UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO: 08-CV-80119 Plaintiff, — CONDENSED JEFFREY EPSTEIN, Defendant. / 8 JANE DOE NO. 3, CASE NO: 08-CV-80232 9 Plaintiff, 10 Vs. 11 JEFFREY EPSTEIN, 12 Defendant. 13 / ~ 14 JANE DOE NO, 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. / 19 JANE DOE NO. 5, CASE NO: 08-CV-80381 20 Plaintiff, 21 Vs 22 JEFFREY EPSTEIN, 23 Defendant. EFTA00310278

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3 14 15 16 JANE DOE NO. 7, Vs. JEFFREY EPSTEIN, CMA., 1 JANE DOE NO. 6, CASE NO: 08-CV-B0994 1 IN THE CIRCUIT COURT OF THE 15TH 2 Plainti?, JUDICIAL CIRCUIT IN AND FOR \eerey e PALM BEACH COUNTY, FLORIDA 5 Def ey erst EN, CASE NO. 502008CA03731900XXMB AB a | CASE NO: 08-CV-80993 Praintif?, Defendant. CASE NO; 08-Cv-80611 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. JEFFREY EPSTEIN. Defendant. 12 1031 Ives Dairy Road —— JANE DOE, CASE NO; 08-Cv-80893 Plaintiff, 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 of 20 ALFREDO RODRIGUEZ Vs. JEFFREY EPSTEIN, Oefendant. —_—___—___/ 22 taken on behalf of the Plaintiffs pursuant 23 toa Re-Notice of Taking Continued Videotaped 24 Deposition (Duces Tecum) 25 --- 1 JANE DOE NO. II, CASE NO: 08-CV-80469 APPEARANCES: : em MERMELSTEIN & HOROWITZ, P.A. 4 JEFFREY EPSTEIN, accnenmneeein 5 Defendant. a | 6 : JANE DOE NO. 101 CASE NO: 08-CV-80591 6, end 7. 7 _ ROTHSTEIN ROSENFELDT ADLER 5 Plaintiff, BY: BRAD J, EDWARDS, ESQ., and Vs. 9 JEFFREY EPSTEIN, 10 ney Defendant. And LM. 11 j 12 JANEDOENO. 102, CASE NO: 08-CV-80656 PODHURST ORSECK - 13 Plaintiff, ° 14 Vs. 15 JEFFREY EPSTEIN, 16 Defendant, Attorney for Jane Doe 101 and 102. —___/ 17 18 19 20 21 Pain Beach Gardens, Florida 33410 22 Attorney for B.8. 23 24 2s 2 (Pages 271 to 274) Kress Court Reporting, Inc. FY EFTA00310279

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APPEARANCES: RICHARD WILLITS, ESQ. 2290 20th Avenue North tahe Worth Florida 33461 Attorney for C.M.A. Appeared via telephone. BURMAN, CRITTON, LUTTIER & COLEMAN, LLP BY: ROBERT CRITTON, ESQ. 515 North Flagler Drive Suite 400 West Palm Beach, Florida 33401 Attorney for Jeffrey Epstein. ALSO PRESENT; JOE LANGSAM, VIDEOGRAPHER CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ (By Ms, Ezell) 278 441, 467 (By Mr. Willits) 334 453, 469 (By Mr, Critton) 338 464 (By Mr, Edwards) 419, 454, 468 (By Mr. Langino) 452 CONTINUED INDEX OF EXHIBITS PLAINTIFFS PAGE 3 Drawing 315 4 Photograph 327 5 Photograph 331 6PI 331 7 Photograph 331 8 Photograph 331 Report 6 9 44 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. Ezell.) Page 277 Deposition taken before MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is a continuation of the deposition of Alfredo Rodriguez. Today is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in 10 the witness? 11 Thereupon, 12 ALFREDO RODRIGUEZ, 13 having been first duly sworn or affirmed, was 14 examined and testified as follows: 15 MR. CRITTON: Before we get started just 16 with regard to Ms. Ezell represents Jane Doe 17 101 and 102, the alleged time of her 18 incidents as of least have been plead in the 19 complaint for 101 Is 99 -- I'm sorry, '98 20 through 2002, with Jane Doe 102 the Spring 21 of -- Spring/Summer of 2003. Mr. Rodriguez 22 never even began employment until '04 and 23 ‘OS. I think her questioning I think -- I 24 can't say she doesn't have standing based on the court order, but I would say it's WOnAUSWNe Page 278 1 completely irrelevant and immaterial and has 2 no probative value with regard to this 3 particular witness based upon the two 4 clients at least that are in suit at this 5 point in time. 6 7 8 9 MS, EZELL: As Mr. Critton well knows I represent a number of other clients whose cases have not been filed and I believe we do have standing to ask questions, and I do 10 intend to do that today. il EXAMINATION 12 BY MS. EZELL: 13 Q. Mr. Rodriguez, you stated last time that 14 there were guests at the house, frequent guests, 15 friends from Harvard, 16 Do you remember that testimony? 17 A. Yes, ma'am. i 18 Q. And was there a lawyer from Harvard named | 19 Alan Dershowitz? i 20 A. Yes, ma'am. 21 Q. And are you familiar with the fact that 22 he's a famous author and famous lawyer? 23 A. Yes, ma'am. 24 Q. How often during the six months or so that you were there was Mr, Dershowitz there? 3 (Pages 275 to 278) Kress Court — a EFTA00310280

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WONOUDWNP A. Two or three times. Q. And did you have any knowledge of why he was visiting there? A. No, ma'am. Q. You don't know whether or not he was a lawyer -- acting as a lawyer or whether he was there as a friend? A. I believe as a friend. Q. Were there also young ladies in the house at the time he was there? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: insta ? A. Yes, ma'am. Q. Were there other young ladies there when Mr. Dershowitz was there? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. Do you have any idea who those young women were? A. No, ma'am. Q. Were any of those the young women that you have said came to give massages? A. Yes, ma'am. Q. And do you have any idea whether or not Mr. Dershowitz was also receiving massages? A. I don't know, Ma'am. Q. I want to ask you to take this piece of paper, please, and a pencil -- MR, WILLITS: Can anybody hear me? MS. EZELL: Yes. Can you hear me? MR. WILLITS: I've heard nothing for about a minute or so. MR. CRITTON: Can you hear me now? MR, WILLITS: Yes. MS. EZELL: I'm asking questions, I'm sorry. MR. CRITTON: Why don't we go off the record for a second. (Thereupon, a discussion was held off the record.) THE VIDEOGRAPHER: We're back on the record. BY MS. EZELL: Q. Mr. Rodriguez, you indicated that there were several staircases in the house? A. Yes, ma'am. Page 279 Page 280 WOON DU DAWNHE Page 281 Q. Can you tell me where those were? A. One in the kitchen, and the one in the formal -- the main entrance. And there was one more added later on, but there is two when I was working there. Q. Could you just give me a rough sketch of the house of where the main entrance was and where | the kitchen was? | A. I'm not an architect but it's something like this. This is the kitchen, this is the main entrance. Q. Will you mark the kitchen with a K, please, and the main entrance with ME? 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? A. This is one, the kitchen, one in the foyer, and the pool. Q. Okay. And would you just put an F where the foyer staircase began? And KS where the kitchen staircase began. 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? t A. T'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 i driveway and we used to take into the back door of } preriere> 4 (Pages 279 to 282) EFTA00310281

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Page 283 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 | giving the massages? t MR, CRITTON: Form. THE WITNESS: I will hear the commotion, some voices, but I was not told they were ll leaving. 12 BY MS. EZELL: 13 Q. And so did you have any duties that had 14 anything to do with their leaving? 15 A. Check the security and see if the gate 16 was closed, that the cars were locked because the 17 garage were here. 18 Q. Would you put a G where the garage was? 19 I believe you testified that you were 20 required to have on your person $2,000 everyday? 21 A. More or less, Ma'am. 22 Q. And if you open the door and a young 23 there to give a massage you would call 24 land go back to the staff house? ‘es, ma'am, Page 286 jf Q. And then you believe would the kitchen and they will wait there. Q. All right. 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: 10 Q. Did any ever come to the front door? il A. Very rarely. 12 Q. And you would let them in the kitchen? 13 A. Yes, ma'am. 14 how did you then turn them over 15 to ? 16 MR. ON: Form. 17 THE WITNESS: I will call her. 18 BY MS. EZELL: 19 Q. How would you call her? 20 A. On her cell phone and she will know they 21 were waiting in the kitchen. 22 Q. And would you bring them in the kitchen 23 and then just leave? 24 A. Yes, ma'am. Q. And where would you go? WANAUAWNE — OWON AU SWNe Page 284 1 A. To my -- to the staff house that was 1 2 here, 2 come in and lead the young woman upstairs. 3 Q. Good, I was going to ask you to show me 3 Correct? 4 where the staff house is. Just put SH. 4 MR, CRITTON: Form. 5 A. It was just maybe five feet, I used to 5 THE WITNESS: I'm sorry, can you repeat 6 stay here. 6 your question? 7 Q. Okay. So what you're saying, it’s about 7 BY MS, EZELL: 8 five feet from the kitchen? 8 Q. T'll try to, yes. 9 A. More or less, yes. 9 When you would answer the door and there 10 Q. Was it connected to the house? li A. No, it's detached but it's very close 12 proximity. 13 Q. Okay. So to get to the staff house would 14 you come out the kitchen door? 15 A. Yes, ma'am. And I came through my -- 16 there was two entrances, one through the laundry 17 here and one to the main entrance to the staff 18 house. 19 Q. Allright. And what was your usual 20 pathway if you left the kitchen to enter the staff 21 house, how would you generally do it? 22 A. Normally I will came to the laundry, the 23 laundry was here and my office was next to the 24 =~ laundry. 25 Q. Okay. Thank you. 10 would be a young lady there to give a massage. 11 A. Yes, ma'am. 12 Q. I believe you testified you would let her 13 in the kitchen. 14 A. Yes, ma'am. 15 Q. Andyou called 16 A. Yes, ma’am. 17 Q. And you then left her in the kitchen 18 alone? 19 A. Yes. 20 Q. And went to the staff house? 21 A. Yes, ma'am. 22 Q. And sometimes you heard the commotion 23 when the young woman was leaving -- 24 A. Yes, ma'am. 25 Q. -- but you didn't necessarily see them 5 (Pages 283 to 286) EFTA00310282

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WONAUDWNE WOANAMUAWNH NN eS ee ad leave. Is that correct? A. Exactly, yes, ma'am. Q. How did it the money that you were keeping — to pay those young women? A. Id tell me who to pay and how much, that's the way we work. Q. And when would she tell you that? A. She will call me by phone and say I'll give so much to so on and so forth. Q. Okay. Was that at the conclusion of the massage? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. Okay. Then I'ma little confused because I thought you said that you didn't see them when they left from giving the massage. A. She will call me and she will say pay X, Y, or Z, and that’s the way I knew how much and to whom. But sometimes they would leave and I didn’t pay those, I don't know who paid them. Q. Okay. So if she calls you and told you to pay X, Y, and Z $200, would you then go back into the kitchen and give X, Y, and Z $200 each? 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 vs. 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? A. She had a laptop but she usually work in the dining room. Q. And where was the dining room? A. All this area facing the garde: north -- I'm sorry, facing south, ii. was at her desk here. Q. So did the dining room have large windows? OPOPO Kress Court Reporting, Inc. P| Page 287 Page 288 Page 289 Ff A. Yes. le south face of the house, | but this ves Q. Allrig nd 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. 10 MR. CRITTON: Form. 11 BY MS. EZELL: 12 Q. And do you know in what form she kept 13 those? 14 A. She had notes, you know, she always have 15 papers, but I don't know. 16 Q. Do you recall seeing the papers with 17 telephone numbers on them? 18 A. Acouple of times. 19 Q. Do you know whether she also kept records 20 on the computer relating to the girls? yal MR. CRITTON: Form. 22 THE WITNESS: Yes, ma'am. 23 +BY MS. EZELL: 24 Q. And how do you know that? 25 A. Everything was recorded in -- everything WON auUlWNre Page 24 1 we did as employees we used to record and kept in 2 the internal circuit we used to have among the ' 3 employees. 4 Q. And so would it be, if I understand you 5 correctly then, was there some sort of a program 6 so could access information that 7 Ms. as putting into that program and she 8 oo information you put in? 9 A. Yes, ma'am. 10 Q. And did you also send each other e-mails 11 that way or did you use a different program for 12 a 13 A. didn't send direct e-mails to me 14 but she will call me on her cell. But I was 15 supposed to send through Citrix to other 16 employees. 17 Q. E-mail them through Citrix? 18 A. Yes, ma'am. 19 Q. Okay. And who would those other 20 employees be, have been, I mean, while you were 21 there? 22 A. Mrs. 23 the ma yes, the secretary, and somebody 6 (Pages 287 to 290) EFTA00310283

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WON DAU AWNHE 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 pictures of the young women wh 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. WON AUAWNH kept any come to give 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 —€ bringing a picture to give to 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? Page 293 A. I don't remember, ma’ Q. Did you ever small compact camera to a 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 ho told you that? A. I think it was . Q. Do you recall what she said about that? sing that re of the 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) EFTA00310284

