10 11 12 13 14 15 16 17 18 19 20 21 22 23 JANE DOE NO. 2, Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, Plaintiff, Vs JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 08-CV-80119 / CASE NO: 08-CV-80232 CONDENSED / CASE NO: 08-CV-80380 / CASE NO: 08-CV-80381 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182344

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—~ IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319.00XMB AB 1031 Ives Dairy Road Suite 228 13 North Miami, Florida August 7, 2009 1:15 p.m. to 5:30 p.m. CONTINUED v7 VIDEOTAPED 18 DEPOSITION 19 of ALFREDO RODRIGUEZ 22 taken on behalf of the Plaintiffs pursuant 23 to a Re-Notice of Taking Continued Videotaped 24 Deposition (Duces Tecum) 25 Suite 2218 Miami, Florida 33160 Attorney for Jane Doe 2, 3, 4, 5, 6, and 7. JANE DOE NO. 101 CASE NO: 08-CV-80591 o eo ~N a MPbWUNne ROTHSTEIN ROSENFELDT ADLER Plaintiff, BY: BRAD J. EDWARDS, ESQ., and (CARA HOLMES, ESQ. Vs. Las Olas City Centre 10 Suite 1650 401 East Las Olas Boulevard JEFFREY EPSTEIN, 1 Fort Lauderdale, Florida 3 10 for Jane Doe and ll / 1 " 14 PODHURST ORSECK = JANE DOE NO. 102, CASE NO: 08-CV-80656 BY: KA ew. ESQ. Plaintiff, 15 25 West Flagler Street 14 Vs. Suite 800 15 JEFFREY EPSTEIN, 16 Miami, Florida 33130 16 —_— Defendant. Attorney for Jane Doe 101 and 102. / a7 LEOPOLD-KUVIN 18 19 BY: ADAM J. LANGINO, ESQ. 19 2925 PGA Boulevard 20 20 Suite 200 rn 21 Palm Beach a Florida 33411 22 Attorney for 23 24 25 2 (Pages 271 to 274) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182345

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Page 277 ; APPEARANCES: 1 Deposition taken before MICHELLE PAYNE, Court ' 2 Reporter and Notary Public in and for the State of ° 2290 10th Avenue Wort 3 Florida at Large, in the above cause. 4 Suite 404 4 wee 5 pwned” deadaay 5 THE VIDEOGRAPHER: This is a continuation Appeared via 6 of the deposition of Alfredo Rodriguez. 8 7 Today is Friday, August the 7th, the year BURMAN, CRITTON, LUTTIER & 8 2009, starting time approximately 1:15 p.m. 8 COLEMAN, LLP _ 9 Will the court reporter please swear in 9 515 North Flagler Drive i ipo Suite 400 Thereupon, 10 West Palm Beach, Florida 33401 12 ALFREDO RODRIGUEZ, u Attomey for Jeffrey Epstein. 13 having been first duly sworn or affirmed, was 12 14 examined and testified as follows: 8 ALSO PRESENT: 15 MR. CRITTON: Before we get started just 16 with regard to Ms. Ezell represents Jane Doe , ER ry OF ANGSAM, VIDEOGRAPH 17 101 and 102, the alleged time of her 16 18 incidents as of least have been plead in the v7 19 complaint for 101 is ‘99 -- I'm sorry, '98 18 20 through 2002, with Jane Doe 102 the Spring ed 21 of -- Spring/Summer of 2003. Mr. Rodriguez 21 | 22 never even began employment until '04 and 22 | 23 ‘05. I think her questioning I think -- I 23 | 24 can't say she doesn't have standing based on the court order, but I would say it's Page 278 = CONTINUED INDEX OF EXAMINATION }1 completely irrelevant and immaterial and has ; 2 no probative value with regard to this WITNESS DIRECT CROSS REDIRECT RECROSS 3 | 3 particular witness based upon the two ; ALFREDO RODRIGUEZ 4 clients at least that are in suit at this 5 point in time. == 6 MS. EZELL: As Mr. Critton well knows I 5 (By Mr. Willits) 334 453, 469 7 represent a number of other clients whose , 8 cases have not been filed and I believe we , “rom “ 9 do have standing to ask questions, and I do 5 (By Mr. Edwards) 419, 454, 468 10 intend to do that today. 11 EXAMINATION > eine “ 12. BY MS, EZELL: 10 13 Q. Mr. Rodriguez, you stated last time that 14 there were guests at the house, frequent guests, oS Rene eee 15 friends from Harvard. 14 3 Drawing 315 16 Do you remember that testimony? 15 4 Photograph 327 17 A. Yes, ma'am. is $c 3 18 Q. And was there a lawyer from Harvard named } 18 7 Photograph 331 19 Alan Dershowitz? 19 8 Photograph 331 20 A. Yes, ma'am. a (eawan4, §, 6, 7, and 8 wore eeteined by Me. 21 Q. And are you familiar with the fact that Ezell.) 22 he's a famous author and famous lawyer? 22 23 A. Yes, ma'am. 3 24 Q. Howoften during the six months or so 25 25 that you were there was Mr. Dershowitz there? 3 (Pages 275 to 278) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182346

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Page 279 Page 281 14 have i 16 A. Yen ma‘am. 17 Q. Were there other young ladies there when 18 Mr. Dershowitz was there? 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 +BY MS. EZELL: 22 Q. Do you have any idea who those young 23 women were? 24 A. No, ma’am. Q. Were any of those the young women that Page 280 1 you have said came to give massages? 1 2 A. Yes, ma'am. 2 3 Q. And do you have any idea whether or not | 4 Mr. Dershowitz was also receiving massages? 4 5 A. I don't know, Ma'am. 5 6 Q. I want to ask you to take this piece of 6 7 paper, please, and a pencil -- 7 8 MR. WILLITS: Can anybody hear me? 8 9 MS, EZELL: Yes. Can you hear me? 9 10 MR. WILLITS: I've heard nothing for 10 11 about a minute or so. 11 12 MR. CRITTON: Can you hear me now? 12 13 MR. WILLITS: Yes. 13 14 MS, EZELL: I'm asking questions, I'm 14 15 sorry. 15 16 MR. CRITTON: Why don't we go off the 16 17 record for a second. 17 18 (Thereupon, a discussion was held off the 18 19 record.) 19 20 THE VIDEOGRAPHER: We're back on the 20 21 record. 21 22 +BY MS. EZELL: 22 23 Q. Mr. Rodriguez, you indicated that there 23 24 were several staircases in the house? 24 25 A. Yes, ma'am. 1 A. Two or three times. 1 Q. Can you tell me where those were? 2 Q. And did you have any knowledge of why he | 2 A. One in the kitchen, and the one in the 3 was visiting there? 3 formal -- the main entrance. And there was one . 4 A. No, ma‘am. 4 more added later on, but there is two when I was 5 Q. You don't know whether or not he was a 5 working there. 6 lawyer -- acting as a lawyer or whether he was 6 Q. Could you just give me a rough sketch of 7 there as a friend? 7 the house of where the main entrance was and where 8 A. I believe as a friend. 8 the kitchen was? 9 Q. Were there also young ladies in the house 9 A. I'm not an architect but it's something 10 at the time he was there? 10 like this. This is the kitchen, this is the main 11 MR. CRITTON: Form. 11 entrance. 12 THE WITNESS: Yes, ma'am. 12 Q. Will you mark the kitchen with a K, 13. BY Me EZELL: 13 please, and the main entrance with ME? grok >oro> foyer, and the pool. the foyer staircase began? And KS where the kitchen staircase began. This is the pool. The pool? Yes, ma'am. And in the upper left? In the terrace, yeah, there was a balcony And where were the staircases? This is one, the kitchen, one in the Q. Okay. And would you just put an F where Page 282 And you said that later another staircase was added? A. Yeah, we rehabilitated this, you know, but you asked me how many stairs there were, to answer your question there were three. Q. Three, So where was the third one? A. The pool, this leads to the pool. Through the outside master bedroom you could go downstairs to the pool. Q. Okay. A stairway then from the outside, from outside the master bedroom? Yes, ma'am. Down to the pool? Yes, ma'am. One of your duties was to answer the . Is that correct? Yes, ma'am. Which door would you answer? Mainly the kitchen. And why was that, why would people mainly come to the kitchen? I A. I'll say it was for practicable reasons because not to go to the main -- it was shorter because the entrance was here, so this was the \ driveway and we used to take into the back door of | a ororsoror 4 (Pages 279 to 282) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182347

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WON AUDAWNH WONAUDBWNe NER RB eee eee OSOWANAUAWNrF OC 21 24 Page 283 the kitchen and they will wait there. Q. Allright. Would you just put BD where the back door of the kitchen was, please? Now, these young women that came to give Mr. Epstein massages, would they usually come to the kitchen door? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. Did any ever come to the front door? A. Very rarely. Q. And you would let them in the kitchen? A. Yes, ma'am. ._ And then how did you then turn them over to ? MR. CRITTON: Form. THE WITNESS: I will call her. BY MS, EZELL: Q. How would you call her? A. On her cell phone and she will know they were waiting in the kitchen. Q. And would you bring them in the kitchen and then just leave? A. Yes, ma'am. Q. And where would you go? Page 284 A. To my -- to the staff house that was here. Q. Good, I was going to ask you to show me where the staff house is. Just put SH. A. It was just maybe five feet, I used to stay here. Q. Okay. So what you're saying, it’s about five feet from the kitchen? A. More or less, yes. Q. Was it connected to the house? A. No, it's detached but it's very close proximity. Q. Okay. So to get to the staff house would you come out the kitchen door? A. Yes, ma'am. And I came through my -- there was two entrances, one through the laundry here and one to the main entrance to the staff house. Q. All right. And what was your usual pathway if you left the kitchen to enter the staff house, how would you generally do it? A. Normally I will came to the laundry, the laundry was here and my office was next to the laundry. Q. Okay. Thank you. WON AU DAWNe 10 j11 112 13 15 | 16 |17 18 | 19 | 20 21 22 23 24 25 WONAUDBWNe A. You're welcome. Q. Could you see the pool from the staff house? A. No, ma'am. Q. How would you know, or would you know when the young women were brought downstairs after ff giving the massages? } MR. CRITTON: Form. THE WITNESS: I will hear the commotion, some voices, but I was not told they were leaving. BY MS. EZELL: Q. And so did you have any duties that had anything to do with their leaving? A. Check the security and see if the gate was Closed, that the cars were locked because the garage were here. Q. Would you put a G where the garage was? I believe you testified that you were required to have on your person $2,000 everyday? A. More or less, Ma'am. Q. And if you open the door and a young woman -_ there to give a massage you would call and go back to the staff house? A. Yes, ma'am. Page 286 | Q. And then you believe would come in and lead the young woman upstairs. Correct? MR. CRITTON: Form. THE WITNESS: I'm sorry, can you repeat your question? BY MS. EZELL: Q. I'll try to, yes. When you would answer the door and there would be a young lady there to give a massage. A. Yes, ma'am. Q. I believe you testified you would let her in the kitchen. A. Yes, ma'am. Q. And you called (AE? A. Yes, ma'am, Q. And you then left her in the kitchen alone? A. Yes. Q. And went to the staff house? A. Yes, ma'am. Q. And sometimes you heard the commotion when the young woman was leaving -- A. Yes, ma'am. Q. -- but you didn't necessarily see them 5 (Pages 283 to 286) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182348

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WONODUDAWNE N NNN RRR Ree eee RRESRRSSSNURRREENESwmnauswne Page 287 leave. Is that correct? 1 A. Exactly, yes, ma'am. 2 Q. How did the money that you 3 were keeping to to pay those young 4 women? 5 A. would tell me who to pay and how 6 much, that's the way we work. 7 Q. And when would she tell you that? 8 A. She will call me by phone and say I'll 9 give so much to so on and so forth. 10 Q. Okay. Was that at the conclusion of the 11 massage? 12 MR. CRITTON: Form. 113 THE WITNESS: Yes, ma'am. 14 BY MS. EZELL: 15 Q. Okay. Then I'ma little confused because 16 I thought you said that you didn't see them when 17 they left from giving the massage. | 18 A. She will call me and she will say pay X, 19 Y, or Z, and that's the way I knew how much and to | 20 whom. But sometimes they would leave and I didn't | 21 pay those, I don't know who paid them. 22 Q. Okay. So if she calls you and told you 23 to pay X, Y, and Z $200, would you then go back 24 into the kitchen and give X, Y, and Z $200 each? | 25 Page 288 A. Sometimes in the kitchen, sometimes in the driveway I will pay them in an envelope, you know. Q. Okay. And she would tell you how much to pay them? A. Yes, ma'am. Q. Where was Ms. when you would call her to tell her that there was someone at the kitchen door to give a massage? A. She was inside the house so I call her on her cell and say, Alfredo, leave them in the kitchen, but I don't know where she was. Okay. Did she have an office? No, ma'am. Did she have a computer in the house? Yes. Where was her computer? She had a laptop but she usually work in the di ning room. Q. And where was the dining room? A. All this area facing the ga north -- I'm sorry, facing south, and a POProro BROUNEBSSYRREGSES eovauaune Page 289 A. Yes. The whole south face of the house, but this was Q. All right. so did she usually work with her laptop on the dining room table? A. She will have all over the house but she will sit down here to work on the desk. Q. Do you know whether she kept any lists of | names of girls to come and give massages? { A. She did, Ma'am. ' MR. CRITTON: Form. i BY MS. EZELL: Q. And do you know in what form she kept those? A. She had notes, you know, she always have papers, but I don't know. Q. Do you recall seeing the papers with telephone numbers on them? } A. Acouple of times. | Q. Do you know whether she also kept records } on the computer relating to the girls? , MR. CRITTON: Form. } THE WITNESS: Yes, ma'am. BY MS. EZELL: | Q. And how do you know that? A. Everything was recorded in -- everything Page 290 we did as employees we used to record and kept in the internal circuit we used to have among the employees. Q. And so would it be, if I understand you correctly then, was there some sort of a program so that could access information that Ms. was putting into that program and she could access information you put in? A. Yes, ma'am. Q. And did you also send each other e-mails that way or did you use a different program for e-mails? A. didn't send direct e-mails to me but she will call me on her cell. But I was supposed to send through Citrix to other employees. Q. E-mail them through Citrix? A. Yes, ma'am. Q. Okay. And who would those other employees be, have been, I mean, while you were there? A. Mrs. Maxwell, Bella in New York, mostly the main people, you know, Bella and -- Q. Lesley was -- A. Lesley, yes, the secretary, and somebody 6 (Pages 287 to 290) was at her desk here. Q. So did the dining room have large windows? Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182349

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WON ODUAWNe GEOSESSEURGEORESwemnauaune else, I don't recall. Q. Was there anyone else that you could e-mail? A. We could e-mail anybody in the organization. Q. On that particular program? A. Yes, ma'am. Q. And so who else would be in that organization? A. Other household managers from Paris or the Island, Manhattan. Q. Do you know whether Ms, BB kept any pictures of the young women who would come to give massages on her laptop? A. Yes, ma'am. Q. You saw those pictures? A. Yes. Q. Were the pictures uniform? And by that I mean, were they all taken, for instance, there at the house so that they would all be fairly standard? MR, CRITTON: Form. THE WITNESS: They will be all over, you know, sometimes out of the country and sometimes in the house. Page 292 BY MS. EZELL: Q. Were these pictures that were taken by someone for the purpose of keeping them in that program? A. I don't know. MR. CRITTON: Form. BY MS. EZELL: Q. Or opposed to, for instance, one of the young ladies bringing a picture to give to Ms. ? A. I don't know. Q. You don't know where the pictures came from? A. No, ma'am. Q. Do you know was there anyone staying in the house who often took pictures of young women? MR. CRITTON: Form. THE WITNESS: There was several cameras in the house and they were used often, but I don't know who used them. BY MS. EZELL: Q. Okay. Do you remember what kind of cameras they were? A. The small compact camera. Q. Any other kind? NESwCmyauawne WON OAUDBWN eH Geil aril arian RWNRKO 15 16 17 18 19 Page 293 fi A. I don't remember, ma'am. Q. Did you ever see using that small compact camera to a picture of the girls? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. When you saw her doing that where were they, the girls? A. The dining room, the library, the first floor of the house. Q. Did you ever see Ms. Maxwell taking pictures of the girls? A. No, ma'am. Q. Did you ever see Mr. Epstein taking pictures of the girls? A. No, ma'am. Q. Were you ever told by anyone that Mr. Epstein sometimes took pictures of the girls? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And do you recall who told you that? A. I think it was Q. Do you recall she said about that? Page 294 A. He likes photography and he likes -- like } a hobby. Q. Do you know which camera or what kind of camera he used to take those pictures? A. No, ma'am, Q. And you said I think you never saw him taking them? A. Yes. Q. So-- MR. CRITTON: Yeah meaning correct? THE WITNESS: Yes. BY MS. EZELL: Q. Was it your understanding that he took those pictures upstairs? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS, EZELL: Q. And when you had occasion to go upstairs do you recall seeing camera equipment? A. No, ma'am. Q. Were you ever told that he took pictures of the girls nude? A. No, ma'am. Q. Were you ever told that he liked to have pictures taken of the girls nude? 7 (Pages 291 to 294) Kress Court Reporting, Inc. a 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182350

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WAN AUMDAWNeE NNN RRR ee ee eee BOBRSSaSURRRGNESeCmvauswne & MR. CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. I believe you were asked before in the deposition about the stairway leading from the kitchen upstairs and whether or not there were pictures on that stairway. A. Yes, there were pictures. Q. Were those pictures some of them of nude young women? MR. CRITTON: Form. THE WITNESS: Not on the stairway, they were in the foyer in the second -- on the foyer and the foyer leading to the master bedroom. BY MS. EZELL: Q. Isee. Were those -- what size generally were those pictures? A. They were, you know, I'll say three by Q. So very large -- A. Yes, ma'am. Q. -- pictures? Were there lots of photographs just around the house on top of furniture in the various rooms? A. Yes, ma'am. Q. And were any of those photographs of young women in the nude? A. Yes, ma'am. Q. Did you recognize any of those young women? A. Yes, a couple. Q. And who was it that you recognized? A. and some other girl from Brazil that was in house but I don't remember her name. Q. Was this a girl that would come and stay in the house or one of the girls that would come and give massages? A. They will stay at the house. Q. Stay at the house. Do you recall a picture of the girl, of a young women nude in a hammock? MR. CRITTON: Form. THE WITNESS: No, I don't remember. BY MS, EZELL: Q. Was there surveillance equipment installed in the house? A. Yes, ma'am. MR, CRITTON: Form. Page 296 WOANOAUDBWNe Page 297 BY MS. EZELL: Q. And was that already installed when you came there? A. Yes, ma'am. Q. Where is it you -- first of all, did they tell you where the equipment was installed? A. No. Q. Did you have any understanding of where the equipment was installed? A. No. Q. Do you know whether or not there was surveillance photography equipment upstairs and downstairs? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And how do you know that? A. I read it through the FBI report after the fact that I -- after I left the job. Q. Before reading through the FBI report did you have any knowledge of the fact that there was surveillance equipment both upstairs and downstairs? A. No, ma'am. Q. While you were there was there ever an occasion when someone came to do any maintenance or repair on the surveillance equipment? A. Yes, ma'am. MR. CRITTON: Object to the form of the last question. MS. EZELL: Pardon? MR. CRITTON: Form of the last question. BY MS. EZELL: Q. Did that happen more than one time? A. I believe so, yes, ma'am. Q. Do you have any recollection of who came there, either the name of the company or the name of the person who would come to repair or do maintenance on the video equipment? A. We used to have a young technician from Ohio who used to maintain all the computers and he would be the only one dealing with those things. Q. So he maintained the computers and the video equipment. A. Yes. Q. Is that correct? MR, CRITTON: Form. BY MS. EZELL: Q. Do you have any recollection of what his name was? 8 (Pages 295 to 298) Kress Court Reporting, Inc. Bina 7115 Rue Notre Dame, Miami yi 41 EFTA00182351

