Epstein Secrets

she was coming to give t 20 massage? 21 A. No. I assumed she was a massage therapy 22 because I was -- I drove Ms. Maxwell to Mar-a-lago. 23 Donald Trump's residence. And I wait in the car while 24 Ms. Maxwell got a -- I think it was a facial or massage. 25 I don't know. But that day I remember this

16 17 18 19 20 21 22 23 24 25 Page 71 Diane's secretary, she stay there for a week with her kids and we took care of her. Who else? Mr. Trump. That's a celebrity. Mr. Robert Kennedy, Junior. Mr. Frederick Fekkai. Q. Who is that? A. Fekkai, Frederick Fckkai, the famous hairstylist. Who e

I was -- I drove Ms. Maxwell to Mar-a-lago. 23 Donald Trump's residence. And I wait in the car while 2

ith her kids and we took care of her. Who else? Mr. Trump. That's a celebrity. Mr. Robert Kennedy, Junior.

-- I drove Ms. Maxwell to Mar-a-lago. 23 Donald Trump's residence. And I wait in the car while 24 Ms. M

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

therapy 22 began coming to Mr. Epstein's home? 22 because I was — I drove Ms. Maxwell to Mar-a-lago. 23 A. She could have been 17. IS, 19. 23 Donald Trump's residence. And I wait in the car while 24 Q. Could she have also been 15? 24 Ms. Maxwell got a -- I think it was a facial or massage. 25 MR. CR

he stay there for a week with her 2 THE WITNESS: No. not that I can remember. 2 kids and we took care of her. 3 BY MS. EZELL: 3 Who else? Mr. Trump. That's a celebrity. 4 Q. Do you know if he and Mr. Epstein were 4 Mr. Robert Kennedy. Junior. Mr. Frederick Fekkai. 5 involved in any business

ago. 23 A. She could have been 17. IS, 19. 23 Donald Trump's residence. And I wait in the car while 2

took care of her. 3 BY MS. EZELL: 3 Who else? Mr. Trump. That's a celebrity. 4 Q. Do you know if he and

3 A. She could have been 17. IS, 19. 23 Donald Trump's residence. And I wait in the car while 24 Q. Co

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

this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00188873 Case 9:08-cv-807.

S CHNITORRA SPO• MTN B. SUWVAN 2.4 KABUL IThlY DONALD J. WARD 'C. CALM MAMMA le 0112:21RIGEL 'EARL LOOP

ed that Jane Doe 102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be

people that Epstein alleges in his Complaint had "no connection whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00188873 Case 9:08-cv-807.36-KA6. Doc gmeOt 291-15 Egere.d oriSI Jocket 1/21/2M.5 Page 11 of t;ase OU-34/9-r<btrt uoc 1604 rueo

deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several occasions during the time period most relevant to my Edwards's clients' complaints; (b) Trump wa

t Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herma

people that Epstein alleges in his Complaint had "no connection whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00726006 (Bill Clinton phone numbers listed under "Doug Bands"). Federal Investigation and Plea ARreement With Epstein 19. In app

deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several occasions during the time period most relevant to my clients' complaints; (b) Trump was quoted

this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00726006 (Bill Clinton pho

ed that Jane Doe 102 was initially approached at Trump's Maralago by Ohislaine Maxwell and recruited to be

t Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herma

people that Epstein alleges in his Complaint had "no connection whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00081189 Case 9:08-cv-807attotAme 2Niall ogerrl eocroFaCAyocitaWW015 Page 11 of (Bill Clinton phone numbers listed under "Doug Ba

deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several occasions during the time period most relevant to my Edwards's clients' complaints; (b) Trump wa

this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00081189 Case 9:08-cv-807a

ed that Jane Doe 102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be

t Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herma

0-c86e-469f-ScI01-ba20bcae87de EFTA00101411 Page 171 1 A. Because either she told me or Ms. Maxwell told 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the one who bring her to the 4 house that afternoon, the first time I saw rive in 5 at this -- Donald Trump'

old 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the one who

xwell told 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the o

old 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the one who b

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

ca0-c86e.4b968d01-ba20bcae87de EFTA00181719 Page 171 1 A. Because either she told me or Ms. Maxwell told 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the one who bring her to the 4 house that afternoon, the first time I sat-, ill drive in 5 at this -- Donald

old 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the one who

xwell told 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the o

old 2 me that her father used to work at Donald Trump's place. 3 And she -- I think he is the one who b

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

6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P

19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Product;attorney client privilege;i

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

6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P

19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Productattorney client privilege;ir

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

nberg at Haley Capital, which was located in the Trump Tower. In late December 1993, Hoffenberg took Dr

arcia Innle ' Katherine Warthen ell Michael James Pike Paul G Cassell Richard Horace Willits Robert C. Josefsberg Adam D. Horowitz Stuart S Mermelstein William J. Realer 11 EFTA00182843 Case 5:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 1 of 8 UNITED STATES DISTRICT CO