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Page 297 | MR. CRITTON: Form. BY MS, EZELL: THE WITNESS: No, ma'am. Q. And was that already installed when you BY MS. EZELL: came there? 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 10 young women? il MR, CRITTON: Form. 12 THE WITNESS: Not on the stairway, they 13 were in the foyer in the second -- on the 14 foyer and the foyer leading to the master 15 bedroom. 16 BY MS, EZELL: 17 Q. Isee. Were those -- what size generally 18 were those pictures? 19 A. They were, you know, I'll say three by five 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? 10 A. No. il Q. Do you know whether or not there was 12 surveillance photography equipment upstairs and 13 downstairs? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 17 Q. And how do you know that? 18 A. I read it through the FBI report after 19 the fact that I -- after I left the job. 20 Q. Before reading through the FBI report did 21 you have any knowledge of the fact that there was 22 surveillance equipment both upstairs and 23 downstairs? 24 A. No, ma'am. 25 Q. While you were there was there ever an WONDUDWNE WOnNAUSBWNe 21 Q. So very large -- 22 A. Yes, ma‘am. 23 Q. -- pictures? Were there lots of 24 photographs just around the house on top of furniture in the various rooms? Page 296 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? occasion when someone came to do any maintenance or repair on the surveillance equipment? A. Yes, ma'am. MR, CRITTON: Form of the last question. BY MS. EZELL: WON AUDWNK A. ind some other girl from Brazil Q. Did that happen more than one time? 10 that was in house but I don't remember her 10 A. Ibelieve so, yes, ma'am. 11 name. 11 Q. Do you have any recollection of who came 12 Q. Was this a girl that would come and stay 12 there, either the name of the company or the name 13 in the house or one of the girls that would come 13 of the person who would come to repair or do 14 and give massages? 14 maintenance on the video equipment? 15 A. They will stay at the house. 15 A. We used to have a young technician from 16 Q. Stay at the house. Do you recall a 16 Ohio who used to maintain all the computers and he 17 _ picture of the girl, of a young women nude in a 17 would be the only one dealing with those things. 18 hammock? 18 Q. So he maintained the computers and the 19 MR. CRITTON: Form. 19 video equipment. 20 THE WITNESS: No, I don't remember. 20 A. Yes. 21 BY MS. EZELL: 22 Q. Was there surveillance equipment 23 installed in the house? 24 A. Yes, ma'am. 25 MR. CRITTON: Form. 21 Q. Is that correct? 22 MR, CRITTON: Form. 23 BY MS. EZELL: 24 Q. Do you have any recollection of what his 25 name was? 8 (Pages 295 to 298) EFTA00310285

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WOnNAULBWNe Page 299 A. I don't remember, Ma'am. He came from New Albany, Ohio. Q. From New -- A. New Albany, Ohio. 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? A. No, ma'am. Q. Do you know whether at that time Mr. Epstein had an office in Palm Beach? A. Not outside the house, no. Q. Do you have any knowledge of whether or not the video equipment was -- and I don't know the technical term, forgive me, but was it the kind of equipment that would record for a certain amount of time and then record over that film? A. I don't know. MR. CRITTON: Form. BY MS. EZELL: Q. You don't know? A. No, ma’am, MR, CRITTON: Just for clarification, I may have misunderstood, but I thought he Page 300 said he didn't even know the video equipment existed until he read the FBI report. MS, EZELL: He said he didn’t know that it was upstairs and downstairs, I believe. MR, CRITTON: I thought he said he didn't know that it even existed. MS. EZELL: I may be wrong. BY MS. EZELL: Q. Did you know it existed before you read the FBI report? A. No, ma'am. Q. I'm sorry, then I was wrong. How did you know then that the young technician from Ohio maintained the computers and the video equipment? A. Because we used to request -- there were always problems with the computers so he came to the house and he was the programmer. It was very sophisticated, MR. CRITTON: Form to the last question, move to strike the answer as nonresponsive. BY MS. EZELL: Q. How did you know then that he maintained the video equipment as well? A. Because he was in charge of computers, WON DUAWNH Page 301 video, even phones. Q. Would he also repair the televisions if they needed work? A. 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. MS. EZELL: Just let the record reflect that the witness pointed to the telephone on the table that has a speaker phone. THE WITNESS: Yes, ma’am. BY MS. EZELL: Q. And did you use that in your work? A. Yes, ma'am. Q. And what did you use it for? A. Mr. Epstein used to page me when he needed me. Q. Did you have one of those phones in the kitchen? A. Yes, ma'am. Q. And was there one out in the staff house Page 302 |} as well? I A. Yes, ma'am. Q. Do you know where others were in the house? A. Probably have like 15 phones. We used to have three in the staff house, one in the cabana, two in the master bedroom, one in each room, kitchen, dining room, Mrs. Maxwell's office, the garage. Q. Where was Mrs. Maxwell's office? A. Under the stairs next to the kitchen. Q. Can you give me some idea of what size space that was? A. It was probably -- we change the floor. Twelve by five, something like that. Q. And was the computer equipment in that space? A. Yes, ma'am. Q. Do you know whether Ms. Maxwell kept the names and telephone numbers of the girls who came} to do massages? | A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. Do you know that because you saw the 9 (Pages 299 to 302) EFTA00310286

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1 names and phone numbers? 1 computer? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 5 Q. And did she generally have phone numbers 6 girls on the computer? 6 for those girls? 7 A. Yes, she did. 7 A. Yes, ma'am. 8 Q. And you know that as well because you 8 Q. And were they generally pictures of the 9 happen to see them? 9 girls? 10 A. Yes, ma'am. 10 MR, CRITTON: Form. 11 MR, CRITTON: Form to the last two il THE WITNESS: No, ma'am. 12 BY MS. EZELL: 13 Q. And did Ms, Maxwell have a list of the 14 girls who came to give massages? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 A. Yes, ma'am. 20 MR. CRITTON: Form. 21 +BY MS, EZELL: 22 Q. Were there pictures on her computer of 23 the girls who came to give massages? 24 MR. CRITTON: Form. 25 BY MS. EZELL: 12 questions. 13. BY MS, EZELL: 14 they similar to the pictures that iS Ms. had on her computer? 16 . CRITTON: Form. 17 THE WITNESS: Yes, ma'am. 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 look like pictures that were posed? 21 A. They were more casual, 22 Q. Did they look as though the person being 23 photographed knew that they were being 24 photographed? 25 MR. CRITTON: Form. Page 304 Page 306 THE WITNESS: No, ma'am. BY MS. EZELL: Q. And what can you tell me about that, what lead you to draw that conclusion? 1 Q. Ms. Maxwell I'm talking about. 2 3 4 5 A. They were probably taken in parties in 6 7 8 9 1 2 A. Yes, ma'am. 3 Q. And were those pictures the more casual 4 ones that you described when I asked whether orf 5 _ not the subject looked as though she knew she was 6 7 8 9 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 10 girls generically, he has probably seen li many, many young girls, there was no -- 12 you've used it interchangeably with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, being photographed? MR. CRITTON: Form. THE WITNESS: I'm sorry, can you repeat? BY MS. EZELL: 10 Q. Yeah. The pictures of the young girls 11 who came to the house to give massages that were 12 on Ms, Maxwell's computer, did they appear to have 13 been taken when the girls knew they were being | 14 photographed? 15 MR, CRITTON: Form. 16 so that’s part of my form objection. 16 THE WITNESS: I don't think they knew 17 MS. EZELL: Okay, thank you. 17 they were being photographed. 18 BY MS. EZELL: 18 BY MS. EZELL: 19 Q. When I asked you about Ms. whether | 19 Q. I believe you said they were more casual 20 she had a list of the girls and tel bers, 20 pictures. 21 I think I asked about those girls that came to 22 give massages, but let me go back and just ask it 23 ‘that way. 24 Did you notice that ms. Bia a list 25 of the girls that came to give massages on her 21 A. Yes, ma'am. 22 Q. Did you notice any nude photographs in 23 those pictures? 24 A. Yes, ma‘am. 25 MR. CRITTON: Form for the last question. Kress Court = inc 10 (Pages 303 to 306) EFTA00310287

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WONDUAWNH N Ce ee le ol ol ol ol Page 307 BY MS. EZELL: Q. Among those pictures in Ms, Maxwell's computer of the young women who came there to give 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 at receptions or banquets? A. Yes, ma'am. Q. And I'm alittle confused about how they were casual and taken while the girls were nude at receptions and banquets? A. What I saw there were parties in Russia, Eastern Europe, I don't know which country, but there were also pictures of nude girls in a shower, for instance, in a shower stall. Q. You said for instance, so were there other places other than the shower? A. Yes, ma'am. Q. Like what? A. Gatherings, you know, in a party. You could tell everybody is smiling so I believe it was a place where they're having fun. Page 308 Q. Were any of those pictures, if you recall, taken in the cabana? A. I don't remember. Q. Do you recall there being parties and gatherings in the cabana at the house? A. I don’t remember. MR. CRITTON: Form. BY MS. EZELL: Q. When Mr. Epstein entertained did you have anything to do with seeing that the bars were stocked and that there was food that was needed and so forth? MR. CRITTON: Form. THE WITNESS: There was no alcohol in the house, only for guests. But, yeah, he will ask sometimes for food. BY MS. EZELL: Q. And do you ever recall him asking for food for parties in the cabana? A. No, ma'am. Q. Was there a chef at the house on EI Brillo Way when you were there? A, I'm sorry? Q. Achef. A. Yes, there was. Page 309 Q. And was there more than one during the time you were there? A. Yes. Q. Do you their names? A. One I don't remember the other one name. Q. Did they appear to be American? A. Yes, ma'am. Q. Do you know the nam A. Could be, ma'am, but I'm not sure of his last name. 12 Q. Do you have any idea where those chefs had g ir training? 14 A. was working in San Francisco when he was hired. Q. Was he still there when you left Mr. Epstein's employ? A. Yes, to my knowledge, ma'am. Q. Did the chef interact with the girls who came to give massages? A. In the kitchen, yes. Q. And did he often offer them some food while they were there? A. Yes, ma'am. Q. Were there occasions where a girl came to WON AUDBWNe Page 310 fi 1 give a massage accompanied by another girl, or 2 another person, let me say? 3 A. Yes, ma'am. 4 Q. And sometimes was that other person a 5 woman and sometimes a man? 6 A. No, ma'am, always a woman, 7 Q. Always a woman. Usually would it have 8 been a woman about the same age as the young woman 9 coming to give the massage? MR. CRITTON: Form, il THE WITNESS: Yes, ma'am. 12 BY MS, EZELL: 13 Q. Were you ever told by ™ 86 pay the person who came who didn't give a massage? A. Yes, ma‘am. 16 Q. Do you recall how much you paid that person? A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. How much? A. 300 to 500 dollars. Q. Were some of those young women who brought other young women for massages regulars, I mean, did they regularly bring other young women? 11 (Pages 307 to 310) EFTA00310288

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MR. CRITTON: Form. shower, I don't know whether he ever used THE WITNESS: Yes, ma'am. plural. BY MS. EZELL: BY MS. EZELL: Q. And were there some who maybe came just Q. Was there more than one picture of a girl once or twice with other young women? in the shower? 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 10 the massage? ll MR. CRITTON: Form. 12 THE W) I will take them to the 13 kitchen oni take them from 14 there. 15 BY MS. EZELL: 16 Q. Do you know where she took them? 17 A. No, ma'am. 18 Q. Were they ever taken to just sit in the 19 living room and wait? 20 MR. CRITTON: Form. 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 10 something sexual? 11 A. Yes, ma'am. 12 Q. And I may have asked you this question, 13 forgive me if I did, did you know those two girls? 14 A. No, ma'am. 15 Did Ms, Maxwell have nude pictures of 16 on her computer? 17 MR. CRITTON: Form. 18 THE WITNESS: I don't know, ma'am. 19 BY MS. EZELL: 20 Q. Did you ever meet a young woman named WON AU AWN WOBNAUAWNH 21 THE WITNESS: I don’t know, ma'am, 21 aro had an with Ms. Maxwell? 22 +BY MS. EZELL: 22 MR. CRITT! 23 Q. These pictures of nude young women taken 23 MS, EZELL: 24 THE WITN 25 BY MS. EZELL: 24 in gatherings where they were smiling, did they appear to you to be taking part in an orgy? lon't remember, ma'am. Page 312 Page 314 |} Q. Did you ever have any conversations with =f Ms. Maxwell about any of the women in those pictures? A. No, ma'am, id you ever have a conversation with about any of the pictures of the mputer? 1 2 3 4 5 6 7 8 A. No, ma'am. 9 Q. You were asked last time about the creams 10 and lotions that Mr. Epstein typically had 11 available to him and you said you thought there 12 was a favorite one but you couldn't remember it. 13 A. Spa. 14 Q. Spa, you did say Spa. 15 A. Yeah. 16 Q. Thank you. 17 18 19 20 21 22 23 24 25 1 MR. CRITTON: Form. 2 THE WITNESS: I don't know, ma'am. 3 BY MS, EZELL: 4 Q. Do you know the word cavorting? 5 A. No, ma'am, I don't know. 6 7 8 9 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 10 sexual? il A. Yes, ma‘am. 12 Q. And in these instances were there girls 13 doing sexual things with other girls? 14 A. Yes, ma'am. 15 Q. And I'm still talking about the pictures 16 on Ms. Maxwell's computer. 17 A. Yes, ma’am. Where did the stairway from the kitchen 18 MR. CRITTON: You're talking about the lead -- to where did it lead? 19 group shots that he's mentioned from Russia A. To the second floor between the first and 20 and Eastern Europe? second bedrooms. 21 MS. EZELL: And girls in the shower. Q. Were either of those bedrooms the master 22 MR, CRITTON: Let me object to the form bedroom? 23 then the way you just now described that. MS, EZELL: He said for instance. MR. CRITTON: He had said a girl in the 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) EFTA00310289