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Page 299 A. I don't remember, Ma'am. He came from Page 301 video, even phones. New Albany, Ohio. Q. Would he also repair the televisions if Q. From New -- they needed work? A. New Albany, Ohio. A. No. Q. New Albany, Ohio. Did he have his own business? A. No, he worked for Mr. Epstein. He will maintain all the computers. Q. Was he there everyday? 10 A. No, ma'am. 11 Q. Do you know whether at that time Mr. 12 Epstein had an office in Palm Beach? 13 A. Not outside the house, no. Q. No. Did you have any kind of intercom system in the house? A. Yes, ma'am. Q. And what kind of system was that? A. It was standard office equipment, Lucid Technologies maybe, but it was an intercom like we using right now. i MS. EZELL: Just let the record reflect that the witness pointed to the telephone on WONAUMDAWNe 14 Q. Do you have any knowledge of whether or the table that has a speaker phone. 15 not the video equipment was -- and I don't know THE WITNESS: Yes, ma'am. 16 the technical term, forgive me, but was it the BY MS. EZELL: 17 __ kind of equipment that would record for a certain 18 amount of time and then record over that film? 19 A. I don't know. Q. And what did you use it for? 20 MR. CRITTON: Form. A. Mr. Epstein used to page me when he 21 +BY MS. EZELL: | 21 needed me. 22 Q. You don't know? 122 Q. Did you have one of those phones in the 23 A. No, ma'am. '23 kitchen? 24 MR. CRITTON: Just for clarification, I 24 A. Yes, ma'am. may have misunderstood, but I thought he 25 Q. And was there one out in the staff house Q. And did you use that in your work? A. Yes, ma'am. Nee Ree ee SSEUSRREBNESwaNauawne Page 302 Page 300 said he didn't even know the video equipment as well? A. Yes, ma'am. Q. Do you know where others were in the existed until he read the FBI report. | MS, EZELL: He said he didn't know that 1 2 3 it was upstairs and downstairs, I believe. 4 house? MR. CRITTON: I thought he said he didn't 5 A. Probably have like 15 phones. We used to know that it even existed. 6 have three in the staff house, one in the cabana, MS. EZELL: I may be wrong. 7 two in the master bedroom, one in each room, BY MS. EZELL: 8 kitchen, dining room, Mrs. Maxwell's office, the Q. Did you know it existed before you read 9 garage. the FBI report? 10 Q. Where was Mrs. Maxwell's office? A. No, ma'am, il A. Under the stairs next to the kitchen. Q. I'm sorry, then I was wrong. 12 Q. Can you give me some idea of what size How did you know then that the young 13 space that was? technician from Ohio maintained the computers and | 14 A. It was probably -- we change the floor. the video equipment? 15 Twelve by five, something like that. A. Because we used to request -- there were 16 Q. And was the computer equipment in that always problems with the computers so he came to |17 space? the house and he was the programmer. It was very | 18 A. Yes, ma'am. sophisticated. }19 Q. Do you know whether Ms, Maxwell kept the | MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came’ move to strike the answer as nonresponsive. 21 to do massages? . me ee re BRESRBRSSSLARRENESwmnauawne BY MS. EZELL: 22 A. Yes, ma'am. Q. How did you know then that he maintained | 23 MR. CRITTON: Form. the video equipment as well? |24 BY MS. EZELL: A. Because he was in charge of computers, | 25 Q. Do you know that because you saw the 9 (Pages 299 to 302) Kress Court Reporting, Inc. FY 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182352

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WOAONAUMDWNe Ll eel eee alll cell ell ool ool ol oad BESBRSSSGVAREBRESwmvuausuwne names and phone numbers? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. Do you know if she kept pictures of the girls on the computer? A. Yes, she did. Q. And you know that as well because you happen to see them? A. Yes, ma'am. MR. CRITTON: Form to the last two questions. BY MS. EZELL: ._Were they similar to the pictures that Ms. had on her computer? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. Did the pictures that they kept there look like pictures that were posed? A. They were more casual. Q. Did they look as though the person being photographed knew that they were being photographed? MR. CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. And what can you tell me about that, what lead you to draw that conclusion? A. They were probably taken in parties in big reception or banquet. MR. CRITTON: Let me offer as a suggestion, not that you have to accept or that you would, you're using the term young girls generically, he has probably seen many, many young girls, there was no -- you've used it interchangeably with just young girls versus young girls who may have come to -- purported to give a massage and, therefore, that may be a different answer, so that's part of my form objection. MS. EZELL: Okay, thank you. BY MS. EZELL: Q. When I asked you about Ms. | | whether she had a list of the girls and telephone numbers, I think I asked about those girls that came to give massages, but let me go back and just ask it that way. Did you notice that Ms. I had a list of the girls that came to give massages on her Page 304 WOON AMNAWNeE Nee Ree ee ee ee SCWUMNAMAWNRHO N = | 22 23 24 25 BNESCMNaUSUNe 14 15 16 17 18 19 20 21 22 24 25 computer? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS, EZELL: Q. And did she generally have phone numbers for those girls? A. Yes, ma'am. Q. And were they generally pictures of the girls? MR. CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. And did Ms. Maxwell have a list of the girls who came to give massages? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. Did she have telephone numbers generally? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. Were there pictures on her computer of the girls who came to give massages? MR. CRITTON: Form. BY MS. EZELL: Page 306 | Q. Ms. Maxwell I'm talking about. A. Yes, ma'am. Q. And were those pictures the more casual ones that you described when I asked whether or =| not the subject looked as though she knew she was being photographed? : MR. CRITTON: Form. THE WITNESS: I'm sorry, can you repeat? BY MS. EZELL: Q. Yeah. The pictures of the young girls who came to the house to give massages that were | on Ms. Maxwell's computer, did they appear to have | been taken when the girls knew they were being photographed? MR. CRITTON: Form. THE WITNESS: I don't think they knew they were being photographed. BY MS. EZELL: Q. I believe you said they were more casual pictures. A. Yes, ma'am. Q. Did you notice any nude photographs in those pictures? A. Yes, ma'am. MR. CRITTON: Form for the last question. 10 (Pages 303 to 306) Kress Court Reporting, Inc. FY 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182353

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Page 307 Page 309 BY MS. EZELL: Q. And was there more than one during the Q. Among those pictures in Ms. Maxwell's time you were there? computer of the young women who came there to give A. Yes. Q. Do you remember their names? A. One was David, I don't remember the other one name, Q. Did they appear to be American? A. Yes, ma'am. Q. Do you know the name IE A. Could be, ma'am, but I'm not sure of his massages, were the nude photographs in that group taken, did they appear to be taken in the house? MR. CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. You said before they appeared to be taken 10 at receptions or banquets? 11 A. Yes, ma'am. last name. 12 Q. And I'ma little confused about how they Q. Do you have any idea where those chefs 13 were casual and taken while the girls were nude at 13 had gotten their training? 14 receptions and banquets? 14 A. was working in San Francisco when 15 A. What I saw there were parties in Russia, 15 he was hired. 16 Eastern Europe, I don't know which country, but 16 Q. Was he still there when you left Mr. 17 there were also pictures of nude girls in a 17 Epstein's employ? 18 shower, for instance, in a shower stall. 18 A. Yes, to my knowledge, ma'am. 19 Q. You said for instance, so were there 19 Q. Did the chef interact with the girls who 20 other places other than the shower? 20 came to give massages? 21 A. Yes, ma'am. ‘21 A. In the kitchen, yes. 22 Q. Like what? /22 Q. And did he often offer them some food 23 A. Gatherings, you know, in a party. You 23 while they were there? 24 could tell everybody is smiling so I believe it 24 A. Yes, ma'am. was a place where they're having fun. Q. Were there occasions where a girl came to WONODAUAWNHE NE Swovnauawne Page 308 Page 310] give a massage accompanied by another girl, or another person, let me say? Q. Were any of those pictures, if you recall, taken in the cabana? 1 1 2 2 3 A. I don't remember. 3 A. Yes, ma'am. 4 Q. Do you recall there being parties and 4 Q. And sometimes was that other person a 5 gatherings in the cabana at the house? 5 woman and sometimes a man? 6 A. I don't remember. 6 A. No, ma'am, always a woman, 7 MR. CRITTON: Form. 7 Q. Always a woman. Usually would it have 8 BY MS. EZELL: 8 been a woman about the same age as the young woman 9 Q. When Mr. Epstein entertained did you have 9 coming to give the massage? 10 anything to do with seeing that the bars were 10 MR. CRITTON: Form. 11 stocked and that there was food that was needed 11 THE WITNESS: Yes, ma'am. 12 and so forth? 12. BY MS. EZELL: 13 MR. CRITTON: Form. 13. Q. Were you ever told by Ms. [IEE to pay 14 THE WITNESS: There was no alcohol inthe | 14 the person who came who didn't give a massage? 15 house, only for guests. But, yeah, he will 15 A. Yes, ma'am. 16 ask sometimes for food. 16 Q. Do you recall how much you paid that 17. BY MS. EZELL: 17 person? 18 Q. And do you ever recall him asking for 18 A. Yes, ma'am. 19 food for parties in the cabana? 19 MR. CRITTON: Form. 20 A. No, ma'am. 20 BY MS, EZELL: 21 Q. Was there a chef at the house on El 21 Q. How much? 22 Brillo Way when you were there? 22 A. 300 to 500 dollars. 23 A. I'm sorry? 23 Q. Were some of those young women who 24 Q. Achef. 24 brought other young women for massages regulars, I 25 A. Yes, there was. 25 mean, did they regularly bring other young women? 11 (Pages 307 to 310) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182354

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lolol ailartanti—4 UAWNHRFOWUAN AU AWNHE 16 17 18 19 20 21 22 23 24 25 MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And were there some who maybe came just once or twice with other young women? A. That's correct, ma'am. Q. Now, where would the young woman who was bringing another young woman go during the time the person that she brought was upstairs giving the massage? MR. CRITTON: Form. THE WITNESS: I will take them to the WOBNAUAWNe kitchen and would take them from 13 there. 14 BY MS. EZELL: 15 Q. Do you know where she took them? A. No, ma'am. Q. Were they ever taken to just sit in the living room and wait? MR. CRITTON: Form. THE WITNESS: I don't know, ma'am. BY MS. EZELL: Q. These pictures of nude young women taken in gatherings where they were smiling, did they appear to you to be taking part in an orgy? Page 312 MR. CRITTON: Form. THE WITNESS: I don't know, ma'am. BY MS. EZELL: Q. Do you know the word cavorting? A. No, ma’am, I don't know. Q. Ineed my Thesaurus. You said they were smiling, did they appear to be having a good time? A. Yes, ma'am. Q. Did they appear to be doing anything sexual? A. Yes, ma'am. Q. And in these instances were there girls doing sexual things with other girls? A. Yes, ma'am. Q. And I'm still talking about the pictures on Ms, Maxwell's computer. A. Yes, ma'am. MR. CRITTON: You're talking about the group shots that he's mentioned from Russia and Eastern Europe? MS. EZELL: And girls in the shower. MR. CRITTON: Let me object to the form then the way you just now described that. MS. EZELL: He said for instance. MR. CRITTON: He had said a girl in the Page 313 shower, I don't know whether he ever used plural. BY MS, EZELL: Q. Was there more than one picture of a girl in the shower? A. There were two girls in the shower. Q. Two girls in the shower together? A. Yes, ma'am. Q. And were those two girls engaged in something sexual? A. Yes, ma'am. Q. And I may have asked you this question, forgive me if I did, did you know those two girls? A. No, ma'am. . Did Ms. Maxwell have nude pictures of on her computer? MR. CRITTON: Form. THE WITNESS: I don't know, ma'am. BY MS. EZELL: . Did you ever meet a young woman named who had an association with Ms. Maxwell? MR. CRITTON: ? MS. EZELL: THE WITNESS: I don't remember, ma'am. BY MS. EZELL: Page 314 | Q. Did you ever have any conversations with Ms. Maxwell about any of the women in those pictures? A. No, ma'am. id you ever have a conversation with mea =: any of the pictures of the girls in her computer? A. No, ma'am. Q. You were asked last time about the creams and lotions that Mr. Epstein typically had available to him and you said you thought there was a favorite one but you couldn't remember it. A. Spa. Q. Spa, you did say Spa. A. Yeah. Q. Thank you. Where did the stairway from the kitchen lead -- to where did it lead? A. To the second floor between the first and second bedrooms. Q. Were either of those bedrooms the master bedroom? A. No, ma'am. Q. Could one go up that staircase through -- could one go up that staircase and reach the 12 (Pages 311 to 314) Kress Court Reporting, Inc. eer mccr 7115 Rue Notre Dame, Miami , FL 33141 EFTA00182355

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Page 315 15 master bath, and there were one, two -- the 16 rest of the bedrooms were here and the 17 master bedroom was here. This is master 18 bath one and master bath two. 19 So the staircase came to the second floor 20 like this and it was between the first and 20 21 second bedroom. And you could go through 21 22 here and you enter a foyer with double doors 22 23 here, double doors here, and you enter the 23 24 master bedroom. 24 25 BY MS. EZELL: 25 1 master bedroom? 1 2 A. Yes, ma'am. } 2 3 Q. And how would you do that? Ifyouwant (| 3 _ 4 to turn the page over for the upstairs you could 4 5 do that. 5 6 A. Okay. 6 7 MR. CRITTON: Are you going to mark this 7 8 as an exhibit? 8 9 MS. EZELL: Uh-huh. 9 10 MR. CRITTON: Would that be Exhibit 3? 10 ll MR. EDWARDS: I think so. 11 12 (Exhibit No, 3 was marked for 12 13 Identification.) 13 14 THE WITNESS: This is the master bedroom, | 14 15 16 17 18 19 Page 316 1 Q. All right. How would you get to the 1 2 master bathroom on that end? 2 3 A. You go through these double doors, go 3 4 around the bed and you gain access to the master 4 5 bedroom -- master bathroom, sorry. 5 6 Q. And then there was another master 6 7 bathroom on the other side of the room? 7 8 A. Yes, ma'am. 8 9 Q. Where generally did the massages take 9 10 ? 10 11 A. Right here, ma'am. 11 12 Q. And is that in the master bathroom? 12 13 A. Master bathroom, yes. 13 14 Q. Do you recall what color the tile was in 14 15 that bathroom? 15 16 A. There was carpet. 16 17 Q. Was there tile on the walls or marble 17 19 A. There was a sauna here with marble but | 19 20 outside the sauna everything was carpet, and the | 20 21 walls, they didn't have any tile. Oh yes, I will )21 22 say four feet off the floor they will have marble. 22 23 Q. And do you remember what color marble it 23 24 was? 24 25 A. White. 25 Page 317 Q. White. By the way, I have some more } water, would you like some? A. Thank you, ma'am. Q. I figure if I'm a little dry you may be too. I believe one of the items that you { mentioned that sometimes had to be picked up after | girls were there giving massages was a back : massager. A. Yes, ma'am. Q. Could you describe that for me, please? A. It was a piece about this big. Q. Would you say that’s about 18 inches? A. Yes, ma'am. And two prongs with the rubber tips and a cord. Q. Okay. A. Or it could be detached too. Q. Do you have any recollection of what make that was? A. No, ma'am. Q. Were there any other massagers that you recall seeing there regularly? A. Those are the ones I remember. I think they are from Sharper Image, but I don't -- Q. Okay. Were there often girls around the pool at the house? A. Yes, ma'am. Q. And were these sometimes the same girls that came to give massages? A. Yes, ma'am. Q. Were there girls in addition to those who came to give massages who hung around the pool? A. The girls who were staying at the house. Q. Okay. And so they weren't girls who just regularly came to hangout around the pool? A. No, ma'am. MS. EZELL: Excuse me. Can we go off the record for a minute? (Thereupon, a recess was had.) THE VIDEOGRAPHER: We're back on the record with tape number two. BY MS. EZELL: Q. Mr. Rodriguez, did you receive a subpoena that asked you to bring documents with you to the A. Yes, ma'am. Q. And did you bring any with you? A. I couldn't find anything at my house. Q. Okay. I believe we talked about a journal that you kept, and you looked for that? 13 (Pages 315 to 318) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182356

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1 2 3 4 5 6 7 8 9 A. Yes, ma'am. Q. And you couldn't find_it? A. L4give it to Detective Q. A. Yes, ma'am. Q. You mentioned that you called Mr. Jean-Luc Bernell about a recommendation when you were looking for a job. A. Yes, ma'am. Q. And did you know him from his visits in the home? A. Yes, ma'am. Q. Did you say that his wife's name was Eva? MR. CRITTON: Form. THE WITNESS: No, ma'am. BY MS. EZELL: Q. Do you know what his wife's name was? A. Eva was a model, a former model from years past who was friend of Mr. Epstein. Q. Do you know if she was married to Glenn Dubin? Do you know Mr. Dubin? MR. CRITTON: Form. THE WITNESS: I believe, yeah, I'm not sure, ma'am. BY MS. EZELL: Page 320 | Q. Is she now a doctor? A. No, she was a model, her husband could be a doctor but I don't think she is. Q. Okay. So is Jean-Luc Bernell married; to your knowledge? A. I don't know, ma'am. Q. I think I must have gotten confused because we were talking about the picture in the house of the little girl who is lifting up her skirt or her underpants, I'd forgotten what it was. A. Yes, ma'am. MR. CRITTON: Form. Q. Do you know where she and her mother live? A. They live in Manhattan. MR. CRITTON: Form. Kress Court Reporting, Inc. =e ~ ~~ NRF OWUOMN OAUDBWNe WON OUDBWNe | 13 14 15 16 | 17 18 19 20 21 22 23 24 25 Page 321 ff BY MS. EZELL: Q. Did they ever visit Mr. Epstein at the home when you were there? A. Yes, ma'am. Q. How old was the little girl at that time? A. Eight years old. Q. Did the girl's father come to visit as well? A. Yes, ma'am. Q. And do you remember his name? A. No, ma'am. Q. Do you remember hearing anything about what he does for a living? No, ma'am. Can you describe him? Tall, American born, I will say 50 years PoP old. What color hair did he have? At that time it was black with a few white hairs. Q. Were there drawings of nude women in the house? A. No, ma'am. Q. Were there paintings of nude women in the house? PO Page 322 | A. Yes, ma'am. i Q. Did any of those appear to be Ms. Maxwell? A. Yes, ma'am. Q. You mentioned that | | who was still working there when you left -- A. Yes, ma'am. Q. -- was a very religious woman -- A. Yes, ma'am. Q. -- and would sometimes be upset about seeing pictures of nude girls or having to pick up sex toys, et cetera. MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And you said that you remembered her crying because there was a picture of the Pope next to a picture of a naked girl. MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS, EZELL: Q. Do you know who that naked girl was? A. I don't remember, ma'am. Q. I believe David Copperfield's name came up in the last deposition as someone who would 14 (Pages 319 to 322) 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182357

