UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIV-MARRA/JOHNSQN JANE DOE NO. 2, -vs- Plaintiff, JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80993, 09-80591, 08-80380, 98-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80656, 09-80802, 09-81092 Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office MP ROSE COURT REPORTING AGENCY, INC. 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 Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181630

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1 APPEARANCES: ) AELSTE 8 18205 Biscayne Miami, Florida ROTI TEIN RO Fort Lauderda Ww 16 25 West Fl 3 RICHARD WILLITS, CHARD H. WILLITS, P.A. 10th Avenu rth, Florida ] WILLIAM J. BERGER, ENFELD*' 2 401 East Las Olas , Florida 15 KATHERINE W. EZELL, PODHURST ORSECK, P.A. 2 On behalf of the Plaintiffs: e North, 7 STUART MERMELSTEIN, ESQUIRE I I IN & H¢ WITZ, ESQUIRE Suite 33461 P.A. Boulevard, Suit 33160 yard, ESQUIRE T ADLER Boulev Suite 33301 ESQUIRE Suite BOO 1650 Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 REPORTING AGENCY, INC. 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181631

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1 On behalf of 2 ROBERT J. CRITTON North Flagler Drive, Palm Beach, BURMAN, 3 515 West Phone: PROS Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 the E COURT ) CRITTON, Defendant: ESQUIRE & LUTTIER Suite Florida REPORTING AGENCY, 33401 400 INC. Page 83 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181632

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PROCEEDINGS Deposition taken before Sandra W. Townsend, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. (Continued from Volume I.) VIDEOGRAPHER: We're going back on the record at 12:52. CROSS EXAMINATION BY MR. LANGINO: Q. Hello. My name is Adam Langino and I represent JM. I'll have fewer questions than the rest of everybody, since I'm going next in line. But one of the things I wanted to ask you -- MR. CRITTON: Before you get started, let me just put on my objection. Adam, your client is J§M., who alleges that she was at Mr. Epstein's house sometime, I think, on one occasion in the summer of '03. This witness is neither relevant, nor material, nor can it lead to the admissibility of any relevant information regarding my client. So I understand -- so you certainly can notice him, but I'll move to strike all of the questions and Fs PROSE COURT REPORTING AGENCY, INC. PC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181633

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answers in response to your questions. MR. LANGINO: Thank you. BY MR. LANGINO: Q. One thing I wasn't sure about was the date of your employment. When did you start with Mr. Epstein? A. I am not sure, sir, but I think I started full time on my salary, I was on the roll in 1991. 1991, — January 1, 1991. Q. In 1991, you started full time with Mr. Epstein? A. Yes, working for him alone. I left all my clients, I left -- dissolved my company. Q. And in what year did you start part time at his house? A. 1990. '90. Q. You mentioned earlier that some of the massage therapists you paid with checks? A. Yes. Q. And some of the massage therapists you paid with cash? A. Sorry. Can you repeat the question? Q. Sure. You mentioned earlier that you paid some of the massage therapists with checks and some with cash? A. PC PROSE COURT REPORTING AGENCY, INC. FP Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181634

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Page 86 Q. Were there any general differences between those massage therapists that you paid with checks and those that you paid with cash? A. No, sir. It was -- when I was there always was a hundred dollars an hour rate. That was for everybody. Q. Did you ever hear Jeffrey Epstein talk about his massages? A. No, sir. Q. At one point you said that you're not -- this might be summarizing your testimony -- that you may not be the best guesser of ages. Is that something that you may have said earlier today? MR. CRITTON: Form. THE WITNESS: Yeah. Yeah. I think I can be thirties, twenties. I don't know. BY MR. LANGINO: QO. Do you have any children? A. I have two. One is a doctor in psychology. And one is a financial manager and he starts his own company. Q. Are either of your children female? No. A Q. Do you have any grandchildren? A I have one granddaughter. PT PROSE COURT REPORTING AGENCY, INC. Fe Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181635

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Q. How old is she? A. She is five. Q. Do you have any relative that you had spent a significant amount of time with that would be a female teenager? MR. CRITTON: Form. THE WITNESS: No, except my daughter. BY MR. LANGINO: Q. Cousin? My daughter, no. > Q. Before when we first started speaking with you, you talked a little bit about your business. Are you still working? A. No. I disabled. Q. You owned that business; is that correct? A. Yeah. Yeah. It was my -- my -- it was me, only me. Q. You ntioned that one of your children is a doctor? A. My dayghter is a doctor in psychology. ~ Q. Are any of your children or any of your family members continuing the business that you started? A. No. They have their own business. Q. You mentioned a few times today that you were never told to check the identification of any of the PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181636

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massage therapists that came to give massages? A. That's correct. Q. How come you said that a couple of times MR. CRITTON: Form. THE WITNESS: You asked me. They asked me. I think I just answer questions. BY MR. LANGINO: Q. As you reflect back in your time working for Mr. Epstein, today do you believe you turned a blind eye to some of the ages of the women or females that worked for Jeffrey Epstein with massages? MR. CRITTON: Form. THE WITNESS: Can you repeat the question? BY MR. LANGINO: Q. Sure. As you sit here today and reflect back on your time working for Jeffrey Epstein, do you believe you turned a blind eye or ignored, purposely ignored the ages of the females that gave him massages? MR. CRITTON: Form. THE WITNESS: I don't know. I don't -- I cannot -- I'm not a judge. I don't know. I don't know. I don't think so. Sincerely, I don't think so. BY MR. LANGINO: fF PROSE COURT REPORTING AGENCY, INC. FP Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181637

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Page 89 QO. When you were working for Mr. Epstein, did you have any doubt that the girls who provided him massages were not of the proper age or not older than 18 years old? MR. CRITTON: Form. THE WITNESS: No. BY MR. LANGINO: Q. Did you keep up with Mr. Epstein's -- keep informed of Mr. Epstein's criminal case while it was in the paper? A. Only what was on tv. What it was on tv, that's how I found out. Q. How do you feel about Mr. Epstein today? A. I feel bad, sincerely I feel bad, because he was -- with me, with my family, with my wife, he was a very generous guy, extremely -- I don't know what the word is in English -- but he would press for perfection. I mean, and that was a very stressful job. But, otherwise, I have no problems with him at all. And I cave no propsems We en a ae feel bad about it, what's happened in his life. Q. Have you had any contact with Mr. Epstein after you ended working there? A. After I work -- after I end working with him? Yes, I did. When this case, when this criminal case PF PROSE COURT REPORTING AGENCY, INC. TT Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181638

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Page 90 started, I got home and I had a card, a business card from a police officer. I think it was Paul from the sha oh — Palm Beach Police Department. ——____ And -- and I got scared. And I was trying to find out what it's all about. Because it was an occasion with Mr. Epstein that we had a disagreement. We settled that. Everything was well and we went our friendly ways and never heard from him again. And I received this from the police department that we need to talk to you. And, so, I got scared. And I called the office in New York. I says, I would like to speak to Mr. Epstein. And he come on, and I said, I told him, I says, Jeffrey, what's going on? What's happening? I thought it was related to the problem that I had personally with him settled. And I says -- no, he says. And he says to me, no, John, it's nothing to do with that, has nothing to do with it. I've been -- I don't know if he told me I been sued or I been -- it's a problem with me, they're investigating something and I cannot talk to you. That was the end. And that's it. Q. Any other conversations with Mr. Epstein -- A. No. Q. -- since that conversation? Po PROSE COURT REPORTING AGENCY, INC. Ft Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cBG6e-4b9f-8d01-ba20bcae87de EFTA00181639

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Page 91 A. No. Q. At some points you were caught stealing from Mr. Epstein; is that true? A. We settled with him as a borrowing money from him. Okay? MR. BERGER: As what? THE WITNESS: Borrowing. MR. LANGINO: Borrowing. BY MR. LANGINO: When you took the money from Mr. Epstein, -- Yes, sir. -- did he give you permission to take that No. At any point did you take a firearm from Mr. Epstein? A. No. Q. At any point did you enter Mr. Epstein's property when you were not allowed to be there? A. Yes. Q. And was that incident where you took some money from him? A. Yes. Q. Can you explain to me how you and Mr. Epstein came to an agreement that the cops would not be called? Ri PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181640

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Page 92 He called me and he say, John, we need to I says, okay. Where? And -- and we met at a luncheonette in Palm Beach and we have a friendly conversation. He asked about my kids, about my family. Then -- is this related to Mr. Epstein's case? Q. It is. A. Because I prefer to keep this -- this -- I was not incriminated. I was not -- I went to the police department. I made my statement and there was no charges filed. I don't think I would like to continue with MR. CRITTON: Let me just put on the record as I think it's completely irrelevant, immaterial, it's not calculated to lead to the -- THE WITNESS: And it was after -- MR. CRITTON: Let me just finish putting my objection on. As I understand it, it occurred long before he ever got the card from the police. I think you're harassing him. I think you're trying to intimidate him and I think it's inappropriate. BY MR. LANGINO: fF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afcIca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181641

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Page 93 QO. How did you feel about Mr. Epstein being loyal to you as an employee for him by not getting you into further trouble with the police? MR. CRITTON: Form. THE WITNESS: I feel that it was part of a relationship over 13 years that I did a lot of a) extra work. And I was more or less says, hey, John, you did it for me, I do it for you. And that was it. And we end fends. We did not break it apart. BY MR. LANGINO: QO. As you sit here today, do you have a sense of personal loyalty to Mr. Epstein? A. No. No. Matter of fact, that job_has-left_me _ a lot of sequels, psychological problems. It was__ extremely damaging to my marriage. Right after I left — ——$ we broke up with my wife. I walk away. I left my house. I left my family. I end up with a woman that she need the money and that's why I went in there and got the money. And that's what I think you wanted to hear. And I want to end it there. I have no -- nothing -- I think my stay there, in reflecting the job, I was not paid well enough for what we did. And too late now. fF PROSE COURT REPORTING AGENCY, INC. PY Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181642

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Page 94 Q. The overall theme of my question is: The fact that Mr. Epstein chose not to get you in trouble with the police further, trouble with the police -- A. Uh-huh. Q. -- so many years ago, has today that caused you or pressed upon you to maybe soften your testimony or change your testimony at all? A. Absolutely not. QO. Have you ever spoken with any independent investigators regarding the actions, the criminal actions that occurred at Jeffrey Epstein's home? A. Yes. When did that occur? A. Right after I receive a card from the police department, when I call Jeffrey and I ask him, what's going on? He says, I cannot talk to you. Somebody will talk to you. wi And then I got a call from this guy that I \cannot recall his name now. Talked to me and we met at Carabbas. And we talked -- what? -- about 15 minutes. And he asked me questions just like you guys are asking me and I says exactly the same answers. And he says, well, there's an investigation against Jeffrey. You has nothing to do with it. You PF PROSE COURT REPORTING AGENCY, INC. fC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181643

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Page 95 have nothing to do, nothing to worry about it, but if you want to hire a lawyer to protect yourself. And I asked -- my question to him was, I_don't want to get incriminated into something that, you know, LL ee ee en re ee somebody trying to incriminate me for -- for my job. rr ree ae And he says, no, no, no. But if you want to get a lawyer, that's fine. And that's where I got Mr. Murrell and j came to us, to sign this, to -- that wa d it. Q. Who got Mr. Murrell for you? A. Who got it? Mr. Epstein. — Q. When you met with this investigator at Carabbas, -- A. Yes. -- did he record your conversation -- Q A. No. Q -- in any way? After this meeting at Carabbas, did you meet with any other investigators? A. No. QO. After -- during your inspection of the massage room after these massages had been completed with Mr. Epstein, -- A. Uh-huh. Q. -- do you remember seeing any -- anything that PY PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-c8G6e-4b9f-8d01-ba20bcaeBb7de EFTA00181644

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you would describe as blood? A. No, never. Q. Do you remember seeing anything that you would describe as a sexual fluid? A. No, never. Q. When you worked for Jeffrey Epstein, the woman that you were married to, what is her name or -- what is her name? A. The woman that I was married to? Q. I think -- the reason I'm asking is because earlier today when you first spoke, I thought I remembered you saying that you -- both you and your wife -- A. That's my -- Q. -- worked for Mr. Epstein? A. It's still my wife. It's still my wife. We didn't -- we got two ways away from a divorce and the lawyers were taking my money by pipeline. Q. And what is her name? A. And we decide not to divorce and we still together. Q. Sorry. I missed that. But what is her name? A. Maria Alessi. Q. Let me just look through my notes to see if I have any other questions. Po PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181645

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Okay. Thank you very much. Welcome. CROSS EXAMINATION BY MR. MERMELSTEIN: Q. Good afternoon, Mr. Alessi. A. Yes, sir. Q. My name is Stuart Mermelstein. I represent a group of the Plaintiffs in these cases and I have some questions for you as well. Your wife, Maria, does she live at the same address as you now? A. Yes, she does. Q. Now, when you began working full time for Mr. Epstein, I believe you said that was around 1991; is that correct? Yes. Was your wife, was she hired at the same time No. She was hired three years after. And how did that come about that your wife was A. My wife was hired because we had a housekeeper that she was doing the cleaning and she left. Then we had another housekeeper, Polish girl, and she left. fF PROSE COURT REPORTING AGENCY, INC. FC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181646

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Page 98 | And then by that time my kids went to college | and my wife was at home. And I suggest my wife to come | to work with me, to help me. Q. So you recommended to Mr. Epstein that he hire your wife? A. Yes. Q. And he did? A. Yes, he did. Q. And what were her job duties there? A. Her only job duties were shopping, basically the shopping, getting movie tickets, show tickets, buy books, bring the food to Mrs. Epstein's -- Mr. Epstein's mother, sometimes drive Mrs. Epstein to the doctors. She was not involved -- and sometimes she did some cleaning for me. Q. Did she live with you in the upstairs apartment? A. Most of the nights we had an apartment right across the bridge on Flagler that it was my -- my property. And we had an apartment there. So she went home. She didn't like to stay there. But I had to stay there because my job starts Q. And did Maria leave her employment the same time as you? PC PROSE COURT REPORTING AGENCY, INC. fC Electronically signed by Sandra Townsend 7 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181647

