. n New York, mostly 23 was at her desk here. 23 them Mind -- 24 Q. So did the dining room have large 24 Q. as -- 25 windows? 25 A. yes, the secretary, and somebody 6 (Pages 287 to 290) Kress Court Reporting, Inc. EFTA00310283  Page 291 Page 293 1 else, I don't recall. 1 ' A. I don't remember"Il .* 2 Q. Was there anyone else that you could 2 Q. Did you ever see sing that 3 e-mail? 3 small compact camera to ia e a pi re of the 4 A. We could e-mail anybody in the 4 girls? 5 organization. 5 A. Yes, ma'am. 6 Q. On that particular program? 6 MR. CRITTON: Form. 7 A. Yes, ma'am. 7 BY MS. EZELL: 8 Q. And so who else would be In that 8 Q. When you saw her doing that where were 9 organization? 9 they, the girls? 10 A. Other household managers from Parks or 10 A. The dining room, the library, the first 11 the Island, Manhattan. 11 floor of the house. 12 Q. Do you know whether Ms kept any 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the young women whit come to give 13 pictures of the girls? 14 massages on her laptop? 14 A. No, ma'am. 15 A. Yes, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 Q. You saw those pictures? 16 pictures of the girls? 17 A. Yes. 17 A. No, ma'am. 18 Q. Were the pictures uniform? And by that I 18 Q. Were you ever told by anyone that Mr. 19 mean, were they all taken, for instance, there at 19 Epstein sometimes took pictures of the girls? 20 the house so that they would all be fairly 20 MR. CRITTON: Form. 21 standard? 21 THE WITNESS: Yes, ma'am. 22 MR. CRITTON: Form. 22 BY MS. EZELL: 23 THE WITNESS: They will be all over, you 23 Q. And do you rtgalleo told you that? 24 know, sometimes out of the country and 24 A. I think it wasM. 25 sometimes in the house. 25 Q. Do you recall what she said about that? Page 292 Page 294 1 BY MS. EZELL: 1 A. He likes photography and he likes -- like 2 Q. Were these pictures that were taken by 2 a hobby. 3 someone for the purpose of keeping them in that 3 Q. Do you know which camera or what kind of 4 program? 4 camera he used to take those pictures? 5 A. I don't know. 5 A. No, ma'am. 6 MR. CRITTON: Form. 6 Q. And you said I think you never saw him 7 BY MS. EZELL: 7 taking them? 8 Q. Or opposed to, for instance, one of the 8 A. Yes. 9 nuunc3 ladies bringing a picture to give to 9 Q. So -- 10 10 MR. CRITTON: Yeah meaning correct? 11 E A I don't know. 11 THE WITNESS: Yes. 12 Q. You don't know where the pictures came 12 BY MS. EZELL: 13 from? 13 Q. Was it your understanding that he took 14 A. No, ma'am. 14 those pictures upstairs? 15 Q. Do you know was there anyone staying in 15 MR. CRITTON: Form. 16 the house who often took pictures of young women? 16 THE WITNESS: Yes, ma'am. 17 MR. CRITTON: Form. 17 BY MS. EZELL: 18 THE WITNESS: There was several cameras 18 Q. And when you had occasion to go upstairs 19 in the house and they were used often, but I 19 do you recall seeing camera equipment? 20 don't know who used them. 20 A. No, ma'am. 21 BY MS. EZELL: 21 Q. Were you ever told that he took pictures 22 Q. Okay. Do you remember what kind of 22 of the girls nude? 23 cameras they were? 23 A. No, ma'am. 24 A. The small compact camera. 24 Q. Were you ever told that he liked to have 25 Q. Any other kind? 25 pictures taken of the girls nude? 7 (Pages 291 to 294) EFTA00310284  Page 295 Page 297 1 MR. CRMON: Form. 1 BY MS. EZELL: 2 THE WITNESS: No, ma'am. 2 Q. And was that already installed when you 3 BY MS. EZELL: 3 came there? 4 Q. I believe you were asked before In the 4 A. Yes, ma'am. 5 deposition about the stairway leading from the 5 Q. Where is it you -- first of all, did they 6 kitchen upstairs and whether or not there were 6 tell you where the equipment was installed? 