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WONAUAWN- Page 323 call or visit. A. Yes, ma'am. Q. Were you ever there when he visited? A. Yes, ma'am. Q. And do you remember did he spend the night? A. No, ma‘am. Q. Did he come for dinner? A. Yes, ma'am. Q. Did that happen more than one time when 10 you were there? 11 A. Yes, ma'am. {12 Q. Do you remember whether or not any of the | 13 young ladies who came to perform massages also | 14 WON AUDBWNeE stayed for dinner? 15 A. No, ma'am. 16 MR. CRITTON: Just so it’s clear, no, you |17 don't remember? 18 THE WITNESS: No, they were not there. | 19 BY MS. EZELL: | 20 Q. Did any of them ever stay for dinner? 21 Just any dinner, not the dinner with David 22 Copperfield. 23 A. You said they, the girls? 24 Q. The girls who came to give massages. 25 A. No, ma'am. 1 Q. In the earlier part of the deposition you 2 stated that you didn't drive the girls but then 3 later you remembered that you did sometimes have | 4 to drive them. 5 A. Yes, ma'am. 6 Q. Do you remember a young woman named fi 7 who came there? 8 A. Yes, I do remember. 9 MS. EZELL: And again, we're going to 10 have the same agreement, if we use a girl's ‘i name it will be shown on the transcript as 12 the initials only. 13 MR. EDWARDS: Agreed. 14 MR. CRITTON: Why don't you give him the | 15 initials? Because in reading the transcript we could end up with 25]f's orllls orllfs, in looking at it by just using the first, I am just offering a suggestion because none of us will remember who in the heck these people are. MS, EZELL: So you're asking me to give both names so we would have two initials? MR. CRITTON: He may not recognize either | 24 the first or the second name but as long as Page 325 we are start with it and then you can use | the initials after that for all I care. BY MS. EZELL: Q. Do you remember a girl named A. I heard that name. Q. So I will refer to her as I. from now on. T'm going to show you a document, we can mark it but I'm not going to leave it. I'm going to take the exhibit. MR. CRITTON: Wait a minute. Are you going to make a copy of it? MS. EZELL: No, I'm not going to leave a copy. MR. CRITTON:, All right. Then I object to you showing him a document that is not part of this record. MS. EZELL: Then object and the Judge can rule, but I'm going to ask him to look at this document. We can mark it as Exhibit 4. THE WITNESS: Oh yeah. BY MS. EZELL: Q. Do you remember this young woman? A. Yes. MR. CRITTON: Let's see. BY MS. EZELL: Q. And was she one of the ones who came to the house to give massages? A. Yes, ma'am. Q. Do you remember her name? A. No, ma'am. Q. Isit possible she was [IP MR. CRITTON: Form. THE WITNESS: I hear that name but I cannot say for sure. BY MS. EZELL: Q. Okay. Did she come often to the house? A. Yes, ma'am. Q. Were you ever aware of her being photographed? A. No, ma'am. Q. Iasked you about David Copperfield before and let me ask you again. In thinking about it is it possible that you remember that she was there for dinner with David Copperfield? MR. CRITTON: Form, asked and answered. THE WITNESS: Possible, yes, ma'am. BY MS. EZELL: Q. Did you ever meet her parents? A. No, ma'am. 15 (Pages 323 to 326) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami = FL 33141 EFTA00182358

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Page 327 Q. I'll take the pictures back. MR. CRITTON: Just put on the record that my client obviously could be here at the deposition, or anyone's clients could be here at the deposition and have full access to the information that's being provided, by taking the photograph back I'm not going to be able to provide to that client, nor will I have possession of it so I could discuss 10 that photograph, it's now been explored with | 10 11 this witness. 11 12 (Exhibit No. 4 was marked for 12 13 Identification.) 13 14 BY MS. EZELL: 14 15 Q. Do you recall that on occasion you drove ,15 16 this young woman to or from Mr. Epstein's house? | 16 17 MR. CRITTON: Form. 17 18 THE WITNESS: I don't remember, ma'am. 18 19 BY MS. EZELL: 19 20 Q. Do you ever recall driving her by the | 20 21 airport and showing her Jeffrey Epstein's plane? | 21 22 MR. CRITTON: Form. 22 23 THE WITNESS: Yes, ma’am. 23 24 ~=BY MS. EZELL: 24 Q. Do you ever recall one time perhaps by 25 WON AUDAWNe WONAUDBWNe accident seeing her naked? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. How did happen? A. I told to go upstairs because I saw Mr. Epstein leave, so we rushed upstairs to clean and this girl was sleeping naked in the sauna, she fall asleep there, there was nobody else there. \ MR. CRITTON: Can I ask just for clarification, is he talki about the person he thought oa bat he wasn't sure 13 PE Swmvauawne NNR RB RR Be eee SBRBRBSSeSTAREGN ER SCMVOUAWNE or the person that's in photo four? 14 MS. EZELL: The person that's in 15 photo four. 16 THE WITNESS: Yes. 17 MR. CRITTON: Okay, thank you. 18 BY MS. EZELL: 19 Q. id just so we're clear, do you think 20 this is but you're not sure? 21 MR. CRITTON: Form. 22 THE WITNESS: I heard the name so many 23 24 times but I know I took her, you know, in 24 25 the Suburban, so it was her. 25 Page 329 } BY MS. EZELL: Q. You mentioned last time that Mr. Epstein asked you to go and rent a car for one of the girls who gave him massages. A. Right. Q. Do you know if that was [.? A. I'm not hundred percent sure, ma'am. Q. Do you know how long that girl kept the car? A. Acouple of months. Q. Did she bring it back to you or did she turn it in at the agency? A. She brought it back to me. Q. Did you ever have any knowledge of Mr. Epstein helping this girl with her college applications? MR. CRITTON: Form. THE WITNESS: I believe Mr. Epstein was giving her money for good grades, that’s what I -- she told me, I understood that. BY MS. EZELL: Q. Was this the girl that you were instructed by Mr. Epstein to take roses to at the completion of her graduation? A. I don't remember exactly, ma'am, but Page 330 there were so many faces, you know, but I cannot say a hundred percent. Q. But it’s possible that this is the same girl? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. And thinking about it carefully you still believe she kept that car for two months? A. Yes, ma'am. Q. Do you recall an encounter with this same girl when you saw a strange vehicle in the driveway one day? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And what happened then? A. Isaw, you know, an old car that didn't belong to the house so I went to the police department, so the police department follow me and | they with flashlight they went into the driver and | ask her because she was -- I forgot I was suppose to pay her but it was late at night, 8:00 p.m., something like that, 8:30, so I recognize her and I said to the police department I know this girl, 16 (Pages 327 to 330) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182359

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so I paid her and she went off. Q. Do you recall how much you paid her? A. Between two and 300 dollars, I believe. Q. How often was Mr. Epstein in Palm Beach during the period you were there? A. He will stay two months -- I mean, two weeks out of the month. MS. EZELL: If I could please have these marked as Exhibits 5 through 8. 10 (Exhibit No's. 5, 6, 7, and 8 were 11 marked for Identification.) 12 MR. CRITTON: Do you want them in the 13 order you gave them? 14 MS. EZELL: It doesn't matter. 15 BY MS. EZELL: 16 Q. Would you look, please, at the exhibit 17 that has been marked as number -- what is it; 18 five? 19 A. Five. Q. Five. Do you recall seeing this young 21 woman at the house when you were there? A. Yes, ma'am, 23 Q. And do you recall her name? 24 A. No, ma'am. MR. CRITTON: Let the record reflect it's WONAUDAWNe 1 written on the photographs is a name, so 2 it's already being suggested to him, I think 3 that’s inappropriate. 4 MS. EZELL: It shouldn't be there, I'm 5 sorry. If I can erase it I will, I didn't 6 realize it was on there. 7 MR. CRITTON: It’s on all of them, Cathy. 8 MS. EZELL: You're right, sorry. 9 BY MS, EZELL: 10 Q. Looking at the girl in ber five, if I 11 told you that her name we would that 12 refresh your recollection as to who she was? 13 A. No, ma'am. 14 Q. Would you look, please, at the girl in 15__ the picture that’s been marked as Exhibit 6? 16 Do you ever recall seeing that girl come 17 to the house to give massages? 18 A. I cannot guarantee that, Ma'am. 19 Q. I understand, it's not the best picture 20 in the world either, you can't see. 21 MR. EDWARDS: I don't know that I 22 understood the answer. You can't guarantee 23 it? 24 THE WITNESS: I cannot guarantee it, sir. 25 BY MS. EZELL: Page 331 Page 332 NR Re oCwanan WOBNAUWDBWNHe al BONE OCMNaUAWNeE 15 N = 22 8 24 25 Page 333 Q. Possibly but you're not sure? | A. Yes, ma‘am. Q. Okay. Would you look, please, at the two photographs that have been marked as Composite Exhibit 7? Do you recall seeing this girl come to the house to give massages? A. I don't remember, ma'am. Q. Okay. That's perfectly all right. MR. CRITTON: Who does that purport to be; number seven? Q. The last one is exhibit what? A. Eight. Q. Eight. Do you recall seeing this girl come to the house to give massages? A. No, ma'am. Q. Okay. MS. EZELL: I don't have any other questions right now. If anybody else wants to go, if I could just reserve that if I find something. MR, WILLITS: I don't know who's next, this is Richard Willits, I have a couple of questions, MR. CRITTON: All right, you're up. MR. EDWARDS: Hold on one second, Richard, they're going to put a microphone by the phone. MR. WILLITS: I only have a couple of questions. (Thereupon, an interruption was had.) THE VIDEOGRAPHER: We're back on the record. EXAMINATION BY MR. WILLITS: Q. Back on the record. Sir, my name is Richard Willits and I just have a couple of questions for you. Do you remember irl coming to the house by the name off ool? A. I hear that name, sir. Q. You know the name, does that ring a bell at all? A. I hear the name in the house. Q. Can you associate that name with a girl? A. Yes, sir. Q. I'm sorry? A. Yes, sir, yes, I do. 17 (Pages 331 to 334) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182360

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1 Q. Do you remember whether she came to the 2 house on more than one occasion? 3 A. I heard her name several times from 4 = sir, but beyond that I cannot say anything 5 else. 6 Q. Okay. Who have you talked to about your 7 knowledge of Mr. Epstein in the last year? 8 A. My wife. 9 Q. Anyone else? 10 A. No, sir. 11 Q. Well, you talked to Mr, Critton. 12 A. We have a conversation in West Palm 13. Beach. 14 Q. Yes. So you talked to your wife, you 15__ talked to Mr. Critton? 16 A. Yes. 17 Q. Had you talked to anyone else in the last 18 year about Epstein? 19 A. No. Q. Did you talk to Mr. Goldberger? A. Yeah, I called Mr. Goldberger first before I talked to Mr. Critton. Q. Okay. So we have your wife, we have Mr. Critton, and we have Mr. Goldberger. Do we have anyone else that you talked to Page 336 in the last year? A. No, sir. Q. How about Mr. Epstein of course? A. No. Q. Where did you usually keep the journal with the names of the girls, in what part of the house? A. In the staff house. Q. Sorry? A. The staff house, the guest house. Q. Right. But you said you had a journal at your own residence with the names of the girls. A. I give the whole journal and all the information regarding this case, sir, to Detective sir. Q. Okay. And the materials that you gave to the Detective, were they kept -- were any of them kept at your own personal residence? A. Yes, they were with me, sir. Q. Okay. When you gave the materials to the Detective, did all of the materials you gave to him come from your residence? A. Yes. Q. Do you remember exactly what you gave to him? NNER RE eee eee Kress Court Reporting, Inc. Page 335 BESSSURREGNESwMmVauawne RB WONOAUDBWNe Page 337 A. I give him a list of notes that I used to take from frequent people -- I mean, people who used to frequent the house and -- I'm sorry, it's been a few years, I don't remember, but it was those years, like it was a file with my personal notes because he told me it was very important and he kind of said can I borrow this from you, and he still has those documents, sir. Q. So even though they pertain to Mr. Epstein you kept those notes at your residence? A. Yes, sir. Q. Okay. Where in your residence did you keep those notes before you gave them to the Detective? In my bedroom. Did you have a file cabinet or -- No. -- chester drawers or something? No, they were laying next to some other papers that I have. Q. Did the other papers pertain to Mr. Epstein? A. No, no, nothing else related to Mr. Epstein. Q. I'm just confused as to why you told us PoOPro> Page 338 before that you had a journal at home and today you say that you gave everything to the Detective. MR. CRITTON: Form. You also may have missed a portion of his earlier testimony if you couldn't hear something, but go ahead. MR. WILLITS: Most likely. THE WITNESS: What I said was I thought I had some information, and then I look with my daughter and we couldn't find anything, and I remember now that I ing in the fle thet I give to Detective ll BY MR, WILLITS: Q. Did anyone help you assemble those papers to give to the Detective? A. No, sir. MR. WILLITS: I don't have any other questions. CROSS EXAMINATION BY MR. CRITTON: Q. Mr. Rodriguez, my name is Bob Critton and I represent Mr. Epstein as you're aware, I have a few questions for you. What I would like to remind you at the start of this is if you know something, tell us, if you don't know something tell us that. 18 (Pages 335 to 338) 7115 Rue Notre Dame, Miami = FL 33141 EFTA00182361

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WOON DU DAWNe WONAUDWNHe 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 339 You're not required to speculate, you're 1 not required to guess, you're not required to 2 assume because some lawyers ask you a leading 3 question or suggested in a report or like the 4 police report like Mr. Mermelstein and Mr. Edwards 5 did, that did you tell the police officers X, Y, 6 or Z without showing you the statement. You're 7 not required to guess, I want personal knowledge, 8 not speculation. Do you understand? 9 A. Yes, I do. 10 Q. Allright. Now, when Mr. Edwards and -- 11 Mr. Horowitz is here today for Mr. Mermelstein, 12 but you remember a lawyer asked you some questions 13 last time you were here? 14 A. Yes. 15 Q. That is he started and he went on for a (16 few hours. Do you recall that? 17 A. Yes, I remember. | 18 Q. He asked you do you remember telling the /19 police officer Y, X, or Z. | 20 Do you remember that? Do you remember 21 that's how he phrased his question? 22 A. Yes, yes. | 23 Q. He never showed you a statement that you | 24 made to the police department; did he? Page 340 A. I'm sorry? 1 Q. He didn't show you a document that said, 2 question, you know, what is your name; answer, my | 3 name is Alfredo Rodriguez -- 4 MR. WILLITS: Object to the form of the 5 question. 6 MR. CRITTON: You need to let me finish 7 it first. 8 MR. WILLITS: I'm sorry, I thought you 9 were, | 10 BY MR. CRITTON: 11 Q. He never showed you a statement of what | 12 the question was and the answer that you gave. 13 True? 14 MR. WILLITS: Object to the form of the 15 question. 16 THE WITNESS: I don't exactly understand 17 your question. 18 BY MR. CRITTON: 19 Q. Do you know what a deposition is? A. Yes, lam. Q. That's what you're doing here. MR. CRITTON: Could I borrow your deposition for just a minute? MR. HOROWITZ: The transcript? It’s Page 341 marked up, no, you can't. MR. CRITTON: I just want to show him. Thank you, Cathy. BY MR. CRITTON: Q. This is the first what Ms. Ezell was kind enough to provide is the first part of your deposition, it was transcribed by the court reporter and provided by all counsel. Do you understand that? A. Yes, I understand that. Q. And no one has provided that to you yet today; have they? A. No. Q. Now, I think you told us that with the police officers you gave a taped statement. Did I understand you correctly? A. Yes. Q. And the only conversation that you had with the police officers, and it may have been a state attorney, it was somebody named Ms. Weiss who I think was referenced in the questions, the only time that you talked with at least Officer and the State Attorney's Office from Palm inty was in a taped statement. Is that correct? Page 342 A. No. Q. Did you talk with them separate and apart from that? A. Yes, I did. Q. Okay. Did they tape that statement? A. No, Q. You told us you also spoke with representatives of the FBI? A. Yes. Q. Okay. And you distingui between the FBI and between Officer ? A. Yes. Q. So how many times did Officer or Detective I think he's from the Palm Beach Police Department speak with you? A. Like three or four times. Q. But he only took one statement? A. One taped. Q. I'm sorry, one taped statement? A. Yes. Q. Allright. So as to if you said something to Officer or not that you would be able to confirm, that would only have | been in a taped statement, one taped statement out of the three, approximately three times he spoke | 19 (Pages 339 to 342) Kress Court Reporting, Inc. rarer 7115 Rue Notre Dame, Miami , FL 33141 EFTA00182362

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1 with you. 1 2 MR. EDWARDS: Form. 2 3 MR. HOROWITZ: Form. 3 4 BY MR. CRITTON: 4 5 Q. Is that correct? 5 6 A. Yes, correct. 6 7 MR. WILLITS: Object to the form. 7 8 MR. HOROWITZ: Join. 8 9 BY MR. CRITTON: 9 10 Q. And when we were here, I think it was 10 11 last week or the last ten days anyway -- I could 11 12 tell you. On July 29th of this year, and Mr. 12 13 Mermelstein started with your deposition and then | 13 14 others asked questions, when Mr. Mermelstein and I | 14 15 think Mr. E asked questions about did you 15 16 tell Officer X, Y, or Z, they didn't show 16 17 you a statement, they didn't give you like a 17 18 transcript like this and say see what the question 18 19 and see what the answer is? 19 20 A. No. 20 21 MR. EDWARDS: Form. 21 22 MR. WILLITS: Object to the form of the 22 23 question. 23 24 BY MR. CRITTON: 24 Q. And you haven't had an opportunity to see Page 344 1 your taped statement since you gave it many years | 1 2 ago? 2 3 A. No, sir. 3 4 Q. Would you agree that your taped statement | 4 5 would probably be a little more accurate than your 5 6 testimony today because of the time period that 6 7 has transpired? 7 8 A. That's correct. 8 9 MR. HOROWITZ: Object to the form. 9 10 MR. WILLITS: Object to the form of the 10 ll question. 11 12 BY MR. CRITTON: 12 13 Q. When you spoke with the FBI over at 13 14 Greens -- I think it was Greens Pharmacy? 14 15 A. Yes. 15 16 Q. Did they take a statement from you, that 16 17 _ Is, did they have a tape recorder or did they just 17 18 make notes? 18 19 A. They took notes. 19 20 Q. Allright. Did you sign anything? 20 21 A. No, sir. 21 22 Q. That is like did they take notes of what 22 23 you said and then you signed it to say yep, that 23 24 accurately reflects what I said? 24 25 A. No, I didn't sign anything. 25 Page 345 Q. When Officer took - spoke with you on those approximately two times when he did not take a taped statement, did he ever present anything for you, anything in writing that he had written to say, Mr. Rodriguez, I would like you to review this to make certain that I took down correctly what you said? A. No, sir. Q. If he had offered to do that would you i have read what he wrote down to determine whether or not he took down that which you had said or told him? MR. EDWARDS: Object to the form. THE WITNESS: Probably I will read it first. BY MR. CRITTON: Q. Allright. And if in fact he had recorded something incorrectly or recorded in a particular way that he wanted it phrased and it was not accurate, would you have told him that? MR. EDWARDS: Object to the form. THE WITNESS: No, I never told him that. BY MR. CRITTON: Q. Listen to my. If he, Officer , had taken down Page 346 } what you said and it was not accurate, that is, he put his interpretation of what you said, would you him that's not accurate, Officer ? MR. HOROWITZ: Form. MR. EDWARDS: Object to the form. THE WITNESS: I will tell him. MR. CRITTON: Go ahead and change. We're |} going to change the tape. We do have time. Cathy, could I borrow back the photographs, please? While you're giving me those back, would it be correct that you're going to keep -- you took as you did with photograph number four you took back five, six, seven, and eight, and you're going to keep those and not allow me or anyone else to have a copy of them? MS. EZELL: Yes. MR. CRITTON: You're going to be equally restrictive; right? MS, EZELL: Right. MR. CRITTON: All right. Thank you. BY MR. CRITTON: Q. You were shown photograph five of a lady, 20 (Pages 343 to 346) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182363