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Page 99 A. Yes, we did at the same time. QO. You testified that you would come into the bedroom and clean up after massages; is that correct? A. That's correct. Q. Did you -- were there occasions where you had your wife help you with that? A. No. No. QO. Were there -- did she have occasion to go into the master bedroom? A. It was occasions before that she will help to set up the tables once in a while, set up the oils and the tables. But I will do the clean up after. Q. Is there a reason for that? A. I was more involved into the final appearance of the house. And it was my responsibility to make sure that every room was perfect after they left and before they went to bed. Q. Was there anyone else who assigned your wife work other than you? A. No. Ms. Maxwell, sometimes she would tell my wife, go buy some stuff, go get this and go get that. She was mostly -- my wife was mostly out of the house. She was -- this house was Mr. Epstein would says, go get me this book, go get me this magazine, go get me tickets, movie tickets for this show and this show and PC PROSE COURT REPORTING AGENCY, INC. Fs Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcaeB7de EFTA00181648

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Page 100 this show. And she would have to travel -- and I was on the phone with my wife constantly, buy this, get this, get this -- and the food, and the food because it was a five-star hotel. Q. Did Ms. Maxwell or Mr. Epstein ever instruct your wife to do housecleaning tasks? A. No. I was blamed for everything. You were blamed for everything? Q A. I was blamed for the good and the bad. Q Did you -- during the time your wife was there, did you also have a hired housekeeper? A. We have a crew of housecleaners. We have a crew of people that would come to the house and do a serial -- I mean, deep cleaning, you know, to the house. Q. Was that every day? A. Once a week -- no, it was twice a week. It was Tuesday and Fridays. It depends on Mr. Epstein's schedule because he didn't -- he didn't want nobody at the house while he was at the_house. So we have to rearrange days for the PO oe ee” ieee = clean-up crew to come in. And I usually did that. As soon as they left I bring the cleaning crew, get the house ready and -- and get set for them for the next trip. Q. Did you have a housekeeper who did PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181649

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Page 101 housekeeping tasks on an everyday basis while you were employed there? A. No. Before my wife went in? No. After your wife. A. No. No. Not a full-time housekeeper. Q. But you said your wife was hired after the housekeeper left? A. Yes. Q. But -- so the person who left before your wife came, was she doing housekeeping chores? A. Yes, she was doing the housekeeping chores. Q. Well, who did it then after your wife became employed there, because she wasn't doing the housekeeping? A. I was. I was doing it and then we hire people for to help us. QO. So you were the main person doing the housecleaning? A. Yeah. Q. And during -- between that time that your wife started and when you left the employment, was there a separate housekeeper employed during that time? A. No. Full time? No. Full-time housekeeper? PF PROSE COURT REPORTING AGENCY, INC. Fs Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181650

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Page 102 No. Q. What about a part-time housekeeper? A. No. Like I told you, daily basis we call this company. And then they will come in with four or five girls and clean the whole house. Q. This is the crew you were talking about? A. The crew. Q. But the crew didn't come when Mr. Epstein was there? A. Right. Q. So on an everyday basis when Mr. Epstein was there, you were the only person who was cleaning? A. Me -- yeah, or my wife will help. At your instruction? Q. A. That's right. Q. But you don't ever remember her cleaning up after massages? A. No. No. Q. Is it possible that you instructed her to clean up? A. It's possible, but -- MR. CRITTON: Form. Asking him to speculate. BY MR. MERMELSTEIN: QO. You can answer. A. It's possible. PY PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181651

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Page 103 QO. When girls would come to give a massage, where would they come in the house? Would they come to the front door? Mostly came to the back kitchen door. Uh-huh. A Q. The back kitchen door? A Q Okay. And is there a bell there? Would they knock or how would they -- There's a door bell. A door bell? They would ring the door bell? Uh-huh. And who generally would answer the door? Me or my wife. So you would let them in? Uh-huh. MR. CRITTON: Stuart, can I just ask you? You use the term, girls. I assume you just mean, that means female woman. It can mean anything? It has no age bracket to it? MR. MERMELSTEIN: That's correct. I'm not referring specifically to ages right now. THE WITNESS: No. BY MR. MERMELSTEIN: Q. So as I understand it, the girl would come to the kitchen entrance, which is the service entrance, Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181652

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Page 104 correct? A. Uh-huh. QO. You have to say yes or no. A. Yes, sir. Q. If you answer uh-huh, that's not clear, so you have to answer yes or no. A. Okay. And you would typically open the door? Yes, sir. And what would happen then? Then I will keep her in the kitchen and go to Mr. Epstein and find out where they want to have the massage, or if it was for him or for Ms. Maxwell. And I immediately, if_they were repeat girls-that are -- they will know exactly where to go. And I will go up with them, set the tables, and they will wait for him or her to go in the room and they sit there until they come up. QO. So did you generally already know that they were coming at the time that they knocked on the door? A. Yes, uh-huh. Q. So you had an appointment schedule? A. Yeah. Because most of the times I was doing the calling, you know. I called J., come in at 3:00 this afternoon. And she will told me, no, I cannot, get somebody else. And I knew it the time they were coming. Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-ch6e-4b9f-8d01-ba20bcae87de EFTA00181653

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Page 105 So I was expecting them most of the time. Q. So you would expect them, they would come in and then you would escort them upstairs? A. Uh-huh. So -- I'm sorry, sir. Yes? Yes. Q. But first you would find Mr. Epstein and check to see if he's ready or find Ms. Maxwell to check to see if she's ready? A. Yes. Q. And which staircase would you -- would you take them up? A. Either way. Q. You would take them either the main staircase or the servant staircase? A. Yes. Q. Why would you take the main staircase, since you're already in the kitchen? A. That's what I says, either way. We can go through the main staircase or we go to the kitchen staircase. So we use both. QO. Okay. Well, I'm talking specifically to escort a girl upstairs. PF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB86e-4b9f-8d01-ba20bcae87de EFTA00181654

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Page 106 A. I escort the girls up there either way, both ways. 7 Q. And, so, when you walked to the upstairs bedroom, let's take the example of when Mr. Epstein is getting a massage? A. Yes. Q. Mr. Epstein wouldn't be up there yet; is that correct? A. That's correct. He would be downstairs somewhere? Q A. Uh-huh. Q Would there be a place -- MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. -- where he would normally be while, you know, he's waiting for the massage to be set up and ready? A. Yes. Where is that? Where would he be? Either at his desk or the pool house. And those were on the first floor? Yes. Q. And, so, when you arrived at the top of the stairs with the girl for the massage, what would you do then? A. Go back to my duties. Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181655

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Page 107 Q. You would just leave? Would the massage table already be set up? A. He knew already that the girls -- the girl went upstairs and it was up to him to come up. Q. Did you have conversations with any of these girls? A. Sometimes. What kind of things would you talk about? A. Regular things. Nothing that I can remember. Nothing. Just... Q. Did any of them ever tell you their ages? A. No, sir. Q. Did any of them ever assure you that they were MR. CRITTON: Form. BY MR. MERMELSTEIN: Or over? No, sir. No one ever mentioned anything about age? No, sir. Q. How did the girls appear to you? Did they appear to be very young? MR. CRITTON: Form. THE WITNESS: Again, the same question you ask Everybody ask me the same thing. They could Po PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181656

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Page 108 have been 16 or 20. Most of them were, I would sews oscn aor says, over 20. And some woman, it was over 60. And one time she came to the door. The husband was waiting outside. And Ms. Maxwell saw this woman, that somebody recommend her. And Maxwell says to me, John, you have to find an excuse. We don't So I had to pay this woman and find an excuse that they going to have to go. And she -- they never had a massage with her. _ But there was -- most of them were womans. They were not girls. BY MR. MERMELSTEIN: QO. So the woman who was over 60 was sent away; she was rejected, correct? MR. CRITTON: Form. THE WITNESS: It was -- I was told to send her away. BY MR. MERMELSTEIN: Q. And it was your understanding when you were told to send her away, it was because of her age, correct? MR. CRITTON: Form. THE WITNESS: I don't know. I don't know. I was told to send her away. Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181657

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Page 109 BY MR. MERMELSTEIN: Q. What was your understanding as to why they were sending her away? MR. CRITTON: Form. Asked and answered nine times now. MR. MERMELSTEIN: He hasn't -- he hasn't answered my question yet. MR. CRITTON: He has. MR. MERMELSTEIN: Go ahead. THE WITNESS: Why? BY MR. MERMELSTEIN: Q. Please answer the question. A. Can you repeat the question? Q. What was your understanding as to why they sent her away? MR. CRITTON: Form. THE WITNESS: My understanding was either they were busy or they didn't want her. BY MR. MERMELSTEIN: Q. What was your understanding as to why they didn't want her? MR. CRITTON: Form. Harassing. THE WITNESS: I don't know. I didn't -- I didn't make too much of it. BY MR. MERMELSTEIN: PF PROSE COURT REPORTING AGENCY, INC. FY Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181658

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Page 110 Q. But every other woman or female who came over to give a massage was much, much younger, correct? A. Yes. Q. So this 60 year old woman was a significant exception, correct? MR. CRITTON: Form. Argumentative. BY MR. MERMELSTEIN: Q. You can answer. A. I don't know how to answer that question. You | ask me to -- | Q. Let me ask you this. MR. CRITTON: Why don't you let him answer the question before you interrupt him. BY MR. MERMELSTEIN: Q. All right. Go ahead. Please answer. It didn't look like you were -- A. I don't know how to answer that question, you asking me what is your opinion of that. And I told you, my opinion of that, either they saw the girl -- I don't think Mr. Epstein ever saw the woman. But Ms. Maxwell saw the woman in the kitchen. And she told me, John, pay her and send her away. Q. Okay. A. That was it. PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181659

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So Ms. Maxwell looked at the woman? Right. Did she have a conversation with her? No. Q. She just looked at her and then said to you to send her away, correct? A. Yeah. Pay her and send her away. Q. Do you recall seeing women who came to give massages who were in their 50s? A. Yes. There were women in the 50s? Yes. How often did that happen? Not too often, but it was -- it was woman that they were in the 50s. I says, again, could have been 49, 45. I don't know. I don't know the ages, but it older woman. QO. How many middle-age women do you recall coming over to give massages? MR. CRITTON: Form. THE WITNESS: I don't remember how many, but I would says<D.D. ) D.D. was, I would says, in the 40s. And she came very, very often. And I understand she was a Massage specialist and a yoga instructor, too, at PF PROSE COURT REPORTING AGENCY, INC. PC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181660

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Page 112 the same time. So that was one of -- and there was another woman that she was supposed to be a teacher at the school of massage therapy that I can't remember her name. But that's it. I mean... BY MR. MERMELSTEIN: Q. So those two you remember who were older? Two. And it was a couple guys that were older that -- some guys that were older, too, guys. Q. Did Mr. Epstein ever have massages done by ~ men? A. ass Q. And did Mr. Epstein ever have massages done by these older women? A. Yes. QO. When you escorted the female in this case for the massage to the upstairs bedroom -- correct? -- you would then leave? Yes. You would then walk back downstairs? Yes. Correct? And would you then -- would you -- you had already told Mr. Epstein that she's there, correct? A. That's correct. fF PROSE COURT REPORTING AGENCY, INC. fC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-cBGe-4b9f-8d01-ba20bcae87de EFTA00181661

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Page 113 Q. And at some point later then Mr. Epstein would come upstairs, correct? A. That's correct. And where would you go? Q A. To my duties, to the kitchen or to my office. Q And I think you testified earlier that the doors of the bedroom would be closed during this massage? A. He would close the door. Q. So Mr. Epstein, when he would arrive upstairs, would close the door? A. Yes, sir. Q. And about how long would the massage last generally? A. Usually an hour. Q. And what would happen at the end? A. They would come down. Most of the repeat girls, they would bring the towels themselves and dump it by the kitchen by the laundry room we had there, in order to help us. Other girls, they just left it up there and they would come down. Either Mr. Epstein will pay or I will pay Did they -- Or Ms. Maxwell will pay them. Fs PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB86e-4b9-8d01-ba20bcaes7de EFTA00181662

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Page 114 Q. Did Mr. Epstein walk down with the girls or did he stay upstairs? A. Sometimes, sometimes no. Sometimes he took a nap or he took a shower. I don't know what they did in the room. I don't know. I don't know. Sometimes he went down right away. Sometimes he stay up there. Q. So when they came down, they would go to the kitchen; is that correct? A. Yeah, most of it. Q. And were you there waiting for them or did you have -- A. My office was right next to the kitchen, so I was there -- and the kitchen was the focal point of the house basically. So they have to go to the kitchen either to get pay or to go to their cars. Q. Did you converse with any of the girls when they came down after the massage? A. Very little. Very little. Q. Did you ever observe a girl who appeared upset, surprised, shocked, anything of that nature when they came down? A. Never. Never. And sometimes you would pay them, correct? Q A. That's correct. Q How much would you -- PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181663

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Page 115 A. _A hundred dol Q. A hundred dollars a massage? Were there ever any exceptions? A. That's the -- I_never pay any more than a hundred dollars per massage. _ ——). were there times when two girls came? A. Two girls came at the same time? Q. Correct. A. Yeah. There were times when two girls come in at the same time and one will go to one room, the other will go to the other room. Or one -- I would set up two tables in his room or I will ask him, where you want to set the massages? He will told me, set in the blue room and set them in my room. Or set them in Ghislaine's room and the red room, depends on who people were there. But there were times where two of the girls at the same time, yes. Q. Was there ever occasions where there was a girl who waited downstairs while one -- while the other girl went upstairs? A. No. Q. That never happened? A. I cannot remember. Q. Was there ever an occasion where you paid a girl who waited and didn't actually give a massage? Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b$f-8d01-ba20bcae87de EFTA00181664

