I EFTA00188908

Case 9:08-cv-80736-KAN, Document 291-17 Entered on FLS Docket 01/21/2015 Page 1 of 8 EXHIBIT 18 EFTA00188909

Case 9:08-cv-80736-KA1.. Document 291-17 Entered on PLS. Docket 01/21/2015 Page 2 of 8 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE Ne.08•CV-130 I 19-CI V-MARRALJOHNSON JANE DOE NO. 2, Plaintiffs JEFFREY EPSTEIN, Defendant. Relined eases 08.80232, 08-80380,98-8038I. 08-80994. 08-80993, 08410811,08-80893. 09-80469, 09.80591. 09.80656,09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday. September 8, 2009 10:12 am.- 3:45 p.m. 2139 Palm Beach Lakes Boulevard Wen Palm Beech, Florida 33401 Reported By. Sandra W. Townsend. FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office 1 On behalf of the Defendant: 2 ROBERT J. CRITTON, ESQUIRE RMAN. RITTON & LUTTIER 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 Page 2 1 APPEARANCES: 1 On behalf of the Plaintiffs: 3 RICHARD WILLITS. ESQUIRE WILLITS. P.A. 6 7 a 12 13 14 15 16 17 STUART MERMELS1EIN. ESQUIRE WILLIAM J. BER ROTHSTEIN ROSENFELDT ADLER KATHERINE W. F2ELL, ESQUIRE PODHURSTORSECK. P.A. Is 19 ADAM I. LANCING. ESQUIRE 20 21 22 23 24 25 1 2 Page 4 EXHIBITS NUMBER DESCRIPTION PAGE 6 Exhibit number I Photographs 45 7 Exhibit number 2 Transcript 130 8 Exhibit number 3 Incident Report 137 9 Exhibit number 4 Incorporation Papers 149 10 Exhibit number 5 Incorporation Papers 150 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401.377.676-2895) EleCtron Ically signed by Sandra Townsend (401-377.876.2895) 760564a-4a1c-4dee-87ac-479898cc7004 EFTA00188910

Case 9:08-cv-80736-KAi',. Document 291-17 Entered on Fu Docket 01/21/2015 Page 3 of 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 5 PROCEEDINGS 2 - - - Deposition taken before Sandra W. Townsend, Court Reporter and Notary Public in and for the State of Florida at Large. in the 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 Florida. My name is Stan Sanders. I'm the vidcographer representing Visual Evidence, Incorporated. Would the attorneys please announce their appearances for the record. MR. WILLITS: 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 14 15 16 17 18 19 20 21 22 23 24 25 Page 7 Q. All right, sir. Did you ever work for Jeffrey Epstein? A. Yes, I did. Q. In what capacity? A. Everything. I started with Jeffrey Epstein around 19 -- please bear with the dates because I trying -- Q. Sure. A. -- to remember. 1969 as a pan-time maintenance guy. And then 1 become a full-time employee, I think it was January 1, 2 -- '91, '92, so '92. Sorry. Q. You said you started in 1969? That would be -- A. No. No. No. No. No. Q. Okay. A. '99. Q. 1999? A. Yeah. Q. All right. And how did you happen to get that job? Was it through an employment agency -- A. No. Q. -- or an ad in the paper? A. I had a company at that time used to take care Page 6 1 MS. EZELL: Katherine Ezell from Podhurst 2 Orseck, on behalf of Jane Does 101 and 102. 3 MR. CRITTON: Bob Griffon, on behalf of 4 Jeffrey Epstein. 5 THEREUPON, 6 JUAN ALESSI, 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 TIIE WITNESS: I do. DIRECT EXAMINATION BY MR. WILLITS: Q. Good morning, sir. A. Good morning. Q. I introduced myself through the vidcographer. My name is Richard Willits. A. Okay. . I re resent a young lady by the name of A. Okay. Q. Is that name familiar to you at all? A. Whose name? Q. Do you recognize that name A. No. Q. What is your residence address, sir? A. My address is Page 8 1 of a lot of residents in Palm Beach. And I got to know 2 Jeffrey through Lesley Wexner. And I used to work in 3 about 20 different, 20.25 different homes in Palm Beach 4 as a maintenance guy. 5 Q. Okay. 6 A. And I have basically my own company and I do 7 repairs for them. I did home sit in for them. 8 Q. And what was -- did you work for Jeffrey 9 Epstein? What was your position when you started? 10 A. When I started, 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 and stuff that he didn't want to have it, -- 19 Q. 1 see. 20 A. -- fix it. 21 Q. And when you started working for Mr. Epstein, 22 were you still working for other people in Palm Beach? 23 A. Yes, I did. 24 Q. Okay. And about how long a period of time did 25 you do this type of work for Mr. Epstein, the 2 (Pages 5 to 8) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-878-2896) Electronically signed by Sandra Townsend (401.377.676.2896) 784afin4a-talcaldee-flec-479898“7004 EFTA00188911