7 pictures on that stairway. 7 A. No. 8 A. Yes, there were pictures. 8 Q. Did you have any understanding of where 9 Q. Were those pictures some of them of nude 9 the equipment was installed? 10 young women? 10 A. No. 11 MR. CRITTON: Form. 11 Q. Do you know whether or not there was 12 THE WITNESS: Not on the stairway, they 12 surveillance photography equipment upstairs and 13 were the foyer in the second -- on the in 13 downstairs? 14 foyer and the foyer leading to the master 14 MR. CRITTON: Form. 15 bedroom. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 16 BY MS. EZELL: 17 Q. I see. Were those -- what size generally 17 Q. And how do you know that? 18 were those pictures? 18 A. I read it through the FBI report after 19 A. They were, you know, I'll say three by 19 the fact that I -- after I left the job. 20 five. 20 Q. Before reading through the FBI report did 21 Q. So very large -- 21 you have any knowledge of the fact that there was 22 A. Yes, ma'am. 22 surveillance equipment both upstairs and 23 Q. -- pictures? Were there lots of 23 downstairs? 24 photographs just around the house on top of 24 A. No, ma'am. 25 furniture in the various rooms? 25 Q. While you were there was there ever an Page 296 Page 298 1 A. Yes, ma'am. 1 occasion when someone came to do any maintenance 2 Q. And were any of those photographs of 2 or repair on the surveillance equipment? 3 young women in the nude? 3 A. Yes, ma'am. 4 A. Yes, ma'am. 4 MR. CRITTON: Object to the form of the 5 Q. Did you recognize any of those young 5 last question. 6 women? 6 MS. EZELL: Pardon? 7 A. Yes, a couple. 7 MR. CRITTON: Form of the last question. 8 Q. And who was it that you recognized? 8 BY MS. EZELL: 9 A. Miland some other girl from Brazil 9 Q. Did that happen more than one time? 10 that was house but I don't remember her 10 A. I believe so, yes, ma'am. 11 name. 11 Q. Do you have any recollection of who came 12 Q. Was this a girl that would come and stay 12 there, either the name of the company or the name 13 in the house or one of the girls that would come 13 of the person who would come to repair or do 14 and give massages? 14 maintenance on the video equipment? 15 A. They will stay at the house. 15 A. We used to have a young technician from 16 Q. Stay at the house. Do you recall a 16 Ohio who used to maintain all the computers and he 17 picture of the girl, of a young women nude in a 17 would be the only one dealing with those things. 18 hammock? 18 Q. So he maintained the computers and the 19 MR. CRITTON: Form. 19 video equipment. 20 THE WITNESS: No, I don't remember. 20 A. Yes. 21 BY MS. EZELL: 21 Q. Is that correct? 22 Q. Was there surveillance equipment 22 MR. CRITTON: Form. 23 installed in the house? 23 BY MS. EZELL: 24 A. Yes, ma'am. 24 Q. Do you have any recollection of what his 25 MR. CRITTON: Form. 25 name was? 8 (Pages 295 to 298 EFTA00310285  Page 299 Page 301 1 A. I don't remember, Ma'am. He came from 1 video, even phones. 2 New Albany, Ohio. 2 Q. Would he also repair the televisions if 3 Q. From New -- 3 they needed work? 4 A. New Albany, Ohio. 4 A. No. 5 Q. New Albany, Ohio. Did he have his own 5 Q. No. Did you have any kind of intercom 6 business? 6 system in the house? 7 A. No, he worked for Mr. Epstein. He will 7 A. Yes, ma'am. 8 maintain all the computers. 8 Q. And what kind of system was that? 9 Q. Was he there everyday? 9 A. It was standard office equipment, Lucid 10 A. No, ma'am. 10 Technologies maybe, but it was an intercom like we 11 Q. Do you know whether at that time Mr. 11 using right now. 12 Epstein had an office in Palm Beach? 