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No. That never happened? Never happened. Q. You mentioned that Mr. Epstein put you in contact with Mr. Murrell; is that correct? MR. CRITTON: Form. THE WITNESS: Not Mr. Epstein. BY MR. MERMELSTEIN: Q. Huh? A. It wasn't Mr. Epstein. Q. Mr. Epstein's investigator put you in contact with Mr. Murrell? A. That's correct. He gave me his name. Q. And did you pay Mr. Murrell out of your own pocket? A. No, I didn't pay nothing. Q. Who is -- what was your understanding as to who was paying for Mr. Murrell? A. I don't know. I don't know who was paying for You never asked Mr. Murrell who was paying his A. No, he never send me a bill. Q. Did you think that Mr. Murrell was doing it for free? PF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181665

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Page 117 A. I don't know. QO. You don't know. As far as you know, Mr. Murrell could have been providing you legal services for free? A. No, I don't think it was provided me for free. I don't think he ever -- that question ever come out of Mr. Murrell. I was in Mr. Murrell's office for about ten minutes. And he says, well, I meet you tomorrow there -- and that's it -- in order to protect you so they don't incriminate you in any way. We left it at that. He never send me a bill. He never send me -- I never talk to Mr. Murrell again, never saw him again. Q. And you never had any kind of understanding with him as to how -- A. No. Q. -- how his bill was going to be paid? A. No. Q. Did you sign any kind of what we call, a retainer agreement, anything where you hired him? A. No. MR. CRITTON: Just so you know, you have an attorney -- nobody's going to tell you this apparently. You have an attorney/client privilege. Any Po PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-Bd01-ba20bcae87de EFTA00181666

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Page 118 conversation that you had with Mr. Murrell, you and your wife, is completely protected, as long as you want to assert that privilege. You can either assert it or not assert it. That's your right. But nobody's apparently going to tell you that, at least Mr. Mermelstein is not going to tell you that. MR. MERMELSTEIN: Well, I was trying to avoid -- MR. CRITTON: Well, you're asking questions of what he said. MR. MERMELSTEIN: I'm not asking them what they said. MR. CRITTON: Same thing. MR. MERMELSTEIN: I'm asking him how he got paid. MR. CRITTON: No, you were -- read back your questions where you were. Anyhow, that's a right you have, so... So much for the law. MR. MERMELSTEIN: I was not asking him what was said during any conversation. I asked him if he signed a retainer. That's a fair question. BY MR. MERMELSTEIN: Q. Do you remember a girl who came to give FY PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181667

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Page 119 massages there by the name of | i Does that name sound familiar at all? No. Do you remember an J? No. Q. What about a §.? Do you remember anyone by the name of i. A. No. Q. Was it frequent that girls would come just once and not appear again? A. Frequently. Q. These girls that would come, would they come with their own equipment or supplies? A. No. Some girls, they come in with a table, the new girls they come in wi ble. And I would told them, no, you don't need the table ey will leave it in the kit se we have tables in every room in the house. QO. Some of the girls, the first time they came they didn't have anything, right? A. They come with that table, one of the tables they hang it in the shoulders, portable tables. But we didn't have portable tables in the room. They were all custom-made tables. Q. Did some girls come without -- for the first Po PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181668

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Page 120 time without any supplies at all, whether equipment or lotions or anything of that nature? A. Probably. QO. Did you have a question in your mind as to whether they were professional at this business? A. No. At massaging? Why not? Q A. No. Q A It was not my job. MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. You just didn't think about it? MR. CRITTON: Form. THE WITNESS: If I was told that a girl is coming, my job was to open the door, let her in and let Mr. Epstein decide where he wants his massage. And that was the end of it. BY MR. MERMELSTEIN: Q. Are you aware that sexual conduct between an adult male and an underage female is criminal; it's against the law? MR. CRITTON: Form. THE WITNESS: Of course I do. —_—_— ———. BY MR. MERMELSTEIN: PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181669

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Page 121 Q. Did you have any concerns while you were working there that criminal acts were occurring with the girls who were coming to the door? MR. CRITTON: Form. THE WITNESS: I had no idea what was going on between them. BY MR. MERMELSTEIN: QO. Let me just give you some other names. Tell me if you recognize any of these names. i. (Nods head.) Name does not ring a bell? (Nods head.) MR. CRITTON: You have to answer out loud. BY MR. MERMELSTEIN: Q You need to say yes or no. A No. Qo. EEE? A Can you repeat that? Q i would be the first name. | would be the second name? A. No. .: Q A. No. Q mn. Fs PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181670

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No. Hi.’ No. None of those girls! -- None of those girls ring a bell at all? -- name familiar to me. Either they came one time, one day and they didn't even told me their names or -- or he paid for it that I don't have -- but none of those names sound familiar to me. Q. You testified that there were -- about the sex toys that you would pick up after -- after there were massages, correct? MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. The vibrators, correct? MR. CRITTON: Form. BY MR. MERMELSTEIN: Q. You can answer. A. Yes. QO. And you mentioned there was a basket with these vibrators or toys in them, correct? Yes. Where was the basket kept? In Ms. Maxwell's closet. And that was in the master bedroom? Fe PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181671

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MR. CRITTON: Form. BY MR. MERMELSTEIN: Or off the master bathroom? Huh? Q A. Her bathroom. Q A Her bathroom. Q. And the closet was -- the entrance to the closet was in her bathroom? A. That's correct. Q. And it was a portable basket, she could move it around, correct? A. Uh-huh. Q. You have to say yes or no. A. Yes, sir. Q. And -- and that's where the, I think you used the word dildo, correct? That's where they were located? A. Yes, sir. Q. Was there occasions where you would -- the dildo, one or more dildos would be out and you would clean them up after a massage that only Mr. Epstein had, not Ms. Maxwell? A. It was -- I will says that it was about three or four occasions that I had to take this dildos and put it back where they supposed to be. And I took it with FY PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181672

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Page 124 gloves and towels and stick it in the sink and throw it in there. Sometimes Ms. Maxwell will have a massage. And sometimes I find it after she's supposed to have a massage, those things. And also when Mr. Epstein had the massage. So I don't know who use it on who. Because sometimes they all disappear up there, Mr. Epstein, Ms. Maxwell and whoever was up there. Q. So as I understand it, you couldn't isolate a particular instant where -- A. I cannot. Q. -- Ms. Maxwell wasn't there, only Mr. Epstein had gotten a massage and then you found the sex toys? A. I cannot isolate that. Q. But it's possible that either Mr. Epstein used Maxwell used it; is that correct? MR. CRITTON: Form. Form. | THE WITNESS: I have no idea to know. MR. MERMELSTEIN: All right. I have nothing further. MR. BERGER: How about if we take a break? Would you like a break for a couple minutes? THE WITNESS: No, that's fine. MR. BERGER: Mr. Willits, would it be possible if I could sit there, because I've got a couple Po PROSE COURT REPORTING AGENCY, INC. Fe Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181673

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Exhibits I'm going to show him? MR. WILLITS: Sure. MR. BERGER: Thanks. CROSS EXAMINATION BY MR. BERGER: Q. Okay. Good afternoon, sir. A. Afternoon, sir. Q. My name is William J. Berger and I represent three of the Plaintiffs in this case. Did you ever hear of the name E.. a young woman named §j.? No, sir. How about a young woman named | g No, sir. Q. Okay. You know, you've referred several times to a falling out or a disagreement that you had with Mr. Epstein? A. Yes. Q. Was that in -- was that the year that you left his employment? | A. Right after -- right after I left. QO. So you had a falling out with him after you left his employment? A. Yes. Well, why did you leave his employment? Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-Bd01-ba20bcae87de EFTA00181674

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Why? Yeah. A. Because I was sick. I was extremely sick. I was bleeding, internally bleeding, and I was bleeding from my butt and I have fistulas in my colon. And I was sick of the job and we had enough. We had good pay, but we had enough of the job, especially because—of— Q. Now, you said you had good pay, but we had enough. What was your pay in 2002? A. 2002, right before I left? I think it was 50, either 55, something like that. And my wife was 30 or 35. I could be wrong. Q. So you think that you were paid $55,000 in Uh-huh. Is that correct? That's correct. And you believe your wife was paid how much? Thirty, $30,000. $30,000 in 2002? Uh-huh. Is that correct? Yes, sir. Oo Fr Oo Fr OOCUmUPPrmlUOUMPUCOULUCUMPP How about 2001, what was your salary and your PY PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181675

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Page 127 Same thing. Okay. And in 2000? A. I was at the same. It never -- we never got raises. We never got -- Q. I think you said at the very beginning -- A. Yes. Q. -- of the deposition that you were paid 45,000 you were first hired full time? Yeah. In 2002, you were earning 55,000? Uh-huh. So you did get some raise? A. Yeah. In the matter of 11 years. Yeah, but we didn't get a raise every six months or every year in any specific date. And the raises were set by the company. Automatically they would come from New York. It was not a negotiate point between me and Mr. Epstein. Q. And then you said earlier with me, you said we had enough, you and your wife. You said, we had enough; is that correct? A. That's correct. QO. What do you mean by that? A. It was extremely stressful job. It was a lot of pressure on us -- on me, on me -- I have to Po PROSE COURT REPORTING AGENCY, INC. fs Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181676

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Page 128 correct -- on me. Everything was blamed on me. If a chef cook a bad meal, it was my fault. And if the table was not proper set royalty style, it was my fault. And the hours were terrible, never have a holiday, Saturdays and Sundays. We were working between 60 and 70 hours a week. And my health was, I think, the most important thing. And also the relation with my wife, it was a big factor in us leaving the company. QO. Now, you said that you were blamed for things? A. Yes, sir. Q. Who would blame you? Who is it that would say that you were blamed? A. I don't know who did the blaming, but I will get my ass chewed out by Ms. Maxwell -- Q. She was the one? Most of the times, yes. Who else did that? Sometimes I had disagreements with him. Mr. Epstein. About what? A Q A Q. "Him," being, who? A Q A Simple things. For me, it's stupid things, nothing -- if this paper -- if this pencil was not put in right there, they will complain. Q. Okay. And is it correct that you left the FP PROSE COURT REPORTING AGENCY, INC. Fs Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-cB6e-4b9f-8d01-ba20bcaes7de EFTA00181677

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Page employment of Mr. Epstein in December of 2002? Does that sound correct? A. That's correct. And the -- now, were you arrested in 2003? I was never arrested. Yes. Q A Q. You did speak to the police? A Q And you did have your statement taken at the State Attorney's Office? A. Yes. Q. But you -- but that was by an Assistant State Attorney, correct? A. Yes. The questioning? (Nods head.) Is that correct? That's correct. You spoke separately with police officers though, correct? MR. CRITTON: Form. BY MR. BERGER: Q. In other words, the date of that statement is in October of 2003; is that correct? A. Yes. And by "that statement," I mean, the Po PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181678

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transcript that I gave you earlier? A. At what date, sir? MR. MERMELSTEIN: 2005. MR. BERGER: I'm sorry. You're correct. Thank you. Sorry. | THE WITNESS: 2005. MR. BERGER: In fact, let's -- Ms. Reporter, would you mark the transcript if anybody needs it? | MR. CRITTON: It's Exhibit 2 now? | MR. BERGER: Is that how you're doing it, just consecutively? MR. CRITTON: Yeah, let's do it; otherwise, it's going to be an awful mess, have five different Exhibit number 1s by everybody. (Exhibit number 2 was marked for identification purposes.) BY MR. BERGER: Q. You see Exhibit 2? It's a transcript; is that correct? A. That's correct. Q. Is that the transcript of the sworn statement that you gave to the Assistant State Attorney in 2005? A. Yes, sir. Q. And during the lunch break, did you have an opportunity to read it? Po PROSE COURT REPORTING AGENCY, INC. PY Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181679

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Page 131 A. Yes, sir. QO. And do you remember that you were placed under oath when you gave that statement? A. Yes, sir. Q. And is everything that you say in here truthful and correct? A. As far as I know, yes, sir. Q. Okay. Now, in connection with the incident in October of 2003 involving Mr. Epstein's house and your entering his house, that incident? A. It was in Geraber 0007 Q. When do you remember that it was? A. I can't remember. Q. Okay. All right. You spoke with police officers in connection with that though, correct? A. I went to the Palm Beach Police Department. Q. Why did you go to the -- A. I speak to one officer. Q. And why did you go there? A. Because Mr. -- when I spoke to Mr. Epstein and we settle the dispute, Mr. Epstein says, you just need to go to the police department and make a statement. MR. WILLITS: Could I have Exhibit number 2, please? Thank you, FP PROSE COURT REPORTING AGENCY, INC. PT Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181680

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Page 132 BY MR. BERGER: QO. Let me see if I understand this correctly. I think you testified earlier that you found a card or you were given a card from a police officer; is that correct? A. That's correct. Q. And as a result of that, you called Mr. Epstein, correct? A. That's correct. Q. Before you got that card, did you have any idea that the police were involved in your life? A. No. MR. CRITTON: Form. BY MR. BERGER: Q. And you called Mr. Epstein after you got that card, correct? A. Yes. Q. Now, how did you get it? Was it mailed to you? A. No. It was putted in my door. I was not home. And they went to my house and they left it in the door. Q. And did it have a note on it, please call? A. Yes. Q. Or was it just a card? fF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181681

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Page 133 A. It was a -- it was a Palm Beach Police Department, please call. QO. Okay. And you didn't call though; you called Mr. Epstein first, right? A. Yeah. Because I was scared. Q. Why were you scared? A. Because I thought it was of the incident that happens previously. Q. And what was that incident? You know that incident. A Q. I'd like to hear you describe it for me. A That incident is, I went to the house and I got some money. Q. What time of day did you go to the house? Night. Was anybody home? No. Where did you get the money? Out of his bag. Out of his? Bag. Bag. Briefcase? Bag? Briefcase. Briefcase? ro Fr ODO FO FP OD FP Oo PF Yes. PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cBGe-4b9f-8d01-ba20bcae87de EFTA00181682