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master bedroom? A. Yes, ma'am. Q. And how would you do that? If you want to turn the page over for the upstairs you could do that. A. Okay. MR, CRITTON: Are you going to mark this as an exhibit? MS, EZELL: Uh-huh. MR. CRITTON: Would that be Exhibit 3? MR, EDWARDS: I think so. (Exhibit No, 3 was marked for Identification.) master bath, and there were one, two -- the rest of the bedrooms were here and the master bedroom was here. This is master bath one and master bath two. So the staircase came to the second floor like this and it was between the first and second bedroom. And you could go through here and you enter a foyer with double doors here, double doors here, and you enter the master bedroom. BY MS. EZELL: BRBBRSSSSAREGHESwLeONauUsWNe Q. Allright. How would you get to the master bathroom on that end? A. You go through these double doors, go bedroom -- master bathroom, sorry. Q. And then there was another master bathroom on the other side of the room? A. Yes, ma'am, Q. Where generally did the massages take place? A. Right here, ma'am. Q. And is that in the master bathroom? A. Master bathroom, yes. Q. Do you recall what color the tile was in that bathroom? A. There was carpet. Q. Was there tile on the walls or marble or -- A. There was a sauna here with marble but outside the sauna everything was carpet, and the walls, they didn’t have any tile. Oh yes, I will say four feet off the floor they will have marble. NN NNR ee eee ee BRBRESSSURREGNESwConauawne Page 315 THE WITNESS: This is the master bedroom, Page 316 around the bed and you gain access to the master Q. And do you remember what color marble it WOnNDU DWN 24 25 Page 317 fl 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 Page 318 | 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. i 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 deposition? 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. | | EFTA00310290

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WOnNDUDWNe WON OAUDAWNHe el da ll ool all ood ol oo SSeSuAansanes |g Do you know Mr. (ag? Yes, ma'am. And you couldn't find it? I give it to Detective Joe. Recarey? Yes, ma'am. 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 w MR. CRITTON: Form. THE WITNESS: No, ma'am, BY MS. EZELL: Q. know what his wife's name was? A. feet a former model from years ho was friend of Mr. Epstein. Q. Do you know if she was married to OPrPoOra>r WON AU AWNe 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. BY MS. EZELL: 14 Q. Andi ought you said that that was 15 Jean- ws 's 16 A. she i is Mrs 17 A. Yes, ma'am. 19 Q. And she is a 20 A. Yes, ma'am. 21 Q. Do you know where she and her mother 22 live? 23 A. They five in Manhattan. 24 MR. CRITTON: Form. Page 321 f BY MS. EZELL: Q. Did they ever visit Mr. Epstein at the nome when you were there? Yes, ma'am, How old was the little girl at that time? Eight years old. Did the girl's father come to visit as OPoPr Yes, ma‘am. And do you remember his name? No, ma'am, Do you remember hearing anything about rhe does for a living? No, ma‘am. Can you describe him? Tall, American born, I will say 50 years rortoror! & 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? A. Yes, ma'am. 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 EFTA00310291

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Page 323 Page 325 i Q. Did he come for dinner? A. Yes, ma'am. Q. Did that happen more than one time when you were there? A. Yes, ma'am. Q. Do you remember whether or not any of the young ladies who came to perform massages also stayed for dinner? A. No, ma'am. MR. CRITTON: Just so it’s clear, no, you 18 don't remember? 19 THE WITNESS: No, they were not there. 20 BY MS. EZELL: 21 Q. Did any of them ever stay for dinner? 22 Just any dinner, not the dinner with David 23 Copperfield. 24 A. You said they, the girls? Q. The girls who came to give massages. I'm going to show you a document, we can mark it but I'm not going to leave it. I'm going 10 to take the exhibit. 11 MR. CRITTON: Wait a minute. Are you 12 going to make a copy of it? 13 MS. EZELL: No, I'm not going to leave a call or visit. 1 we are start with it and then you can use A. Yes, ma'am. 2 the initials after that for all I care. Q. Were you ever there when he visited? 3 BY MS. EZELL: mec: A. Yes, ma'am. 4 Q. Do you remember a girl na ? Q. And do you remember did he spend the 5 A. Iheard that name. night? 6 Q. Sol will refer to her as now A. No, ma'am. 7 on. 8 9 copy. 15 MR. CRITTON: All right. Then I object 16 to you showing him a document that is not 17 part of this record. 18 MS, EZELL: Then object and the Judge can 19 rule, but I'm going to ask him to look at 20 this document. We can mark it as Exhibit 4. 21 THE WITNESS: Oh yeah. 22 +BY MS, EZELL: 23 Q. Do you remember this young woman? 24 A. Yes. MR. CRITTON: Let's see. a Page 326 Page 324 A. No, ma’am., Q. In the earlier part of the deposition you stated that you didn't drive the girls but then later you remembered that you did sometimes have 1 BY MS. EZELL: 2 3 4 5 to drive them. 6 7 8 9 1 2 Q. And was she one of the ones who came to 3 the house to give massages? 4 A. Yes, ma'am. 5 Q. Do you remember her name? 6 7 8 9 A. Yes, ma‘am. Q. Do you remember a young woman named A. who came there? A. Yes, I do remember. A. No, ma'am. Q. Is it possible she wal MR. CRITTON: Form. THE WITNESS: I hear that name but I 10 MS. EZELL: And again, we're going to 10 cannot say for sure. 11 have the same agreement, if we use a girl's 11 BY MS. EZELL: 12 name it will be shown on the transcript as 12 Q. Okay. Did she come often to the house? 13 the initials only. 13 A. Yes, ma‘am. 14 MR. EDWARDS: Agreed. 14 Q. Were you ever aware of her being 15 MR. CRITTON: Why don't you give him the |15 photographed? 16 initials? Because in reading the transcript 16 A. No, ma'am. 17 we could end up with 25 C's or E's or T's, 17 Q. Iasked you about David Copperfield 18 in looking at it by just using the first, I 18 before and let me ask you again. In thinking 19 am just offering a suggestion because none 20 of us will remember who in the heck these 21 people are. 22 MS. EZELL: So you're asking me to give 23 both names so we would have two initials? MR. CRITTON: He may not recognize either the first or the second name but as long as 19 about it is it possible that you remember that she 20 was there for dinner with David Copperfield? 21 MR. CRITTON: Form, asked and answered. 22 THE WITNESS: Possible, yes, ma'am. 23 BY MS. EZELL: 24 Q. Did you ever meet her parents? 25 A. No, ma'am. 15 (Pages 323 to 326) EFTA00310292

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WON AUDWNH RBBRBSSNATRREHNES weCmvaunswne 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 that photograph, it's now been explored with this witness. (Exhibit No. 4 was marked for Identification.) BY MS. EZELL: Q. Do you recall that on occasion you drove this young woman to or from Mr. Epstein's house? MR. CRITTON: Form. THE WITNESS: I don't remember, ma'am, BY MS. EZELL: Q. Do you ever recall driving her by the airport and showing her Jeffrey Epstein's plane? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS, EZELL: Q. Do you ever recall one time perhaps by accident seeing her naked? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. How di happen? A. Itold 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 talking now about the person he thought was A. but he wasn't sure or the person that's in photo four? MS. EZELL: The person that’s in photo four. THE WITNESS: Yes. MR. CRITTON: Okay, thank you. BY MS. EZELL: a just so we're clear, do you think this | but you're not sure? . CRITTON: Form. THE WITNESS: I heard the name so many times but I know I took her, you know, in the Suburban, so it was her. WONDUDBWNe BY MS. EZELL: Q. You mentioned last time that Mr. Epstein asked you to go and rent a car for one of the one who gave him massages. Right. . Do you know if that I'm not hundred percent sure, ma'am. . 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 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) EFTA00310293

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WONADAUMDWNHE Page 331 so I paid her and she went off. 1 Q. Do you recall how much you paid her? 2 A. Between two and 300 dollars, I believe. 3 Q. How often was Mr. Epstein in Palm Beach 4 during the period you were there? 5 A. He will stay two months -- I mean, two 6 weeks out of the month. 7 MS. EZELL: If I could please have these 8 marked as Exhibits 5 through 8. 9 (Exhibit No's. 5, 6, 7, and 8 were 10 marked for Identification.) 11 MR. CRITTON: Do you want them in the 12 order you gave them? 13 MS, EZELL: It doesn't matter. 14 BY MS, EZELL: 15 Q. Would you look, please, at the exhibit that has been marked as number -- what Is It; five? A. Five. Q. Five. Do you recall seeing this young woman at the house when you were there? A. Yes, ma'am. Q. And do you recall her name? A. No, ma'am, MR. CRITTON: Let the record reflect it's Page 332 written on the photographs is a name, so it's already being suggested to him, I think that's inappropriate. MS, EZELL: It shouldn't be there, I'm sorry. If I can erase it I will, I didn't realize it was on there. MR. CRITTON: It's on all of them, Cathy. MS. EZELL: You're right, sorry. BY MS. EZELL: Q. Looking at the girl in number five, if I told you that her name was F.E., would that refresh your recollection as to who she was? A. No, ma'am. Q. Would you look, please, at the girl in the picture that's been marked as Exhibit 6? Do you ever recall seeing that girl come to the house to give massages? A. I cannot guarantee that, Ma'am. Q. 1 understand, it’s not the best picture in the world either, you can’t see. MR. EDWARDS: I don't know that I understood the answer. You can't guarantee it? THE WITNESS; I cannot guarantee it, sir. BY MS. EZELL: 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 MS. EZELL BY MS, EZELL: 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. . 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: 1 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 a young girl coming to the house by the name ofa A. I hear that name, sir. Q. You know the name, does that ring a bell at all? I hear the name in the house. Can you associate that name with a girl? Yes, sir. I'm sorry? Yes, sir, yes, I do. POPOP 17 (Pages 331 to 334) Kress Court Reporting, Inc. p | EFTA00310294

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Page 335 1 Q. Do you remember whether she came to the 2 house on more than one occasion? 3 I heard her name several times from i. 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 Page 337 A. Igive 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. 10 Epstein you kept those notes at your residence? 11 A. Yes, sir, 12 Q. Okay. Where in your residence did you 13 keep those notes before you gave them to the 14 Detective? WONnNAUAWNHe 15 talked to Mr. Critton? 15 A. In my bedroom. 16 A. Yes. 16 Q. Did you have a file cabinet or -- 17 Q. Had you talked to anyone else in the last 17 A. No. 18 year about Epstein? 18 Q. -- chester drawers or something? 19 A. No, they were laying next to some other 20 papers that I have. 21 Q. Did the other papers pertain to Mr. 22 Epstein? 23 A. No, no, nothing else related to Mr. 24 «Epstein. Q. I'm just confused as to why you told us 19 A. No. 20 Q. Did you talk to Mr, Goldberger? 21 A. Yeah, I called Mr. Goldberger first 22 before I talked to Mr. Critton. 23 Q. Okay. So we have your wife, we have Mr. 24 Critton, and we have Mr, Goldberger. 25 Do we have anyone else that you talked to Page 338 1 in the last year? 1 before that you had a journal at home and today 2 A. No, sir. 2 you say that you gave everything to the Detective. 3 Q. How about Mr. Epstein of course? 3 MR, CRITTON: Form. You also may have 4 A. No. 4 missed a portion of his earlier testimony if 5 Q. Where did you usually keep the journal 5 you couldn't hear something, but go ahead. 6 with the names of the girls, in what part of the 6 MR. WILLITS: Most likely. 7 house? 7 THE WITNESS: What I said was I thought I 8 A. In the staff house. 8 had some information, and then I look with 9 Q. Sorry? 9 my daughter and we couldn't find anything, 10 A. The staff house, the guest house. 11 Q. Right. But you said you had a journal at 12 your own residence with the names of the girls. 13 A. I give the whole journal and all the 14 information regarding this case, sir, to Detective 15 Joe Recarey, sir. 16 Q. Okay. And the materials that you gave to 17 the Detective, were they kept -- were any of them 18 kept at your own personal residence? 19 A. Yes, they were with me, sir. 20 Q. Okay. When you gave the materials to the 21 Detective, did all of the materials you gave to 22 him come from your residence? 23 A. Yes. 24 Q. Do you remember exactly what you gave to 25 him? 10 and I remember now that I put everything in il the file that I give to Detective Recarey. 12 BY MR. WILLITS: t 13 Q. Did anyone help you assemble those papers | 14 to give to the Detective? 15 A. No, sir. 16 MR, WILLITS: I don't have any other 17 questions. 18 CROSS EXAMINATION 19 BY MR. CRITTON: 20 Q. Mr. Rodriguez, my name is Bob Critton and 21 I represent Mr. Epstein as you're aware, I have a 22 few questions for you. 23 What I would like to remind you at the 24 start of this Is if you know something, tell us, 25 if you don't know something tell us that. Kress Court Reporting, Inc. penned 18 (Pages 335 to 338) EFTA00310295

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WON AUAWNH WONANAWNHH eS WON OUDAWNHKOSO 20 You're not required to speculate, you're not required to guess, you're not required to assume because some lawyers ask you a leading question or suggested in a report or like the police report like Mr. Mermelstein and Mr, Edwards did, that did you tell the police officers X, Y, or Z without showing you the statement. You're not required to guess, I want personal knowledge, not speculation. Do you understand? A. Yes, Ido. Q. All right. Now, when Mr, Edwards and -- Mr. Horowitz is here today for Mr. Mermelstein, but you remember a lawyer asked you some questions last time you were here? A. Yes. Q. That is he started and he went on for a few hours. Do you recall that? A. Yes, I remember, Q. He asked you do you remember telling the police officer Y, X, or Z. Do you remember that? Do you remember that's how he phrased his question? A. Yes, yes. Q. He never showed you a statement that you made to the police department; did he? A. I'm sorry? Q. He didn't show you a document that said, question, you know, what is your name; answer, my name is Alfredo Rodriguez -- MR. WILLITS: Object to the form of the question. MR. CRITTON: You need to let me finish it first. MR, WILLITS: I'm sorry, I thought you were, BY MR. CRITTON: Q. He never showed you a statement of what the question was and the answer that you gave. True? MR. WILLITS: Object to the form of the question. THE WITNESS: I don't exactly understand your question. BY MR. CRITTON: 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 Kress Court Re} Page 339 Page 340 WONAUSLWNPE 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 Recarey and the State Attorney's Office from Palm Beach County 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 distinguished between the FBI and between Officer Recarey? A. Yes. Q. So how many times did Officer Recarey, or Detective Recarey, I think he's from the Palm Beach Police Department speak with you? Like three or four times. But he only took one statement? One taped. I'm sorry, one taped statement? Yes. All right. So as to whether or not if you said something to Officer Recarey or not that you would be able to confirm, that would only have been in a taped stelament, one taped statement out of the three, approximately three times he spoke OP>oropr 19 (Pages 339 to 342) EFTA00310296

