Epstein Secrets

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

5 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 1 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 i

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

oe. 21 MR. LIINO: Adam Langino on behalf of 22 plaintiff, ■ 23 MS. EZELL: Cathy Ezell on behalf of Jane 24 Doe 101 and 102. 25 MR. CRITTON: Bob Critton on behalf of Page 13 1 Q. When was that? 2 A. I began on September of 2004. 3 Q. And where were you employed? 4 A. I work -- well, I have se

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

lm Beach. And I got to know 2 Orseck, on behalf of Jane Does 101 and 102. 2 Jeffrey through Lesley Wexner. And I used to work in 3 MR. CRITTON: Bob Critton. on behalf of 3 about 20 different. 20.25 different homes in Palm Beach 4 Jeffrey Epstein. 4 as a maintenance guy. 5 THEREUPON, 5 Q. Okay.

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

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

9 EFTA00602853 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein 01319 08/11/2009 Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege 01316 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo

edes C. Estrada Doe v. Epstein Joint-privilege 02044 09/04/2009 Katherine W. Ezell Bradley J. Edwards E.W., Doe v. Epstein — Letter from Bob Critton Joint-privilege 02048 09/04/2009 Robert C. Josefsberg Bradley J. Edwards E.W., Doe v. Epstein — Letter from Bob Critton Joint-privilege 0

9 EFTA00310066 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein 01319 08/11/2009 Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege 01316 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo

. Estrada Doe v. Epstein Joint-privilege 02044 09/04/2009 Katherine W. Ezell Bradley J. Edwards Doe v. Epstein — Joint-privilege e er r m Bob Critton 02048 09/04/2009 Robert C. Josefsberg Bradley J. Edwards Doe v. Epstein — Joint-privilege Letter from Bob Critton 02054 05/12/2009 Spence

you know, they told me to tell, to be honest, to tell the truth, my lawyers. BY MR. EDWARDS: Q Yeah. You know that I represent three girls, Mr. Mermelstein represents seven girls, Mr. Hill one, and that's just the lawyers that are here. A bunch of these girls are all alleging that Mr. Epstein was upst

either. Okay. That's all I have. Thank you. THE WITNESS: You're welcome. MR. CRITTON: can I switch with you? CROSS BY MR. CRITTON: , my name is Bob Critton, I represent Mr. Epstein. I have a few follow-up questions based on • ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 since 600 4440 P

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

That's lawyer stuff. I don't know. 2 MR. BERGER: Okay. That's all I have. 3 CROSS EXAMINATION 4 BY MR. CRITTON: 5 Q. Mr. Alessi, my name is Bob Critton, as you 6 know, and I represent Mr. Epstein. 7 A. Yes, sir. 8 Q. You've been -- this deposition started at 9 10:00. It's almost -- it's clo

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

That's lawyer stuff. I don't know. 2 MR. BERGER: Okay. That's all I have. 3 CROSS EXAMINATION 4 BY MR. CRITTON: 5 Q. Mr. Alessi, my name is Bob Critton, as you 6 know, and I represent Mr. Epstein. 7 A. Yes, sir. 8 Q. You've been -- this deposition started at 9 10:00. It's almost -- it's clo