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Page Q. How did you -- did you know that there was | money in the briefcase? | A. Yes. How did you know that? Because I replenish that case many times QO. Now, how many months after you left Mr. Epstein's employment did this occur? A. I don't have -- I would says, three to four months. Q. I would just ask a favor of you. The court reporter needs to see your face so she can understand what you're saying. She's looking -- you put your hand in front of your mouth. That's all. Now, when you worked for Mr. Epstein, did you learn that he kept money in that briefcase? A. Yes. Q. And, so, when you went to his house on that occasion, did you just assume that there would be money in the briefcase? A. Yes. QO. And -- and did you take money out of that briefcase? A. Yes. Q. Now, is that the only time that you took money | FY PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181683

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No. -- of his briefcase? It was twice. When was the other time? Couple weeks before. What time of day was that? At night. And how much did you take out the first time? It was a total of $6,300. That's for both times? Yeah. Can you break them down? A. Q. A. Q. A. Q. A. Q. A. QO. A. Q. A. I think one time was $1,500. Another time was the rest. Q. Now, you left in December of 2002 and then there were these two incidents that you just described? A. Uh-huh. Q. Did you have any contact with Mr. Epstein in between leaving his employment and the first of these two instances? A. None. Q. And as far as you knew, did anybody see you take the money on either occasion? A. None. PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181684

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Page 136 Q. And, so, when you saw the card from the police, you assumed it had to do with these two instances? A. Yes, sir. Q. And there was no other reason why you thought it had to do with Mr. Epstein? A. No, sir. Q. And when you called him, did you discuss these two incidents with him? A. When I call Mr. -- You said you got the card -- No. -- and then you called him? No, we did not discuss that money or nothing involved. I ask him, what's going on, Jeffrey? What's happening? I got this and I thought that this was all over. No, he says, John, it has nothing to do with that money. QO. Did you ever read the incident report by the police, the Palm Beach Police Department? Did you ever read it? A. No. MR. CRITTON: Regarding what? Ft PROSE COURT REPORTING AGENCY, INC. FP Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01 -ba20bcae87de EFTA00181685

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Page 137 MR. BERGER: Regarding these incidents. BY MR. BERGER: QO. You never read it? No. me hand you this. MR. CRITTON: Is there an extra copy? MR. BERGER: Yeah. BY MR. BERGER: Q. What I'm showing you, have you ever seen this before? A. No. MR. BERGER: Let's have this marked as Exhibit 3, please. MR. CRITTON: Can I keep this? (Exhibit number 3 was marked for identification purposes.) BY MR. BERGER: Q. It appears to be about 20 pages and it has, Palm Beach Police Department Incident Report, on the top page. Turn to the third page. And you see where it starts the narrative, the Paragraph? Do you see where that starts? A. Yes, sir. And it says: "On Sunday, October 5, '03 at Fe PROSE COURT REPORTING AGENCY, INC. Fs Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcaes7de EFTA00181686

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Page 138 | approximately 8:24 hours, I was dispatched to a burglary at 358 El Brillo Way." Do you see that? A. Yeah. QO. Now, October 5, 2003, do you recall that that was about when the time you took the money from | | Mr. Epstein's briefcase was? | A. Yes. I don't recall. But if they say it, I have to agree with it. Q. Well, you left in December of 2002. And before I showed you this document, you said that these incidents occurred about three or four months later. So apparently they occurred more than three or four months later; is that correct? A. Apparently, yes. Q. Well, now after -- after looking at this, sir, do you actually recall that it occurred more than three or four months later? A. After looking at this? QO. Yeah. A. It could be. Q. But do you actually remember it being more than three or four months? A. I don't remember if it was more than three months. FP PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181687

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Page 139 Q. Okay. Okay. Now, if you look further down, you'll see it says, quote, Epstein further advised a black Glock handgun was taken from the book shelf located behind the desk, unquote. Do you see that? Yes. Did you take a black Glock handgun from him? Absolutely not. Do you know if anybody did? No, sir. Q. Is this the first time that you ever heard that Mr. Epstein may have told the police -- A. No. This question I was asked by the police. Q. Okay. Now, you see the next sentence? It says: "Epstein advised he suspected cash had been taken from his briefcase on two other occasions while he was in town for the weekend. The first was over the Labor Day weekend, August 30 to September 1. The second time was a weekend in mid-September 2003." Do you see -- Yeah. -- the mention of those two incidents? Uh-huh. Yes? Uh-huh. PF PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181688

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Page 140 You've got to say yes or no. A. Yes, sir. Q. Now, look up at the top of that paragraph. You see where it says: "After" -- it's about the fourth sentence -- "Epstein advised that on Saturday evening, October 4, 2003, he left his briefcase at his desk and went to bed at approximately 12:30 a.m. Epstein said when he left his briefcase, it contained approximately $5,000 U.S. currency." A. Uh-huh. Q. Do you see that? A. Yes. Q. And then it goes further on, it says -- after a sentence or two, it says: "Epstein stated at approximately 7:15 hours on Sunday, October 5, 2003, while sitting at his desk, he noticed the briefcase had been opened and some of the cash was missing. Epstein believed approximately $3,500 was taken from the briefcase." Do you see that? A. Yes. Q. Now, when you read this whole paragraph here, do you agree that Mr. Epstein is -- and assuming that the police took this down accurately -- that Mr. Epstein is describing three separate instances -- cf PROSE COURT REPORTING AGENCY, INC. Fe Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181689

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Page 141 No. -- where he believes money was taken? MR. CRITTON: Form. THE WITNESS: I don't agree with this. BY MR. BERGER: Q. No? A. No. Q. Well, he says: "The first" -- at the bottom, it says: "The first was over Labor Day weekend, August 30 to September 1, 2003." You see it says that at the bottom? The very bottom. "The first was over Labor Day weekend, to September 1, 2003." Do you see that? Uh-huh. Yes or no? Yes. Q. And then it says: "The second time was a weekend in mid-September 2003." Do you see that? A. Yes. Q. And then above, do you see where he talked about October 4, 2003? You see mention of that? Or October 5, 2003? PF PROSE COURT REPORTING AGENCY, INC. PF | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181690

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Page 142 A. Right here. Q. Right in the middle, it says: "Epstein stated at" -- yes. A. No. I don't agree with this. I never saw I'm not asking -- that's not what I'm asking. What I'm saying, sir, do you see though that the police report refers to three instances; is that correct? A. No. Q. Okay. But it's correct that the police report refers to three instances, correct? MR. CRITTON: Form. BY MR. BERGER: Q. The police talk about three instances, right? A. That's correct. MR. CRITTON: Form. BY MR. BERGER: Q. Now, how many times did you take cash from Mr. Epstein? A. Twice. Q. So do you have any idea what he's talking about here? A. No. Q. Now, the first time that you took cash, was it FY PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181691

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Page 143 on August 30 to September 1, 2003? A. I can't remember. Or September -- mid-September 2003? Q. A. I can't remember. Q. Okay. Is the third incident accurate where it talks about October 5 or October 4, 2003? A. I don't know if it's accurate or not, but I know that I went to the house twice. Q. Not three times? A. Not three times. Q. Any idea why Mr. Epstein would talk about three times? A. No idea, sir. Q. And any idea why he would talk about a Glock handgun? A. No, sir. MR. CRITTON: Form. BY MR. BERGER: Q. Now, you said that -- that you had a -- okay. I've put this aside. I'm going to ask you another question, so why don't you -- I don't want to distract you. Now, you said that your disagreement or your falling out with Mr. Epstein was after you left his employment. Do you remember saying that? Fs PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181692

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Page 144 Yes. After -- after this incident. And what did that disagreement have to do with? Did it have to do with these incidents? Of course. I screw it up. Okay. And do you know who Mr. Adam Fetterman A Yes. Q Who is he? A. _He's my lawyer. Q And did Mr. Epstein pay for Mr. Fetterman's legal services for you? A. No. I pay on my own pocket. Q. Now, let me ask you some questions about some property in Palm Beach County, Mr. Alessi. Do you remember that in or around 1983 you and your wife bought a home at Bilbao Street in Royal Palm Beach? A I didn't bought it. I build it. Q. You built it. You didn't buy it? A No. QO. And do you remember that in April of 1995, you and your wife purchased a single-family home in -- on Northumberland Court in Wellington? Do you remember that? A. It was a lot. FP PROSE COURT REPORTING AGENCY, INC. FP Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181693

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It was a lot. Okay. Yes, we purchase that. Okay. MR. CRITTON: What was the first date you gave about built home? MR. BERGER: July 1983. MR. CRITTON: Thank you. BY MR. BERGER: Q. And does the purchase price of $22,600; is that correct -- A. Sounds familiar. Q. -- for the -- for the Northumberland Court is that correct? Uh-huh. Yes or no? April of 1995. A Q A. What date was that? Q A That's correct. Q. Now, do you recall that in December of 1997 you and your wife bought apartment number 1902 at 1515 South Flagler Drive -- That's correct. A Q. -- in West Palm Beach; is that right? A Yes, sir. Q And does the purchase price of $105,000; is PF PROSE COURT REPORTING AGENCY, INC. PY Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181694

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that accurate? A. That's correct. Q. Now, do you recall that in November of 1998 you and your wife bought apartment 1901 at 1515 South Flagler? A. Yes. Q. And the purchase price was $159,000? A. That's correct. Q. So in -- so did you -- as of November of 1998, did you own both apartment 1902 and apartment 1901 at the 1515 building? A. Yes. But I didn't own the house in Royal Palm Beach. I didn't -- I sold that. With that money we bought that apartments. Q. You built the house at the Royal Palm Beach address? A. Yes. Q. After buying the lot? A. Yes. We bought the lot years, years back. QO. Now, in October of 2001, do you remember buying a multi-family residential property at Yarmouth Drive in Wellington? A. I still have it. Q. And do you remember the purchase price being $310,000? Po PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c8Ge-4b9f-8d01-ba20bcae87de EFTA00181695

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Page 147 A. Yes, sir. QO. And this is while you worked for Mr. Epstein, correct? 2001, October 2001? Yeah. And you still own it; is that what you said? Yes. And is that a rental apartment building? Yeah, it's a rental. Q. And now, do you recall that in September 2002 you and your wife purchased a multi-family residential property at QJ in west Palm Beach? A. That's correct. Q. And the purchase price was $590,000? Do remember that? A. Yes. Q. And then in October of 2004 you bought the -- you bought a multi-family residential property -- strike that. In October of 2004 your wife purchased a multi-family residential property at Po A. That is not correct. That is a house. That's where you live now? That's where we live now. PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcaeB7de EFTA00181696

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Page 148 And that's just a single-family home? 2 A. That's a single-family home. 3 Q. Okay. And now, did Mr. Epstein contribute any money to the purchase of any of these properties? 5 A. He contribute the -- he contribute the $20,000 towards the purchase of the first property. 7 Q. Well, the first property was back in 1983? A. No. No. The first property at FY 10 QO. That's apartment 1902? A. 1902. 12 Q. Did he contribute any other money towards any 13 of the other properties? 14 A. No. 15 Q. So you paid $590,000 for the property at 16 Ss Without the assistance of Jeffrey Epstein? 17 A. That's correct. I had a loan, took a big loan 18 on that. 19 Q. So he had absolutely nothing to do with your 20 purchase of that property? 21 A. Nothing. 22 Q. And he contributed nothing towards any -- to the purchase of any of the other properties that I mentioned? 25 A. Nothing. PF PROSE COURT REPORTING AGENCY, INC. Fs Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcaes7de EFTA00181697

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Page 149 Okay. MR. BERGER: Mark this as Exhibit 4, please. (Exhibit number 4 was marked for identification purposes.) BY MR. BERGER: Q. Look at Exhibit 4, sir. It's two pages. And it's from Florida Department of State, Division of Corporations? A. Yeah. Q. And would you turn to the next page, the second page? On the second page, do you see your signature and your wife's? A. Yes. QO. And do you recognize this as an application for registration of a fictitious name? A. Yes. Q. And is that -- did you and your wife apply for registration of a fictitious name? A. Right. This was done by our lawyer, Fetterman. Q. And was that done in January of 2003? Look in the upper right. A. Yes. Is that correct? Po PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181698

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Uh-huh. Yes? Yes. Q. And the fictitious name was Las Villas Alessi Properties, correct? A. That's correct. Q. And did Jeffrey Epstein have anything whatsoever to do with the registration of this fictitious name? A. Absolutely nothing. MR. BERGER: Mark this as the next Exhibit. (Exhibit number 5 was marked for identification purposes.) MR. WILLITS: Spell the name of that last -- MR. BERGER: It's Las Villas, V-I-L-L-A-S, Alessi Properties. MR. WILLITS: Thank you. BY MR. BERGER: Q. The next Exhibit, sir, has papers from the Department of State, Division of Corporations. Do you see it makes reference to Alessi Properties, LLC? Up at the top. It says: "Detail by officer/registered agent name." And then under that it says, "Florida limited liability company." Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cBG6e-4b9f-8d01-ba20bcae87de EFTA00181699

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Page 151 A. Where is that, sir? Just point it. Q. Then it says, Alessi Properties, LLC; is that right? A. Yes, sir. QO. Then do you see the next couple pages includes a letter from Adam Fetterman to the Department of State? Do you see that? A. Yes, sir. Q. And then the next -- the next page is an articles -- articles of organization for Florida limited liability company. Do you see that? A. Yes, sir. Q. And then on the very last page, is that your signature? A. Yes, sir. Q. Okay. Is that your application to organize the Florida limited liability company, Alessi Properties, LLC? A. Yes. I just sign it. This was done by the lawyer. Q. Did Jeffrey Epstein have anything to do with the creation of this company? A. Absolutely nothing. Q. Did Jeffrey Epstein pay for Mr. Fetterman's services to do this? Po PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181700