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WON DULBWNeE N NN en BROBRSSSYRTDSEGHESwCmnaMNswnNe with you. MR, EDWARDS: Form. MR. HOROWITZ: Form. BY MR. CRITTON: Q. Is that correct? A. Yes, correct. MR. WILLITS: Object to the form. MR. HOROWITZ; Join. BY MR. CRITTON: Q. And when we were here, I think it was last week or the last ten days anyway -- I could tell you. On July 29th of this year, and Mr. Mermelstein started with your deposition and then others asked questions, when Mr. Mermelstein and I think Mr, Edwards asked questions about did you tell Officer Recarey X, Y, or Z, they didn’t show you a statement, they didn't give you like a transcript like this and say see what the question and see what the answer is? A. No. MR. EDWARDS: Form. MR. WILLITS: Object to the form of the question. BY MR. CRITTON: Q. And you haven't had an opportunity to see Page 344 your taped statement since you gave it many years ago? A. No, sir. Q. Would you agree that your taped statement would probably be a little more accurate than your testimony today because of the time period that has transpired? A. That's correct. MR. HOROWITZ: Object to the form. MR, WILLITS: Object to the form of the question, BY MR. CRITTON: Q. When you spoke with the FBI over at Greens -- I think it was Greens Pharmacy? A. Yes. Q. Did they take a statement from you, that is, did they have a tape recorder or did they just make notes? A. They took notes. Q. Allright. Did you sign anything? A. No, sir. Q. That is like did they take notes of what you said and then you signed it to say yep, that accurately reflects what I said? A. No, I didn't sign anything. WONAUAWNH Page 345 Q. When Officer Recarey 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 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 question. If he, Officer Recarey, 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 have told him that's not accurate, Officer Recarey? 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, ae EFTA00310297

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Page 347 1 HB and 1 think you told us that you had seen 2 her; you recognized her photograph. NNNN loll <li eel alll eellial ad BROBRSSSYSREGBNESwCavauawne A. Yes, I did. Q. On how many occasions did you ever see her at the Epstein home? More than three times. . More than three? . Yes, sir, . That's as accurate as you can be? Yes. - . More than three? More than three. Q. Whether it was four or five you don't know, but more than three? A. More than three, sir. Q. In terms of ‘s age, did you ever ask her what her age ? 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 Page 348 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: WONAULWNe Page 349 Q. I'm sorry? A. Yes, I did, I told the police. Q. And at the time that you spoke with the police and gave them a statement, isn't it true, } Mr. Rodriguez, that you were no longer employed by | Mr. Epstein? A. Yes. Q. And you understood that you were required to tell the police officers the truth at that time? A. Yes, Q. And if I understood your testimony I believe from July 29th through today, you at no time asked any of these girls how old they were. True? A. No. Q. And as to whether the girls were under 18 or 18 or over 18, you really didn't know one way or the other at the time. Would that be a fair statement? A. Yes. MR. WILLITS: Object to the form of the question. BY MR, CRITTON: Q. On Exhibit 6 there is a person who's Page 350 covered, the lady that Ms, Ezell asked you about! believe was on the right-hand side of the photograph. There is a young lady on the left-hand side with a black hat on. Do you recognize her at all? A. No, I don't recognize her. Q. Okay. Thank you. With regard to the photograph four that you saw that you think possibly might be jgm™., I think you told us that you recall seeing woman in the sauna at Mr. Epstein's house on one occasion and she was naked. } A. Yes. Q. Was that near the end of your employment or the middle or the front end? A. I saw her on January 2005, sir, and I was terminated in March, so that was two months prior. Q. And did you ever tell anyone that you had seen her nakedj sauna? A. Itold . Q. Okay. And what did IB say? A. She was surprised. Q. Okay. Did you wake the young lady up in the sauna? A. No, Q. And do you know how old the young lady 21 (Pages 347 to 350) EFTA00310298

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WONAULHWNHH BRBRRSSSNARRGHESemvaunsune 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 MN did you anything to anyone else when you lady you believe naked in the sauna? A. I believe I mentioned that to my wife. Q. Allright. Anyone else? A. No. Q. And did]. continue -- assuming it was A.H., 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 I'm staying with Cathy here -- whether| , yOu had told us something about the picture of the Pope near a picture ed person, naked woman. That's what told 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 WONAULWNe 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 } 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 f consider to be unusual or overly aggressive. MS. EZELL: Objection to form. BY MR. CRITTON: Q. True? A. Itdepends 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) EFTA00310299

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WONQAUAWNHE WON OAWMDWNHe Sl darth il oll oll ate — SOWONAUNDBWNRO 21 24 25 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. All right. 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 '0S there were -- you said that there were -- I think you said downstairs -- and I'm talking about really from the kitchen area 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 il 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. Yes, that's upstairs. That's upstairs? Upstairs. And that was -- was Ii is that how OPOP WOON AUDWNe Page 357 you say her name? A. Yes, her Q. Okay. It's picture where so! 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. Allright. And downstairs in the kitchen ughter, there was a looked like was pulling 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 OPOPOPr 23 (Pages 355 to 358) Kress Court Reporting, Inc. pd EFTA00310300

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WONAUABWNE WOON ADUAWNE CO dl eel ar all ool cll ool el el COON AUNDWNHEO 21 Page 359 didn't recognize who those people were. Is that correct? MR. EDWARDS: Object to the form. THE WITNESS: I knew this parti irl because it was the daughter of Mrs. BY MR. CRITTON: Q. Okay. And is that the picture you're talking about? A. This is the picture I'm talking about. Q. Okay. And that was a three by five? A. Yes. Q. All right. And the only thing that you could see was a portion, that is of her other than say her waist or her shoulders or her arms or something, that’s one where you could see kind of like the Coppertone commercial, a picture of her cheek? A. Yes. Part of her buttocks. MR. LANGINO: Object to the form. BY MR. CRITTON: Q. Okay. And was there another picture at the top of the foyer, large one, or is that the only one that you can recall? A. There were two of the same girl in different poses. WON AUBWNHe Page 360 Q. But showed the same thing? 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. In the bathroom -- in the bathroom or in that location were there any pictures of any women in any stage of undress? A. Yes. Q. Allright. And were any of those pictures, did they involve -- or were they of any of the girls that have been described as women who came over to give Mr. -- purportedly to give Mr. Epstein a massage? 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 located? 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. 16 or 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 ? 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 OPro> 24 (Pages 359 to 362) EFTA00310301

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WONAUSWN Pe N NORD be et Oe ee ee 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. Allright. 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. 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 Kress Court Page 363 Page 364 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. 10 Q. Okay. You actually went in her office? il A. Yes. 12 Q. And was her computer on so that you 13 didn't need to access the password? 14 A, It was off. 15 Q. Okay. So you just turned it on? 16 A. Yes, sir. 17 Q. And then you were able to access her 18 computer? 19 A. Exactly. 20 Q. And what possessed you to go in and to 21 access her personal computer? 22 A. Ineeded to send some documents to the 23 New York office and it was the only computer 24 working in the house. 25 Q. Okay. And how many occasions did you use WON AUDWNH 1 her computer? 2 A. Several times. 3 Q. Was she ever aware that you used her 4 computer? 5 MR, LANGINO: Form. 6 THE WITNESS: I don't think so. 7 BY MR. CRITTON: 8 Q. Did you ever ask Ms, Maxwell for 9 permission to use her computer? 10 A. Iwas the house manager, I believe I was 11 supposed to use everything in the house to 12 accomplish my duties, in that case sending 13 financial reports or e-mails. 14 Q. So would you have been -- did you ever 15 use Mr. Epstein's computer? 16 A. No. 17 Q. Okay. But you used Ms. Maxwell's 18 computer? 19 A. Yes. 20 Q. Did you ever use Ms. || computer? 21 A. Yes. 22 Q. In looking at Ms. Maxwell still, you went 23 into Ms. Maxwell's computer with at least the idea 24 of sending some documents? A. Yes. 25 (Pages 363 to 366) Inc. EFTA00310302

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WOOnNAUDAWNH Sweeovaunswne GRORRSSRSUSRSGNE Up to New York? Yes, Were you going to pdf them? Yes. And did she have a fax machine -- not a fax machine, a copy machine in her office as weil? A. Yes, Q. Okay. So how would you generally do that? Would you do that through a Microsoft program? A. Through Citrix. Q. Through Citrix. All right. With Citrix, and that is, if you said you saw some names of individuals on her computer if you were just going to pdf some documents up to New York why would you of - what would of caused you to have seen any names on her computer? MS, EZELL: Objection to form. THE WITNESS: All the calls that came to 358 El Brillo, they came through the telephone, they have a transcript somehow 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 ePProOre WON AU SBWNe Page 368 to go back to some calls that they were requesting, especially when the hurricane season happened. BY MR. CRITTON: Q. Okay. So if I understand, even the computer you used would have had that same feature? A. No, no, it was totally different. Mine was slower and all the time was breaking down that’s why we have the guy from Ohio came and fixed the computers. Q. Okay. Were there other computers that you used that feature, that is that -- 13 A. On rs. Maxwell, and the staff 14 house. 15 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. All right. 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 — number 561, whatever it was, It was a transcript of the phone calls of Page 370 | 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 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) EFTA00310303

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WAN AUM WNP N NN Pe ell el alll all all oll eel eel mod BRBRBRSSEYARRENESwCmv]aMseNY 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 than your wife? WON AUSWNe 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. I think 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. Allright. 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. 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. All right. 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 who you saw in the house who were nude, one was Nadia? A. Yes. Q. And you knew Nadia was someone who was in her 20's? 27 (Pages 371 to 374) Kress Court Reporting, a EFTA00310304

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WONAUAWNE WON OUDAWNH RBRBSBRBSSSSRSRSEES BWNHRFROWONODUDBWNeHKO Page 375 A. Yes. Q. All right. And then you saw another picture of a Brazilian woman who had traveled or flown on the plane before? A. Yes. Q. Allright. And she also appeared to be a woman to you not only in the photograph but from your having seen her who appeared to be in her 20's? A. Yes. . Excuse me. Thank you. You talked about computer. Was she hooked into your main m? A. Not to my office in the staff house but she was hooked into the main house. Q. Okay. The same Citrix system? A. Yes. Q. And you said thgllighac pictures of women on her computer that you saw. Is that correct? A. Yes. Q. Okay. And were those the same types of pictures that Ms. Maxwell had, that is, females, pictures of females who had traveled in with Mr. Epstein from his plane? WONnNDUW PWN Page 376 A, This were different pictures. Q. Okay. Were any of hers of any of the girls who came in on the plane, or the ladies or women? A. No. Q. What were her pictures of? A. They were young women I don't remember seeing nudity on you know. computer. Q. All right. say hers, the 10 photographs that had on her computer j 11 were all of individuals who appeared -- or not appeared, but were dressed and appeared to be modeling? 14 A. Yes. 15 Q. Would it be a correct statement that none 16 of the women that you saw, the pictures of 17 the women that you saw on computer were | 18 any of the girls, women, whoever came to give massages? Is that correct? MR, EDWARDS: Object to the form. MS, EZELL: Form. THE WITNESS: That's correct. BY MR, CRITTON: Q. You said that I you thought also had Page 377 names and addresses of -- let me start over. Strike that, seen your testimony, you said rt again. ou nn oo the names and phone numbers of some of the massage girls. A. Yes, Q. Or at least of the people that you thought may have been called to give massages. A. Yes. MS. EZELL: Form. MR. EDWARDS: Form. BY MR. CRITTON: Q. And was that in the same format that you saw on Ms, Maxwell's computer? A. No. Q. Okay. W uld you have been -- have had to use| computer? A. She will in some information from her desk or telephone numbers, so I will. Q. And that’s where you would have seen it? A. Yes. Q. I think you testified at your last deposition, or the start of your deposition that the number of women that you remember came over to give massages was something eight to ten, twelve, I don't remember, what's your best recollection? A. Can you repeat that, please? Q. Of the women, of different women that you knew came over to give massages during the time that you worked for Mr. Epstein, '04 to '05, during that time period, approximately how many women were there? MR. EDWARDS: Object to the form. THE WITNESS: To give massages? BY MR. CRITTON: Q. Yes, sir. A. Fifteen, yeah. Q. So something between one and the names you would have seen on Ms.| computer along with a phone number? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. Do you remember how many you would have seen? A. Fifteen. Q. Okay. id us earlier today that you saw from time to time taking 28 (Pages 375 to 378) EFTA00310305