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WONAUDWNHe Swemvauawne _ e NN NNN Ree eee ee BRSRRSSAUAGRGN , and I think you told us that you had seen 1 Q. I'm sorry? , you recognized her photograph. 2 A. Yes, I did, I told the police. A. Yes, I did. 3 Q. And at the time that you spoke with the Q. On how many occasions did you ever see 4 police and gave them a statement, isn't it true, her at the Epstein home? 5 Mr. Rodriguez, that you were no longer employed by A. More than three times. 6 Mr. Epstein? Q. More than three? 7 A. Yes. A. Yes, sir. 8 Q. And you understood that you were required Q. That's as accurate as you can be? 9 to tell the police officers the truth at that A. Yes. 10 time? Q. More than three? 11 A. Yes. A. More than three. 12 Q. And if I understood your testimony I Q. know, but more than three? A. More than three, sir. Q. In terms of ff 's age, did you ever ask her what her age was? A. No, sir. Q. Did she appear to you to be someone at least from seeing her and recalling her that she appeared at least to you to be while a young woman appeared to be someone who was 18 or older? A. No, sir. Q. Okay. Well, did you ever say anything to the police or did you ever -- were you ever concerned about that such that you told someone? A. No, sir. Q. Haven't you told the police, sir -- let me strike that, let me ask it this way. In your taped statement that you gave to the police did you not tell them that all of the girls appeared to you to be 18 or above? A. Sir, as far as when all these actions that were taking place I was under an environment that I thought I was going to be -- in other words, I was afraid of any reprisal Mr. Epstein and Mrs. Maxwell if I say something that is any idea of me because I have this confidentiality agreement. What I saw that they were very young, but I cannot say that they were 18 and old. Q. Right. Let me just take you back to my question again and see if you can answer my question. MR. CRITTON: Could you please read it back? (Thereupon, a portion of the record was read by the reporter.) THE WITNESS: I think I told the police that. BY MR. CRITTON: Whether it was four or five you don't Page 347 Page 349 13 believe from July 29th through today, you at no 14 time asked any of these girls how old they were. 15 True? 16 A. No. 17 Q. And as to whether the girls were under 18 18 or 18 or over 18, you really didn't know one way 19 or the other at the time. Would that be a fair 20 statement? 21 A. Yes. 22 MR. WILLITS: Object to the form of the 23 question. 24 BY MR, CRITTON: Q. On Exhibit 6 there is a person who's Page 348 Page 350 1 covered, the lady that Ms. Ezell asked you about I 2 believe was on the right-hand side of the 3 photograph. There is a young lady on the 4 left-hand side with a black hat on. 5 Do you recognize her at all? 6 7 8 9 A. No, I don't recognize her. Q. Okay. Thank you. With regard to the photograph four saw that you think possibly might be , I think you told us that 10 you recall seeing that woman in the sauna at Mr. } 11 Epstein's house on one occasion and she was naked. | 12 A. Yes. 13 Q. Was that near the end of your employment 14 or the middle or the front end? 15 A. I saw her on January 2005, sir, and I was 16 terminated in March, so that was two months prior. 17 Q. And did you ever tell anyone that you had 18 seen her naked i sauna? 19 A. I told 20. Q. Okay. And what did [i say? 21 A. She was surprised. 22 Q. Okay. Did you wake the young lady up in 23 the sauna? 24 A. No. 25 Q. And do you know how old the young lady 21 (Pages 347 to 350) Kress Court Reporting, Inc. [IN 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182364

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WON OAUAWNE N | = dll ert =< andl ll orl atl ag a was at that time? A. No, I didn't know. Q. If I was to tell you she was born in December of '86 which would have made her 18 at the time, and you would say, not surprised? MS. EZELL: Objection, form. MR. WILLITS: Object to the form of the question. MR. HOROWITZ: Join. THE WITNESS: I would say I wouldn't know. BY MR. CRITTON: Q. Other than telling did you say anything to anyone else when you saw [i the lady you believe was naked in the sauna? A. I believe I mentioned that to my wife. Q. Allright. Anyone else? A. No. . And did i. continue -- assuming it was , did she continue to sleep in the sauna, that is, she didn't know you were there? A. She never knew that I was there. Q. She didn't at least acknowledge that she knew. Correct? A. Yes, correct. Page 352 Q. You were asked by Ms. Ezell -- I'm just going to cover a couple of things as | is I'm staying with Cathy here -- whether you had told us something about the picture of the Pope near a picture person, naked woman. That's who ll you, you never saw those photos. Correct? A. I did saw the pictures. Q. You did see the pictures? A. Yes. Q. And the photos that you saw of the naked woman that was near the Pope's photograph, was that someone that you knew or just a picture of a naked woman? A. It was somebody -- somebody that was a visitor in the house, but I don't know her name. Q. And the visitors, that would have been one of the plane women, you described the women who came in on planes, or that they came with Mr. Epstein from time to time? A. They came with Mr. Epstein from time to time. Q. Allright. And those are women that I think you testified at your last deposition all appeared to be in their 20's or older. Is that WON DUDAWNeE correct? A. I think so, sir. Q. Allright. I assume that in over the course of your life separate and apart from your wife you've seen a naked woman before. A. Yes. Q. And I assume that in your 50 some odd years -- how old are you, sir? A. 55. Q. In your 55 years you've seen pictures of f naked women both photographs, paintings, statutes. | Would that be a fair statement? A. Yes. Q. And in terms of at least in this particular case there is all sorts of -- as you know there is testimony, and you've been asked a number of questions about sex related issues, that is whether you saw in photographs or whether you saw anyone engaged in any type of sexual activity. Correct? A. Correct. Q. And I assume that you understand that men and women -- we'll start there first, that men and women actually do have sex in this world? A. Yes. Page 354 | Q. That comes as no grand surprise to you? A. No, Q. And you understand that people actually enjoy sex from time to time? A. Yes. Q. Are you familiar with that concept at least? A. Yes. Q. Allright. And what may be typical sexual activity for one man and woman, or whatever the permutation might be, another couple, or } another man and woman, or another man or woman may | consider to be unusual or overly aggressive. MS. EZELL: Objection to form. BY MR. CRITTON: Q. True? A. It depends on your point of view. Q. That's what I mean. Everyone has a different point of view about sex and what may be considered typical sexual activity for someone, someone else may consider that's a bit adventurous? MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: 22 (Pages 351 to 354) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182365

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Page 355 Q. I'm not trying to make you a sex expert. Also, I assume that when you've been in CVS or Walgreens, for that matter Publix or Winn Dixie I assume that you've -- I don't want to assume anything. Have you ever been in an aisle where you've actually seen condoms being sold? A. Yes. Q. And where lubricants are being sold? A. Yes. Q. And as well as massage oils and other types of oils actually are sold in those kinds of stores? A. Yes. Q. And they're available so that someone walking through Walgreens or Publix or CVS could actually take it off the shelf, put it in their cart, go up and pay for it and take it home? A. Yes. Q. Allright. In the photographs that you talked about, and if I understood you correctly, at least during the time that you were there, Mr. Rodriguez, in '04 and '05 there were -- you said that there were -- I think you said downstairs -- and I'm talking about really from the kitchen area WON AUMAWNH Page 356 up the back stairway, or what would be the kitchen stairway to the upper floor, there was I think you said, but correct me if I'm wrong, please, that you don't recall seeing there being any pictures or photographs of any nude women. Is that correct? A. They were not nude women in the staircase. Q. That's all I'm talking about right now. In that area you never saw any pictures, or photographs, paintings, any type of depiction of a nude woman on that staircase going upstairs. Correct? A. Correct. Q. Allright. And I think you said downstairs you saw a picture of -- the only picture that you saw of I'd say of a younger child that displayed some form of -- I don't want to say nudity because it’s probably not that, but of some portion of their body that was exposed, and I think you described it as her cheek. A. Yes, that's upstairs. Q. That's upstairs? A. Upstairs. Q. And that was -- | is that how WONAUDBWNe NRSESSRaResses be WON AUDBWNKHK OC 22 RES BRSEBESGSNURGRONKSwmvauawne SO©mMYNDUHEAWNHE _ - 12 13 14 15 16 17 18 19 20 21 | 22 23 24 25 & Page 357 you say her name? A. Yes, Q. Okay. It's there was a picture where someone it like was pulling on their swimsuit? A. Yes. Q. Do you recall ever seeing the old Coppertone -- A. Yes. Q. Let me ask the question. I know you know what this is. Have you ever seen the old Coppertone commercials and billboards that used to be plastered all over certainly Florida and other places where there is a cute little girl who appears to be two, three, four years old and someone is pulling down at least a portion of her swimsuit so she's exposing a small portion of her cheek is exposed? A. Yes. Q. Okay. Is that what the picture of the young girl looked like that is Mr. Epstein's God daughter? A. More or less, yes. Q. All right. And downstairs in the kitchen Page 358 } were there any pictures of women in any stage of | undress? A. No, Q. And then I think you said as you walk upstairs, or as you walked up the stairway from the kitchen at the top of the landing, I think you described -- did you describe it as the foyer? A. Yes. Q. Okay. But it's really the landing, the upstairs landing? A. Yes. Q. I think you said there were -- there was -- were or was a three by five picture or pictures? A. Yes. Q. Of women in some stage of undress? A. Yes. Q. Okay. And when you say three by five, I assume you meant three feet? Three feet. By five feet? Yes. Were they photographs? Yes, they were photographs. And I think you also told us that you OPOrO> 23 (Pages 355 to 358) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182366

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WONAUDAWNE RRR RR Ree ee BESRBRSSSUAGRGNEKSLCMmNaOUEWNHY Page 359 didn't recognize who those people were. Is that 1 correct? | 2 MR. EDWARDS: Object to the form. 3 THE WITN i r on! 4 because it wa 5 BY MR. CRITTON: 6 Q. Okay. And is that the picture you're 7 talking about? 8 A. This is the picture I'm talking about. | 9 Q. Okay. And that was a three by five? | 10 A. Yes. ll Q. All right. And the only thing that you 12 could see was a portion, that is of her other than 13 say her waist or her shoulders or her arms or 14 something, that’s one where you could see kind of | 15 like the Coppertone commercial, a picture of her 16 cheek? 17 A. Yes. Part of her buttocks. 18 MR. LANGINO: Object to the form. 19 BY MR. CRITTON: 20 Q. Okay. And was there another picture at 21 the top of the foyer, large one, or is that the 22 only one that you can recall? 123 A. There were two of the same girl in 24 different poses. 25 Page 360 Q. But showed the same thing? j A. Yes. Q. Okay. As you walked through into -- then if I understood it correctly, you go to the pretty much to the end of the hallway, then you go through another small vestibule, double doors, two sets of double doors, and as you go straight ahead then you make a left around the bed and then you end up in the bathroom. A. Yes. Q. Inthe bathroom -- in the bathroom or in | 11 that location were there any pictures of any women | 12 in any stage of undress? 13 A. Yes. 14 Q. Allright. And were any of those )15 pictures, did they involve -- or were they of any 16 of the girls that have been described as women who | 17 Swmvausawne came over to give Mr. -- purportedly to give Mr. |18 Epstein a massage? 19 A. Yes. 20 Q. And do you remember who any of the names | 21 of any of those people were? 22 A. No. 23 Q. And the pictures you saw, where were they | 24 located? 25 Page 361 A. Inside his closet, the walk-in closet. Q. And those pictures, I think you called it a mosaic? A. Yes. Q. And of the mosaic, approximately how many pictures were in the mosaic? A. 16or 20. Q. Okay. And of those pictures how many did you recognize? A. About three or four. Q. Allright. Were they -- as to who those people were, you don't know, you just recognized three or four of them? A. Mr. Epstein when he was younger, and then different girlfriends, but I didn't recognize except the ones -- Q. Okay. You said three or four of those were pictures of the girls who came over to give a massage? A. Yes. Q. Okay. But as to who those girls were you don't know as you sit here today? A. No, sir. Q. And as to what their ages were you don't know? Page 362 No, sir. That's correct? That's correct. And as to what they depicted in the photographs of the girls were they in different stages of undress? A. Yes. Q. Was everyone undressed to some degree, that is, they were described as nude, or at least the questions asked were these people nude? Were they actually nude or someone may have had their top off? A. There were two girls completely naked in a shower in a sexual act. Q. Is that the one when Ms. Ezell asked you questions, that’s one of the photographs that you were talking about? A. No, sir. Q. That was a different -- A. Different one. Q. Okay. And the mosaic that you saw where you saw two girls involved in a sexual act, do you know where that photograph was taken? A. I think it was taken in one of the rooms in the house because there is an oval bathtub, but O>ro> 24 (Pages 359 to 362) Kress Court Reporting, Inc. [A 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182367

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WON AUMAWNeE WONAUMDAWNeE BRESSBRBSSSRRESDEES usb NFOWAN AU DAWNrHO Page 363 I don't know which room, sir. Q. Okay. Did you recognize both the girls or just one of the girls? A. The two girls. Q. Then there were -- there was one or two other photographs of girls that you recognized? A. Yes. Q. Okay. And were they fully unclothed or did they have some degree of clothes on and/or off? A. They were naked. Q. All right. And all of the remaining pictures at least within that mosaic were of individuals that you did not know? A. No, sir. Q. And that you did not recognize as having been at the house. Is that correct? A. Yes, that's correct. Q. You were also asked about some -- let me switch for just a minute. You were asked about a vibrator that you saw, and I think you described it as a back massager that was approximately 18 inches long that had a couple of rotating heads on it. A. Yes. Page 364 Q. And I think you ultimately came up with the idea as it was something you had seen at like a Sharper Image store. A. Yes, sir. Q. Have you ever seen one of those types of devices, that is a back massager with the rotating heads also sold -- well, let me ask you this. Strike that last question. Have you ever been to Brookstone? A. Yes. Q. Okay. Have you ever seen a massager like that at Brookstone? A. Yes. Q. Okay. You were asked whether Ms. Maxwell kept the names of any of the girls who came to give massages on -- let me ask it this way. I think you were asked whether Ms. Maxwell ever kept the names of any of the girls who came to give massages and I think your response was yes. A. Yes. Q. Okay. Did she keep them on a pad of paper, did she keep them in a notebook, did she keep them in a computer? A. We used to have internal books for rFSwmvaunawne NER Re Re Re Re SWAN DAUDBWN 21 N N 23 24 25 Swmruausauwne ian Ne Page 365 pilots, masseuses, chefs, so she have a copy of the black book with herself and as well as the computer. Q. Did you ever go on Ms. Maxwell's computer to see what she had in it? A. Yes. Q. And was that something you were allowed to do? A. No. Q. Okay. You actually went in her office? A. Yes. Q. And was her computer on so that you didn't need to access the password? A. It was off. Q. Okay. So you just turned it on? A. Yes, sir. Q. And then you were able to access her computer? A. Exactly. Q. And what possessed you to go in and to access her personal computer? A. Ineeded to send some documents to the New York office and it was the only computer working in the house. Q. Okay. And how many occasions did you use her computer? A. Several times. Q. Was she ever aware that you used her computer? MR. LANGINO: Form. THE WITNESS: I don't think so. BY MR. CRITTON: Q. Did you ever ask Ms. Maxwell for permission to use her computer? A. Iwas the house manager, I believe I was supposed to use everything in the house to accomplish my duties, in that case sending financial reports or e-mails. Q. So would you have been -- did you ever use Mr, Epstein's computer? A. No. Q. Okay. But you used Ms. Maxwell's computer? A. Yes. Q. Did you ever use Ms. | computer? A. Yes. Q. In looking at Ms. Maxwell still, you went into Ms. Maxwell's computer with at least the idea of sending some documents? A. Yes. 25 (Pages 363 to Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182368

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WONAUDAWNe ne | ull all ell ell al Lal SSEURRRGNESweovauawne NNNN bWNe 25 Q. Up to New York? 1 A. Yes. 2 Q. Were you going to pdf them? 3 A. Yes. 4 Q. And did she have a fax machine -- not a 5 fax machine, a copy machine in her office as well? 6 A. Yes. 7 Q. Okay. So how would you generally do 8 that? Would you do that through a Microsoft 9 program? 10 A. Through Citrix. 11 Q. Through Citrix. All right. With Citrix, 12 and that is, if you said you saw some names of 13 individuals on her computer if you were just going 14 to pdf some documents up to New York why would you | 15 of -- what would of caused you to have seen any 16 names on her computer? 17 MS. EZELL: Objection to form. 18 THE WITNESS: All the calls that came to 19 358 El Brillo, they came through the 20 telephone, they have a transcript somehow 21 that they connect to the computer, so you can pull it and you register the time, who called, who didn't call, and you can pull this at your request. So I used to use that Page 368 to go back to some calls that they were 1 requesting, especially when the hurricane 2 season happened. 3 BY MR. CRITTON: 4 Q. Okay. So if I understand, even the 5 computer you used would have had that same 6 feature? 7 A. No, no, it was totally different. Mine 8 was slower and all the time was breaking down 9 that’s why we have the guy from Ohio came and 10 fixed the computers. 11 Q. Okay. Were there other computers that 12 you used that feature, that is that -- 13 A. Oni |, Mrs. Maxwell, and the staff 14 house. Q. Staff house being yours? A. The guest house, yes, my office. Q. So you could go out to your guest house then and look for the same information? A. No. Q. Allright. I don't understand but why don't we take a break because we're almost out of tape. (Thereupon, a recess was had.) THE VIDEOGRAPHER: We're back on the Page 369 record with tape number three. BY MR. CRITTON: Q. Mr. Rodriguez, I was asking you about Ms. Maxwell's computer and you told me how you went on the computer. If she was out of town would she take her computer with her? A. No, Q. It was something she left there? A. Yes. Q. Allright. And when you went on to pdf, I think you said it was really one time that you saw the names of some of these girls? A. Yes. Q. And if I understand it correctly, it was -- did it have the name and then a phone number? A. Yes. Q. And was that something that was automatically downloaded from the system? A. Yeah, from the phone system to the computer so we have a transcript. Q. When you say a transcript, the fact that Sally Jones, phone number 561, whatever it was, called, A. It was a transcript of the phone calls of Page 370 jj the house, we can get it from the computer. Q. Okay. And I'm distinguishing, transcript, it would tell you the name and phone number, it wouldn't tell you what was said? A. It was the message also. Q. Okay. Now I understand. And so Ms. Maxwell when you said she had the names of some of these girls who may have given massages, or at least were what you called earlier girls | that gave massages, or females that gave massages, | she would have had it because that was information [f that was downloaded from the Citrix system into her computer? A. Yes. MS. EZELL: Objection, form. BY MR. CRITTON: Q. Okay, I understand. Now, you said she also had some pictures. Is that that one time you also saw pictures? A. Yes. Q. And were you going through her computer at that time? A. No. Q. The question is, if all you were going to do was try to pdf some financial information to 26 (Pages 367 to 370) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182369