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Page 152 A. Absolutely no. QO. Now, this was -- this Alessi Properties, LLC, it appears to have been incorporated in August of 2003. Do you recall that? Does that sound correct? A. Yeah. Q. And between December of 2002, when you left Mr. Epstein's employment, and August of 2003, when you incorporated Alessi Properties, LLC, did you speak to Jeffrey Epstein? A. Never spoke again. Q. Or with anybody on his behalf, such as his staff or an investigator for him? Anybody? A. Nothing. Q. Okay. Did you go to his home between January and August of 2003? A. No. Except twice, the two incidents that it happened. Q. But those -- and those happened later, after August of 2003, correct? Those happened either -- A. Yeah. I never went to the home for any reason to talk to him or to anybody. Q. Okay. So in September and October when you went to Mr. Epstein's house -- A. Yeah. QO. -- uninvited, -- PC PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181701

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Page 153 Uh-huh. Q. -- you just assumed that he would have money in his briefcase? A. I assume. Q. You hadn't talked to him in nine months; is that your testimony? A. That's my testimony. Q. And you said that you needed that money because of a woman that you were mixed up with? A. That's correct. Q. What's her name? Eva DaSilva (phonetics). And where does she -- I'm sorry. Vonia DaSilva (phonetics). already forgot the name. Q. Vonia? Vonia DaSilva. A Q. Where is she now? Where does she live? A I have no idea. She left -- she left the state. She was a girl from Brazil. The biggest mistake of my life. Q. And then you said during the questioning of one or two of the attorneys that you entered into a separation agreement with Mr. Epstein that included a confidentiality agreement and a release. Do you Po PROSE COURT REPORTING AGENCY, INC. FY Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cBG6e-4b9f-8d01-ba20bcaes7de EFTA00181702

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remember saying that? A. Yeah. MR. CRITTON: BY MR. BERGER: Q. A. Q. And those were signed by you? And Mr. Form. Epstein. And was that signed after the October incident? No. This was signed in January 2003. When you left? Right after I left. Okay. Right after I left, office in New York. again. They send me the check. January, Q. A. Q. A. Q. That was January Do you Not in Do you Yes, I Mr. paper via Fed Ex. the end of it. 2003. have here. have do. it was done through the Epstein never spoke to me It was done through the lawyers in New York. They send us a That happened in a copy of those documents? them at home? And let me just make sure I know what the documents are. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 There's a separation agreement? PROSE COURT REPORTING AGENCY, INC. 3afc3ca0-c86e-4b9f-8d01-ba20bcaes7de EFTA00181703

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Page 155 Just a separation agreement. And that includes a confidentiality provision? It was a -- there's a provision inside. Q. And it also includes in it a release or is the release separate? A. I don't know. Lawyer terms. I'm not familiar with that. Q. Did you have a lawyer represent you in connection with that? A. No. I never need it. Q. And you said Mr. Epstein paid you $30,000 to you and $20,000 to your wife? | A. That's correct. | Q. And how was that paid to you? | A. Cash -- I mean, check. It was a check but it was taken -- taxes were taken out. So it was minus taxes. it one check for each of you? MR. CRITTON: Can we take a five-minute break? MR. BERGER: Sure. MR. CRITTON: Do you want to finish one line of questioning? MR. BERGER: No, go ahead. Go ahead. VIDEOGRAPHER: Off the record at 2:15. Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181704

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Page 156 (Brief recess.) VIDEOGRAPHER: We're back on the record at | 2:21. | BY MR. BERGER: Q. How many times have you talked with investigators of Mr. Epstein? A. One time. Q. And that's the one time that you've mentioned | already? A. Yes. | Q. And have you met -- talked to Mr. Critton before today? | A. Oh, wait a minute. Sorry. I have to go back on that. Twice. One time when the criminal case started when they, like, find the card and Jeffrey says, I cannot talk to you, somebody will call you. I talked the investigator that I told you. And the second time was, I guess, you -- I don't know who was it, but they send -- they send me the -- I don't know if it was an investigator or they just give me your notice that I was going to be subpoena. MR. CRITTON: I think that came from Mr. Willits' office. MR. WILLITS: Jack Hill's office. Po PROSE COURT REPORTING AGENCY, INC. TT Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181705

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Page 157 MR. CRITTON: That wasn't an investigator. It was a subpoena server? THE WITNESS: Yeah. BY MR. BERGER: Q. Process server. Process server. Now, this is Mr. Robert Critton. Have you talked to him before today? A. Yes, sir. Q. How many times have you talked to Mr. Critton? A. Once in my house. And we talk about ten minutes yesterday? Monday? Monday? Q. Yesterday? A. Yesterday. Q. Okay. And what did you discuss? A. Discuss the same questions that you telling me. And he told me basically, say the truth. Tell the truth, nothing but the truth. And be firm and be -- speak your mind and don't be afraid. I thought that this incident about my life never would have come out. I wish it would have never come out. But I guess it come out and it's too late. Q. Well, you know what this case is about, don't you? A. Of course. I think it's a case against Mr. Epstein. But it's not a case against me, is it? PF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9t-8d01-ba20bcae87de EFTA00181706

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No. Oh. And you know it's -- (Brief interruption.) BY MR. BERGER: Q. And you know it's a serious case for the people that are bringing it? THE COURT: Form. THE WITNESS: Absolutely. BY MR. BERGER: Q. So you had this conversation with Mr. Critton yesterday? A. Not about the seriousness, no. Q. No. No. But the conversation that you had with Mr. Critton was yesterday, correct? A. Yes. Told him he -- he told me basically he was going to be here, that a bunch of lawyers were going to ask me questions and that I should be truthful and nothing else, basically. QO. Well, what else did he say? A. What else did Mr. Critton says? Nothing. He asked me about my health, because I was in the hospital this week. He asked me how I felt. And I says, well, I want to get this done. I want to get it over, done, and go on with my life for Po PROSE COURT REPORTING AGENCY, INC. Pe Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181707

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Page 159 the rest of my life. I want to finish with this. I don't want nothing to do with Jeffrey Epstein or this case, once and for all. Q. Did you talk to him about the confidentiality agreement that you mentioned? A. No. Or separation agreement? No. $30,000 that you were paid? tell you that this case that we're here $30,000 where? What $30,000? You said you were paid $30,000 and your wife was paid $20,000. A. Yes. Yes. The separation agreement. No. Q. You didn't talk about that? A. No. QO. Did he tell you there were young women suing Mr. Epstein? Did he tell you that yesterday? A. No. He mentioned to me that it was a lot of lawsuits against Mr. Epstein, criminal and civil suits. fF PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181708

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Page 160 And -- not yesterday, but when he was in my house with his secretary. Q. Not yesterday? A. Not yesterday. Q. When was he was at your house with the secretary? A. About two months ago, a month and a half ago. Q. You can't look to him to answer. You've got to answer. A. I cannot remember exactly the date, but I would say it was about a month ago. Q. Maybe I misunderstood. Was Mr. Critton at your house yesterday? A. No. He called me yesterday. Q. He called you yesterday? A. Yes, sir. Q. And you talked for about ten minutes yesterday on the phone? A. No more. Q. Did you tell me everything that you and Mr. Critton talked about yesterday? A. Yes. Now, he visited your house -- Q A. Yes. Q -- a month and a half or two months ago -- PF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181709

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Absolutely. -- with his secretary? Yes. And did she take notes? Yes, she did. Pardon me? She did. She took notes. Just by pen and paper? Pen and paper. Not a machine like the court reporter? No. Were you taped? Did somebody tape record you? No. Did he show you the notes that she took down? No. Typed up and show you the transcript? No. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. No? Now, how long was Mr. Critton at your house then? A. For about half an hour. QO. And did you know that he was coming? Did he call ahead of time? A. Yeah. Q. And, so, what did you expect was going to happen? PT PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181710

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Page A. He was going to come in and ask questions about this case. Q. So what did he say? A. Same questions that you guys are asking me, exactly the same questions. Q. Nothing more? A. Basically what you saw, what you did, what your job description was, what you did, how you start your day, how was your day and how was -- what time you started, what time you finish and what you did, and what was your responsibilities. And that was it. Q. Okay. And were you paid anything for that? A. Absolutely not. The only money that I got, it was from you for this $47 check for coming in here. QO. Okay. A. And I will take no money from nobody. Q. Okay. Were there -- were there any other times that you talked to either Mr. Critton or anybody from his office? A. No. Q. You described every time that you've ever talked to either Mr. Critton or people from his office? A. No, sir. QO. You've described all those times that you've talked to Mr. Critton or people from his office? I'm PF PROSE COURT REPORTING AGENCY, INC. Fs Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181711

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Page 163 not asking the question clearly. Did you talk to Mr. Critton any other time? A. No. I talked to Mr. Critton twice, once in my house, once yesterday. | Q. Now, how about Mr. Jack Goldberger, | Mr. Epstein's criminal defense attorney, did you ever | talk to him? | A. No. Q. Did you ever talk to Alan Dershowitz about any of these matters? A. No, sir. Q. Or Roy Black? A. No, sir. Q. Now, I'm just going back over some different things that you mentioned. You said that there was a Roladex that you created of names of women? A. Not it was a name just woman. It was companies, air condition companies. It was cleaning companies. It was suppliers. And it was -- it was a Roladex that I left it there. Q. Did you have a list of girls on your Roladex? MR. CRITTON: Form. THE WITNESS: No. We had a list of girls in a -- in a -- in a sheet with plastic that we have FP PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181712

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Page all the massage therapists. It was two pages or three pages of people in a plastic sheet that we had it where -- by the telephones. That was it. BY MR. BERGER: Have the names? Names and phones. Telephone numbers? Uh-huh. What about addresses? No, no addresses. What about dates? No, sir. And who prepared the list? Either Ms. Maxwell -- Ms. Maxwell. Was it typed? Yeah. They were types. No. Typed. Yeah. Who typed it? Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. I don't know who type it, but it came from New The list? A. Yeah. Q. Did you -- did you give the information that went into the list? Po PROSE COURT REPORTING AGENCY, INC. TY Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181713

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No. Where was the list kept? A. In many places. It was in Mrs. Maxwell's desk. It was one in the kitchen, one in my office, one in my room because sometimes I was in my room and I have to call. these people. It was one in the new house when they build the new house. It was all over. And it was also those -- those files for the house -- the house running operation. QO. Was it the same list that was in all those places? A. Basically, yes. Was the list updated? Yes. Did you keep a copy of the list? No, I don't have a copy of the list. Q. When you left Mr. Epstein's employment, you didn't take a copy with you? A. Not at all. Q. And when you worked for Mr. Epstein, you didn't write notes about what you did and what you saw? A. No. No? Q A. No. I had too much to do. Q You didn't put anything in a computer about PC PROSE COURT REPORTING AGENCY, INC. PC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181714

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what you saw at the house? A. No, sir. QO. Did you ever talk to your wife about what you saw at the house? A. Like what? Saw about what? QO. About the dildos. About the massages. Did you ever talk to your wife about that? A. Yeah. And that's one of the reasons that I never send my wife after -- this hap -- these dildos and things like that happened right at the end of my stay there. It never happened before. Right at the last couple months before I left. And that -- Q. And that's when young girls -- MR. CRITTON: Let him finish his answer. THE WITNESS: And my -- my worry about was that my wife will panic. And I never send her up there to clean up the rooms or anything else. BY MR. BERGER: Q. Is that when young girls started coming to the MR. CRITTON: Form. THE WITNESS: One girl that I can think of. BY MR. BERGER: QO. Just one? A. One girl. That girl that she show me the PF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181715

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picture. Oo. EE.? A. That's the only one that I can think she was young, but I don't know how old. Q. Do you still have the transcript from -- from the police in front of you, from the State Attorney's Office? It's below that. It's at the bottom. Keep going. You see? Turn to page 9. Page 9. Now, look at me. It says, page 10, but it also says page 9. So you got page 9? Page 9 and page 10. Okay. Oh, okay. Page 9. Okay. I want you to see page 9. MR. CRITTON: You want the transcript page 9? MR. BERGER: Yeah. BY MR. BERGER: QO. Let me just make sure you're on the right page. Yeah. Look at line 13. It says, answer: "No, sir. Mostly no. We saw one or two young ones in the last year." PT PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcaes7de EFTA00181716

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Do you see that? MR. CRITTON: Form. It's taken out of context. There's no question. BY MR. BERGER: QO. Do you see those words? A. Did they seem -- did they seem young to you? No, sir, mostly were no. We saw two young ones in the last year. QO. Well, it actually says, "we saw one or two young ones in the last year." A. "We saw one or two young ones in the last year. Before that they were all adults." Q. The one or two young ones in the last year that you're referring to, who are they? A. One was I. and the another one was i. Q. Don't write on that. Okay? Don't write on that with your pen. Look at paragraph -- look at line 19. A. Yes. Q. It says, quote, I remember one girl was young, unquote. Do you see that? Yeah. MR. CRITTON: Form. BY MR. BERGER: PF PROSE COURT REPORTING AGENCY, INC. FP Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181717

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Q. Who were you referring to? A. &£f. Q. And then you see under that at line 22, it says, quote, but I imagine she was 16, 17. In my judgment she was 16, 17, unquote. | Do you see that? | MR. CRITTON: Form. THE WITNESS: Yeah. BY MR. BERGER: Q. Were you referring to JP? MR. CRITTON: Form. THE WITNESS: I think so, yeah. Oh, can I read this again? BY MR. BERGER: Q. Sure, go ahead. Take your time. A. "During the last year while you were working for him, what do you mean, they look young? Did they look like they were still in high school? Yes. And the only one that I knew was in high school was N. I remember one girl was young. We never ask her how old she was. I never asked N. how old she was. I think she was in the last year of high school. Right. Understand. Question. But I imagine she was 16, 17. I don't know. Fs PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181718