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Page 379 1 pictures in the dining room and the library. 1 Q. Regular conversation? 2 A. Yes. 2 A. Yes. K Q. Photographs. 3 Q. And, therefore, you might interject 4 A. Yes. 4 yourself back in because you've been asked to pay 5 Q. Okay. Was she taking -- the pictures she 5 someone or to let them out? 6 took were people who were clothed? 6 MR. LANGINO: Form. 7 A. Yes. 7 THE WITNESS: Yes, I was called to pay 8 Q. And were any of the pictures that she 8 them. 9 took of any of the girls that you ever -- let me 9 BY MR, CRITTON: 10 strike that. il If I understood your original testimony 12 -- I don't want to say original. If I understood 13 your testimony from July 29th to what you told us 14 today as to the women who did come to give 15 massages they'd knock or somehow you would be 16 aware that they were at the back door, you would 17 punch the security code and lead them into the 18 kitchen. 19 A. Yes. 20 Q. Okay. When you brought them into the 21 kitchen you would say, hi, they would say hi back 22 to you, or something to that, short greeting, 23 you'd offer them water, there was never any 24 alcohol in the whole house other than I think you said for one person at one time. Is that a fair 10 Q. Allright, And when you hear that 11 conversation that would be another way that you 12 would know that the women were leaving? 13 A. Yes. 14 Q. And sometimes they'd leave without you 15 even being involved, if I understood it correctly? 16 A. That's correct. 17 Q. So, the only places that you ever saw the 18 women who came to give massages would be -- of the | 19 some fifteen women during the time you were there | 20 would be either when you let them into the house 21 and escorted them into the kitchen or as they were 22 leaving? 23 A. Yes. 24 Q. And I think you described one j earlier today is that you may have in the statement? car, in the Suburban? A. Yes. A. Yes. Q. Alri left the kitchen, you Q. And that's the only person that you can understoo| came down, and what remember having driven any place, that is, of the happened thereafter you don't have any personal women who were described as having given massages? } knowledge whatsoever? MR. EDWARDS: Objection. A. That's correct. MS. EZELL: Objection, form. MR. EDWARDS: Form. BY MR. CRITTON: Q. At some point in time MAE ior contact you and say pay such and such X amount of dollars, she is now getting ready to leave. that. I drove a lot of girls, but I don't remember the names associated with the faces. But this particular girl A., or 1 2 3 4 5 6 7 8 THE WITNESS: Sir, I have to clarify 9 10 il 12 others, C., whatever, I remember driving in BES weaonausaune 13 A. Yes. 13 the Suburban, but I cannot say this was -- 14 Q. That maybe one. Another set of 14 BY MR. CRITTON: 15 circumstances might be you use the word commotion, | 15 Q. Let me clarify because what I want to be 16 you might hear a commotion, I assume you don't 16 clear is, is Ido remember you testifying that 17 mean -- well, let me ask you, when you say 17 when some of the 20 plus year old models or 18 commotion, do you mean a disturbance, something 18 females would fly in with Mr. Epstein they might 19 that was seriously like raised voices or merely 19 want to go shopping, they might want to go to the 20 you just heard some people talking? 20 store, they may want to go to the drug store, they 21 A. Conversation of people leaving. 21 may want to go to the beach, wherever they wanted 22 Q. Okay. Not a commotion in the form of a 22 to go and you would drive them. 23 disturbance but a commotion in the sense that you 23 A. Yes, 24 heard people talking? 24 Q. All righ I remember in A. Yes, 25 response to _ today she asked 29 (Pages 379 to 382) EFTA00310306

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EF Sweaonauswne Page 383 you about having drivel and you recalled MR. EDWARDS: Form. THE WITNESS: I only remembelillll right Page 385 f Q. She also I think asked was Mr. Dershowitz ever there when one of the women who gave a 1 Q. Allright. Ms. Ezell asked you about Mr. having had her in the Suburban specifically. 2 Dershowitz being present in Mr. Epstein's home, A. Yes. 3. and I think she asked -- and I think that you said Q. Do you remember any of the other girls, 4 Mr. Epstein was a -- and he and Mr. Dershowitz women to give massages ever having driven | 5 were friends? them, or only one that you remember? 6 A. Yes. 7 8 9 now for the fact that I was driving by the airport and I showed her Mr, Epstein's plane. BY MR. CRITTON: Q. All right. Which really takes me back to were advised or if you heard conversation and you saw them you would see them when they left? A. Yes. Q. And you sow because she was in the Suburban on at least one occasion? A. Yes. Q. And, therefore, you never saw these girls, these women who gave the massages in the Page 384 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 }j any of the women came to Mr, Epstein's home tof 14 really where I started with this series of 14 give a massage? 15 questions, 15 A. Yes. 16 You saw the girls, the women who came in 16 MR. EDWARDS: Form. 17 to give the massages, when they came in if you 17 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. 1 dining room or the library. Would that be a fair 1 BY MR. CRITTON: 2 statement? 2 Q. Okay. Were you in any way attempting in 3 A. That's correct. 3 your response to Ms. Ezell to imply that Mr. 4 MR. EDWARDS: Form. 4 Dershowitz had a massage by one of these young 5 BY MR. CRITTON: 5 ladies? 6 Q. Allrig ‘ore, the pictures 6 A. I don't know, sir. 7 that you saw taking of girls, women, 7 Q. You have no knowledge? 8 either in the dining room or library, those were 8 A. No, sir. 9 other individuals other than those who may have 9 Q. And you certainly weren't implying that 10 given or who came for massages. Is that correct? [10 that occurred, you just have no knowledge. li MS, EZELL: Form. 11 Correct? 12 MR. EDWARDS: Form. 12 MR. EDWARDS: Form. 13 THE WITNESS: It's confusing, sir, 13 THE WITNESS: I don't know. 14 because there were a bunch of girls. 1 14 BY MR. CRITTON: 15 don't know which one they were but Isaw her | 15 Q. Sorry? 16 taking pictures of the groups. 16 A. I don't know. 17. BY MR. CRITTON: 17 Q. I think in response to one of Ms. Ezell's 18 Q. As to whether they were people who came | 18 questions you responded that -- let me ask it this 19 inn the planes or there may have been a massage |19 way. 20 girl or more than one woman who gave a massage, | 20 You never saw Mr. Epstein ever take 21 you just don't know as you sit here, you'd just be 21 photographs of anyone. Would that be a correct 22 speculating. Is that correct? 22 statement? 23 MR. EDWARDS: Form. 23 A. Yes. 24 THE WITNESS: I don't know. 24 Q. Would it be a correct statement you never 25 BY MR. CRITTON: saw Mr. Epstein initiate a phone call to anyone? 30 (Pages 383 to 386) EFTA00310307

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WAN AUDBWNE 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 o_o you that Mr. Epstein would take photographs. Did I understand you correctly? A. I'm soi repeat that? Q. Did M r tell you that Mr. Epstein took a raph 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. GB 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 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. OPOPOP 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. Page 387 Page 388 BSwe@mvnausawne 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 Page 390 | 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 i Palace and she with her husband, Harry Helmsley, I think they owned a number of real estate in f addition to hote! 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) EFTA00310308

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WONDUAWNH 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, 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. Ahouse 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 worked similar to Mr, Epstein -- now, Mr. Epstein was single? A. Yes. Q. All right. 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. At least 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 Page 391 Page 392 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 10 hada massage table, were they similar to the 11 massage table that was in Mr, Epstein's home? 12 A. Yes, sir. 13 Q. Allright. Almost same make and model? 14 A. Same type, yes. 15 Q. And did other individuals in houses that 16 you worked at and other places where you helped 17 out other estate managers, would those individuals 18 have massages from time to time? 19 A. Yes. 20 Q. So having a massage or a massage table in 21 someone's house that you might -- that lives in 22 Palm Beach or Montauk or New York or something, 23 would you consider that unusual? 24 MR. HOROWITZ: Form. THE WITNESS: No. WONAUNDWNe Page 394 1 BY MR, CRITTON: 2 Q. I think you told me at least in Mr. 3 Epstein's home other than for one guest he didn't 4 have any type of alcohol in the house. Is that 5 correct? 6 7 8 9 A. That's correct. Q. Was that basically you understood that that was one of the policies and procedure, no alcohol in the house? 10 A. Yes. il Q. And did you ever see any type of illegal 12 or inappropriate drugs? 13 A. No, sir. 14 Q. And was that another policy or procedure, 15 absolutely no drugs of any kind? 16 A. No smoking in the house, 17 Q. All right. So no drugs, no smoking, no 18 alcohol? 19 A. Yes. 20 Q. Was that pretty typical for other Palm 21 Beach places that you were familiar with? 22 A. No. 23 Q. All right. And other places you'd always 24 find alcohol? 25 A. Yes. 32 (Pages 391 to 394) EFTA00310309

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WON DAUAWNe WONAUDAWNHH RSESRREGEES CONAUDBWNR OS 21 24 25 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. THE WITNESS: I'd say more than half. BY MR. CRITTON: Q. So maybe seven, eight, nine, ten? A. Yes. Q. Of those people that came on -- of those seven to ten that came on more than one occasion, did those Individuals come on many occasions? A. Yes. Q. And as to the women who were -- who you understood were coming to give the massages -- MR. EDWARDS: Form. MR. CRITTON: I'm not done yet. THE VIDEOGRAPHER: I need to go off the record for a second. (Thereupon, an interruption was had.) OPOPO WON AU AWNe 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 message pads that had I think in most instances your wile, Do you recall that? A. Yes, 1 do Q. I think one of the indivi that you identified that called often vedi: A. Yes. Q. Which is one of Mr. Edwards’ clients. This lady called on a regular basis, or at least from looking at your pad she would call on a pretty regular basis, Is that true? A. Yes. Q. And she and others who are reflected on those message pads, they were calling to come to give massages. Correct? A. Yes. Page 397 jj MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. And I don't know whether he asked, do you remember a person nai A. Yes. Q. And would she call from time to time aski she could come to give a massage just like ? MR. 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. Th call will say I need to talk to and fifteen minutes later will tell, Alfredo, we're going to have a massage with so and so. Q. Soeither Hl oll would calito ask —f 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’ Q. ot lll = 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 Ms. 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 Ms. M. -- let me use the initials 33 (Pages 395 to 398) EFTA00310310

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WON AUBWNr that way it will show up correctly. Did r 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, H Q. When 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 4 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 August, Mr, Rodriguez -- August. -- August of '04 through February of '05? March of '0S. 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. OPOPOoPr Page 399 Page 400 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 WOnNAMAWNH 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 22 out of here? 23 A. No, sir. 24 Q. Did any of them tell you verbally that they were uncomfortable? Page 402 | FoR gs anyone say help me or I'm scared? > oO} 2 1 2 3 0. 4 Q. Did all of them appear to be at least 5 when they came to the back door in a reasonably 6 7 8 9 . 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? EFTA00310311 you verbally that they were in fear when they came 34 (Pages 399 to 402)

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Page 405 A. No. them stop and have anything to eat or did you MR. EDWARDS: Form. always see them at the end, that is they're ready BY MR. CRITTON: to go? Q. For those women -- I think I need -- let me strike that. On some occasions you'd see the women come down from upstairs because you would either let them out of the house or you might give them an envelope that had money in it. Is that 10 correct? ll A. Yes. 12 Q. Did any of those -- Mr, Edwards asked you 13 some questions -- I think it was Mr. Edwards, 14 whether they had sat down and had anything to eat, 15 whether they had cereal or anything like that. 16 A. Yes. 17 Q. Did you ever observe any of those women 18 before they went upstairs eating anything at the 19 house? 20 A. Sometimes. 21 Q. And I think he used -- he meaning Mr. 22 Edwards, used cereal and ice cream. 23 A. Yes. 24 Q. And he said, if I recall from the last deposition, kids like ice cream. 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 ae Sr. either if you heard conversation or called you and said would you pay such 10 and such? 11 A. Yes. 12 Q. At which time you would give them the 13 envelope with money? 14 A. Yes. 15 Q. In that set of circumstances they were on 16 their way basically to leave? 17 A. Yes. 18 Q. When you saw them leave did any of them 19 at any time, any of the ones that you saw during 20 August of '04 through March of '05 appear to you 21 to be scared? 22 A. No, sir. 23 Q. Did any girls, women ever appear to have 24 been injured in any way? 25 MR, EDWARDS: Form. WON DUDWNH WOOnNAUDBWNe Page 404 1 A. Yes. 1 THE WITNESS: No, sir. 2 Q. Do you remember him asking you that? 2 BY MR. CRITTON: 3 A. Yes. 3 Q. Did anyone appear to be in shock? 4 Q. Are you familiar that teenagers like ice 4 A. No, sir, 5 cream? 5 Q. Was anyone ever crying? 6 A. Yes. 6 A. No, sir. 7 Q. Are you familiar that people who are 20 7 Q. Was anyone disheveled or appeared to be 8 and 30 years old like ice cream? 8 unhappy? 9 A. Yes. 9 A. No, sir. 10 Q. Are you familiar that older people, even 11 our age, Mr. Rodriguez, like ice cream too? 12 A. Yes. 13 Q. Okay. And when the individuals would sit 14 there, and that is these women who would come over 15 to give a massage and they would -- you would 16 observe them eating, did they appear to be 17 comfortable? 18 A. Yes. 19 MR. HOROWITZ: Form. 20 BY MR. CRITTON: 21 Q. Did they appear to be interacting with 22 either you or the chef? 23 A. Yes. 24 Q. When any of those women would come over 25 to give massage came downstairs, did you ever see 10 Q. Did all of them appear, that is the ones 11 that you saw leave the house that you had an 12 opportunity to observe during that time period, 13 did they appear to be approximately the same 14 personality, same demeanor that they had had when j 15 they came into the house? 16 MR. HOROWITZ: Form. 17 THE WITNESS: Yes. 18 BY MR. CRITTON: 19 Q. Did anyone ever tell you when they came 20 down the stairs that they had been injured? 21 A. No. 22 Q. I'm talking about the young lady, the 23 women who had given the massages that you saw 24 actually leave the house, that is you had some 25 interaction with, either some interaction as they 35 (Pages 403 to 406) EFTA00310312