12 MS. EZELL: Just let the record reflect 13 A. Not outside the house, no. 13 that the witness pointed to the telephone on 14 Q. Do you have any knowledge of whether or 14 the table that has a speaker phone. 15 not the video equipment was -- and I don't know 15 THE WITNESS: Yes, ma'am. 16 the technical term, forgive me, but was it the 16 BY MS. EZELL: 17 kind of equipment that would record for a certain 17 Q. And did you use that in your work? 18 amount of time and then record over that film? 18 A. Yes, ma'am. 19 A. I don't know. 19 Q. And what did you use it for? 20 MR. CRITTON: Form. 20 A. Mr. Epstein used to page me when he 21 BY MS. EZELL: 21 needed me. 22 Q. You don't know? 22 Q. Did you have one of those phones in the 23 A. No, ma'am. 23 kitchen? 24 MR. CRITTON: Just for clarification, I 24 A. Yes, ma'am. 25 may have misunderstood, but I thought he 25 Q. And was there one out in the staff house Page 300 Page 302 1 said he didn't even know the video equipment 1 as well? 2 existed until he read the FBI report. 2 A. Yes, ma'am. 3 MS. EZELL: He said he didn't know that 3 Q. Do you know where others were in the 4 it was upstairs and downstairs, I believe. 4 house? 5 MR. CRITTON: I thought he said he didn't 5 A. Probably have like 15 phones. We used to 6 know that it even existed. 6 have three in the staff house, one in the cabana, 7 MS. EZELL: I may be wrong. 7 two in the master bedroom, one in each room, 8 BY MS. EZELL: 8 kitchen, dining room, Mrs. Maxwell's office, the 9 Q. Did you know it existed before you read 9 garage. 10 the FBI report? 10 Q. Where was Mrs. Maxwell's office? 11 A. No, ma'am. 11 A. Under the stairs next to the kitchen. 12 Q. I'm sorry, then I was wrong. 12 Q. Can you give me some idea of what size 13 How did you know then that the young 13 space that was? 14 technician from Ohio maintained the computers and 14 A. It was probably -- we change the floor. 15 the video equipment? 15 Twelve by five, something like that 16 A. Because we used to request -- there were 16 Q. And was the computer equipment in that 17 always problems with the computers so he came to 17 space? 18 the house and he was the programmer. It was very 18 A. Yes, ma'am. 19 sophisticated. 19 Q. Do you know whether Ms. Maxwell kept the 20 MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came 21 move to strike the answer as nonresponsive. 21 to do massages? 22 BY MS. EZELL: 22 A. Yes, ma'am. 23 Q. How did you know then that he maintained 23 MR. CRITTON: Form. 24 the video equipment as well? 24 BY MS. EZELL: 25 A. Because he was In charge of computers, 25 Q. Do you know that because you saw the 9 (Pages 299 to 302) Reoortino, Inc. EFTA00310286  Page 303 Page 305 1 names and phone numbers? 1 computer? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 5 Q. And did she generally have phone numbers 6 girls on the computer? 6 for those girls? 7 A. Yes, she did. 7 A. Yes, ma'am. 8 Q. And you know that as well because you 8 Q. And were they generally pictures of the 9 happen to see them? 9 girls? 10 A. Yes, ma'am. 10 MR. CRITTON: Form. 11 MR. CRITTON: Form to the last two 11 THE WITNESS: No, ma'am. 12 questions. 12 BY MS. EZELL: 13 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 re they similar to the pictures that 14 girls who came to give massages? 15 Ms had on her computer? 15 MR. CRITTON: Form. 16 . CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 Q. Did the pictures that they kept there 19 A. Yes, ma'am. 20 look like pictures that were posed? 20 MR. CRITTON: Form. 21 A. They were more casual. 21 BY MS. EZELL: 22 Q. Did they look as though the person being 22 Q. Were there pictures on her computer of 23 photographed knew that they were being 23 the girls who came to give massages? 24