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Page 170 In my judgment she was 16, 17." I was talking about, I was referring about N. at that time. QO. So at line 22, look at line 22. A. Yes, sir. QO. It says, quote, but I imagine she was 16, 17, unquote. You were referring to who? To N. Okay. You can put that down. You mentioned Joe Joe. You said Joe Joe was the house man in New York? A. Yes. I met Joe Joe. QO. And do you know his full name? A. Joe Joe work with his wife. They were Funtanella (phonetics), Funtanella. Joe Joe and Lynn was his wife, Funtanella. Q. When is the last time you talked to them? A. Wow. Never talked to them again in over ten Q. Now, you mentioned in response to Ms. Ezell's questions, you said something about H's father. Do you remember talking about that? A. Uh-huh. Q. How do you know that person was her father? fF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01 -ba20bcae87de EFTA00181719

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Page 171 A. Because either she told me or Ms. Maxwell told me that her father used to work at Donald Trump's place. And she -- I think he is the one who bring her to the house that afternoon, the first time I saw drive in at this -- Donald Trump's house. QO. Now, you said you know -- you knew who Alan Dershowitz or you know who Alan Dershowitz is, right? A. Many times. And he was at the house? Q A. He's been at the house a lot of times. Q Was he ever at the house when there were naked women at the house? A. No. No? They were never naked woman at the house, sir. I remember one occasion when one English girl -- I think she was English or German girl -- came to the house. And usually in Europe they use topless, they don't wear anything. But she was taking the sun outside and she came to the house with nothing on and I chase them out. I says, not in this house. You don't do it. You go outside, put the towel and come in here. Because she came to get something from the kitchen wearing nothing. And I did not allow that. Q. But when Alan Dershowitz was there, were there Po PROSE COURT REPORTING AGENCY, INC. fr Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181720

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any women that were topless? A. No, not that I can remember. Q. What about when Prince Andrew was there? A. Not that I can remember, sir. Q. Did you ever see Alan Dershowitz walking around naked? A. No, sir. Q. about Prince Andrew? A. No, sir. Q. You mentioned your divorce, that it cost -- it cost money. Did Jeffrey Epstein pay for anything | connected with the divorce? A. Absolutely nothing. Q. Let me go back for a minute to the confidentiality provision in the separation agreement. Did you -- did you discuss with anybody why there had to be a confidentiality provision? Did you talk to somebody about that? A. No. No. I discuss it with Mr. Epstein when he told me, he finally come out and says, John -- I know they were going to try to replace us. And -- and we got upset because I was not ready to leave yet. But at the same time we were expecting to be left out. And I left there before they decide to let me go. And I went to -- I remember very clearly, I Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181721

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Page 173 } went to his office in the pool house and it was -- I talk to him and says, John, -- I went with some faxes that came to my office and they were people interviewing * for my job. So I feel very pissed about it. And I went to his office and said, Jeffrey, | what is this? And what is this? And what is this? He says, well, that's Ghislaine. I'm not involved into that. And I says, okay. We're going to leave, Jeffrey. That's it. We're done. And what you going to do for me? And he says, well, what you want? And I says, give me at least a year's salary. And that's what it turn out to be, around $50,000, plus the van. And he says, okay, John, wish you good luck. And the last day I was there we shake hands and we left. But my relationship with him, it was good. It was friendly. At the beginning of the -- my job was very friendly. Then he changed when Ms. Maxwell come in. I didn't like to work for her. She was a bitch. And she make us life hell. And that's why we left. But it was not with Mr. Epstein. Q. Do you know why there was a confidentiality provision in your agreement? FY PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcaes7de EFTA00181722

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Page 174 No. That's lawyer stuff. I don't know. MR. BERGER: Okay. That's all I have. CROSS EXAMINATION BY MR. CRITTON: QO. Mr. Alessi, my name is Bob Critton, as you know, and I represent Mr. Epstein. A. Yes, sir. Q. You've been -- this deposition started at 10:00. It's almost -- it's closing in on 3:00 but for about 45 minutes or an hour that we took for lunch. I'm going to try to be relatively brief so we can get you out of here. Okay? A. Okay, sir. Q. You've been asked questions by five different lawyers who represent various Plaintiffs in this case. A. Yes, sir. Q. In some instances you've been asked the same question multiple times? A. Yes, sir. Q. The testimony -- you've also been asked a number of questions about your separation from Mr. Epstein sometime at the end of December of '02 and the entrance or your entering into a separation agreement with him? A. Uh-huh. PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181723

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Page 175 QO. Correct? A. Yes. Q. And subsequently there was an incident in 2003 that you've described in some detail, based on the questions that have been asked, and you and Mr. Epstein reached an amicable agreement; you repaid him the monies that you had taken and you parted? A. Yes. Q. Is that a fair statement? A. And I will have to add something to that. When we talk at the luncheonette, we have coffee, he says, John, if you were not my best employee that I ever have and that you would not take care of my mother, I would have put you away. And that's the way he come out to me. And I says, I like you and let's -- just pay me back in one or two weeks, because I send the money back and it got lost. So he give me another -- not him, but his lawyer says, you got another month to pay. So between I got the money -- the money order was lost in the mail. So I send it back. I pay everything, $6,310. I think it was 6310. And that was it. Q. And I'm more interested, not so much in the details, Mr. Alessi, but the color, so to speak, the lawyers have put on this, is, is that as a result of PC PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181724

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Page 176 your separation from Mr. Epstein in late-2002 and the incident in 2003, that somehow you have colored your testimony to help Mr. Epstein today. And my question to you is: Have you told us the truth today as to every question that's been asked and the questions that are going to be asked of you? A. To every one of you. MR. WILLITS: Object to the form of the question. BY MR. CRITTON: Q. And with regard to the agreements that you entered into with Mr. Epstein, in particular the confidentiality agreement, you were asked a question by Ms. Ezell whether you understood that you're not bound by confidentiality today. And you responded in the affirmative, right? You understand that you're to tell us -- to answer every question fully to the best of your knowledge? A. Absolutely. And that you have done today? Q A. Yes. Q Okay. MR. WILLITS: Object to the form of the question. BY MR. CRITTON: fF PROSE COURT REPORTING AGENCY, INC. i Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcaes7de EFTA00181725

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Page 177 Q. You told us off the record -- and I don't know whether it was on the record, so I want to be clear because you've been sitting here a long time. You're currently under care and treatment for having chemotherapy; is that correct, sir? A. Yes, I have. Q. And I think you told us earlier that you were in the hospital two days last week? A. Last week, yeah. Q. And, so, we've -- you've done great. You've probably done better than the lawyers today. But you'd like to get this over today and finished? A. I hope so. Q. All right. There have been a lot of questions about your job description and duties at Mr. Epstein's. And if I understood it correctly, is basically, once you became the full-time house manager, you were responsible for all aspects of the operation of the El Brillo residence? A. I was. MR. WILLITS: Object to the form of the question. BY MR. CRITTON: Q. And during the time that you were responsible for all aspects of the El Brillo residence, that Po PROSE COURT REPORTING AGENCY, INC. Co Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181726

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Page 178 included not only maintenance and repair, but appropriate staffing, laundry, cleaning, shopping, cooking, whatever -- whatever needed to be done at the home? A. That's correct. MR. WILLITS: Object to the form of the question. BY MR. CRITTON: Q. And during the time that you were there as the full-time -- as the house manager from 1992 up until December of 2002, you did all those different types of responsibilities; is that a fair statement? A. Yes. MR. WILLITS: Object to the form of the question. BY MR. CRITTON: Q. And at some point -- let me strike that. The original deal, so to speak, that you cut was with Mr. Epstein; that is, when you became the full-time house manager; is that true? A. That's true. Q. And some point within -- what? -- a year or so, I think Eva -- Eva -- A. Eva. Q. Anderson -- PY PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181727

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Page Left. Q. -- was no longer Mr. Epstein's -- Dr. Eva Anderson was no longer Mr. Epstein's girlfriend, -- A. That's correct. Q. -- and a new girlfriend came in and that was Ghislaine Maxwell? A. That's correct. Q. And when Ms. Maxwell came in, she, in essence, took over as your immediate supervisor? A. That's correct. Q. During the time that you worked for Mr. Epstein, did you have a good, excellent, fair, what was -- how would you describe your relationship with him? Good, excellent or fair. I will think good. Q. And did you interact with him very much or does he interact with anybody very much? A. He doesn't interact very much. At the early years, yes, he did come to the kitchen and we used to sit down in the kitchen and he would discuss my kids, my family, his family, and he will talk to me. was -- we were told not even to look at his face. Not even to -- this was done by -- this was even done by, At the end of my stay there, it was -- I | | fF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-Bd01-ba20bcae87de EFTA00181728

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Page 180 they hire a Countess from Europe to write this book and to write ideas of how the house of royalty should be. And that's the way Ms. Maxwell wanted the house to run, as a royal house. And I was pissed off at that and I never agreed with that and I never went with the book. I threw the book away. And that was it. MR. CRITTON: Let me move as non-responsive to my question. Move to strike. MR. WILLITS: He should allowed to finish what he thinks is responsive to your question, even if you don't agree. BY MR. CRITTON: Were you finished, sir? Yes, I finish. MR. CRITTON: See, he's finished. MR. WILLITS: He wasn't, but okay. BY MR. CRITTON: Q. I'm trying to -- listen carefully to my question because I'm trying to get you out of here sooner rather than later. If I understood your testimony is, is that, you had -- you considered your relationship with Mr. Epstein to be good during those years? A. Good. Q. And would you describe your relationship with FP PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcaes7de EFTA00181729

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Ms. Maxwell as not being as good? A. Yes. Q. When -- you were -- you had an opportunity over lunch, Mr. Berger gave you a copy of a statement that you gave to the State Attorney's Office on November 21, 2005, we've marked as Exhibit, I think, Exhibit -- MR. CRITTON: What did we mark it as, 2? THE WITNESS: At what page? MR. WILLITS: Yes. It was 2. MR. CRITTON: Thank you. BY MR. CRITTON: Q. No, just statement, the whole statement. You had an opportunity to look at it over lunch? A. Yes. Q. And that's a statement you gave back on November 21st of 2005? A. Uh-huh. Q. Is that correct? A. That's correct. Q. And at that time you were there with Mr. Murrell, who was your attorney. And you gave a statement and I think as well your wife spoke with the State Attorney's Office? PF PROSE COURT REPORTING AGENCY, INC. FC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181730

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Page 182 A. That's correct. Q. And whatever questions the State Attorney asked of you at that time, I assume you fully answered; is that correct? A. Absolutely. Q. And then page 9 where Mr. Berger took you with regard to the questions -- and before I get -- I'm going to come back to page 9 in a minute. But if I understood your earlier testimony in response to one of the lawyers who asked you questions, is, there were a number of European women, all who you deemed to be 20-plus years old, that would travel with Mr. Epstein to various places and as well would come to the house from time to time? A. That's correct. Q. And I think you testified in response to Mr. Berger's questions today, is that the only female that you understood that came to the house during the time that you were the house manager who you knew to be under the age of 18 was .? A. That's correct. Q. And you knew she was under 18 because you would pick her up from high school? A. That's correct. Q. And that's a young girl who I think you PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181731

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A. 16, 17. Q. And I think you said she never was involved in giving any massages to Mr. Epstein? A. I don't think so, never. Q. And the times that you saw her, Mr. Epstein was mentoring her on a career which ultimately turned into her becoming an actress? A. I think so. Yeah, that was the main purpose. Q. And on multiple occasions when she would be over, she would be over there at Mr. Epstein's home with her mother; is that correct? A. Yes, that's correct. Q. And of the girls that came or the women that came to give massages to Mr. Epstein over the years you were there, I think you've described on page 9 of your deposition that you may have seen a hundred or 200 different massage therapists? A. It could be less. I don't think it's more than 200, but it could be less than 200, yes. It was -- it was 11 years or 12 years or 13 years of constant people going in and out and people that were coming to the house, he will bring for another state, he will bring in his planes. People that it came from Europe, massage therapists, there were men and woman. They live PF PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181732

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Page 184 | in Miami, we -- so it was so many that I cannot remember how many. QO. Okay. And I understand that. I'm just referring back to your statement where it says at page 9, line 9, the question was: "Yeah. Yeah. Not the same girl. I mean, during 11 years I probably saw a hundred, 200 different massage therapists." Do you see that? A. Yes. Q. All right. And if I understood your testimony is, the ones the -- that is, of the massage therapists, as you've just described, you saw some men? A. Yes. Q. You saw more women? A. More woman. Q. And all of the women, at least from your viewpoint, were 18, 19 or older? A. Yes. MR. CRITTON: Why don't you change your tape right now. VIDEOGRAPHER: Off the record at 2:54. (Brief recess.) VIDEOGRAPHER: We're back on the record at 2:55. BY MR. CRITTON: Po PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcac87de EFTA00181733

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Page 185 Q. Mr. Alessi, in the 11 years that you worked for Mr. Epstein, with regard to the massage therapists -- and I'm talking about all of them, women, men, the ones that were 18, 19, 20, or the ones that were older -- did you ever see -- or, first of all, did you ever hear any complaints about -- from the massage therapists about the massage they had given to Mr. Epstein? A. No. Q. Did you ever see a massage therapist during those 11 years that appeared to you to be distraught? Never. To be in some form of a shock? To be scared? A Q A. Never. Q A I never see anybody scared. Q. Did you ever see someone who looked like they were upset or crying? A. No, sir. Q. I think you, in response to Mr. -- well, not sure who asked the question -- but they -- you were asked whether you ever spoke to the individuals -- A. Yes. Q. -- when they came down. And I think you said from time to time you might have some small talk with Po PROSE COURT REPORTING AGENCY, INC. FC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181734