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WAN AUSBWNe N N lad ~ RRBOBRSSSNARZEBRESwPMmVaUsEYNe were leaving the house, did anyone ever tell you that they had been injured? A. No, sir. Q. Did they ever tell you that they had been forced to do something against their will? A. No. Q. Did they ever tell you that they had been forced to do something inappropriate? A. No. Q. Did they ever tell you that they had been assaulted in any way? A. No. Q. Did they ever tell you that they had been inappropriately touched? A. No, MR, HOROWITZ: Form. This Is 2 cumulative. He's already told you the limited contact he had. This is totally inappropriate line of questions. MR. CRITTON: Is that a form objection? MR, HOROWITZ: You're exceeding the scope of the direct because nobody asked him -- MR. CRITTON: Form, you get form in federal court, that's what you get. Give me your form. 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 t. 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? Page 407 Page 408 1 MR. EDWARDS: Form. 2 THE WITNESS: No. 3 BY MR. CRITTON: 4 Q. Did you ever hear anyone yell rape or 5 assault or battery? 6 MR. HOROWITZ: Form. 7 THE WITNESS: No, 8 BY MR, CRITTON: 9 Q. Did you ever hear anyone yell out in 10 anger? 11 A. No, 12 Q. You've gone online, Mr. Rodriguez, and 13 looked at various articles or postings that have 14 been made regarding these cases. Is that a fair 15 statement? 16 A. I'm sorry? 17 Q. If I understood your testimony from July 18 29th and a little bit today, is that you've gone 19 online and read some articles and/or what the 20 police report may have said, that is, you've read 21 information that you've -- about these lawsuits 22 after the time that you left Mr. Epstein's 23 employment. 24 A. Yes. Q. Correct? Page 410 | 1 A. Yes. 2 Q. And, therefore, you have at least seen 3 certain allegations and what people say occurred, 4 or at least their recitation of what may have 5 occurred at Mr. Epstein's home. 6 A. Yes. } 7 Q. You have no personal knowledge one way or 8 the other. 9 MR. HOROWITZ: Object to the form. 10 MR. EDWARDS: Form. 11 BY MR. CRITTON: 12 Q. Correct? 13 A. That's correct. 14 Q. Are you also aware that the individuals 15 who have filed lawsuits want in some instance 16 millions of dollars? 17 A. Yes. 18 Q. Okay. Are you aware that some of them 19 are now claiming that they were sexually 20 assaulted? 21 A. Yes. 22 Q. And battered? 23 A. Yes. 24 Q. And you have no information, no personal 25 knowledge in that regard. Is that true? { 36 (Pages 407 to 410) Kress Court Reporting, Inc. [i EFTA00310313

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EBBESweonauasawne N NN ee nal i he BRBORBRSSSUATEGHESCoOnNaUAYWNH A. Yes. MR, EDWARDS: Form. MR. HOROWITZ; Form. BY MR. CRITTON: Q. Allright. Were you aware of the backgrounds of any of these women who came over to give massages? MR. HOROWITZ: Form. THE WITNESS: No, sir. BY MR. CRITTON: Q. Well, have you -- did any one of the fernales who ever came to give massages, did they ever tell you that they were prostitutes? A. No, sir. Q. Did they ever tell you that they had been lead into a life of prostitution? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. Did they ever tel! you about their family life, whether it involved prostitution, abuse, prior posttraumatic stress syndrome, drugs, alcohol, abuse by individuals, physical abuse as well as verbal abuse? A. No, they didn't tell me. 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 a 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. A. Exactly. Q. You called the police? A. Yes, I did. Q. Did you go to the police or you called the police and they came? A. I went to the police department. Q. So how did you -- did you actually leave Page 412 WONAUDBWNe 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. Allright. And if 1 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? Yes. Q. And then you recognized that al? 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 A. No, becaus' id me already but I forgot she was going e 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'msorry, January of '05. A. No. i Q. You some conversations that you } had had with who was I think she was one of the house -- the main housekeeper, A. Yes Qa. told you a number of thoughts that she hi it correct? A. Yes. Q. Andas 4 tM vin chet you about ~~ let me strike that. 37 (Pages 411 to 414) EFTA00310314

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Page 415 Page 417 1 I think you told us, you were asked 1 A. To bring the pictures from my computer? 2 questions about sex toys, I think you certainly 2 Q. Let me rephrase the question. I thought 3 described the back massagers. Correct? 3 what you said last time was that as to the 4 A. Yes. 4 pictures that you did see of naked women -- of a 5 Q. I think you said the only sex toys that 5 naked woman or naked women on the computer, that 6 you ever saw were in the armoire at the end of Mr. 6 you've looked at those photographs through your 7 Epstein's bed. 7 computer. 8 A. Yes. 8 A. No. 9 Qa _ Okay. And whatever other sex toys that 9 Q. Okay. Then I may have misunderstood you. 10 to was a reference, that's something 10 Was your reference to Ms. Maxwell's computer that 11 tha told you. Is that correct? 11 you made at the last deposition? 12 A. That's correct. 12 A. Yes. 13 13 Q. You were asked at the last deposition, I 14 don't remember who asked the question, but whether 15 you had ever seen pornography on any computer. I 16 think one of your responses was you saw some 17 photos of a naked woman who appeared to you to be 18 a model. 19 A. Yes. 20 Q. Okay. Do you consider every photograph, 21 picture, painting of a naked nude woman to be 22 pornography? 23 MR. HOROWITZ: Form. 24 MS, EZELL: Objection, form. THE WITNESS: I consider -- well, if it's Q. Okay. Your computer that you had either 14_ in the staff house or that you -- 15 A. Didn't access. 16 Q. You couldn't access those files? 17 A. That's correct. 18 Q. All right, now I'm with you. So the 19 photographs you've talked of the nude individuals, 20 or the naked women, were the photographs that 21 we've already talked about with both, i.e., in 22 Ms, Maxwell's computer? 23 A. Yes. 24 Q. Thank you for clearing that up. I'm going to ask you to assume that Page 416 a frontal picture it's pornography, I will who you've described as having come to Mr, look at my way. Epstein's house on three or four times a week for BY MR. CRITTON: a period of time, one of her claims in this case Q. In your view? is that she has been emotionally traumatized by 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. be true for purposes of this question. Did you ever observe any what you would have seen as el al trauma or any type of disturbance wi on the many times she came 10 to your house? il MR. EDWARDS: Form. 12 THE WITNESS: I didn't see any. 13. BY MR, CRITTON: 14 Q. Does it make sense to you that a person 15 who claims emotional trauma would continue to come 16 back to the house, does that make sense to you, 17 sir? 18 MR. EDWARDS; Form. 19 MR. HOROWITZ: Form. 20 MR, WILLITS: Object to the form of the 21 question. 22 THE WITNESS: I'm not a psychologist. 23 MR. EDWARDS: Can you state your answer, 24 I didn't hear it? THE WITNESS: Yeah, I'm nota 1 2 3 4 5 her contact with Mr. Epstein. Just assume that to 6 7 8 9 NN NNN eR ee ee - BRBBRSSESNYSEREREGHRESwCMVAUAWNY 38 (Pages 415 to 418) EFTA00310315

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Page 421 F psychologist, I don’t know. Q. What's the address? MR, CRITTON: I have no further A. 22 Foch Avenue, Paris. F-O-C-H. i questions. Q. Okay. Do you know a telephone number for REDIRECT EXAMINATION Balsone? | 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, 10 what cars did he own or were in the driveway? ll A. We have two Suburbans, two Mercedes 600, 12 anda Cobra, and a motorcycle. 13 Q. And which, if any, did he drive? 14 A. He preferred the Mercedes or any of the 15 Suburbans. 16 Q. All right. Do you know where he owns 17 homes? 18 A. Yes. 19 Q. Where? 20 MR. CRITTON: Form, 21 THE WITNESS: Paris, New York City, El 22 Brillo, Saint James Island -- I'm sorry, an 23 Island in the Caribbean, and a ranch in New 24 Mexico. BY MR. EDWARDS: 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? i A. He came on two occasions and stay with me 10 for a week because Mr. Epstein wanted me to get 11 into his style of running the house, and he was 12 good enough to give me some inside information, 13 what he likes and doesn't like, so he told me the 14 same thing was in Paris. 15 Q. And think that you described Mr. 16 Epstein usually had about two massages a day, or 17 at least we were calling them massages. 18 A. Yes, sir. 19 MR. CRITTON: Form. 20 BY MR. EDWARDS: 21 Q. And did Mr, Balsone describe it in a 22 similar fashion -- 23 A. Yes. 24 Q. - in Paris? 25 And did he also tell you that the girls WONDUAWNE WON AUAWN PE Page 420 Page 422 were very young in age that he was receiving these Q. Have you been to any of the other properties? massages from? A. No. MR. CRITTON: Form. Q. Do you know the house managers at any of THE WITNESS: Yes. the other properties? A. Yes. Q. Did he indicate whether or not -- or how 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. old these girls were? A. No, he didn't told me. Q. Just that the age group was similar to 10 the age group that he was interested in in Palm 11 Beach? 12 MR. EDWARDS: Form. 13 THE WITNESS: Yes. 14 BY MR. EDWARDS: 15 Q. And did you talk to any of the house 16 managers in New York? 17 A. No. 18 Q. Who was the house manager in New York at | 19 the time when you were the house manager at El_— | 20 Brillo? 21 A. His nickname was Jo-Jo, but I don't 22 remember. Jo-Jo and his wife, but I don't 23 remember his name, sir. | Q. Do you know whether Mr. Epstein would | have massages when he was in New York at his New} 1 2 3 4 5 BY MR. EDWARDS: 6 7 8 9 MR. CRITTON: Mr. Balsone was which one? THE WITNESS: Baslone was the house manager of Paris, 22 Foch Avenue. BY MR. EDWARDS: N NN Ree ee a a7 RBROBRSSSUAREGHESeCmrAaUMsWNeY 39 (Pages 419 to 422) Kress Court Re! Inc. EFTA00310316

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WONAUAWNE N ee ll on all ool al a RROBSESSEUSREGNESeCmnNaUaUNeS York house? A. He will have massages. MR, CRITTON: Form. BY MR. EDWARDS: Q. And are we still talking about a habit of two a day? MR. CRITTON: Form. THE WITNESS: I don't know that. BY MR. EDWARDS: Q. Okay. So for the time period when you have been familiar with Mr. Epstein and known his habits, is it fair to say that he would have roughly two girls a day in that same age group wherever he was? A. Yes. MR. CRITTON: Form. BY MR. EDWARDS: Q. All right. And have you talked to anybody that has given you similar information from his Island home? A. No. Q. Do you know any of the girls that have been over to his Island? A. Yes. Q. And who are they? WON AU SWNH Page 424 A. Nadia, the girls who used to stay at the home in El Brillo used to go over there to the Island. Q. When he would have these girls -- 1 guess we've kind of categorized them as the girls who would come over with him on an airplane and stay at the house. A. Yes. 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? A. Yes. Q. So these girls that came on the airplane with him, were they also -- did they also have knowledge that these young girls were coming over to give massages? MR. CRITTON: Form. THE WITNESS: Yes, sir. BY MR. EDWARDS: Q. Okay. oil oS from the airpla' r tha at you remember? A There many, sir, I don't 22 recall right now, But is for sure, 23 was one of the main air , but I don’ 24 remember that. Page 425 | 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. ED’ ; Q. Wit jas well? A. Yes. MR, CRITTON: Form. BY MR. EDW, : Q. With ? A. Yes. 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 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) EFTA00310317

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Page 427 Page 429 1 glass of wine by the pool, stay inside. 1 usually it's Yahoo dot com or at Bellsouth dot 2 BY MR. EDWARDS: 2 ~~ ~net. 3 Q. Did he ever talk to any of the girls? 3 A. It was very uncommon. I don't remember, 4 A. 1 don't know, sir. 4. sir. 5 Q. Certainly he knew that they were there? 5 Q. Did everybody in the -- I think you 6 MR. CRITTON: Form. 6 called it the organization, did everybody have 7 THE WITNESS: I don't know, sir. 7 e-mails? 8 BY MR. EDWARDS: 8 A. Yes. 9 9 Q. Do you know how nows Mr. 10 Epstein? 7: 11 A. No, sir. 12 Q. Or how long she’s known him? 13 MR. CRITTON: Form. 14 THE WITNESS: She was on board two years 15 or a year and a half before I came on board. 16 BY MR. EDWARDS: 17 Q. Okay. 18 A. So it's probably 2003 or 2. 19 Q. Allright. You mentioned this Citrix 20 system. 21 A. Yes. 22 Q. Is that a system that was used to operate 23 the phones and the computers? 24 A. The computers mainly. Q. Allright. But you then also described Q. Okay. Would that include 10 A. Yes. || 11 Q. All right. And did Mr. Epstein have an 12 e-mail? 13 A. Yes. 14 Q. Did you ever correspond with Mr. Epstein 15 by e-mail? 16 A. Yes. 17 MR. EDWARDS: You can go ahead. 18 THE WITNESS: That's the only one that I 19 remember. 20 THE VIDEOGRAPHER: Okay, we're off the 21 record. 22 (Thereupon, a recess was had.) 23 THE VIDEOGRAPHER: We're back on the 24 record with tape number four. BY MR. EDWARDS: Page 430 It 1 Q. Mr. Rodriguez, what was Mr. Epstein’s 2 email? 3 A. Jeep project at something -- Jeep 4 project -- I can't remember it right now. 5 Q. Okay. In the course of this next 10 or 6 7 8 9 Page 428 some system where someone would cail on the telephone and that would be automatically downloaded to the computer? A. Yeah, you can retrieve who called in a transcript written who called, what's the message, the time so you have it on a piece of paper, you 15 minutes -- WON ANMNSDWNHE can print it out. A. Ican recall. Q. Is it your understanding that is also Q. -- if it comes to you just tell me. So part of the Citrix system? it was Jeep project -- 10 A. Yes. 10 A. Like Jeep, the brand name Jeep, Jeep il Q. Allright. Did you have an e-mail? 11 project at -- 1 can't remember. 12 A. Right now, yes. 12 Q. Okay. Was that his only e-mail to your 13 Q. No, when you were working at ~ 13 knowledge? 14 A. Yes, I did. 14 A. No. 15 Q. - Mr. " 15 Q. He had other e-mail addresses? 16 And did have an e-mail? 16 A. Yes. 17 A. Yes. 17 Q. Do you know what any of his other e-mail 18 Q. And did all of the e-mails end the same 18 addresses were? 19 way such as Epstein's house dot com or something? | 19 A. No, I don't remember. 20 A. Yes. 20 Q. Do you know who the carriers were for the 21 Q. Okay. What i e-mail? 21 other e-mail addresses owned by Jeffrey Epstein? 22 A. I don't remembe™ 22 A. No, sir. 23 Q. What was your e-mail? 23 Q. Whether it was Yahoo or hot mail or -- 24 A. Staff house -- I don’t remember, sir. 24 A. No, none of those. 25 Q. Do you recall how it ended? I mean Q. Okay. Was this Jeep project e-mail run 41 (Pages 427 to 430) Kress Court Reporting, Inc. FO EFTA00310318