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Page 371 New York what were you doing getting to names and phone numbers and then pictures of girls? A. Iwas trying to get some information. I was working the computer and I just happen -- they have the icon of the file and I open and it was right there, so I was not looking but, you know, it was already accessible to me. Q. And how many photographs did you then scroll through to look at? A. Probably 30. Q. Okay. And why? A. Just curiosity, sir. Q. So again, you never told anyone other WON AUAWNeE 14 than your wife? 15 A. No. 16 Q. Correct? 17 A. Yes, correct. Q. Of the pictures that you saw, if I understood it correctly, some of those were pictures of -- well, I think you said some of them reflected parties or banquets? A. Yes. Q. Ithink you described some of the pictures gatherings that appeared to be either in Russia or Eastern Europe? Page 372 A. Yes. Q. Allright. And then you talked about a picture of two girls in the shower that you didn't know the girls. Correct? A. Yes. Q. That's correct? A. That's correct. Q. All right. And that in all of the photographs that you saw the individuals seemed to be having a good time? A. Yes. Q. Allright. Would it be a correct statement that in none of the photographs did anyone seem to be distressed or disturbed or show any type of negative emotion, at least from what you observed? A. That's correct. MS. EZELL: Objection, form BY MR. CRITTON: Q. And in terms of the photographs that you did see, were any of the photographs that you saw, did they appear -- did they appear to have been of women that you had seen fly in with Mr. Epstein on his plane? A. Yes. WONAUDAWNeE NN NNER BR Be Be BRR WON AUMAWNH Page 373 Q. Okay. Were any of the photographs that were in -- again, I'm talking about Ms. Maxwell's computer now, were those photographs of individuals who were any of the girls or ladies that came over to give massages? A. No. They stay at the house. Q. Okay. So the photographs that you saw on Ms. Maxwell's computer of females in any state of undress or at parties or at banquets, those were all of individuals who would fly in with Mr. Epstein at various periods of time that had traveled with him? A. That's correct. Q. Okay. Those are the girls that you told us I think at your last deposition and reaffirmed here today, those girls all appeared to be in their 20's? A. Yes, sir. Q. Allright. Now, you were also asked some questions, a lot of questions about surveillance. And if I understood your testimony, and this is where it goes back to what do you know, what don't } | you know, what were you speculating on, what did you know at the time, what do you know now, at least I need you to distinguish that for me so Page 374 that I know what you knew at the time, and as distinct from what you may have read in the newspaper or been told by some lawyer or someone else that may not be accurate. Okay? A. Yes, sir. Q. With regard to the -- with regard to surveillance equipment, if I understood your testimony today is you were completely unaware of the existence of any surveillance equipment in the house during the 2004/2005 time period that you worked there. Is that correct? A. Yes. Q. And therefore, where it was, what may have existed, whether it in fact actually did exist, whether anyone maintained it, you have no personal knowledge whatsoever. Is that true? A. That's true. MR. WILLITS: Object to the form. BY MR, CRITTON: Q. You talked about pictures of two women saw in the house who were nude, one was A. “Yes. Q. And you knew [J was someone who was in her 20's? 27 (Pages 371 to 374) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182370

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Page 377 Page 375 1 A. Yes. 1 names and addresses of -- let me start over. 2 Q. Allright. And then you saw another 2 Strike that. 3 picture of a Brazilian woman who had traveled or J understood your testimony, you said 4 flown on the plane before? 4 thal i -- start again. 5 A. Yes. 5 You said tha’ had the names and 6 Q. Allright. And she also appeared to be a 6 phone numbers of some of the massage girls. 7 woman to you not only in the photograph but from 7 A. Yes. 8 your having seen her who appeared to be in her 8 Q. Or at least of the people that you 9 20's? 9 thought may have been called to give massages. 10 A. Yes. 10 A. Yes. 11 me. Thank you. You talked about 11 MS, EZELL: Form. 12 computer. Was she hooked into your | 12 MR. EDWARDS: Form. 13 main system? 13. BY MR. CRITTON: 14 A. Not to my office in the staff house but 15. she was hooked into the main house. 16 Q. Okay. The same Citrix system? 17 A. Yes. 18 Q. And you said that} had pictures of 19 women on her computer that you saw. Is that 20 correct? 21 A. Yes. 22 Q. Okay. And were those the same types of 23 pictures that Ms. Maxwell had, that is, females, 24 pictures of females who had traveled in with Mr. 25 Epstein from his plane? 14 Q. And was that in the same format that you 15 saw on Ms. Maxwell's computer? 16 A. No. 17 Q. Okay. Wh j uld you have been 18 -- have had to ia computer? 19 A. She will instruct me to get some 20 information from her desk or telephone numbers, so 21 ‘Iwill. 22 Q. And that's where you would have seen it? 23 A. Yes. 24 Q. I think you testified at your last 25 deposition, or the start of your deposition that Page 376 Page 378 the number of women that you remember came over to}: give massages was something eight to ten, twelve, 1 A. This were different pictures. 2 Q. Okay. Were any of hers of any of the 3 girls who came in on the plane, or the ladies or 4 women? 5 A. No. 6 7 8 9 1 2 3 I don't remember, what's your best recollection? 4 A. Can you repeat that, please? 5 Q. Of the women, of different women that you 6 7 8 9 Q. What were her pictures of? A. They were young women mi you know. knew came over to give massages during the time that you worked for Mr. Epstein, '04 to ‘05, I don't remember seeing nudity on during that time period, approximately how many computer. women were there? 10 Q. All right. say hers, the 10 MR. EDWARDS: Object to the form. 11 photographs that had on her computer 12 were all of individuals who appeared -- or not 13 appeared, but were dressed and appeared to be 11 THE WITNESS: To give massages? 12. BY MR. CRITTON: 13 Q. Yes, sir. 14 modeling? 14 A. Fifteen, yeah. 15 A. Yes. 15 Q. So something between one and 16 Q. Would it be a correct statement that none 16 the names you would have seen on Ms. 17 of the women that you saw, the pictures of 17 computer along with a phone number? 18 the women that you saw on computer were | 18 MR. EDWARDS: Form. 19 THE WITNESS: Yes. 20 BY MR. CRITTON: 19 any of the girls, women, whoever came to give 20 massages? Is that correct? 21 MR. EDWARDS: Object to the form. 21 Q. Do you remember how many you would have 22 MS, EZELL: Form. 22 seen? 23 THE WITNESS: That's correct. 23 A. Fifteen. 24 BY MR. CRITTON: 24 Q. Okay. id us earlier today 25. Q. You said that [J you thought also had 25 that you saw from time to time taking 28 (Pages 375 to 378) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182371

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WONOAUDAWNH Page 379 pictures in the dining room and the library. 1 Q. Regular conversation? A. Yes. 2 A. Yes. Q. Photographs. 3 Q. And, therefore, you might interject A. Yes. 4 yourself back in because you've been asked to pay Q. Okay. Was she taking -- the pictures she 5 someone or to let them out? took were people who were clothed? 6 MR, LANGINO: Form. A. Yes. 7 THE WITNESS: Yes, I was called to pay Q. And were any of the pictures that she 8 them. took of any of the girls that you ever -- let me 9 BY MR. CRITTON: strike that. 10 Q. All right. And when you hear that If I understood your original testimony 11 conversation that would be another way that you -- I don't want to say original. If I understood 12 would know that the women were leaving? your testimony from July 29th to what you told us | 13 A. Yes. today as to the women who did come to give 14 Q. And sometimes they'd leave without you massages they'd knock or somehow you would be | 15 even being involved, if I understood it correctly? aware that they were at the back door, you would | 16 A. That's correct. punch the security code and lead them into the 17 Q. So, the only places that you ever saw the kitchen. 18 women who came to give massages would be -- of the | A. Yes. |19 some fifteen women during the time you were there Q. Okay. When you brought them into the | 20 would be either when you let them into the house kitchen you would say, hi, they would say hi back 21 and escorted them into the kitchen or as they were to you, or something to that, short greeting, 22 leaving? you'd offer them water, there was never any 23 A. Yes. alcohol in the whole house other than I think you 24 Q. And I think you described one instance said for one person at one time. Is that a fair earlier today is that you may have had in the statement? 1 car, in the Suburban? A. Yes. 2 A. Yes. Q. All right. You left the kitchen, you 3 Q. And that’s the only person that you can understood came down, and what | 4 remember having driven any place, that is, of the ' happened thereafter you don't have any personal 5 women who were described as having given massages? } knowledge whatsoever? 6 MR. EDWARDS: Objection. | A. That's correct. 7 MS. EZELL: Objection, form. MR. EDWARDS: Form. | 8 THE WITNESS: Sir, I have to clarify BY MR. CRITTON: 9 that. I drove a lot of girls, but I don't Q. At some point in time Ms. || might 10 remember the names associated with the contact you and say pay such and such X amount of 11 faces. But this particular girl Hibr dollars, she is now getting ready to leave. 12 others, Hg whatever, I remember driving in A. Yes. 13 the Suburban, but I cannot say this was -- Q. That maybe one. Another set of 14 BY MR. CRITTON: circumstances might be you use the word commotion, | 15 Q. Let me clarify because what I want to be you might hear a commotion, I assume you don't 16 clear is, is I do remember you testifying that mean -- well, let me ask you, when you say 17 when some of the 20 plus year old models or commotion, do you mean a disturbance, something 18 females would fly in with Mr. Epstein they might that was seriously like raised voices or merely 19 want to go shopping, they might want to go to the you just heard some people talking? 20 store, they may want to go to the drug store, they A. Conversation of people leaving. 21 may want to go to the beach, wherever they wanted Q. Okay. Not a commotion in the form of a 22 to go and you would drive them. disturbance but a commotion in the sense that you 23 A. Yes. heard people talking? 24 Q. All right. And then I remember in A. Yes. 25 response to Ms. Ezell's questions today she asked 29 (Pages 379 to 382) Kress Court Reporting, Inc. Fs 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182372

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WON OAUDAWNe NNNN Kee Ree Re eee BESBRSSSUARRBNESwemvausuwne Page 383 you about having driven}. and you recalled 1 having had her in the Suburban specifically. 2 A. Yes. 3 Q. Do you remember any of the other girls, 4 women me to give massages ever having driven | 5 them, or is. the only one that you remember? 6 MR. EDWARDS: Form. 7 THE WITNESS: I only remember. right 8 now for the fact that I was driving by the 9 airport and I showed her Mr. Epstein's 10 plane. 11 BY MR. CRITTON: 12 Q. Allright. Which really takes me back to 13 really where I started with this series of 14 questions. 15 You saw the girls, the women who came in 16 to give the massages, when they came in if you 17 were advised or if you heard conversation and you 18 saw them you would see them when they left? 19 A. Yes. 20 Q. And you saw. because she was in the 21 Suburban on at least one occasion? 22 A. Yes. 23 Q. And, therefore, you never saw these 24 girls, these women who gave the massages in the Page 384 dining room or the library. Would that be a fair statement? A. That's correct. MR. EDWARDS: Form. BY MR. CRITTON: Q. All right. So, therefore, the pictures that you saw taking of girls, women, either in the dining room or library, those were other individuals other than those who may have given or who came for massages. Is that correct? MS, EZELL: Form. MR. EDWARDS: Form. THE WITNESS: It's confusing, sir, because there were a bunch of girls. I don't know which one they were but I saw her taking pictures of the groups. BY MR. CRITTON: Q. As to whether they were people who came in on the planes or there may have been a massage girl or more than one woman who gave a massage, you just don't know as you sit here, you'd just be speculating. Is that correct? MR. EDWARDS: Form. THE WITNESS: I don't know. BY MR. CRITTON: Page 385 Q. Allright. Ms. Ezell asked you about Mr. Dershowitz being present in Mr. Epstein's home, and I think she asked -- and I think that you said Mr. Epstein was a -- and he and Mr. Dershowitz were friends? A. Yes. Q. She also I think asked was Mr. Dershowitz ever there when one of the women who gave a massage was present in the home? A. I don't remember that. Q. That's what I want to clear up. Is it your testimony that Mr. Dershowitz was there when any of the women came to Mr. Epstein's home to give a massage? A. Yes. MR. EDWARDS: Form. BY MR. CRITTON: Q. As to whether any of those women were ever associated with Mr. Dershowitz would it be a correct statement that you have absolutely no knowledge? A. I don't know, sir. Q. You don't know? A. I don't know, sir. MS. EZELL: Form. Page 386 | BY MR. CRITTON: Q. Okay. Were you in any way attempting in your response to Ms. Ezell to imply that Mr. Dershowitz had a massage by one of these young ladies? A. I don't know, sir. Q. You have no knowledge? A. No, sir. Q. And you certainly weren't nena t that that occurred, you just have no Correct? MR. EDWARDS: Form. THE WITNESS: I don't know. BY MR. CRITTON: Q. Sorry? A. I don't know. Q. I think in response to one of Ms. Ezell's questions you responded that -- let me ask it this way. You never saw Mr. Epstein ever take photographs of anyone. Would that be a correct statement? A. Yes. Q. Would it be a correct statement you never saw Mr. Epstein initiate a phone call to anyone? 30 (Pages 383 to 386) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182373

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WON AUAWNHE Page 387 A. To place a phone call? Q. Yeah. Did you ever see him place a phone call? A. Yes. Q. If in fact, maybe it was this way, is that you never saw him call someone to schedule a massage appointment. Correct? A. That's correct. Q. I think you said that Ms. [I told you that Mr, Epstein would take photographs. Did I understand you correctly? A. I'm you repeat that? Q. Did Ms. ever tell you that Mr. Epstein took a photograph of anyone? A. No, she said to me Mr. Epstein is like he's an amateur photographer. Q. Okay. I may have misunderstood you then. Let me clarify that testimony. It's your testimony that Ms. | | told you that Mr. Epstein is an amateur photographer? A. Yes. Q. She never told you that -- or let me strike that. Is it correct that she never told you that Mr. Epstein took photographs of any of the Page 388 girls, women, who came over to give him a massage? A. That's correct. Q. Allright. Mr. Rodriguez, other than Mr. Epstein I think you told us you had worked for a lady named Ms. Hammond? Yes, And you had worked for a gentleman -- Sidney Bowman. Is he the gentleman from Fisher Island? No, Arturo Torres. All right. In addition to Ms. Hammond up in Palm Beach you worked for other individuals as well? A. I did it part-time but I don't have her name right now, sir. Q. During your career as a -- let me strike that. Had you worked other than those places, Mr. Arturo -- A. Arturo Torres, yes. Q. Arturo Torres, Ms. Hammond, the other individual you can't remember, and Mr. Epstein, have you worked for other individuals as an estate manager or general house manager? A. No, sir. OPO>ro> WON OUDAWNHE Page 389 Q. Of the time that you've done that approximately how many years does that include in your working life? A. Eight years, ten years. Q. Allright. And have you worked for -- have you been in other circumstances where you have worked around -- well, let me step back. With all of the individuals that you mentioned, estate manager, house manager, has this | been for individuals who have or at least appear to have substantial wealth? A. Yes. Q. And as part of your duties, or not duties but as part of being a house manager or general manager for an estate do you interact with other estate managers? A. Yes. Q. And do you assist each other from time to time if someone needs help? A. That's correct. Q. And I assume that you've been in other estates in Palm Beach and probably in Fort Lauderdale and other locations? A. Yes. Q. As part of during your working career did you ever work in restaurant or a personal services type business where you would provide like catering or something like that to other wealthy individuals? A. Idid. Q. Give us a little of your background if you could then, Mr, Rodriguez. A. I work in Long Island, Montauk Lake Club and Marina, a very exclusive country club where Mr. Nixon used to spend his summers, Richard Nixon. I worked for Leona Helmsley in New York. Very demanding lady. And then Mr. Torres in Texas in his ranch and as well as Fisher Island. And I was a general manager of one of his restaurants in San Antonio, Texas. This is the most high profile people that I worked for. Q. Okay. When you worked for Ms. Helmsley, Leona Helmsley, she used to have the Helmsley | Palace and she with her husband, Harry Helmsley, 1} } think they owned a number of real estate in addition to hotel properties. A. That's correct. Q. When you would -- I think you described her as a demanding person? A. Yes. 31 (Pages 387 to 390) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182374

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Page 391 Q. Allright. In terms of these wealthy people that you've worked for, these individuals, do they all have, that is at least in terms of Mr. Epstein, the way that his household was managed, was it similar to other set of circumstances that you've been involved with? MR. HOROWITZ: Object to form. THE WITNESS: They have a common ground, WOMAN DUMDAWNe yes. BY MR. CRITTON: Q. Allright. And in terms of you talked about Mr. Epstein that there was some sort of a manual or a procedure book with regard to his house. A. House manual, yes. Q. A house manual. Did other houses have house manuals as well? Is that reasonably -- I mean not common but it’s something that you've seen before? MR. EDWARDS: Form. THE WITNESS: I know a lot of houses do but that was the only estate that we have a house manual. BY MR. CRITTON: Q. And other individuals like where you've Page 392 worked similar to Mr. Epstein -- now, Mr. Epstein was single? A. Yes. Q. Allright. And him having a lot of -- or bringing a lot of attractive women and other people to his house, I assume that didn't offend you in any way? MR. EDWARDS: Object to the form. THE WITNESS: No, sir. BY MR. CRITTON: Q. Atleast based upon your experience in dealing with other individuals either of some notoriety like Ms. Helmsley or when you said the club that you worked up is in Montauk -- A. Montauk Lake Club and Marina. Q. Right. You ran into separate and apart from Richard Nixon were there a lot of people, corporate people, business people? A. Yes. Q. People of substantial resources and wealth? A. Yes. Q. Have you found at least in your experience that most of those people are pretty discreet about -- when I say discreet, private RSESERSSSLAREERESwmVausune BE Swmnaunsawne 13 14 (15 16 17 18 19 20 21 22 124 25 N NNNEEeee a nd RESSRSSSUAREGHESwovauawne Page 393 about what they do? MR. HOROWITZ: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q. And have you worked at other locations, that is, in the other houses that you've worked where they have massage tables? A. Yes. Q. And in those other locations where they had a massage table, were they similar to the massage table that was in Mr. Epstein's home? A. Yes, sir. Q. Allright. Almost same make and model? A. Same type, yes. Q. And did other individuals in houses that you worked at and other places where you helped out other estate managers, would those individuals have massages from time to time? A. Yes. Q. So having a massage or a massage table in someone's house that you might -- that lives in Palm Beach or Montauk or New York or something, would you consider that unusual? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. I think you told me at least in Mr. Epstein's home other than for one guest he didn't have any type of alcohol in the house. Is that correct? A. That's correct. Q. Was that basically you understood that that was one of the policies and procedure, no alcohol in the house? A. Yes. Q. And did you ever see any type of illegal or inappropriate drugs? A. No, sir. Q. And was that another policy or procedure, absolutely no drugs of any kind? A. No smoking in the house. Q. All right. So no drugs, no smoking, no alcohol? A. Yes. Q. Was that pretty typical for other Palm Beach places that you were familiar with? A. No. Q. All right. And other places you'd always find alcohol? A. Yes. 32 (Pages 391 to 394) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182375