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them afterward? A. Yeah. QO. Did you usually see them if they came down? A. Yeah. Q. So you would have had an opportunity to observe their appearance, correct? A. That's correct. Q. Have you seen people who look distraught, in shock, scared, upset, angry in the past -- not massage therapists -- have you seen people in your life experiences? A. Oh, yeah, yes. MR. MERMELSTEIN: Object to the form. BY MR. CRITTON: Q. So if -- well, let me ask it this way: In your life experiences before you worked for Mr. Epstein, and, in fact, during the time you worked for Mr. Epstein, have you seen individuals not associated with Mr. Epstein who appeared to be distraught, in shock, scared, upset, angry or injured? A. Yes. MR. MERMELSTEIN: Object to form. BY MR. CRITTON: Q. Have you seen people who appeared to you to have been traumatized by a particular event? Po PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-6d01-ba20bcae87de EFTA00181735

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Page 187 MR. MERMELSTEIN: Object to form. | THE WITNESS: Yes. | BY MR. CRITTON: Q. Have you seen people who seem to be -- well, I assume you've seen people who have yelled or screamed as a result of some event that had occurred in your presence? A. Yes. | Q. On the massage therapists that you saw at Mr. Epstein's house from 1992 up until the time you left in December of '02, did you ever see any type of reaction, distraught, shock, scared, upset, crying, disheveled, injured, disoriented, yelling or screaming for help at any time? A. No, sir. QO. Once the massage -- once -- let me strike If I understood your testimony, you helped set up -- either you set up the room or you helped set up the massage room? A. Uh-huh. Q. And you might be the person or it might be someone else who would lead the massage therapists or the female up to the room, the male or the female up to the room? FP PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181736

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Page 188 A. Yes, sir. Q. Once that person was upstairs, you then would come back down and resume your multiple duties downstairs? A. Absolutely. QO. As to what occurred during the course of a massage, do you have any personal knowledge during the 11 years you were there? A. There was absolutely no way to know or to get into the room. The windows were what they have, those automatic electric shutters. They were completely dark, completely a hundred percent dark, the rooms. And it was -- nobody saw it. I knew it when I was at the house that I never saw anything was going on inside. QO. So you have no personal knowledge what occurred during any particular massage? A. Nothing. Q. And I think you said -- well, let me strike that. In other individuals whom you have done work for at big houses in Palm Beach, did those people from time to time have massages, too? A. I never work in a house inside as I did work for Mr. Epstein. Q. Yours was outside maintenance work? PF PROSE COURT REPORTING AGENCY, INC. Co Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181737

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Page 189 I was the maintenance guy outside. All right. And if -- well, let me strike You're aware that there's all sorts of spas. The Breakers? PGA? Trump? A. Absolutely. Q. The Ritz Carlton? The Four Seasons? And probably a thousand other places in Palm Beach County? MR. WILLITS: Object to the form of the question. BY MR. CRITTON: Q. Well, let me strike that. Are you aware that there's more than ten places that someone can get a massage in Palm Beach County? A. Of course. Q. Are you aware that there's probably more than a hundred places, maybe a thousand places in Palm Beach County from Boca Raton up through Jupiter and all the way out west where people can get a therapeutic or a massage? A. Yes. Q. And I assume you were aware that -- or were you aware of that during the time period that you worked for Mr. Epstein? Po PROSE COURT REPORTING AGENCY, INC. Co Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181738

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Page 190 A. Yes. Q. And I think you told us that you were aware that there were massage schools? A. Yes. Q. And is it your understanding that generally massages are given in a -- in a room with a table where the lights are generally turned down? A. And music on, yeah. Q. All right. You were asked a question about vibrators or I think that the word was sex toys. If you'll turn to page 20 of your statement, If you look at page -- if you just glance at A. Okay. Q. -- through line 22. Take a chance. If you'll just look at that, then I'll ask you a couple questions. Read to yourself, please. Otherwise, the court reporter will have to take down everything you say. A. Yeah. Q. And at least the statement that you gave back in -- on November 21st of 2005, almost -- almost four years ago now, you describe that there were -- that you saw two types of massagers or vibrators; is that Fs PROSE COURT REPORTING AGENCY, INC. FP Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-6d01-ba20bcae87de EFTA00181739

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Page 191 correct? A. That's correct. Q. And is that your best recollection, as you sit here today? A. That's the best recollection. QO. And one of the vibrators, you said was, as you described earlier, looked like a dildo? A. Right. QO. And -- MR. WILLITS: Object to the form of the question. BY MR. CRITTON: Q. Well, let me ask you this: Was the item that you described, that's described at lines 12, 13 and 14, and 15 -- 12, 13 and 14 on page 20, is that what you described, is that what you were talking about as the dildo? A. QO. I assume you're familiar with what a dildo I know that it's one of those -- Q. You don't have to describe it. Just are you familiar with what one is? A. No, I don't. I'm not really familiar with that type of instruments. But what did I saw it and is Po PROSE COURT REPORTING AGENCY, INC. PC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181740

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Page 192 it true now, is it true when I make this statement, it was a big rubber man's -- Penis? -- looking penis, with double head, two heads. And -- And I don't know how is it even called. And I am sorry. It's a little unpleasant. Q. That's all right. The second item that you described was a neck and back vibrator; is that correct? A. Yeah. They have this vibrators, they have the cordless and they have these balls and they have different types of those vibrators, too. QO. Like you can get them at Brookstone or something like that? A. Yeah. Yeah. Yes, sir. Q. So at least when you were at Mr. Epstein's, and I think as you described in response to lawyer's questions today, is during the last couple of months that you worked at Mr. Epstein's you saw these two vibrators? A. Yes. Q. And on those two occasions you'd take those vibrators, if you went up to clean afterwards, you'd put on your gloves, pick them up with a towel and you'd PF PROSE COURT REPORTING AGENCY, INC. Ft Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181741

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Page 193 clean them off and you'd put them back in Mrs. Maxwell's -- A. Closet. Q. -- closet in her bathroom? MR. WILLITS: Object to the form of the question. THE WITNESS: I put it back in the closet and inside the closet there was a laundry basket that is where she had those. BY MR. CRITTON: Qo. And as to whether or not someone actually used those items or how they were used, all you know is you found them -- A. I find it in the sink. MR. BERGER: Objection. Mr. Critton is testifying. Leading. MR. WILLITS: Objection, also, to the form. BY MR. CRITTON: QO. Let me ask you this: Do you know, if I understand it correctly, you found the two vibrators, one for the neck and back and the other one that you described as a dildo, you found them in the sink on those few occasions near the end of your employment? A. Yes. MR. BERGER: Objection. Testifying. Leading. PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcaes7de EFTA00181742

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Page 194 THE WITNESS: I find it in the sink. BY MR. CRITTON: Q. And then you would clean up and put it back in Ms. -- A. I will put my rubber gloves, get a towel, put them under the sink, run the water and put them in the closet. And you put them back in Ms. Maxwell's closet? Closet. Q A Q. Why? Why into her closet? A Because they were always kept there. Q. All right. You testified earlier, is that if you were going to call someone for a massage, it would either be you or Ms. Maxwell, if I understood you correctly? A. Yeah. Q. Okay. A. At the end -- at the end of my stay was also another girl, Sarah, Sarah that came. And then she was handling everything, as far as calls to these girls. Q. Did Mr. Epstein ever make these calls? A. I never heard. Q. If Mr. Epstein was not in residence, that is, if he was in New York or some place else other than Palm Beach, did you and your wife still stay at the home or Po PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 . Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181743

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would you go to one of your apartment? A. No. We went to our apartment. Q. And then when he wasn't there, would you have pretty more regular hours around the house? A. Pretty much. Pretty much, yeah. That was the days that we had to have the cleaning crew, I still had to go to the house and oversee the cleaning operation, oversee the gardener because there was not, when they were there the gardener weren't supposed to make noise, so we have to take care of the pool, the chlorine and all that stuff. Q. So you would still do your regular but you could finish pretty much 9:00 to 5:00? A. Yes. That was much easier. Q. And when he was -- how often would he generally be in Palm Beach? A. Too much. Q. All right. But if -- would he be here at least a couple -- A. I would says, at least three times a year -- a month, three weeks a month, three weekends a month. Usually they come in on a Thursday. Either they left a Monday or Tuesday. Q. And then they go wherever else they were going and then things would get back to more of a 9:00 to 5:00 Fs PROSE COURT REPORTING AGENCY, INC. cf Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181744

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type routine? A. That's right. Q. And if he was in residence, that's when your job became much more all encompassing? A. Exhausting. QO. Okay. You were asked about a female named MMM. i. think you originally thought it was §., but m.: Yeah. You recall now; is that correct? Yes. Yes. Q. And I think you described her, I think your recollection was, is that you remember her being at the house the last few months that you worked for Mr. Epstein? A. Yeah. The last few months. QO. And that's the only time that you remember her actually being there? A. Yeah. Q. Because you actually recall when she used to work at Mar-a-lago, and then you recall her starting to come to -- A. To the house. QO. -- Mr. Epstein's home? Right. Po PROSE COURT REPORTING AGENCY, INC. fC Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181745

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Page 197 Q. And I think you testified that at one time you had to pick her up and she lived at her house or she was living with her boyfriend at some house out in Royal Palm Beach; is that correct? A. That's right. Q. Did you know anything about [.? A. Not necessarily. Not that I can remember. knew the one time either Ms. Maxwell or Mr. Epstein me that she was arrested because she was working in in the restaurant and she took her -- the tips, her tips for that day. And the next day she was arrested and the money have to be returned and -- it was something about that, but that's it. That's all I know. Q. Okay. Was it -- let me ask you this: Do you remember her stealing some money from the Roadhouse Restaurant where she was working? A. That's what I heard, that it was a report, there was a police report. QO. All right. And, so, at least you understood from Mr. Epstein or Ms. Maxwell that she had stolen money from her employment? Yeah. Again, you never saw the police report? No. Nor the date of it? Fs PROSE COURT REPORTING AGENCY, INC. Fe Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181746

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| Page 198 No. That's correct? That's correct. Q. And as to whether she repaid the money or what happened with that criminal charge, do you know? A. No, I don't. Q. Do you know whether there's an arrest out for her -- a warrant out for her arrest at the current time? A. No, sir. Q. Were you aware of any of her other background; that is, before she ever met Mr. Epstein, were you aware that she, back in, say, 1997, that she was involved in a sexual battery between with her and three girls and three boys that were engaged in sexual or lewd acts and they were found by some individuals in, as was described, compromising positions with the males on top of the females, including her, and she was intoxicated? Did she ever talk about that with you? A. No. MR. BERGER: Objection. Compound question. And Counsel is testifying. MR. WILLITS: Object to the form. MS. EZELL: Join. BY MR. CRITTON: QO. Were you aware that she had, prior to the time FY PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181747

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Page 199 she ever met Mr. Epstein, that she had -- her mother described her as having significant drug problems? MR. BERGER: Objection. Counsel is testifying. THE WITNESS: No. BY MR. CRITTON: Q. Mrs. Ezell used -- she referred to a J -- MS. EZELL: Santiago. THE WITNESS: Santiago. BY MR. CRITTON: QO. Have you ever heard of a | sti iS MS. EZELL: Thank you. You're right. THE WITNESS: I know that his name was but I don't know if it was Santiago or [. don't remember the last name. I never spoke to him, except ask him to move his car one time. BY MR. CRITTON: Q. And did Mr. -- got it wrong -- did Mr. QM bring MJ. to the Epstein house on more than one occasion? A. Yes. QO. And did you consider her, at least from your viewpoint, was she one of the individuals who came to give massages? A. She was supposed to be a massage therapist. Po PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181748

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Page 200 Q. And, so, Mr. -- at least Mr. J -- i” -- assuming, if I asked you to assume his name was a. was he aware that his live-in girlfriend was coming to Mr. Epstein's house to give him a massage? A. I don't know if he was aware of it. waiting outside. Q. All right. And you understood that she, that is, i. and Mr. | or a. a f | lived together out in Royal Palm Beach? A. Yes. Q. And as to what their relationship was and as to what -- that is, their internal relationship was and whether there was abuse, either physical or verbal, associated with that, do you have any personal knowledge? A. Not except that that time that I went to pick up and she was crying and she told me the furniture, > couch was slit with like a razor blade or a knife, also the screen porch at the entrance, it was cut. And I ask, I said, what happened here? She says, well, my boyfriend got mad and he it. Q. And she indicate -- she, .. told you it was boyfriend that caused all that damage? A. Yeah. Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181749

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Page 201 Q. With regard to .. did it ever appear to you that she was forced to come to Mr. Epstein's home? A. I don't think so. I don't know if it was forced between them, but I never saw force. I never saw -- I was there the first time Ms. Maxwell met her immediately that she went into the spa, when she was walking into the spa. And I was surprised to see that afternoon she was at the house. Q. Did you ever see anyone forcing J. onto the Epstein's premises; that is, either by grabbing her by the arm or by the hand and dragging her in? A. No. Either her or nobody else. Q. Did you ever see Ms. -- i. when she came to the home where she appeared to be -- that is, when she arrived at the home to be upset or angry or distraught? A. No. Q. And specifically with regard to .. when she left on those occasions where you saw her in person leave the house, did she appear to be in the same, I'd say, overall demeanor and mood when she left as she had been when she came? A. Yeah, normal. She was normal. Did she smile? Q A. Yeah. Q Say hello to you? Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181750

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Page They all smile after they got paid. MR. CRITTON: All right. That's all I have. Thank you, Mr. Alessi. THE WITNESS: You're welcome. MR. WILLITS: I don't have any questions. MR. BERGER: Okay. MS. EZELL: I do. RECROSS EXAMINATION BY MS. EZELL: Q. Sorry. Let me find my place, here. First of all, forgive me. I didn't mean to mislead anyone. It is QR, not Santiago. I think he lived on Santiago Street. A. Yeah. Santiago Street in Royal Palm Beach. Right. And I confused the two. My head is not going very well now, so... Do you need to take a break? Please. No, I am fine. I am fine. Well, it was my head that wasn't going very You mentioned that your wife, I believe you that -- let me start over. I believe you said one reason you wanted to was that it was causing psychological problems -- A. Yes, it is. Fe PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181751