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WONDUAWNH Page 431 through the Citrix system? A. Yes. Q. Okay. And was there a certain company that came out and fixed the actual Citrix system? A. Yes. Q. And who was that? A. We used to have our own in-house technician from Ohio, Q. The same guy you were telling us about before? WON AM AWN A. Yes. 11 Q. All right. He would fix the video 12 equipment or the -- 13 A. Computers mainly. Q. And if the Citrix system broke down too then he would be in charge of it? A. He was the only one dealing with this, we couldn't hire anybody else. Q. Do you know why that is? A. No. It was too many lines into the house from many properties. Q. And do you know who that person is, remember his name now? A. I don't remember, sir. Q. Iunderstood you to say at some point in Page 432 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 || one of them? MR. CRITTON: Form. THE WITNESS: I cannot guarantee that, I cannot say hundred percent, sir. BY MR. EDWARDS: Q. Wasi one of them? A. Could be, s| 16 Q. How about 17 A. It's the same thing, 1 cannot say a 18 hundred percent, sir. 19 Q. I think that you used the phrase there were so many girls. A. Yes, sir. Q. That you're not sure which ones you saw? A. No, sir, SO many names. Q. Okay. While David Copperfield was ever 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 stayed for dinner with David Copperfield? A. That's correct. Q. Was there ever a time where MM. and David Copperfield were in a bedroom r? A. I don't think Mr. Copperfield went upstairs. When the police came to the driveway with =: the car, what did yow 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 cal! 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? 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 a massage going on in the bedroom? 42 (Pages 431 to 434) EFTA00310319

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Page 437 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 -- il 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 WON AU AWNHE WON AUMAWNe 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. ai 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. 25 Q. Okay. And did each one of them have Page 436 1 A. No, that was very private. I would put 2 his coffee uld shut the door. 3 Q. A had a work station or 4 work com house? 5 A. Yes. 6 7 8 9 1 handwritten names and numbers or were these 2 computer printouts so they were the same? 3 A. They were very organized. Once in awhile 4 they used to be updated, so we used to have these 5 books with obsolete dates, you know, so we discard 6 j 7 8 9 Q. What did she do in terms of work? A. She will set appointments for comedy shops, movies. I will get the tickets but, you know, she was appointments for the masseuse, or 10 travel arrangements with the pilots, that type of 11 thing. 12 Q. And would she keep track of all of the 13 girls who were coming to his house in Palm Beach 14 or at the other houses as well? 15 MR. CRITTON: Form. 16 THE WITNESS: All of the houses. 17 BY MR. EDWARDS: 18 Q. Allright. So if he was going to be in 19 Paris and he wanted girls over in that house she 20 would keep track of that as well? 21 MR. CRITTON: Form. 22 THE WITNESS: Exactly. 23 +BY MR. EDWARDS: 24 on when you talked about seeing ll computer and seeing the names and them and have the new ones, Q. By obsolete dates are you saying that there were girls that came over and then they no longer came over anymore? 10 A. That's correct. 11 MR, CRITTON: Form. 12 BY MR. EDWARDS: 13 Q. Okay. So if a girl that was coming over 14 for a period of time got too old and was no longer =f 15 able to come over and somebody else took her place } 16 then her page would disappear from that book? \ 17 MR. CRITTON: Form. 18 THE WITNESS: I believe so, sir. 19 BY MR. EDWARDS: 20 Q. You were asked about other homes that you } 21 worked at for other wealthy people and asked if i 22 these other homes had a massage table. 23 A. Yes. 24 Q. And you said that they did? 25 A. Yes. 43 (Pages 435 to 438) EFTA00310320

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Page 439 Page 441 Q. And you said that that was -- the massage MR. EDWARDS: I don't have anything else. table was similar in kind to that used by Mr. MS. EZELL: I have a few. Epstein? EXAMINATION A. That's correct. BY MS. EZELL: Q. And others had massage oils and that was similar in kind to Mr. Epstein's as well? A. Yes. Q. And you didn't think that the massage 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. Q. Okay. And how old were the girls that 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, 10 Q. So you don't know wether there were or 11 were not? 12 A. No, ma'am, 13 Q. There wasn't just one massage table 14 there; was there? 15 A. We used to have two and we have an extra 16 reserve, I think there were three in the house. 17 Excuse me, I'll take that back. All the bedrooms 18 used to have one. 19 Q. Okay. Thank you. Did you ever hear 20 about a girl na 21 A. No, no, ma’am. 22 Q. And those pictures on Ms. Maxwell's 23 computer, did you ever see one of a girl naked in 24 a hammock? MR. CRITTON: Form. Asked and answered. WON AUNDBWNe WOnNAUNDBWNe Page 440 Page 442 | 1 THE WITNESS: I saw on a book not on a 2 computer. 3 BY MS, EZELL: 4 Q. You saw a picture of a girl naked ina 5 book or on a book? 6 7 8 9 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 A. The book was done for Nadia and she was on the hammock, that's the only one I saw. say I have girls to bring him and -- Q. I'm sorry, the book was done for Nadia? 7 sir. A. She was on the cover, o -- coming over in teams -- 10 Q. Then there were other people inside the A. No. 11 book? Q. -- or pairs? 12 A. Yes, ma'am. A. No. 13 Q. And in that book there was a picture of a Q. So there were a lot of things about Mr. 14 girl naked in a hammock? 15 A. Yes. 16 Q. Where did Nadia keep that book? 17 A, There were a few of those examples but I don't know where she kept it. 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. : Downstairs, yes, ma'am. 23 . Did Nadia keep scrapbooks or photograph 24 - A. Yes. NN NN ee he ood J REBSBESSSUAREBNESwmnauNsewNne 44 (Pages 439 to 442) EFTA00310321

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Page 445 | a... ike lh, she was and me, I guess. She was to hel juties, Q. And is that what your understanding was as to what lila did? A. I'm sorry? Q. -- of friends, girls? A. Yes, ma'am. MR, CRITTON: Form. BY MS. EZELL: Q. Do you remember there being a young man gho would bring girls to the house named Tony Figueroa? A. No, ma'am. The only person that I saw that night A. was at the house, she was driving 10 the car, but I didn't see any males. 11 MR, CRITTON: You said he, he being whom? 12 BY MS. EZELL: 13 Q. I didn't quite understand that either. 14 Tony Figueroa was driving. 15 A. She was with this girl that night, A. I 16 think that's the only time I saw a male at the 17 house, ma'am. 18 Q. And you're talking about the night when 19 you came and found the old car in the driveway? 20 A. Exactly, yes, with the police, yes. 21 Q. How did you remember that it was Tony 22 Figueroa? 23 A. It's the only person, male that I 24 remember. Q. But you don't know his name? a WONAUSWNe WONOAUMDWNP ve you spoken to any lawyers or 12 investigators about this case since you were 13 deposed last? 14 A. No, ma'am, 15 Q. I believe Mr. Critton was askin 16 questions relating to the incident we fl 17 inacar in the driveway and you went t the 18 police and he was speaking of that time as being 19 in January of '05. Do you remember when it was? 20 A. I will put that in that month, ma'am, but 21 I cannot guarantee. 22 Q. Let me just show you something that we 23 can mark as the next exhibit. 24 I would just ask that if -- yes, the name is In here that we redact it to show just the Page 446 1 A. No, no, no, Ma'am. 1 initials. 2 Q. Got you. Thank you. 2 MR. EDWARDS: We're going to attach this; 3 MR. CRITTON: Can I ask one quick? 3 right? 4 There was a man wit you don't know 4 MS. EZELL: Yes. 5 who it was? 5 MR. CRITTON: You're going to let us have 6 THE WITNESS: That's the only male that's 6 this one? 7 been to the house, so when she asked me the 7 MS. EZELL: Yes. With initials. 8 question I assume, you know. 8 (Exhibit No. 9 was marked for 9 MR. CRITTON: Do you know who Tony 9 Identification.) 10 Figueroa is? 10 BY MS, EZELL: il THE WITNESS: No, sir. il Q. Have you ever seen this report? 12 MR. CRITTON: Okay. Now I think I 12 A. I saw it typed, not handwritten like 13 understand. Thank you. Sorry, Cathy. 13 this. 14 MS. EZELL: That's okay. 14 Q. Did the police bring you one that was 15 BY MS, EZELL: 16 Q. Lasked y ier j chef's name 17 could have be: nd I was wrong, I 18 wanted to ask you a diffe! 19 Could it have been ? 20 A. I don't remember his last name. 21 Q. Do you remember an assistant of some sort 15 typed? 16 A. No, the only time I saw my own report was 17 on the internet because my daughter told me do you } 18 know that you're in Palm Beach and this and that, | 19 so I was in New York on vacation and that's why I 20 read it but this is the first time I'm looking at 21 this. 22 who worked there for awhile when you were there | 22 Q. Okay. 23 named ? 23 MR. HOROWITZ: Do you have extra copies? 24 A. Yes. 24 MS. EZELL: I do, I don't want to give Q. What did she do? them out, I'd rather -- I don't mind them 45 (Pages 443 to 446) EFTA00310322

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Page 447 Page 449 A. This is why I was fired. This is the reason I was let go. 10 MR. CRITTON: There is no question right 11 now. I'm sure there will be. 12 MR. EDWARDS: I'll ask it if you want. 13 THE WITNESS: I'm thinking out loud. 14 BY MS. EZELL: 15 Q. Did you notice the date on this report? 16 A. November 28th, yes, ma'am. 17 Q. And do you have any reason to believe 18 that that’s not accurate? 19 A. No, that’s it, yeah. 20 Q. And as you look at other information on 21 the report do you see anything else that’s not 22 accurate? 23 A. Let me finish reading this, please. 24 Q. Sure. MR, CRITTON: Let me just object to the own safety because I was carrying cash, I explained that to him, and he say why you called 10 the police, and I said because I saw a clunker in 11 the driveway and it’s dark. In Palm Beach there 12 is nonights. So I called for my own safety. I 13 was coming from Publix buying my groceries and I 14 had cash in my pocket. And I said I called the 15 police because I was concerned about my own 16 safety. 17 And I recogni girl and I figured 18 because I remember told me earlier that day | 19 -- it was a hectic day, he just left Palm Beach 20 and I was catching up with my breath, you know, I 21 went to buy my groceries, and I explained that. 22 So he was upset that this will spill, you know, to 23 the public or the street. But I didn't realize 24 this was written or something, you know. Q. You were not fired though until sometime 1 attaching it to the deposition as long as it 1 Q. Can you tell me what you mean by that? 2 has just the initials. 2 A. Mr. Epstein used to give a lot of gifts 3 THE WITNESS: This is the report when I 3 to the police department, so we used to have 4 called to the police to the house? 4 certain leeway in terms of speeding or some other 5 BY MS, EZELL: 5 things. So he used to put a baseball cap Palm 6 Q. Let me let you look at it, I'd rather you 6 Beach Police Department on the dashboard. 7 tell us if it is. 7 So when he saw I called the police for my 8 8 9 9 Page 448 Page 450 jf 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 form. Can I look at your copy, please? 1 2 3 4 5 Spanish). 6 7 8 9 THE WITNESS: This is the first time I saw this. BY MS. EZELL: 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. BY MS. EZELL: Q. Did you overhear the conversation between A.H. and the policeman? A. Yes, ma'am. Q. And is that part accurate as well? 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. 10 Because, you know, I have to say this for 11 myself, you know, I never did something illegal, I 12 was working hard to please him and sometimes more 13 than I was supposed to, many hours beyond my 14 duties, and so -- but he was concerned about this. 15 And I say, Mr. Epstein, you told me A. Yes. 16 safety is the paramount of this house, in this Q. And then your conversation with Mr. -- 17 case it was me, but obviously he didn't care about with Officer Munyan -- 18 me, it was his safety. A. Yes, ma'am, Q. -- is that accurately reported here as well? A. Yes, ma'am. Q. Now you stated that this is why you got fired, A. Yes, ma'am. 19 MR. CRITTON: Form. Move to strike. 20 BY MS, EZELL: 21 Q. Can you translate for me what you said a 22 moment ago in -- I don't know -- 23 A. In Spanish he said "conose" amnesty, but 24 he used the word “conose amnistia", I'll give you 25 amnesty so you have a chance to continue working Kress Court — Inc. 305-866-7688 RERRESSSLAREGHES eavausune 46 (Pages 447 to 450) EFTA00310323

