Epstein Secrets

Volume II October 20, 2009 133 • 7 10 11 12 13 • 14 15 16 17 18 19 2C 21 22 23 24 25 APPEARANCES: On behalf of the Defendant: ROBERT D. CRITTON, JR., ESQUIRE BURMAN CRITTON LUTTLER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, Florida 33401 Phone: On behalf of Plaintiff

14 15 16 17 18 19 20 21 22 23 24 25 162 (Plaintiff's Exhibit No. 3 was marked for identification.) BY MR. CRITTON: Q Pursuant to Mr. Critton's suggestion, we marked that as Plaintiff's Exhibit 3, and ask you to take a look at that photograph and tell me if you recognize this individual

9:1 210:21 199:8,19 159:18 doing 219:1 220:1 213:16 203:13,11 163:25 172:20 220:1,1 215:10,12 203:15,18 183:22 205:21 earlier 218:24 Critton's 204:24 III:2 216:8 described 182:23 III:16 door 143:9 147:15 152:14 162:4 208:19 208:20,22 =7:17 219:12 days 183:17 204:23 DESCRIPT

you that question. A Yes. Q Is the item that you describe as a back massager, have you seen that like -- let me strike that. Do you know what Brookstone is? A Yes. • ESQUIRE 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, R 33410 voorcesouir

lorida Prose Court Reporting 25 0167 I APPEARANCES: 2 On behalf of 3 4 5 6 7 8 9 10 11 On behalf of the Defendant, Jeffrey Epstein: ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTTIER, ESQUIRE BURMAN, CRITTON, LUTHER & COLEMAN, LLP West Palm Beach, Florida lilcifiCl/Documentstleand%20Scitings/Produ

Q. How large was it? 3 A. It was like this big (indicating). 4 Q. Okay. 5 A. It was like a neck massager. 6 Q. You know like -- you know what Brookstone 7 is, a store? 8 A. Yeah. 9 Q. Have you ever been in there and they have 10 these massages that, like you can reach behind your 11 back and

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 MS. EZELL: As Mr. Critton well knows I 7 represent a number of other dients whose 8 cases have not been filed and I believe we 9 do have standing to ask questions, and I

that is a back massager with the rotating 7 heads also sold -- well, let me ask you this. 8 Strike that last question. 9 Have you ever been to Brookstone? 10 A. Yes. 11 Q. Okay. Have you ever seen a massager like 12 that at Brookstone? 13 A. Yes. 14 Q. Okay. You were asked whether Ms. Maxwell

RECT CROSS REDIRECT RECROSS 2 3 3 ALFREDO RODRIGUEZ 4 4 5 (8y Ms. Ezell) 278 441, 467 5 6 (By Mr. Willits) 334 453, 469 7 6 (Ely Mr. Critton) 338 464 7 9 (By Mr. Edwards) 419, 454, 468 10 8 11 9 (By Mr. langino) 452 12 10 13 11 14 12 CONTINUED INDEX OF MINTS 13 PLAINTIF

that is a back massager with the rotating 7 heads also sold -- well, let me ask you this. 8 Strike that last question. 9 Have you ever been to Brookstone? 10 A. Yes. 11 Q. Okay. Have you ever seen a massager like 12 that at Brookstone? 13 A. Yes. 14 Q. Okay. You were asked whether Ms. Maxwell

3 Mr. Mermelstein? 14 MR. MERMELSTEIN: Yes. 15 THE COURT REPORTER: Mr. Goldberger, do 16 you want a copy? 17 MR. GOLDBERGER: Yes. Send it to Critton. 18 Bill him, seriously. 19 (Witness excused.) 20 (Deposition was concluded.) 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY

uld you describe that? 11 A. It was for massage, muscle massage with rubber 12 head, vibrate when you press the button. You can buy 13 them in Brookstone's. I saw them. 14 Q. Anything -- so you opened the drawer to 15 put something away and you saw that? 16 A. Yes. 17 Q. Anything else you se

ly used 12 those items or how they were used, all you know is you 13 found them -- 14 A. I find it in the sink. 15 MR. BERGER: Objection. Mr. Critton is 16 testifying. Leading. 17 MR. WILLITS: Objection, also, to the form. 18 BY MR. CRITTON: 19 Q. Let me ask you this: Do you know, if I 20

, they have the 12 cordless and they have these balls and they have 13 different types of those vibrators, too. 14 Q. Like you can get them at Brookstone or 15 something like that? 16 A. Yeah. Yeah. Yes, sir. 17 Q. So at least when you were at Mr. Epstein's, 18 and I think as you described in

ly used 12 those items or how they were used, all you know is you 13 found them -- 14 A. I find it in the sink. 15 MR. BERGER: Objection. Mr. Critton is 16 testifying. Leading. 17 MR. WILLITS: Objection, also, to the form. 18 BY MR. CRITTON: 19 Q. Let me ask you this: Do you know, if I 20

, they have the 12 cordless and they have these balls and they have 13 different types of those vibrators, too. 14 Q. Like you can get them at Brookstone or 15 something like that? 16 A. Yeah. Yeah. Yes, sir. 17 Q. So at least when you were at Mr. Epstein's, 18 and I think as you described in