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Page 203 -- and problems with your marriage? Absolutely. What kind of psychological problems? : I say, psychological problems. I says, marital problems. That would be a better answer it. Because the stressful was on me. If there was a dust, spot of dust, they never came to her. And she was able to -- she was over involved with the cleaning crew, but it was never from Mr. Epstein or Ms. Maxwell yell, they will never go to Mari to ask, hey, Mari, why this doesn't look good. And, so, I had all the blame. And the only person I have to take it out was my wife, unfortunately. And that was the worst mistake, to have my wife working in there. Q. Did she ever complain to you or seem disturbed by what she thought was going on there? A. No. She never saw anything. Q. Was there ever a guest there by the name of Tommy Matola? A. Tommy Matola? No. Not when I was there. Q. You mentioned this morning that there were some visitors who were very important men, Noble Prize winners? A. Yes, ma'am. PF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181752

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Page 204 Q. Are you -- do you recall a Martin Nowak? A. I think that sounds familiar. If he is an old guy, old man? I think so. Mathematician? Yes. Biologist? Yes. His name Martin. I recall that, yes. And do you recall a guest, Murray Gell-Mann? Mary Gell-Mann? MR. WILLITS: I think you said -- MS. EZELL: Murray. MR. WILLITS: -- Murray and he said Mary. BY MS. EZELL: Q. Murray, Murray Gell-Mann. And, again, I'm speaking of these -- these -- A. Is that a man or a woman? I believe it's a man. Murray Gell-Mann. Could be, but I don't Q. Do you recall the name Jerry Edelman? A. No. QO. What about -- can't read my own writing here -- Henry Risorski (phonetics) ? A. Henry Risorski, yes. Yes. Q. Was he a frequent visitor or -- fF PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181753

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Page A. Not too frequent. But, also, he was a science -- I think so, he was into the science. QO. And Larry Summers? A. Larry Summers. Yes. Larry Summers was a lawyer? Q. I think perhaps he was the president of a college? A. I don't know. Q. No? A. No. Q. Well, then among those that you recall, Mr. Nowak, the biologist and Mr. Risorski, did they ever have massages that you can recall? A. I cannot recall, no. Q. Was it your impression that Mr. Epstein liked to surround himself with extraordinarily bright people? A. Yes. MR. CRITTON: Form. BY MS. EZELL: Q. And is it your impression, also, that he's rather bright and brilliant himself? A. Yes. MR. WILLITS: Form. BY MS. EZELL: Q. id -- did you ever gain the impression that Po PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181754

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he was some sort of brain scientist? MR. CRITTON: Form. THE WITNESS: No. No. No. I know his background. And I -- over the years I learn how he come up and into the business and how he make his fortune. And I don't think he was a brain scientist. BY MS. EZELL: Q. Nobody ever told you that? A. No. Q. If you take a look again at page 9 of the transcript, Exhibit 2? A. Okay. Q. Let me call your attention to line 2, which begins with the question: "Did he have girls come over to give massages?" A. Yes. And you said: "Yes." 10] A. Yes. Q The next question is: "How many massages would he have in one day?" And I think you said earlier, maybe -- sometimes they'd have three a week? A. No. No. That was not the question. Sometimes he had one, two or three a day. Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181755

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Page 207 Q. That's what I wanted to ask you. Up to three a day sometimes? A. Up to three a day. Q. And did that happen often? A. Very often. Or he had yoga in the morning or in the afternoon it was a massage. I don't know that again. When it was yoga, it was in the pool house. When it was massage, it was upstairs. So I don't what they did when closed doors, you know. But it was a couple of these girls that were yoga experts and they were massage therapists at the same time, so I don't know. But there were -- many times there were two, three massages a day. Also, she had a massage just about every day. Q. Meaning, Ghislaine? A. Yes. Q. Then on line 12, the question was: "Did the massage therapists seem young to you?" And you said: "Mostly, no. You saw one two young ones in the last year." A. Yeah. Q. Then, again, still -- MR. CRITTON: Object to form. BY MS. EZELL: Q. -- still talking about the massage therapist, fF PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181756

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Page 208 they asked you: "What do you mean, when they looked young?" On line 17. Do you see that? MR. CRITTON: Form. THE WITNESS: Yeah. BY MS. EZELL: QO. Then you go on to say: "I remember one girl was young. We never asked how old she was. It was not my job." And the questioner said: "Right. I understand." And you said: "I imagine she was 16 or That's correct. -- "in my judgment." Yes. MR. CRITTON: Form, I think. BY MS. EZELL: Q. There was -- the only people being discussed in all of this conversation were the massage therapists, right? MR. CRITTON: Form. THE WITNESS: Well, we discuss about N., this girl that I mention in here. I thinking about her because -- what's her name? fs PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cBGe-4b9f-8d01-ba20bcae87de EFTA00181757

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BY MS. EZELL: Q. V.? A. Vv. I think she was a massage therapist for sure, because we set up the tables for her. But at this -- MS. EZELL: Let me just -- excuse me. Just a minute. Let's make it JM. That's all. MR. CRITTON: Okay. I'm sorry. THE WITNESS: [§. And I lost my concentration. MR. CRITTON: Why don't you read his response to him? She can read it back to you. (Previous answer was read.) THE WITNESS: Yeah. I was -- in this statement I was thinking of her, i. -- no, V. BY MS. EZELL: Q. R.? A. Sorry again. It was MM. that I knew she was underage and I knew it because I went to the high school and pick her up. But she was not a massage therapist, -- No, she was not. -- as far as you know? Fe PROSE COURT REPORTING AGENCY, INC. PF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Jafc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181758

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Page 210 | A. As far as I know, she was not. Q. And you were talking throughout this page about those girls that came to give massages? | MR. CRITTON: Form. BY MS. EZELL: Q. Correct? MR. CRITTON: Form. Argumentative. Asked and answered. THE WITNESS: No. If I says she was a massage | therapist, I would says, no. But, then again, I don't know if she was a massage therapist, too. BY MS. EZELL: Q. Okay. You do mention [JJ on page 21 of your statement. If you look at line 7, you mention a young girl, but she was not a massage therapist? Let me take a look. Page 21. At about line 7. Line 7. MR. CRITTON: But it in the context of your answer -- MS. EZELL: Sure. MR. WILLITS: And the question, too. THE WITNESS: Question: "How" -- let me start it from the beginning -- from the end. Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181759

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Page 211 Many of the -- it's been a while. It wash It was J It was J§f It was so many, §, Mj it was so many names, that I think if you name -- if you -- any girl's name, she's been there probably, a It was also a young girl but she was not a massage therapist. She came to the house as a friend. I talking about Jf because I knew she was not a Massage therapist because she went to high school and she was a singer, an opera singer and she was brought to the house by her mother. So I knew they had nothing to do with massages. They were friends and they were going to the movie with her, dinner with her. And she had -- I think she travelled with her, too. They travel. Q. My only point is, that on page 9 you were talking about the massage therapists. And you said that you remember that there were a couple of young ones the last year. And, so, among the young massage therapists that you might remember in the last year, would i be that person or -- MR. CRITTON: Form. BY MS. EZELL: Po PROSE COURT REPORTING AGENCY, INC. CT Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181760

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Page 212 -- would be the young one? Yeah. QO. You stated that Ms. Maxwell was very hard on you and you got blamed for everything, and that you -- you liked the job and you liked Mr. Epstein, but you didn't like working for Mrs. Maxwell? A. That's correct. Q. Can you tell me why, other than that she blamed you for everything? A. She came from a very wealthy family and she was -- just my opinion; I give my personal opinion -- that she was rotten spoiled and she tried to drive the house like a palace and not a home. I was -- I discussed it with her, many, many times we have discussions. And sometimes I even refuse to do her orders, knowing that I was going to be backed up by Mr. Epstein or do the right thing, my thinking of running the house should be. But we never had a good relationship at all from the beginning, I don't think so. But I was -- have to be her driver and she will go and shop all over the malls and I will have to go behind her, pay for it and bring the bags to the car. Next day or the same day she will do shopping and buy and say, John, go to this store and get it. It was a lot of work. It was a lot that she created and PF PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181761

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Page 213 most of this jobs that she created. Q. And one of those things you also had to do with her was to take her to different spas? A. Yes. Q. And there she would recruit young women to come and do massages? A. Because she was English. And she didn't know the area too much as well as I knew. So she -- she says, John, make a list of all the massage -- the spas in the area from Jupiter to Boca Raton. And we went to all the main spas. And then we went to the schools for massage therapists, and all the massage parlors, and massage, the small massage. So I make a list from the telephone book and we would go from one to the another one. I would wait in the car and she goes in. And sometime she took a couple minutes and walk out with cards, business cards. And that -- she did the recruiting. And from then, she pick up the girls and that was the end of it. I never did any recruiting and I never really saw him doing it. Q. You really never saw? A. Never saw Mr. Epstein recruiting anybody. MS. EZELL: All right. I have no other PF PROSE COURT REPORTING AGENCY, INC. TY Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181762

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Page 214 questions. Thank you, sir. MR. MERMELSTEIN: I just have a couple follow | RECROSS EXAMINATION BY MR. MERMELSTEIN: | Q. Mr. Alessi, I'll be very brief. You testified that a process server came and gave you the subpoena to appear here today, correct? | A. Yes. Q. For your deposition? A. Yes. Q. Did you call anyone after you received the subpoena to talk to them about this? A. No. Q. call anyone? A. No. Q. Did you -- how did you come in contact with Mr. Critton's office to set up the meeting that you discussed? A. His -- his secretary left me a messages on my -- in my machine. And then you called back? Then I called back. And you set up the meeting that you mentioned? And we set up a meeting for the Labor Day, Po PROSE COURT REPORTING AGENCY, INC. Fe Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181763

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Page 215 Labor Day, Monday. Q. What about -- but you said a month and a half ago -- oh, this was before you were subpoenaed, is when you had the meeting at your house with Mr. -- A. Yes, before I was subpoenaed. Q. How did that meeting come about? How did that get set up? Who called who? A. Okay. Before -- I am stuck on this question. I don't know. I think it was Mr. Critton office. I think it was Mr. Critton office. They call me. And they left me a message that I must discuss -- call Mr. -- yeah. I had a message in my phone that to call Mr. Critton because he would like to speak to me about Jeffrey Epstein. That was the message. And I call it. Then I spoke to him. We set up an appointment. I was sick at that time. And he came to my house and we discussed it. Q. Other than Mr. Critton, -- A. Yes. Q. -- in the last few months have you spoken to anyone about the civil cases or your testimony? A. No, not even my kids. QO Did you discuss this with your wife? A. My wife, yes. My kids, no. Q What did you and your wife talk about? fF PROSE COURT REPORTING AGENCY, INC. fF Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181764

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Page 216 A. Same thing, what's going on. How bad the situation was. What do you mean, "how bad the situation was?" How -- I guess how he got into this mess. How Mr. Epstein got into this mess? {Nods head.) Can you be more specific as to what you and said? A. No. It was just the publicity, you know, that his name was on the -- on the magazines and the paper and tv. And I thought that that would never happen. Q. And you and your wife felt bad for Mr. Epstein because of that? A. You know, after you know somebody and he becomes a friend of yours for ten years, I think you feel bad, no matter how bad he has made. And I don't know what he has done or what -- what the final results of this will be. I still will feel bad about it, just because the person that he was and how generous he was with me and other people. Q. Just to be clear, other than Mr. Critton and your wife, you haven't spoken to anyone else about the civil cases or your deposition testimony? A. No, sir. MR. MERMELSTEIN: All right. That's all I Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-cBGe-4b9f-8d01-ba20bcaeB7de EFTA00181765

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Page 217 have. MR. CRITTON: I have one last question. RECROSS EXAMINATION BY MR. CRITTON: Q. I want to just clear up one thing, Mr. Alessi. Go to page 9. A. Page 9, looks like the one that is important. Q. That's right. We've belabored this one to MR. WILLITS: I think the ink has worn off the page by now. BY MR. CRITTON: Q. It's Exhibit 2. This is the statement that you gave to the State Attorney's Office on November 21st of '05. Mr. Berger asked you questions about the young girl. Ms. Ezell just asked you some questions about that. So what I want to do is clarify, so that I know what -- so there's no confusion, at least in the record. On page 9, line 16, it says: "During the last year when you were working with him, what do you mean they looked young? Did they look like they were still in high school?" Po PROSE COURT REPORTING AGENCY, INC. PT Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcaes7de EFTA00181766

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Page 218 And your answer was: "I remember one girl was young. We never asked how old she was. It was not my job." Did I read that question and answer correctly? A. That's correct. Q. If I understood your testimony in response to Mr. Berger, the girl that you were referring to, because there's a reference to high school, was J.? A. Yeah, that's correct. Q. Not §.? A. No. [RB didn't look to me like a 16 year MR. WILLITS: All right. Thank you. That's all I have. MR. WILLITS: You have the right to read and sign this deposition if it's typed up. I'm not going to be ordering it, but if somebody types it up you have the right to read and sign it or you can waive that right. It's up to you entirely. If you want to waive the right to read it, tell the court reporter you want to waive the right. THE WITNESS: Can you repeat that again? MR. CRITTON: Why don't we go off the record. (Discussion held off the record.) THE WITNESS: I waive that right. I don't Po PROSE COURT REPORTING AGENCY, INC. Po Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181767

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Page 219 1 think I need to see. 2 (Witness excused.) (Deposition was concluded. ) Po PROSE COURT REPORTING AGENCY, INC. fF lectronically signed by Sandra Townsend (401 ‘ectronically signed by Sandra Townsend (401 3afc3ca0-cB6e-4b9f-8d01-ba20bcae87de EFTA00181768