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WON AUAWNH WON OAUDAWNE RRBRBRESSSUARRGNES Page 451 with me. 1 But I didn’t ask him why. He just came 2 fast. You're always in the run, you have to be on 3 your toes, and the next thing he said I took the 4 wrong Suburban and they let me go. 5 But I never find out what happened 6 because | have to say this. Being so many people 7 in the house I didn't know if I displease one of 8 the girls, or something I said or I did, I don't 9 think so. So they let me go very mysteriously. 10 But this is it. ll Q. TIunderstood you to say that Mr. Epstein 12 gave lots of gifts to the police department. 13 A. Yes, ma'am. 14 Q. And you said something about a baseball 15 cap. 16 A. Well, the police department used to give 17 us in retribution dozens of baseball caps with the 18 Palm Beach Police Department, you put one of those | 19 on the dashboard you don't get a ticket. 20 Q. Oh. 21 A. Stuff like that. Key rings and so on and 22 so forth. There is -- everybody knows this, I 23 don't think it's a secret. Mr. Epstein give 24 $85,000 simulator for the police to shoot, you Page 452 know, and it was returned after the scandal broke 1 out. 2 MR. CRITTON: Move as nonresponsive to 3 any question, Move to strike. 4 MS, EZELL: I don’t have any other 5 questions. 6 EXAMINATION 7 BY MR. LANGINO: 8 Q. Mr. Rodriguez, do you know where the main | 9 server, the main computer server was located 10 inside the house? ll A. In the garage. 12 Q. Do you know the names of any of the 13 programs -- computer programs -- 14 MR. WILLITS: I am missing something. 15 Whose questioning now? 16 MR. LANGINO: Adam Langino. 17 BY MR. LANGINO: 18 Q. Do you know the names of some of the main | 19 computer programs that are used as part of your 20 routine as the house manager of the house? 21 A. The main computers? 22 Q. Programs. 23 24 A. Besides Ci i Q. Regarding did you ever see 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 toas | masseuses. And when he asked you those questions} he referred to them often as women. Did you think of those masseuses as women? 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? OPOPO A. Yes. Q. 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 jtton abo who we were referring to in this deposition, and her date of 12/30/86. 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 47 (Pages 451 to 454) EFTA00310324

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WON AUSBWNe —_ RRSORPRBSSNRRRESESeCmrauawne indicated is accurate or accurately reflects the events of that night, I want to make sure that Mr. Willits hears and that we go through it and you can elaborate on any part of it, Okay. On Sunday, 11/28/2004, at approximately 19:00 hours, so we're talking about 7:00 at night, the property manager of 358 El Brillo Way, Alfredo Rodriguez, came to the station to complain there was a strange vehicle parked in the driveway. A. Yes. Q. That's true? A. Yes. Q. When Officer Koerner and I, this is Officer Munyan talking, arrived at 358 El Brillo, we located a white female later identified as A.H., date of birth 12/30/86 waiting in the driveway. A. That's correct. Q. Okay. MR, CRITTON: Form. Are you asking him whether the statement is correct or that you're reading it correctly? BY MR, EDWARDS: Q. No, the statement is correct. A. Yes. Q. That’s what you understood me to ask you? A. Yes. Q. Okay. Rodriguez arrived at that time and stated he did remember as there to pick up -- was coming there to pi an envelope the homeowner, Jeffrey Epstein, left for her. And that’s correct as well. Right? A. Yes. MR, CRITTON: Form. BY MR. EDWARDS: Q. This document right here, is it refreshing your recollection as to that night? A. Yes. MR. CRITTON: Form. BY MRL EDWARDS: Q. Rodriguez quickly entered the house then returned with a sealed envelope wit first name on It. A. Yes. Q. Do you remember who wrote her first name on that envelope? . A. Idid. Q. Okay. The envelope red to have money in it, in my opinion, Jj was very nervous with us standing there. Page 455 Page 456 WON AM DWN Page 457 Did you get that impression that H. was very nervous in her car when the police showed up? A. Yes. Q. Was that an indication to you that she realized that there were police there and that there was some form of illegal activity that she was involved in at Jeffrey Epstein's house? MR, CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. H.'s cell phone rang, she answered it quickly, said, in quotes, “I can't talk, I can't talk, I'm at school, I got to go." Did you hear that part of it? A. Yeah. Q. Okay. That's obviously a lie. Right? MR, CRITTON: Form. BY MR. EDWARDS: Q. She's saying she's at schoo! when really she's right in front of Jeffrey Epstein's house? A. Yes. Q. And again, another indication that she's doing something she shouldn't be doing. Right? MR. CRITTON: Form. MS. EZELL: Object to the form. Page 458 BY MR. EDWARDS: } Q. If she was a masseuse and was at someone's house in relation to pick up money from a massage she had given, that's not the typical answer that you would expect. Right? MR. CRITTON: Form. THE WITNESS: That's right. BY MR. EDWARDS: Q. Okay. It didn't shock you or surprise you as Mr, Critton asked you earlier that she would make up a tele or a lie about her whereabouts considering what she was doing. Right? A. No. MR. CRITTON: Form. BY MR. EDWARDS: Q. Then hung up, talking about Ms. i I asked her who it was on the phone, she stated it was her mom. I asked her how she knows Epstein, H, stated the i $ at Abercrombie & Fitch in the Mall, she met Epstein through a femaie friend at work, Epstein allows them to come over any time and use the house and pool. Then she quickly left. Did you hear that conversation? Jf) Wee 48 (Pages 455 to 458 Kress Court — Inc, 305-866-7688 EFTA00310325

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Page 459 quickly said it was money. Is that accurate? Page 460 1 A. Yes, they were next to me. 1 Q. lLasked what kind of job H. performs, 2 Q. Okay. Is that the entire substance of 2 Rodriguez smiled and says she is a massage 3 that conversation between Ms. jjjjand the police 3 therapist. 4 officer? 4 A. Yeah. 5 A. Yes. 5 Q. Why did you tell him that? 6 Q. She didn't mention that she comes over to 6 MR. CRITTON: Form. 7 his house and goes into a bedroom with Mr. 7 THE WITNESS: Because I understood she 8 Epstein. Right? 8 came to give massage. 9 MR. CRITTON: Form. 9 BY MR. EDWARDS: 10 THE WITNESS: No. 10 Q. Well, that's what somebody had told you? 11 BY MR. EDWARDS: ll A. Yes. 12 Q. And she didn't tell the police officer 12 Q. At this point in time though you knew 13 that she is a masseuse; did she? 13 that more was going on than a massage? 14 A. No, 14 MR. CRITTON: Form. 15 Q. And that didn't surprise you either; did 1S BY MR. EDWARDS: 16 it? 16 Q. Right? 17 A. No, 17 MR. CRITTON: Form. 18 MR. CRITTON: Form. 18 THE WITNESS: That's right. 19 BY MR. EDWARDS: 19 BY MR. EDWARDS: 20 Q. I then asked Rodriguez what was in the 20 Q. Iasked -- this is the police officer 21 envelope, Rodriguez was hesitant but -- what is 21 talking, I asked which muscle she rubbed. 22 that word? 22 Do you remember the police officer asking 23 A. But then. 23 «that? 24 Q. But then I said it was drugs and he 24 A. Yes. Q. And you knew what he was implying. 1 A. That's correct. 1 Right? 2 Q. When he first asked you what was in the 2 MR. CRITTON: Form. 3 envelope were you nervous? 3 THE WITNESS: Yeah. a A. No, because I was trying to -- I didn’t 4 BY MR. EDWARDS: 5 want to disclose these private things with the 5 Q. That it was obvious to him that she was 6 police so that’s why I was concerned about that. 6 over there to sexually please Mr. Epstein. Right? 7 Q. When you're talking about private things, 7 MR, CRITTON: Form. 8 the fact that there are young girls coming over? 8 THE WITNESS: That's correct. 9 MR. CRITTON: Form. 9 BY MR. EDWARDS: 10 THE WITNESS: It was late, you know, 10 Q. And that's coming from a police officer il exactly. 11 who's not the house manager. Right? 12 BY MR. EDWARDS: 12 MR. CRITTON: Form. 13 Q. I'll let you answer, What are the 13 THE WITNESS: That's right. 14 private things that you were nervous to tell the 14 BY MR. EDWARDS: 15 police? 15 Q. You knew right away what he was asking 16 A. This was inside the compound, the 16 and you say, Rodriguez laughed said, in quotes, 17 property Itself, so you have to keep 17 “off the record, he, Epstein, has many young girls 18 confidentiality, and the police was there, that's 18 come over for that," end quote. 19 why. Not that I was doing something wrong butI | 19 Do you remember telling him that? 20 was trying to keep them -- 20 MR. CRITTON: Form. 21 Q. I'm not suggesting that you were doing 21 THE WITNESS: Yes. 22 something wrong. 22 BY MR. EDWARDS: 23 A. Exactly. So he asked me is there any 23 Q. And when you were saying come over for 24 drugs there, and I said, no, it's just money. 24 that, it was -- 25 That's all I said. 25 A. Massage or something. Page 461 49 (Pages 459 to 462) Kress Court — Inc. 305-866-7688 EFTA00310326

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Page 465 f 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. 10 BY MR. EDWARDS: 11 Q. Okay. There's always a different girl at 12 the pool or inside with him when he's here. 13 MR. CRITTON: Form. 14 THE WITNESS: Yes. 15 MS. EZELL: You left out a word, young. 16 BY MR. EDWARDS: 17 Q. Sorry, I'll read the last sentence again, 18 There's always a different young girl at 19 the pool or inside with him when he's here. 20 Do you remember telling the police 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 10 bedroom to observe whatever went on between a 11 masseuse and Mr. Epstein or anyone else for that 12 matter at any time? 13 MR. HOROWITZ: Form. 14 THE WITNESS: No, sir. 15 BY MR. CRITTON: 16 Q. And so when Mr. Edwards asked you, you 17 were aware that sexual activity or may have been 18 sexual activity occurring upstairs, you have no 19 personal knowledge, you're just speculating; 20 aren't you, sir? WON OUDAWNe WONOAUWMSBWNe 21 officer that? 21 MR. HOROWITZ: Form. 22 A. Yes, 22 MR, EDWARDS: Object to the form. 23 MR, CRITTON: Form. 23 THE WITNESS: I never saw them. 24 +BY MR. EDWARDS: Q. And that's true, Right? 24 +BY MR. WILLITS: Q. And therefore you can only speculate -- Page 464 Page 466 } 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 1 MR. WILLITS: Object to the form. 2 MR. CRITTON: I need to ask the question 3 first. 4 MR, WILLITS: It was the earlier 5 question, 6 BY MR. CRITTON: 7 Q. All right. If you did not see what was 8 going on you can have no personal knowledge. 9 True? were young and were up in the bedroom with Mr. 10 MR. HOROWITZ: Object to the form. Epstein to sexually please Mr. Epstein. il MR. EDWARDS: Object to the form. MR. CRITTON: Form. 12 THE WITNESS: Yes. THE WITNESS: That's right. MR. EDWARDS: I don't have anything else. We've already attached this; right? Here ts the one that can be attached. 13. BY MR. CRITTON: 14 Q. And, therefore, what you're doing is 15 speculating or guessing what may have been 16 occurring. True? BSSNRRRSNRESweenausuwne MR. WILLITS: Who is next? 17 MR. HOROWITZ: Form. MR. CRITTON: Me. 18 MR. EDWARDS: Form, RECROSS EXAMINATION 19 MR. WILLITS: Form. BY MR. CRITTON: 20 THE WITNESS: I use my age together. 21 Q. Mr. Rodriguez, looking at Exhibit 9 which 21 +BY MR. CRITTON: 22 is the police report that was prepared on November | 22 Q. I'm not saying that you don't, but 23 28, 2004, this is the first time you've seen it. 23 without having personal knowledge you're best 24 Correct? 24 guessing what may have occurred up there between | 25 A. That's correct. 25 Mr. Epstein and one of the massage women, or for 50 (Pages 463 to 466) Kress Court Reporting, Inc. 305-866-7688 EFTA00310327

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WON AUAWNHE a Page 467 that matter anyone else who was upstairs? 1 A. Yes. 2 MR. HOROWITZ: Form. 3 MR. EDWARDS: Form, 4 MR. WILLITS: Object to the form. 5 MR. CRITTON: Thank you. 6 MS, EZELL: I just have a couple of 7 questions. 8 EXAMINATION 9 BY MS. EZELL: 10 Q. Following up on that, you did however see 11 this same young woman asleep naked in the sauna? | 12 A. Yes, ma'am. 13 Q. And you did along read and 14 -- and you did also find sex toys and massagers of | 15 various kinds and creams scattered around on 16 several occasions after these young women had been} 17 upstairs with Mr. Epstein? 18 MR. CRITTON: Object to form, asked and 19 answered about six times. 20 THE WITNESS: Yes. 21 MS. EZELL: No other questions. 22 MR. EDWARDS: Sorry, last one. It has 23 nothing to do with this report. 24 EXAMINATION 25 Page 468 BY MR. EDWARDS: 1 Q. During Mr. Critton's questioning he asked 2 you about whether or not we had ever shown you a | 3 previous taped statement that you had given to a 4 police officer, and we did not do that; did we? 5 A. No, 6 Q. We can represent to you that we don't 7 have It to show it to you otherwise we would like 8 to do that. 9 However, he asked you did you tell the 10 police officers at that time that the girls il appeared to be 18 years or older, and I believe 12 that you said when you gave the statement to the | 13 police that you did; right, say that? 14 A. Yes. 15 Q. And I wrote, I put it in quotes, you said 16 that because you were fearful of reprise from 17 Ms, Maxwell and Mr. Epstein. 18 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? 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 w ious professional t 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. Itwas between 200 and 500, sir, but so i =~ between those two amounts. Q. 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) EFTA00310328

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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. WOONAUBAWNE 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 Florida, =) County Of Dade. ) L MICHELLE PAYNE, Court Reporter and bad did stenog) report the deposition 7 ALFREDO RODRIGUEZ; that 8 review of the transcript was not requested; and that the foreguing pages, 8 ser earad from 270 to 872, Mechisiew ore a true party 1 financially interested in the action. ‘The foregoing certification of this 16 trenscript does not apply to any reproduction of the same by any means unless under the direct 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, in EFTA00310329