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WONAMUAWNE Cl tl orl all ol all orth all art Page 395 All right. And you might find drugs? Yes. And some pretty wild parties? Yes. Now, with regard to the women who came to give massages, of those women, of those approximately fifteen that you described, how many | of them came more than one -- more than one occasion? MR. HOROWITZ: Form. 10 THE WITNESS: I'd say more than half. 11 BY MR. CRITTON: | Q. So maybe seven, eight, nine, ten? 13 A. Yes. 14 Q. Of those people that came on -- of those 15 seven to ten that came on more than one occasion, | 16 FO >O>re WON OUDAWNeE did those individuals come on many occasions? |17 A. Yes. 18 Q. And as to the women who were -- who you | 19 understood were coming to give the massages -- 20 MR. EDWARDS: Form. 21 MR. CRITTON: I'm not done yet. 22 THE VIDEOGRAPHER: I need to go off the 23 record for a second. 24 (Thereupon, an interruption was had.) Page 396 THE VIDEOGRAPHER: We're back on the record. BY MR. CRITTON: Q. Mr, Rodriguez, I want to turn to the -- stay with the women who came to give or at least were called to give the massages. You were shown a number of message pads, | I think Mr. Mermelstein who represents a number of -- or at least certainly Jane Doe 2 and some others, you were identified or shown a bunch of 10 message pads that had I think in most instances {11 WON AUDAWNE your initials, Do you recall that? 112 A. Yes, I do. /13 Q. I think one of the indiv that you 14 identified that called often was .? }15 A. Yes. 116 Q. Which is one of Mr. Edwards’ clients. |17 This lady called on a regular basis, or 18 at least from looking at your pad she would call 19 on a pretty regular basis. Is that true? 20 A. Yes. 21 Q. And she and others who are reflected on 22 those message pads, they were calling tocometo (23 give massages. Correct? | 24 A. Yes. | 25 Page 397 fj MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. And I don't know whether he asked, do you remember a person named A. Yes. Q. And would she call from time to time asking if she could come to give a massage just like R. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q. So at least those two individuals, they were overtly, that is, they were asking whether they could come to give Mr. Epstein a massage. Correct? A Il call a will say I need to talk il and fifteen minutes later will tell, , we're going to have a massage with so and so. Q. Soeither I or [I would call toask | if they could come and then a massage would be set } then they would show up? A. That's correct, sir. Q. Okay. And from time to time they would bring other people as well? A. That's correct. Q. Both i ang .? A. Yes. Q. Of the females that -- the women that came to the house, did you ever see anyone force any of these women onto the property? A. No, sir. Q. Did you ever see anyone force them into the house? A. No. Q. Did you ever see anyone force them into the kitchen? A. No, sir. Q. Did you ever use any force, any type of intimidation or coercion to bring them into the house and get them into the kitchen? A. No, sir. Q. Did you ever observe [i [IEE using any force or intimidation or coercion -- A. No, I did not. Q. -- with any of these individuals? A. I did not. MR. EDWARDS: Object to the form. BY MR. EDWARDS: Q. Did FLEE -- tet me use the initials 33 (Pages 395 to 398) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182376

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WOMAN AUDAWNe N NNR eRe eR Re eee Page 399 that way it will show up correctly, Did ever use from what you saw, did she ever use any force or coercion or intimidation with any of the women that she brought to the house? MR. HOROWITZ: Form. MR. EDWARDS: Object to the form. THE WITNESS: No, sir. BY MR. CRITTON: Q. Okay. I'm just talking about what you observed during the time. And you know what I mean by force? A. Yes. Q. You know what I mean by intimidation? A. Yes. Q. Could to be verbal intimidation or coercion, either verbally or using some form of her body, or their bodies. A. Yeah, I understand that. MR. EDWARDS: Form. MR, HOROWITZ: Form. MS. EZELL: Objection, form. BY MR. CRITTON: Q. When [i brought individuals to the house, did you ever see her use any force or intimidation or coercion from what you could observe with those women who had come to give a massage? A. No. MR. EDWARDS: Form. MR. HOROWITZ: Form. MS. EZELL: Form. BY MR. CRITTON: Q. With any of the fifteen women that you observed who came to the home to give massages during the time period '04 through I think you said February of '05, the time period I think was it rer Mr. Rodriguez -- August. -- August of '04 through February of '05? March of '05. Through the beginning of March '05? Yes. Okay. That's the time period I'm focussing on. Of the approximately fifteen women that you came to see to give massages that you let in the back door after punching the security code, did any of them ever appear to be scared? A. No. OPoro> Kress Court Reporting, Inc. Page 400 WONAUMAWNe Page 401 | Q. Did any of them ever appear to be frightened? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. Did any of the women appear to be fearful? A. No. Q. Did any of them appear to be uncomfortable in coming into the house? MR. EDWARDS: Form. THE WITNESS: No. BY MR. CRITTON: Q. At any time did any of them express to you verbally that they were in fear when they came into the house? A. No, sir. Q. Did any one of the fifteen girls that came to the back door, then into the kitchen, and prior to your leaving them in the kitchen say, Mr. Rodriguez, or Alfredo, or sir, could you get me out of here? A. No, sir. Q. Did any of them tell you verbally that they were uncomfortable? Page 402 |) A. No. | Q. Did anyone say help me or I'm scared? A. No. Q. Did all of them appear to be at least when they came to the back door in a reasonably good mood? A. Yes. Q. They all appeared to be happy? A. Yes. Q. Smile, I'd say interact with you verbally in your greetings? A. That's correct. Q. Did any one of the fifteen girls that you observed during the August '04 through March 2005 time period from your personal observation appear to be there -- appear to be at the Epstein home not voluntarily? MR. EDWARDS: Object to the form. MR. HOROWITZ: Object to the form. THE WITNESS: No. BY MR. CRITTON: Q. Did any one of the fifteen women who came to give the massage ever tell you that they had been forced to come to the house or coerced into coming to the house? 34 (Pages 399 to 402 7115 Rue Notre Dame, Miami ——— FL 33141 EFTA00182377

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WONAUAWNHE A. No. 1 MR. EDWARDS: Form. 2 BY MR. CRITTON: 3 Q. For those women -- I think I need -- let 4 me strike that. 5 On some occasions you'd see the women 6 come down from upstairs because you would either | 7 let them out of the house or you might give them 8 an envelope that had money in it. Is that 9 correct? 10 A. Yes. li Q. Did any of those -- Mr. Edwards asked you | 12 some questions -- I think it was Mr. Edwards, 13 whether they had sat down and had anything to eat, | 14 whether they had cereal or anything like that. 15 A. Yes. 16 Q. Did you ever observe any of those women before they went upstairs eating anything at the house? A. Sometimes. Q. And I think he used -- he meaning Mr. Edwards, used cereal and ice cream. A. Yes. Q. And he said, if I recall from the last deposition, kids like ice cream. Page 404 Yes, Do you remember him asking you that? Yes. Are you familiar that teenagers like ice ? A. Yes. Q. Are you familiar that people who are 20 and 30 years old like ice cream? A. Yes. Q. Are you familiar that older people, even our age, Mr. Rodriguez, like ice cream too? A. Yes. Q. Okay. And when the individuals would sit there, and that is these women who would come over to give a massage and they would -- you would observe them eating, did they appear to be comfortable? A. Yes. 18 MR. HOROWITZ: Form. 19 BY MR. CRITTON: 20 Q. Did they appear to be interacting with 21 either you or the chef? 22 A. Yes. 23 Q. When any of those women would come over to give massage came downstairs, did you ever see Page 405 them stop and have anything to eat or did you always see them at the end, that is they're ready to go? A. I didn't know, they came from downstairs, they went to the kitchen, but I didn't know they were there because I was in the guest house. Q. Okay, that's my question. You only observed them either if you heard conversation or had called you and said would you pay such and such? A. Yes. Q. At which time you would give them the envelope with money? A. Yes. Q. In that set of circumstances they were on their way basically to leave? A. Yes. Q. When you saw them leave did any of them at any time, any of the ones that you saw during August of '04 through March of '05 appear to you to be scared? A. No, sir. Q. Did any girls, women ever appear to have been injured in any way? MR. EDWARDS: Form. THE WITNESS: No, sir. BY MR. CRITTON: Q. Did anyone appear to be in shock? A. No, sir. Q. Was anyone ever crying? A. No, sir. Q. Was anyone disheveled or appeared to be unhappy? A. No, sir. Q. Did all of them appear, that is the ones that you saw leave the house that you had an opportunity to observe during that time period, did they appear to be approximately the same personality, same demeanor that they had had when j they came into the house? H MR. HOROWITZ: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. Did anyone ever tell you when they came down the stairs that they had been injured? A. No. Q. I'm talking about the young lady, the women who had given the massages that you saw actually leave the house, that is you had some interaction with, either some interaction as they 35 (Pages 403 to 406) Kress Court Reporting, Inc. rere 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182378

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WON AMAWNH N NNR RRR Re ee ee Page 407 were leaving the house, did anyone ever tell you 1 that they had been injured? 2 A. No, sir. 3 Q. Did they ever tell you that they had been 4 forced to do something against their will? 5 A. No. 6 Q. Did they ever tell you that they had been 7 forced to do something inappropriate? 8 A. No. 9 Q. Did they ever tell you that they had been 10 assaulted in any way? ll A. No. 12 Q. Did they ever tell you that they had been =| 13 inappropriately touched? 14 A. No. 15 MR. HOROWITZ: Form. This is a 16 cumulative. He's already told you the 17 limited contact he had. This is totally 18 inappropriate line of questions. ;19 MR. CRITTON: Is that a form objection? 20 MR. HOROWITZ: You're exceeding the scope | 21 of the direct because nobody asked him -- 22 MR. CRITTON: Form, you get form in 23 federal court, that's what you get. Give me 24 your form. 25 Page 408 MR. HOROWITZ: Form, cumulative. MR. CRITTON: Great. Why don't you let me finish the question and then you can object to it. Could you give me back what my last question was, please? (Thereupon, a portion of the record was read by the reporter.) THE WITNESS: No. BY MR. CRITTON: Q. Did they ever tell you that they had been sexually assaulted in any way? MR. EDWARDS: Form. MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. I'm sorry? A. No. Q. At any time did you hear anyone -- strike that. As to the women who came to give a massage, did you ever hear anyone scream? A. No, sir. Q. Did you ever hear anyone cry out what sounded like to you help? N NNR RR RR Ree ee Page 409 MR. EDWARDS: Form. THE WITNESS: No. BY MR. CRITTON: Q. Did you ever hear anyone yell rape or assault or battery? MR. HOROWITZ: Form. THE WITNESS: No. } BY MR. CRITTON: | Q. Did you ever hear anyone yell out in i anger? A. No. | Q. You've gone online, Mr. Rodriguez, and | looked at various articles or postings that have | been made regarding these cases. Is that a fair statement? A. I'm sorry? Q. If I understood your testimony from July 29th and a little bit today, is that you've gone online and read some articles and/or what the police report may have said, that is, you've read } information that you've -- about these lawsuits | after the time that you left Mr. Epstein's employment. A. Yes. i Q. Correct? } Page 410 A. Yes. Q. And, therefore, you have at least seen certain allegations and what people say occurred, or at least their recitation of what may have occurred at Mr. Epstein's home. A. Yes. MR. HOROWITZ: Object to the form. MR. EDWARDS: Form. BY MR. CRITTON: Q. Correct? A. That's correct. Q. Are you also aware that the individuals who have filed lawsuits want in some instance millions of dollars? A. Yes. Q. Okay. Are you aware that some of them are now claiming that they were sexually assaulted? A. Yes. Q. And battered? A. Yes. Q. And you have no information, no personal knowledge in that regard. Is that true? 36 (Pages 407 to 410) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182379

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WON AU ABWNe Nn el eel eet alll ell ell et ool ool ed GESBRSCSUSGEDBHESLCMmVauawne A. Yes. 1 MR. EDWARDS: Form. 2 MR. HOROWITZ: Form. 3 BY MR, CRITTON: 4 Q. Allright. Were you aware of the 5 backgrounds of any of these women who came over to | 6 give massages? 7 MR. HOROWITZ: Form. 8 THE WITNESS: No, sir. 9 BY MR. CRITTON: 10 Q. Well, have you -- did any one of the 11 females who ever came to give massages, did they 12 ever tell you that they were prostitutes? 13 A. No, sir. 14 Q. Did they ever tell you that they had been 15 lead into a life of prostitution? 16 MR. HOROWITZ: Form. 17 THE WITNESS: No. 18 BY MR. CRITTON: 19 Q. Did they ever tell you about their family 20 life, whether it involved prostitution, abuse, 21 prior posttraumatic stress syndrome, drugs, 22 alcohol, abuse by individuals, physical abuse as 23 well as verbal abuse? 24 A. No, they didn't tell me. Page 412 Q. And, obviously, you have no personal knowledge one way or the other -- A. No, sir. Q. -- with regard to what their backgrounds were before they ever met or came in contact with Mr. Epstein? A. No, sir. Q. Did any person, female, who came to give @ massage at the Epstein home, did anyone ever come downstairs and say, Mr. Rodriguez, or sir, call the police? MR. EDWARDS: Form. MR. HOROWITZ: Form. THE WITNESS: No, sir. BY MR. CRITTON: Q. I think you said on one occasion you saw someone parked in a vehicle inside the gate that you didn't recognize. 18 A. Exactly. 19 Q. You called the police? 20 A. Yes, I did. 21 Q. Did you go to the police or you called 22 the police and they came? 23 A. I went to the police department. Q. So how did you -- did you actually leave Page 413 } the property in your car? A. Iwas pulling over from Publix so I turned around and I went to the police and say -- Q. Okay. You were coming back to the home when you saw that car there? A. Exactly. Q. And they sent -- they, the police, sent a police car with you to come there? A. Yes. Q. Did you and the police officer walk up to the car? A. The police went first. Q. All right. And if I understand that, that was in January of ‘05? A. Yes. Q. And when you did that then did you follow behind the police officer to see who was in the car? A. Yes. Q. And then you recognized that as | A. Yes. Q. And J said she had come back or was there to get some money? A. Yes. Q. And did you in fact give her money? Page 414 | A. Yes, I did. Q. And I think you said you told the police officer you recognized her? A. Yes. Q. Did you have to get permission to pay her or did you just pay her? A. No, because told me already but I forgot she was going to be that late, so that was my concern in calling the police. Q. Okay. And that person who came, do you have any idea what her age was at that time? A. That night? Q. Right, January of ‘08, A. No, no. Q. I'm sorry, January of '05. A. No. Q. You mentioned some conversations that you } had had with who was I think she was one of the house -- main housekeeper. A. Yes. Q ed told you a number of thoughts that she had. Is that correct? A. Yes. Q. And as to [J what she told you about ~~ let me strike that. 37 (Pages 411 to 414) Kress Court Reporting, Inc. a 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182380

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WANDUAWNeE N | alll meal eel | ll eal | ll cell ol BESBRSSSUARREBNESwmvauawne Page 415 I think you told us, you were asked questions about sex toys, I think you certainly described the back massagers. Correct? A. Yes. Q. I think you said the only sex toys that you ever saw were in the armoire at the end of Mr. Epstein's bed. A. Yes. Q. Okay. And whatever other sex toys that to which there was a reference, that's something | that told you. Is that correct? A. That's correct. Q. You were asked at the last deposition, I don't remember who asked the question, but whether you had ever seen pornography on any computer. I think one of your responses was you saw some photos of a naked woman who appeared to you to be a model. A. Yes. Q. Okay. Do you consider every photograph, picture, painting of a naked nude woman to be pornography? MR. HOROWITZ: Form. MS. EZELL: Objection, form. THE WITNESS: I consider -- well, if it's Page 416 a frontal picture it's pornography, I will look at my way. BY MR. CRITTON: Q. In your view? A. Yes. Q. So if you looked at -- I don't remember whether Playboy still has -- say a Playboy that has a frontal nudity shot of a woman, you would in essence say that Playboy is selling pornography? A. Yes. Q. Therefore, every person who buys a Playboy that has over the last umpteen tens of years that has a frontal picture of a woman in the nude would be purchasing pornography whether it's from CVS, or Walgreens, or Eckerd as they existed, or any grocery store that sells them? A. Yes. MS. EZELL: Objection, form MR. EDWARDS: Form. MR. HOROWITZ: Form. BY MR. CRITTON: Q. The photographs -- I'm sorry, the pictures that you saw in the computer, I think you were able to draw those up or bring those up from your own computer. WON AUAWNH 10 12 13 14 15 16 17 18 19 20 21 22 23 '24 25 WON AUDWNe Page 417 A. To bring the pictures from my computer? | Q. Let me rephrase the question. I thought what you said last time was that as to the pictures that you did see of naked women -- of a naked woman or naked women on the computer, that you've looked at those photographs through your computer. A. No. Q. Okay. Then I may have misunderstood you. Was your reference to Ms. Maxwell's computer that you made at the last deposition? A. Yes. Q. Okay. Your computer that you had either in the staff house or that you -- A. Didn't access. Q. You couldn't access those files? A. That's correct. Q. All right, now I'm with you. So the photographs you've talked of the nude individuals, or the naked women, were the photographs that we've already talked about with both, i.e., in Ms. Maxwell's computer? A. Yes. Q. Thank you for clearing that up. I'm going to ask you to assume that i. who you've described as having come to Mr. Epstein's house on three or four times a week for a period of time, one of her claims in this case is that she has been emotionally traumatized by her contact with Mr. Epstein. Just assume that to be true for purposes of this question. Did you ever observe any what you would have seen as | trauma or any type of disturbance with ll on the many times she came to your house? MR. EDWARDS: Form. THE WITNESS: I didn't see any. BY MR. CRITTON: Q. Does it make sense to you that a person who claims emotional trauma would continue to come back to the house, does that make sense to you, sir? MR. EDWARDS: Form. MR, HOROWITZ: Form. MR, WILLITS: Object to the form of the question. THE WITNESS: I'm not a psychologist. MR. EDWARDS: Can you state your answer, I didn't hear it? THE WITNESS: Yeah, I'm not a 38 (Pages 415 to 418) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182381

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WONOAUDAWNe NN NNN ee ee ee ee BESRBRSSSNSGRENESwemrauswne psychologist, I don't know. MR. CRITTON: I have no further questions. REDIRECT EXAMINATION BY MR. EDWARDS: Q. Mr. Rodriguez, I don't know if we covered this last time, I think that we did not, but can you tell us during the period of time when you worked at that house at El Brillo, Mr. Epstein's, what cars did he own or were in the driveway? A. We have two Suburbans, two Mercedes 600, and a Cobra, and a motorcycle. Q. And which, if any, did he drive? A. He preferred the Mercedes or any of the Suburbans. Q. All right. Do you know where he owns homes? A. Yes. Q. Where? MR. CRITTON: Form. THE WITNESS: Paris, New York City, El Brillo, Saint James Island -- I'm sorry, an Island in the Caribbean, and a ranch in New Mexico. BY MR. EDWARDS: Q. Have you been to any of the other properties? A. No. Q. Do you know the house managers at any of the other properties? A. Yes. Q. And who are they? A. Balsone in Paris, good friend of mine from Brazil. And the people in New York give me the briefing when I came aboard. There is a couple from the Philippines. And I talked to the couple that used to own the Island -- I mean who used to manage the Island, a couple from South African. Balsone was closer to me. Q. Have you talked to Balsone about whether or not Mr. Epstein has massages when he is at that place? A. Yes, I did. Q. And what did he say about that? A. That he had a lot of massages over there too. MR. CRITTON: Mr. Balsone was which one? THE WITNESS: Baslone was the house manager of Paris, 22 Foch Avenue. BY MR. EDWARDS: if BNESLCmVMAUEaWNeY 14 NNER BEER rFOoOwWwOaAN aM BB BR WON AUDAWNe 10 11 12 13 |14 )15 16 /17 | 18 19 20 21 ee 24 25 Page 421 Q. What's the address? A. 22 Foch Avenue, Paris. F-O-C-H. Q. Okay. Do you know a telephone number for Balsone? A. No, I don't remember, sir. Q. All right. How did it come up that you talked to him about whether or not Mr. Epstein had massages at that house? A. He came on two occasions and stay with me for a week because Mr. Epstein wanted me to get into his style of running the house, and he was good enough to give me some inside information, what he likes and doesn't like, so he told me the same thing was in Paris, Q. And I think that you described Mr. Epstein usually had about two massages a day, or at least we were calling them massages. A. Yes, sir. MR. CRITTON: Form. BY MR. EDWARDS: Q. And did Mr. Balsone describe it in a similar fashion -- A. Yes. Q. -- in Paris? And did he also tell you that the girls Page 422 were very young in age that he was receiving these massages from? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Did he indicate whether or not -- or how old these girls were? A. No, he didn't told me. Q. Just that the age group was similar to the age group that he was interested in in Palm Beach? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. And did you talk to any of the house managers in New York? A. No. Q. Who was the house manager in New York at the time when you were the house manager at El Brillo? A. His nickname was Jo-Jo, but I don't remember. Jo-Jo and his wife, but I don't remember his name, sir. Q. Do you know whether Mr. Epstein would have massages when he was in New York at his New 39 (Pages 419 to 422) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182382

