7
Shared Docs
7
Same-Page
9 / 9
Mentions
6 17 18 19 20 21 22 23 24 25 EXHIBITS 1 Message pad 2 Documents INDEX OF EXAMINATION WITNESS DIRECT CROSS ALFREDO RODRIGUEZ (By Mr. Mermelstein) 12 (By Mr. Edwards) 157 (By Mr. Langino) 260 INDEX OF EXHIBITS PAGE 72 115 Page 6 Page 8 1 Doe right here on the copy you gave me. I'm
Richard Willits, representing MR. BERGER: William J. Berger, representing M., M. and Jane Doc number two. MR. MERMELSTEIN: Stuart Mennetstein of Mermelstein and Horowitz. representing Jane Does numbers two through eight. MR. LANGINO: Adam Langino, on behalf of 1 2 3 4 5 6 7 8 9 10 11 12 13
, he hire me to -- he just 11 bought the house. 12 Q. I'm sorry? 13 A. He just had bought the house -- 14 Q. Okay. 15 A. -- where he live on El Brillo. And he hire me 16 through Mr. Wexner's references to do repair works. And 17 basically what I did the most was taking walls apart, 18 windows
9 guest? 10 MR. REINHART: Objection to the fomi, lack of 11 foundation, and a standing objection as to her 12 knowledge of anything involving El Brillo Way or 13 Jeffrey Epstein. Instruct her not to answer. 14 THE WITNESS: At the instruction of my lawyer, 15 I must invoke my Fifth Amendment rig
you're not required to 3 assume because some lawyers ask you a leading 4 question or suggested in a report or like the 5 police report like Mr. Mermelstein and Mr. Edwards 6 did, that did you tell the police officers X, Y, 7 or Z without showing you the statement. You're 8 not required to guess, I
Q. And when we were here, I think it was 11 last week or the last ten days anyway -- I could 12 tell you. On July 29th of this year, and Mr. 13 Mermelstein started with your deposition and then 14 others asked questions, when Mr. Mermelstein and I 15 think Mr. Edwards asked questions about did you 16
d of caused you to have seen any 17 names on her computer? 18 MS. EZELL: Objection to form. 19 THE WITNESS: All the calls that came to 20 358 El Brillo, they came through the 21 telephone, they have a transcript somehow 22 that they connect to the computer, so you 23 can pull it and you registe
telephone or view a videofeed of the deposition, but will not be seen by our client. Regards, Adam D. Horowitz, Esq. WvAv.sexabuseattorney. C0111 Mermelstein a Horowitz, P.A. 18206 Biscayne Boulevard Suite 2218 Miami, FL 33160 Tel: Fax: From: Michael J. Rice [mato: Sent: Tuesday, September 15, 2009
wles Sent: Tuesday,Janu!!!!!!!!!!!!!!" To: Sloane, Carmen Subject: Schedule For Wednesday and Thursday Schedule for 01/06/10: 6am - Leave 358 El Brillo wawy for Galaxy Aviation at Palm Beach International Airport 7am - Take of from PHI 10:15am - Land at Teterboro Airport, NJ and go straight to 9 E.
5pm - Pre clear customs in Cyril E. King airport in St Thomas 6:10pm - Take of from Cyril E. King airport in St Thomas for PBI 9:30pm - Home at 358 El Brillo way 1 EFTA00182023 State of Florida Department of Corrections - Community Corrections TRAVEL PERMIT/INTRASTATE TRANSFER REQUEST Name: Jeffrey
21 Q. All right. And how did you happen to get that 22 MR. MERMELSTEIN: Stuart Mermelstein of 22 job? Was it through an employment agency -- 23 Mermelstein and Horowitz. representing Jane Does 23 A. No. 24 numbers two through eight. 24 Q. -- or an ad in the paper? 25 MR. LANGINO: Adam Langino. on
d bought the house -- 14 Q. I introduced myself through the videographer. 14 Q. Okay. 15 My name is Richard Willits. 15 A. -- where he live on El Brillo. And he hire me 16 A. Okay. 16 through Mr. Wexner's references to do repair works. And 17 Q. re resent a young lady by the name of 17 basica
Q. And when we were here, I think it was 11 last week or the last ten days anyway -- I could 12 tell you. On July 29th of this year, and Mr. 13 Mermelstein started with your deposition and then 14 others asked questions, when Mr. Mermelsteln and I 15 think Mr. Edwards asked questions about did you 16
now if we covered 7 this last time, I think that we did not, but can 8 you tell us during the period of time when you 9 worked at that house at El Brillo, Mr. Epstein's, 10 what cars did he own or were in the driveway? 11 A. We have two Suburbans, two Mercedes 600, 12 and a Cobra, and a motorcycle.
hat privilege. 4 You can either assert it or not assert it. 5 That's your right. But nobody's apparently going 6 to tell you that, at least Mr. Mermelstein is not 7 going to tell you that. 8 MR. MERMELSTEIN: Well, I was trying to 9 avoid -- 10 MR. CRITTON: Well, you're asking questions of 11 wha
stood it correctly, is basically, once you 17 became the full-time house manager, you were responsible 18 for all aspects of the operation of the El Brillo 19 residence? 20 A. I was. 21 MR. WILLITS: Object to the form of the 22 question. 23 BY MR. CRITTON: 24 Q. And during the time that you
hat privilege. 4 You can either assert it or not assert it. 5 That's your right. But nobody's apparently going 6 to tell you that, at least Mr. Mermelstein is not 7 going to tell you that. 8 MR. MERMELSTEIN: Well, I was trying to 9 avoid -- 10 MR. CRITTON: Well, you're asking questions of 11 wha
stood it correctly, is basically, once you 17 became the full-time house manager, you were responsible 18 for all aspects of the operation of the El Brillo 19 residence? 20 A. I was. 21 MR. WILLITS: Object to the form of the 22 question. 23 BY MR. CRITTON: 24 Q. And during the time that you
Entities connected to both Mermelstein and El Brillo

Jeffrey Epstein
PERSONJane Doe
PERSON
Ghislaine Maxwell
PERSON
Palm Beach
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSONLeon Black
PERSON
George W. Bush
PERSON
Palm Beach County
LOCATION
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Palm Beach Police Department
ORGANIZATION
West Palm Beach
LOCATION
United States
LOCATION
Bill Clinton
PERSON
Marc Rich
PERSON
Alfredo Rodriguez
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSON