Epstein Secrets

, does that mean. at 22 Q. Right. 22 least to Mr. Alessi. that that's married, and if 23 A. Or I was not

ted cases: 08.10232. 0840360. 9840381 08.10994. 0640993. 0840811. 08.80893. 09.80169. 09.10591.09.80656.09.80802.0941092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday. September 8. 2009 1012 am.. 3:45 pm. 2139 Palm Beach Lakes Boulevanl West Palm Beach. Banda 31301 Reported By Sandra W Towns

e dates because I 8 The time is 12 minutes after 10:00 in the morning. 8 trying -- 9 This is the videotaped deposition of Juan 9 Q. Sure. 10 Alessi in the matter of Jane Doe number two versus 10 A. -- to remember. 1969 as a part-time 11 Jeffrey Epstein. This deposition is being held at 11 m

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

09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday. September 8, 2009 10:12 am.-

he above cause. VIDEOGRAPFIER: Today is September 8, 2009. The time is 12 minutes after 10:00 in the morning. This is the videotaped deposition of Juan Alessi in the matter of Jane Doe number two versus Jeffrey Epstein. This deposition is being held at 2139 Palm Beach Lakes Boulevard in West Palm Beach F

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

: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME II Tuesday, September 8, 2009 10:12 a.m. - 3:45 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 Reported By: Sandra

81645 Page 97 1 A. Okay. 2 Q. Thank you very much. 3 A. Welcome. 4 CROSS EXAMINATION 5 BY MR. MERMELSTEIN: 6 Q. Good afternoon, Mr. Alessi. 7 A. Yes, sir. 8 Q. My name is Stuart Mermelstein. I represent a 9 group of the Plaintiffs in these cases and I have some 10 questions for

N 5 BY MR. MERMELSTEIN: 6 Q. Good afternoon, Mr. Alessi. 7 A. Yes, sir. 8 Q. My name is Stuart Merm

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

ositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

ons of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

DATE &TIME Jane Doe #4 September 16, 2009 c/o Mermelstein & Horowitz PA at 1:00 PM 18205 Biscayne Bouleva

ate himself in front of you? A: I don't remember him doing that. Ile might have hut I really don't remember. (Sworn Statement of I0/05/05 at 7). • Juan Alessi Stated that Only One Girl Looked Young Police Report at 57: "Alessi stated that towards the end of his employment the masseuses were younger and yo

t have hut I really don't remember. (Sworn Statement of I0/05/05 at 7). • Juan Alessi Stated that Only One Girl Looked Young Police Report at 57: "Alessi stated that towards the end of his employment the masseuses were younger and younger-. However, he said no such thing: Q: Did they seem young to yo

amed partner in Mr. I ferman's firm. See Tab 31, Florida Bar Website page. 39. Mr. Herman, who is the named partner in the former firm of Herman, Mermelstein, filed five lawsuits, each asking for S50 million, against Mr. Epstein. Each lawsuit is entitled "Jane Doc # vs. Jeffrey Epstein," despite the fact

they coordinate their efforts in joint conference calls at least two times per month. At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the witnesses for approximately six to eight hours, often repeating the same or similar questions t

ons of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

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

age 174 1 A. No. 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.

3 CROSS EXAMINATION 4 BY MR. CRITTON: 5 Q. Mr. Alessi, my name is Bob Critton, as you 6 know, and I r

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

989 09/04/2009 Bradley Edwards William Berger Alessi Depo W/P; Attorney Client Privilege; Irrelevant

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

989 09/04/2009 Bradley Edwards William Berger Alessi Depo W/P; Attorney Client Privilege; Irrelevant

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