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1 York house? 1 2 A. He will have massages. 2 3 MR. CRITTON: Form. 3 4 BY MR. EDWARDS: 4 5 Q. And are we still talking about a habit of 5 6 twoaday? / 6 7 MR. CRITTON: Form. '7 8 THE WITNESS: I don't know that. 8 9 BY MR. EDWARDS: 9 10 Q. Okay. So for the time period when you 10 11 have been familiar with Mr. Epstein and known his | 11 12 habits, is it fair to say that he would have 12 13 roughly two girls a day in that same age group 13 14 wherever he was? 14 15 A. ‘Yes, /15 16 MR. CRITTON: Form. 16 17 BY MR. EDWARDS: 17 18 Q. All right. And have you talked to | 18 19 anybody that has given you similar information | 19 20 from his Island home? | 20 21 A. No. | 21 22 Q. Do you know any of the girls that have 22 23 been over to his Island? 23 24 A. Yes. 24 25 Q. And who are they? 25 Page 424 Q. When they would be staying at the house would he also have the local Palm Beach girls coming over that you were told to call masseuses? = 11 A. [BIE the girls who used to stay at the 1 home in El Brillo used to go over there to the 2 Island. 3 Q. When he would have these girls -- I guess 4 we've kind of categorized them as the girls who 5 would come over with him on an airplane and stay 6 at the house. 7 A. Yes. 8 9 10 A. Yes. 112 Q. So these girls that came on the airplane /13 with him, were they also -- did they also have 14 knowledge that these young girls were coming over 15 to give massages? 16 MR. CRITTON: Form. 17 NNNNNN PRR RR Re Re Ree UBWNKFOWDNAUDBWNKOUWMANAUDWNeE THE WITNESS: Yes, sir. 18 BY MR. EDWARDS: 19 Q. Okay. Who girls from the 20 airpla r than that you remember? 21 A. There many, sir, "t 22 recall right now. But is for sure, et 23 was one of the main girlfriends, but I don't 124 remember that. | 25 Page 425 |i Q. And is your understanding that Mr. Epstein was intimate with any of those girls? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. With all of them? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. with A. Yes. MR. CRITTON: Form. BY MR. ED' H Q. With A. Yes. MR. CRITTON: Form. BY MR. EDWARDS: Q. And the girls who would come over on the airplane? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Did you ever have occasion to go into the bedroom and find the vibrators or back massagers out after Mr. Epstein was in the room with any of as well? Page 426 | the girls that came over on the plane? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. So that's something that would be out after the girls that came over on the plane or the girls that came over for the massages? A. Yes. MR. CRITTON: Form. BY MR. EDWARDS: Q. And at the time when you were house manager you had a 15-year old daughter? A. Yes. Q. Did she live down here? A. In New Jersey. Q. Okay. When Alan Dershowitz was at the house I understood you to say that these local Palm Beach girls would come over to the house while he was there but you're not sure if he had a massage from any of those girls. A. Exactly Q. And what would he do while those girls were at the house? MR. CRITTON: Form. THE WITNESS: He will read a book with a 40 (Pages 423 to 426) Kress Court Reporting, Inc. [IE 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182383

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WON AN DAWNe WOANAUAWNHe NR RRP RRP Re Re SCWUOMNDAUDBWNHKO 21 24 25 Page 427 glass of wine by the pool, stay inside. 1 BY MR. EDWARDS: 2 Q. Did he ever talk to any of the girls? 3 A. I don't know, sir. 4 Q. Certainly he knew that they were there? 5 MR. CRITTON: Form. 6 THE WITNESS: I don't know, sir. 7 BY MR. EDWARDS: 8 Q. Do you know how a knows Mr. 9 Epstein? 10 A. No, sir, 11 Q. Or how long she's known him? 12 MR. CRITTON: Form. 13 THE WITNESS: She was on board two years | 14 or a year and a half before I came on board. 15 BY MR. EDWARDS: 16 Q. Okay. 17 A. So it’s probably 2003 or 2. 18 Q. Allright. You mentioned this Citrix 19 system. 20 A. Yes. 21 Q. Is that a system that was used to operate 22 the phones and the computers? 23 A. The computers mainly. 24 Q. Allright. But you then also described Page 428 some system where someone would call on the 1 telephone and that would be automatically 2 downloaded to the computer? 3 A. Yeah, you can retrieve who called in a 4 transcript written who called, what's the message, 5 the time so you have it on a piece of paper, you 6 can print it out. 7 Q. Is it your understanding that is also 8 part of the Citrix system? 9 A. Yes. 10 Q. All right. Did you have an e-mail? 11 A. Right now, yes. 12 Q. No, when you were working at -- 13 A. Yes, I did. 14 Q. -- Mr. i 15 And ‘cr have an e-mail? 16 A. Yes. 17 Q. And did all of the e-mails end the same 18 way such as Epstein's house dot com or something? | 19 A. Yes. 20 Q. Okay. What was e-mail? 21 A. I don't remember. 22 Q. What was your e-mail? 23 A. Staff house -- I don't remember, sir. 24 Q. Do you recall how it ended? I mean 25 Page 429 usually it's Yahoo dot com or at Bellsouth dot net. A. It was very uncommon. I don't remember, sir. Q. Did everybody in the -- I think you called it the organization, did everybody have e-mails? A. Yes. Q. Okay. Would that include A. Yes. Q. All right. And did Mr. Epstein have an e-mail? A. Yes. Q. Did you ever correspond with Mr. Epstein by e-mail? A. Yes. MR. EDWARDS: You can go ahead. THE WITNESS: That's the only one that I remember. THE VIDEOGRAPHER: Okay, we're off the record, (Thereupon, a recess was had.) THE VIDEOGRAPHER: We're back on the record with tape number four. BY MR. EDWARDS: Q. Mr. Rodriguez, what was Mr. Epstein's e-mail? A. Jeep project at something -- Jeep project -- I can't remember it right now. Q. Okay. In the course of this next 10 or 15 minutes -- A. I can recall. Q. -- if it comes to you just tell me. So it was Jeep project -- A. Like Jeep, the brand name Jeep, Jeep project at -- I can't remember. Q. Okay. Was that his only e-mail to your knowledge? A. No. Q. He had other e-mail addresses? A. Yes. Q. Do you know what any of his other e-mail addresses were? A. No, I don't remember. Q. Do you know who the carriers were for the other e-mail addresses owned by Jeffrey Epstein? No, sir. Whether it was Yahoo or hot mail or -- No, none of those. Okay. Was this Jeep project e-mail run O>o> 41 (Pages 427 to 430) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182384

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1 through the Citrix system? 2 A. Yes. 3 Q. Okay. And was there a certain company 4 that came out and fixed the actual Citrix system? 5 A. Yes. 6 Q. And who was that? 7 A. We used to have our own in-house 8 technician from Ohio. 9 Q. The same guy you were telling us about 10 before? 11 A. Yes. 12 Q. Allright. He would fix the video 13 equipment or the -- 14 A. Computers mainly. 15 Q. And if the Citrix system broke down too 16 then he would be in charge of it? 17 A. He was the only one dealing with this, we 18 couldn't hire anybody else. 19 Q. Do you know why that is? 20 A. No. It was too many lines into the house 21 from many properties. 22 Q. And do you know who that person is, 23 remember his name now? 24 A. I don't remember, sir. 25 Q. Iunderstood you to say at some point in time that you saw photographs of some of the girls that were at the house to give massages on Ms. Maxwell's computer. A. Yes. Q. And -- MR. CRITTON: Form to the last question. BY MR. EDWARDS: Q. And do you know which of the girls? A. No, sir, Q. Was [i one of them? MR. CRITTON: Form. THE WITNESS: I cannot guarantee that, I cannot say hundred percent, sir. BY MR. EDWARDS: Q. Wasffifone of them? A. Could be, sir. Q. How about | i A. It's the same thing, I cannot say a hundred percent, sir. Q. I think that you used the phrase there were so many girls. A. Yes, sir. NNR RR eR eee ee FOWUDNDAUAWNRFOWMNAUSWNHeE 8 23 Q. That you're not sure which ones you saw? 24 A. No, sir, So many names. 25 Q. Okay. While David Copperfield was ever Page 431 Page 432 BREEN ESwar]9Hawne 17 RRORRSSS RSwemnausauwne 12 Cart i eral ort Onaunsbw Page 433 at the house did any of these girls, these local Palm Beach girls come over to the house as well? A. They were earlier, sometimes they will leave and he will stay for dinner. Q. All right. And you remember there was one time where maybe [i]. stayed for dinner with David Copperfield? A. That's correct. Q. Was there ever a time where [}. and David Copperfield were in a bedroom together? A. I don't think Mr. Copperfield went upstairs. Q. When the police came to the driveway with in the car, what did you tell the police, if anything, that you were paying for? A. They asked me whose this people, and I said they're a masseuse. Q. Okay. Why would you tell them that they're a masseuse, that's the name you were supposed to call them? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. And for these massages you were paying between 300 and 500 dollars each time? Page 434 fj A. Yes, sir. Q. And that's usually for an hour up in the bedroom with Mr. Epstein? A. More or less, yes. Q. You never told your 15-year old daughter at the time that she could come over to Mr. Epstein's for $500 an hour? A. No, sir. MR. CRITTON: Form. BY MR. EDWARDS: Q. Why is it that you never asked your daughter to come over if it's just a massage? MR. CRITTON: Form. THE WITNESS: My daughters are too clean for that, sir. BY MR. EDWARDS: Q. Too clean to give a massage? MR. CRITTON: Form. THE WITNESS: They are good students, they are in another type of environment, sir, we are poor but you know, they're good students. BY MR. EDWARDS: Q. It's because you knew there was more than @ massage going on in the bedroom? 42 (Pages 431 to 434) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182385

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Page 437 fj MR. CRITTON: Form. THE WITNESS: Yes, sir. BY MR. EDWARDS: Q. What are some of Mr. Epstein's companies, if you know the names? A. Well, he was the Price -- Price Com, it was one of his companies, he had a phone company in Palm Beach. A lot of offshore companies that I don't recall, sir. 10 Q. When you say Price Com -- 11 A. Price dot Com, he owned that for awhile. 12 And the local phone company in Palm Beach was his 13 but then he sold it again. But there is too many. 14 Q. As house manager you're obviously at his 15 house every single day, did you inquire as to what 16 he did in terms of making money? 17 A. No, sir, I only got through the internet 18 because I put his name on Google and then I find 19 out the rest of his companies. 20 Q. So during the day when he would go to the 21 cabana I think that you described last time that 22 he would work there? 23 A. He would work there. 24 Q. Do you know what he would do in terms of working? telephone numbers of various girls that were referred to as masseuses, did that also give you access to the girls that were coming over to Mr. Epstein's house in Paris and New York and New Mexico? MR. CRITTON: Form. THE WITNESS: We used to have a book in every car, in every plane, in every boat that Mr. Epstein with all the names of all 10 these people so it was not necessarily a 11 secret. 12 BY MR. EDWARDS: 13 Q. When we're talking all these people, are 14 we talking about -- 15 A. Masseuses and, you know, chefs, the 16 important people in the life of Mr. Epstein, you 17 know, used to have a black book with all the 18 names. 19 Q. So there were many black books? 20 A. Yes. 21 Q. And do you know where those black books 22 are now? 23 A. There were tons of those in the house 24 but, you know, I don't know. Q. Okay. And did each one of them have WON AUDWNe WON AM DBWNHe Page 438 |} Page 436 1 A. No, that was very private. I would put 1 handwritten names and numbers or were these 2 his coffee there and I would shut the door. 2 computer printouts so they were the same? 3 Q. And had a work station or 3 A. They were very organized. Once in awhile 4 work computer within the house? 4 they used to be updated, so we used to have these | 5 A. Yes. 5 books with obsolete dates, you know, so we discard 6 Q. What did she do in terms of work? 6 them and have the new ones. 7 A. She will set appointments for comedy 7 Q. By obsolete dates are you saying that 8 shops, movies. I will get the tickets but, you 8 there were girls that came over and then they no 9 know, she was appointments for the masseuse, or 9 longer came over anymore? 10 travel arrangements with the pilots, that type of 10 A. That's correct. 11 thing. 11 MR. CRITTON: Form. 12 Q. And would she keep track of all of the 12. BY MR. EDWARDS: 13 girls who were coming to his house in Palm Beach | 13 Q. Okay. So if a girl that was coming over 14 or at the other houses as well? 14 for a period of time got too old and was no longer 15 MR. CRITTON: Form. 15 able to come over and somebody else took her place jj 16 THE WITNESS: All of the houses. 16 then her page would disappear from that book? | 17. BY MR. EDWARDS: 17 MR. CRITTON: Form. 18 Q. All right. So if he was going to be in 18 THE WITNESS: I believe so, sir. 19 Paris and he wanted girls over in that house she 19 BY MR. EDWARDS: 20 would keep track of that as well? 20 Q. You were asked about other homes that you 21 MR. CRITTON: Form. 21 worked at for other wealthy people and asked if 22 THE WITNESS: Exactly. 22 these other homes had a massage table. 23 BY MR. EDWARDS: 23 A. Yes. . And when you talked about seeing computer and seeing the names and 24 Q. And you said that they did? A. Yes. 43 (Pages 435 to 438) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182386

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Page 439 Q. Okay. And how old were the girls that Page 440 would come to these other homes? A. They seem older. Q. Older than the ones that would come to Mr. Epstein's home? A. Yes. Q. And did you ever work at a place where there would be girls calling up on the phone to sy! I have girls to bring him and -- No, sir. -- coming over in teams -- No. -- or pairs? No. So there were a lot of things about Mr. Epstein’ s house and his arrangement that were very unusual compared to the other places where you worked? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. And there were no drugs and alcohol or no wild parties at Mr. Epstein's house, that is somewhat different from some of the other places where you worked? A. Yes. Q>OPro> N N ee RESRBESSREURREONESwmvausewne 1 Q. And you said that that was -- the massage 2 table was similar in kind to that used by Mr. 3 Epstein? 4 A. That's correct. 5 Q. And others had massage oils and that was 6 similar in kind to Mr. Epstein's as well? 7 A. Yes. 8 Q. And you didn't think that the massage 9 table at a home was unusual? 10 A. No. 11 Q. Allright. Did any of the other houses 12 where you worked have masseuses that were 14, 15, 13 and 16 years old? 14 MR. CRITTON: Form. 15 THE WITNESS: No, sir. 16 BY MR. EDWARDS: 17 Q. And did any of the other homes where you 18 worked have different girls of that age coming 19 every single day? 20 A. Yes. 21 MR. CRITTON: Form, 22 BY MR. EDWARDS: 23 Q. They had different girls? 24 A. Yes. WONAUDWNeH 12 Page 441 MR. EDWARDS: I don't have anything else. MS. EZELL: I have a few. EXAMINATION BY MS. EZELL: Q. Mr. Rodriguez, I may have missed something. Did you say that there weren't any wild parties ever at El Brillo Way? A. I never saw what was going on inside the house, Ma'am. Q. So you don't know wether there were or were not? A. No, ma'am. Q. There wasn't just one massage table there; was there? A. We used to have two and we have an extra reserve, I think there were three in the house. Excuse me, I'll take that back. All the bedrooms used to have one. Q. Okay. Thani Did you ever hear about a girl named a A. No, no, ma'am. Q. And those pictures on Ms. Maxwell's computer, did you ever see one of a girl naked in a hammock? MR. CRITTON: Form. Asked and answered. THE WITNESS: I saw on a book not on a computer. BY MS. EZELL: Q. You saw a picture of a girl naked in a book or on a book? A. The book was done for [I and she was on the hammock, that’s the only one I Q. I'm sorry, the book was done for A. She was on the cover. Q. Then there were other people inside the book? A. Yes, ma'am. Q. And in that book there was a picture of a girl naked in a hammock? A. Yes. Q. Where did [I keep that book? A. There were a few of those examples but I don't know where she kept it. Q. Was it laying around the house somewhere? A. Yes. Q. Downstairs? A. , yes, ma'am. Q. Did keep scrapbooks or photograph A. Yes. 44 (Pages 439 to 442) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182387

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WANAUDAWNHE NNNNNN BR BeBe ee ee UBWNHKFOWMNAUMDBWNKOWMNADAUDWNE Q. -- of friends, girls? A. Yes, ma'am. MR. CRITTON: Form. BY MS, EZELL: Q. Do you remember there being a young man who would bring girls to the house named Tony Figueroa? A. No,ma'am. The only person that I saw that nigh as at the house, she was driving the car, but I didn't see any males. MR. CRITTON: You said he, he being whom? BY MS. EZELL: Q. I didn't quite understand that either. Tony Figueroa was driving. A. She was with this girl that night I think that's the only time I saw a male at the house, ma'am. Q. And you're talking about the night when you came and found the old car in the driveway? A. Exactly, yes, with the police, yes. Q. How did you remember that it was Tony Figueroa? A. It's the only person, male that I remember. Q. But you don't know his name? A. No, no, no, Ma'am. Q. Got you. Thank you. MR. CRITTON: Can Lask one quick? There was a man with i. you don't know who it was? THE WITNESS: That's the only male that’s been to the house, so when she asked me the question I assume, you know. MR. CRITTON: Do you know who Tony Figueroa is? THE WITNESS: No, sir. MR. CRITTON: Okay. Now I think I understand. Thank you. Sorry, Cathy. MS. EZELL: That's okay. BY MS, EZELL: Q. Iasked you earlier if the chef's name could have been and I was wrong, I wanted to ask you a different name. Could it have been ? A. I don't remember his last name. Q. Do you remember an assistant of some sort who worked there for awhile when you were there named A. Yes. Q. What did she do? GDRONMOVCDVNOUEAWNe SBURRRONESLCmVAaUaWNe 19 |20 21 22 (23 24 Page 445 A. BRIE wos bce IRIE she was bascen and me, I guess. was to help | | in er duties. Q. And is that what your understanding was as to what did? ur understanding that || was with her duties? Have you spoken to any lawyers or investigators about this case since you were deposed last? A. No, ma'am. Q. I believe Mr. Critton was asking you questions relating to the incident when was in a car in the driveway and you went and got the police and he was speaking of that time as being in January of ‘05. Do you remember when it was? A. I will put that in that month, ma'am, but I cannot guarantee. Q. Let me just show you something that we can mark as the next exhibit. I would just ask that if -- yes, the name is in here that we redact it to show just the Page 446 [I initials. MR. EDWARDS: We're going to attach this; right? MS. EZELL: Yes. MR. CRITTON: You're going to let us have this one? MS, EZELL: Yes. With initials. (Exhibit No. 9 was marked for Identification.) BY MS. EZELL: Q. Have you ever seen this report? A. I saw it typed, not handwritten like this. Q. Did the police bring you one that was ? A. No, the only time I saw my own report was_ ff on the internet because my daughter told me do you know that you're in Palm Beach and this and that, so I was in New York on vacation and that's why I read it but this is the first time I'm looking at this. Q. Okay. MR. HOROWITZ: Do you have extra copies? MS. EZELL: I do, I don't want to give them out, I'd rather -- I don't mind them 45 (Pages 443 to 446) Kress Court Reporting, Inc. a 7115 Rue Notre Dame, Miami , FL 33141 EFTA00182388

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attaching it to the deposition as long as it has just the initials. THE WITNESS: This is the report when I called to the police to the house? Q. Let me let you look at it, I'd rather you A. This is why I was fired. This is the reason I was let go. MR. CRITTON: There is no question right now. I'm sure there will be. MR. EDWARDS: I'll ask it if you want. THE WITNESS: I'm thinking out loud. WOBNAUAWNEH | WON AUMDAWNHeE ] j Q. Did you notice the date on this report? A. November 28th, yes, ma'am. Q. And do you have any reason to believe that that's not accurate? A. No, that's it, yeah. Q. And as you look at other information on the report do you see anything else that's not A. Let me finish reading this, please. MR. CRITTON: Let me just object to the form. Can I look at your copy, please? THE WITNESS: This is the first time I Q. Have you had a chance now to read it? A. Yes, ma'am. Q. Okay. Does this report accurately describe what occurred that evening? A. Yes, ma'am. MR. CRITTON: Form. Did you overhear the conversation between and the policeman? A. Yes, ma'am. Q. And is that part accurate as well? r conversation with Mr. -- o> -- is that accurately reported here as oP Now you stated that this is why you got Page 449 Q. Can you tell me what you mean by that? A. Mr. Epstein used to give a lot of gifts to the police department, so we used to have certain leeway in terms of speeding or some other things. So he used to put a baseball cap Palm Beach Police Department on the dashboard. So when he saw I called the police for my own safety because I was carrying cash, I explained that to him, and he say why you called the police, and I said because I saw a clunker in the driveway and it's dark. In Palm Beach there is no nights. So I called for my own safety. I was coming from Publix buying my groceries and I had cash in my pocket. And I said I called the police because I was concerned about my own safety. And I recognized the girl and I figured f because I remember told me earlier that day | -- it was a hectic day, he just left Palm Beach } and I was catching up with my breath, you know, I went to buy my groceries, and I explained that. So he was upset that this will spill, you know, to the public or the street. But I didn't realize this was written or something, you know. Q. You were not fired though until sometime Page 450 | in March? } A. Exactly, yes. But he gave me -- Mr. Epstein used the word I'm going to give you -- he make fun of my Spanish and he said (speaking in Spanish). And I said, yes, Mr. Epstein. Okay, I'll give you one more chance. And I said what's going on. But, you know, it meant a few words, I couldn't talk to him too much, but this was it. Because, you know, I have to say this for myself, you know, I never did something illegal, I was working hard to please him and sometimes more | than I was supposed to, many hours beyond my duties, and so -- but he was concerned about this. And I say, Mr. Epstein, you told me safety is the paramount of this house, in this case it was me, but obviously he didn't care about me, it was his safety. MR. CRITTON: Form. Move to strike. BY MS. EZELL: Q. Can you translate for me what you said a moment ago in -- I don't know -- A. In Spanish he said “conose” amnesty, but he used the word “conose amnistia", I'll give you amnesty so you have a chance to continue working Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 46 (Pages 447 to 450) EFTA00182389

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Page 451 with me. But I didn't ask him why. He just came fast. You're always in the run, you have to be on your toes, and the next thing he said I took the wrong Suburban and they let me go. But I never find out what happened because I have to say this. Being so many people in the house I didn't know if I displease one of the girls, or something I said or I did, I don't think so. So they let me go very mysteriously. But this is it. Q. Iunderstood you to say that Mr. Epstein gave lots of gifts to the police department. A. Yes, ma'am. Q. And you said something about a baseball cap. A. Well, the police department used to give us in retribution dozens of baseball caps with the Palm Beach Police Department, you put one of those on the dashboard you don't get a ticket. Q. Oh. A. Stuff like that. Key rings and so on and so forth. There is -- everybody knows this, I don't think it’s a secret. Mr. Epstein give $85,000 simulator for the police to shoot, you WON AUDAWNF 1 know, and it was returned after the scandal broke 2 out. 3 MR. CRITTON: Move as nonresponsive to 4 any question, Move to strike. 5 MS. EZELL: I don't have any other 6 questions. 7 EXAMINATION 8 BY MR. LANGINO: 9 Q. Mr. Rodriguez, do you know where the main 10 server, the main computer server was located 11 __ inside the house? 12 A. In the garage. 13 Q. Do you know the names of any of the 14 programs -- computer programs -- 15 MR. WILLITS: I am missing something. 16 Whose questioning now? 17 MR. LANGINO: Adam Langino. 18 BY MR. LANGINO: 19 Q. Do you know the names of some of the main 20 computer programs that are used as part of your 21 routine as the house manager of the house? 22 A. The main computers? 23 Q. Programs. 24 A. Besides i 23 6Q Reverding Sc did you ever see Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Page 452 | WONOUDWNe PF Sowmnauauwne al ll etal ort art @OnNaUDWN 19 BSES 24 25 Page 453 | her do you believe under the influence of drugs? A. No. Q. Did you ever see steroids in the house? A. No. MR, LANGINO: Thank you. MR. EDWARDS: Do you have anything, Richard? MR. WILLITS: Yes. MR. EDWARDS: Okay, shoot. EXAMINATION BY MR. WILLITS: Q. Mr. Critton asked you several questions about the females who you were told to refer to as masseuses. And when he asked you those questions he referred to them often as women. | Did you think of those masseuses as women? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. WILLITS: . Why? Because I saw them, they were females. What is your definition of a woman? Person of the opposite sex, I'm a male. Is a three-year old a woman? eo e>oO> Page 454 | Yes. . Okay. MR. WILLITS: I don't have any other questions. MR. EDWARDS: I do but only just to follow-up with this police report that we've just been provided which I'm not sure if it has a designation. MR. CRITTON: Exhibit 9. MR. EDWARDS: Okay. EXAMINATION BY MR. EDWARDS: Q. You were asked by Mi n about I. who we were referring to as i deposition, and her date of birth is And Mr. Critton was indicating to you earlier that at the time that you had this dealing with her in the driveway that she was 18 years old. It appears that this occurred November 28, 2004, which would indicate that she is 17 years old. I think the question that was asked of you is, are you surprised by that, so I'll ask you the same question? A. No, sir. Q. Allright. This report that you have = FL 33141 47 (Pages 451 to 454) EFTA00182390

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Page 455 Page 457 1 indicated is accurate or accurately reflects the 1 Did you get that impression that i was 2 events of that night, I want to make sure that Mr. 2 very nervous in her car when the police showed up? 3 Willits hears and that we go through it and you 13 A. Yes. 4 can elaborate on any part of it. Okay. | 4 Q. Was that an indication to you that she 5 On Sunday, 11/28/2004, at approximately 5 realized that there were police there and that 6 19:00 hours, so we're talking about 7:00 at night, 6 there was some form of illegal activity that she 7 the property manager of 358 El Brillo Way, Alfredo 7 was involved in at Jeffrey Epstein's house? 8 Rodriguez, came to the station to complain there 8 MR. CRITTON: Form. 9 was a strange vehicle parked in the driveway. 9 THE WITNESS: Yes. 10 A. Yes. 10 BY MR. EDWARDS: 11 Q. That's true? 11 Q. JJ's cell phone rang, she answered it 12 A. Yes. |12 quickly, said, in quotes, "I can't talk, I can't 13 Q. When oreo I, this is 13 talk, I'm at school, I got to go." 14 Officer [J talking, at 358 El Brillo, 14 Did you hear that part of it? 15 we located a white female later identified as 15 A. Yeah. 16 =. date of birth EEE waiting in the 16 Q. Okay. That's obviously a lie. Right? 17 driveway. 17 MR. CRITTON: Form. 18 A. That's correct. 18 BY MR. EDWARDS: 19 Q. Okay. 19 Q. She's saying she's at school when really 20 MR. CRITTON: Form. Are you asking him 20 she's right in front of Jeffrey Epstein's house? 21 whether the statement is correct or that 21 A. Yes. 22 you're reading it correctly? 22 Q. And again, another indication that she's 23 BY MR. EDWARDS: 23 doing something she shouldn't be doing. Right? 24 Q. No, the statement is correct. 24 MR. CRITTON: Form. 25 A. Yes. 25 MS. EZELL: Object to the form. Page 456 Page 458 [| Q. That's what you understood me to ask you? 1 BY MR. EDWARDS: A. Yes. 2 Q. If she was a masseuse and was at Q. Okay. arrived at that time and 3 someone's house in relation to pick up money from stated he did remem Eh was there to pick up -- 4 amassage she had given, that’s not the typical was coming there to pickup an envelope the 5 answer that you would expect. Right? homeowner, Jeffrey Epstein, left for her. 6 MR. CRITTON: Form. And that's correct as well. Right? 7 THE WITNESS: That's right. A. Yes. 8 BY MR. EDWARDS: MR. CRITTON: Form. 9 Q. Okay. It didn't shock you or surprise BY MR. EDWARDS: 10 you as Mr. Critton asked you earlier that she Q. This document right here, is it |11 would make up a tale or a lie about her refreshing your recollection as to that night? |12 whereabouts considering what she was doing. A. Yes. /13 Right? MR. CRITTON: Form. 14 A. No. BY MR. EDWARDS: 15 MR. CRITTON: Form. Q. quickly entered the house then 16 BY MR. EDWARDS: return a sealed envelope with Is first /17 Q. Then hung up, talking about Ms. i I name on it. /18 asked her who it was on the phone, she stated it A. Yes. 19 was her mom. I asked her how she knows Epstein, Q. Do you remember who wrote her first name 20 stated the following. She works at Abercrombie on that envelope? 21 Fitch in the Wellington Greens Mall, she met A. Idid. 22 Epstein through a female friend at work, Epstein Q. Okay. The envelope appeared to have 23 allows them to come over any time and use the money in it, in my opinion. § was very nervous {24 house and pool. Then she quickly left. NNNNNN BERR Ree Re ee UBDWNKFKOWANDAUDAWNKFOWANAUAWNE with us standing there. 125 Did you hear that conversation? 48 (Pages 455 to 458) Kress Court Reporting, Inc. orem 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182391

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WONAUDBWNHe NN | SS el cell oll cell lll el cell aoe el el Page 459 A. Yes, they were next to me. Q. Okay. Is that the entire substance of that conversation between Ms. [and the police officer? A. Yes. Q. She didn't mention that she comes over to his house and goes into a bedroom with Mr. Epstein. Right? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS: Q. And she didn't tell the police officer that she is a masseuse; did she? A. No. Q. And that didn't surprise you either; did | it? A. No. MR. CRITTON: Form. BY MR. EDWARDS: Q. I then asked Rodriguez what was in the envelope, Rodriquez was hesitant but -- what is that word? A. But then. Q. But then I said it was drugs and he quickly said it was money. Is that accurate? A. That's correct. Q. When he first asked you what was in the envelope were you nervous? A. No, because I was trying to -- I didn't want to disclose these private things with the police so that's why I was concerned about that. Q. When you're talking about private things, the fact that there are young girls coming over? MR. CRITTON: Form. THE WITNESS: It was late, you know, exactly. BY MR. EDWARDS: Q. I'll let you answer. What are the private things that you were nervous to tell the police? A. This was inside the compound, the property itself, so you have to keep confidentiality, and the police was there, that's why. Not that I was doing something wrong but I was trying to keep them -- Q. I'm not suggesting that you were doing something wrong. A. Exactly. So he asked me is there any drugs there, and I said, no, it’s just money. That's all I said. WONAUDAWNe 14 19 Page 461 | Q. Iasked what kind of job [ff performs, Rodriguez smiled and says she is a massage therapist. A. Yeah. Q. Why did you tell him that? MR. CRITTON: Form. THE WITNESS: Because I understood she came to give massage. BY MR. EDWARDS: Q. Well, that’s what somebody had told you? A. Yes. Q. At this point in time though you knew that more was going on than a massage? MR. CRITTON: Form. BY MR. EDWARDS: Q. Right? MR. CRITTON: Form. THE WITNESS: That's right. BY MR. EDWARDS: Q. lasked -- this is the police officer talking, I asked which muscle she rubbed. Do you remember the police officer asking that? A. Yes. Q. And you knew what he was implying. Right? MR. CRITTON: Form. THE WITNESS: Yeah. BY MR. EDWARDS: Q. That it was obvious to him that she was over there to sexually please Mr. Epstein. Right? MR. CRITTON: Form. THE WITNESS: That's correct. BY MR. EDWARDS: Q. And that's coming from a police officer who's not the house manager. Right? MR. CRITTON: Form. THE WITNESS: That's right. BY MR. EDWARDS: Q. You knew right away what he was asking and you say, Rodriguez laughed said, in quotes, “off the record, he, Epstein, has many young girls come over for that," end quote. Do you remember telling him that? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. And when you were saying come over for that, it was -- A. Massage or something. 49 (Pages 459 to 462) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182392

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WOOMONAUDAWNH ath ed 25 Q. -- to sexually please Mr. Epstein. Right? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. I mean, that's what you were telling the police officer. MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Okay. There's always a different girl at the pool or inside with him when he's here. MR. CRITTON: Form. THE WITNESS: Yes. MS. EZELL: You left out a word, young. BY MR. EDWARDS: Q. Sorry, I'll read the last sentence again. There's always a different young girl at the pool or inside with him when he's here. Do you remember telling the police officer that? A. Yes. MR. CRITTON: Form. BY MR. EDWARDS: Q. And that's true. Right? A. Yes. Q. When he's at the house there is always a young girl inside with him. MR. CRITTON: Form. BY MR. EDWARDS: Q. Right? A. That's right. Q. Okay. And whether the company line is to call them a masseuse, you knew that these girls were young and were up in the bedroom with Mr. Epstein to sexually please Mr. Epstein. MR. CRITTON: Form. THE WITNESS: That's right. MR. EDWARDS: I don't have anything else. We've already attached this; right? Here is the one that can be attached. MR. WILLITS: Who is next? MR. CRITTON: Me. RECROSS EXAMINATION BY MR. CRITTON: Q. Mr. Rodriguez, looking at Exhibit 9 which is the police report that was prepared on November 28, 2004, this is the first time you've seen it. Correct? A. That's correct. Page 463 Page 464 WONAUDAWNHe Page 465 Q. And as to -- it was read to you by Mr. Edwards and he then asked you a number of questions whether you remembered something. Correct? A. Yes. Q. Okay. Just so I'm clear, he's asking you } to speculate on what may or may not have occurred upstairs in the bedroom. I want to be very clear. Mr. Rodriguez, were you ever up in the bedroom to observe whatever went on between a masseuse and Mr. Epstein or anyone else for that matter at any time? MR. HOROWITZ: Form. THE WITNESS: No, sir. BY MR. CRITTON: Q. And so when Mr. Edwards asked you, you were aware that sexual activity or may have been sexual activity occurring upstairs, you have no personal knowledge, you're just speculating; aren't you, sir? MR. HOROWITZ: Form. MR. EDWARDS: Object to the form. THE WITNESS: I never saw them. BY MR. WILLITS: Q. And therefore you can only speculate -- MR, WILLITS: Object to the form. MR. CRITTON: I need to ask the question first. MR. WILLITS: It was the earlier question. BY MR. CRITTON: Q. Allright. If you did not see what was going on you can have no personal knowledge. True? MR. HOROWITZ: Object to the form. MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q. And, therefore, what you're doing is speculating or guessing what may have been occurring. True? MR. HOROWITZ: Form. MR. EDWARDS: Form. MR. WILLITS: Form. THE WITNESS: I use my age together. BY MR. CRITTON: Q. I'm not saying that you don't, but without having personal knowledge you're best guessing what may have occurred up there between Mr. Epstein and one of the massage women, or for 50 (Pages 463 to 466) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182393

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WOMNAUAWNE N DS ll ell el ell oll el oe en Page 467 that matter anyone else who was upstairs? A. Yes. MR. HOROWITZ: Form. MR. EDWARDS: Form. MR. WILLITS: Object to the form. MR. CRITTON: Thank you. MS. EZELL: I just have a couple of questions. EXAMINATION BY MS. EZELL: Q. Following up on that, you did however see this same young woman asleep naked in the sauna? A. Yes, ma'am. Q. And you did along with find and -- and you did also find sex toys and massagers of various kinds and creams scattered around on several occasions after these young women had been’ upstairs with Mr. Epstein? MR. CRITTON: Object to form, asked and answered about six times. THE WITNESS: Yes. MS. EZELL: No other questions. MR. EDWARDS: Sorry, last one. It has nothing to do with this report. EXAMINATION Page 468 BY MR. EDWARDS: Q. During Mr. Critton's questioning he asked you about whether or not we had ever shown you a previous taped statement that you had given to a police officer, and we did not do that; did we? A. No. Q. Wecan represent to you that we don't have it to show it to you otherwise we would like to do that. However, he asked you did you tell the police officers at that time that the girls appeared to be 18 years or older, and I believe that you said when you gave the statement to the police that you did; right, say that? A. Yes. Q. And I wrote, I put it in quotes, you said that because you were fearful of reprise from Ms. Maxwell and Mr. Epstein. A. That's correct. MR. CRITTON: Form. BY MR. EDWARDS: Q. Okay. Is everything that you've said today and told us today, is it true? A. Yes. Q. To the best of your knowledge? Swmvauswne Dr Swmnuaunawne 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. MR. EDWARDS: Nothing else. MR. WILLITS: Is it my turn? MR. EDWARDS: Yes. EXAMINATION BY MR. WILLITS: Q. Mr. Rodriguez, you mentioned the last time about a lady who was an lous professional ; masseuse by the name of Do you remember that? A. Yes, I do remember. Q. Did you ever pay her? A. Yes, sir. Q. Okay. How much did you pay her? A. It was between 200 and 500, sir, but somewhe -- between those two amounts. Q. For A. Yes, sir. MR. WILLITS: Okay. I don't have any other questions. MR. CRITTON: You have a right to read this deposition when the other part is typed and make any changes that you want. Would you like to do that? It's your right a hundred percent. The court reporter can provide you or whoever set your deposition -- THE WITNESS: I tried to be truthful. MR. CRITTON: All you have to do is tell her you would like to waive. Do you waive the reading and signing? MR. EDWARDS: You can either read or you can waive reading? THE WITNESS: I don't understand what I have to do. MR. CRITTON: Why don't we go off the record and you can explain it to him. MR. EDWARDS: We can go off the record. THE VIDEOGRAPHER: Off the record. (Thereupon, a discussion was held off the record.) THE WITNESS: Waive. (Thereupon, the deposition was concluded at 5:30 p.m.) 51 (Pages 467 to 470) Kress Court Reporting, Inc. fF 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182394

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THE STATE OF FLORIDA, ) COUNTY OF DADE. ) I, the undersigned authority, certify that ALFREDO RODRIGUEZ personally appeared before me on the 7th day of August, 2009 and was duly sworn. WON AU DWNe 10 WITNESS my hand and official seal this 18th day of August, 2009. MICHELLE PAYNE, Court Reporter Notary Public - State of Florida CERTIFICATE ‘The State Of Florkta, —) County Of Dade. ) 1, MICHELLE PAYNE, Court Reporter and I further certify that said deposition was I further certify that I am not an 13 attorney or counsel of any of the parties, nor am 1 a relative or employee of any attorney or 14 counsel of party connected with the action, nor am T financially interested in the action, 17 control and/or direction of the certifying reporter. DATED this 18th day of August, 2009. MICHELLE PAYNE, Court Reporter 52 (Pages 471 to 472) Kress Court Reporting, Inc. a 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182395

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