Case 9:08-cv-80736-Ktuv. Document 291-17 Entered on FLS Jacket 01/21/2015 Page 4 of 8 Page 9 maintenance and taking out walls? 2 A. It was couple months. It was couple months 3 before. 4 Q. And what was the name of your company? 5 A. Alessi Maintenance. 6 Q. And how were you paid? 7 A. By him? 8 Q. Ycs. 9 A. Usually by check or cash sometimes. 10 Q. Do you know what company actually paid your 11 company? 12 A. It was Jeffrey Epstein and Company. 13 Q. So you said you had that position for a couple 14 of months. 15 What happened next? 16 A. Then Mr. Epstein asked me to, if I wanted to 17 be his employee, because I was going from one house tc 18 another house to another house, one hour here. I was 19 just running around Palm Beach all day. 20 So he asked me if I would just work for him, 21 exclusively for him. 22 Q. Okay. 23 A. And we agreed with the terms and I become a 24 full-time employee as a maintenance guy. And I was 25 taking care of everything, as far as maintenance. Page 11 1 about seven months before -- after I become a full-time 2 employee. 3 Q. Okay. And how did Ms. Maxwell come into the 4 picture? 5 A. It was his girlfriend, his main girlfriend. 6 Q. Okay. Had you known her before she became -- 7 A. No. 8 Q. -- your -- 9 A. Never know her before. 10 Q. I'm sorry. I didn't get a chance to finish my 11 question. 12 Would you have referred to her as your 13 supervisor or your superior or what would you have 14 called Mrs. Maxwell? 15 A. I used to call her Ghislaine. 16 Q. Okay. And how was it explained to you that 17 you were now to deal with Ms. Maxwell, as opposed to 18 Jeffrey Epstein? 19 A. She would tell me, I am going to take care of 20 the house. 21 Q. Okay. That was explained to you by 22 Ms. Maxwell? 23 A. Uh-huh. 24 Q. Is that a yes? 25 A. Yes. Page 10 1 Then my job changed little by little to house 2 man, estate manager, and then to a majordomo. 3 Q. Okay. When you first agreed to terms with 4 Mr. Epstein and you first started working for him full 5 time, what were those terms, do you remember? 6 A. The terms is basically was how much -- he 7 asked me how much I was making in all the properties. 8 And I says, well, I make this -- this amount 9 of money. 10 And he says, fine. 11 Q. And how much was that, did he pay you? 12 A. Around $45,000. I think I started with 45. 13 Q. Okay. And when you started to work for him as 14 a full-time employee, did you have anybody that you 15 reported to or did you deal directly with Mr. Epstein? 16 A. At the beginning with Mr. Epstein, directly to 17 him. 18 Q. Did that change? 19 A. Later on, yes. 20 Q. And how did that change? 21 A. When Ms. Maxwell, Ghislaine Maxwell came to 22 the picture. 23 Q. Okay. About when was it that she came into 24 the picture? 25 A. Exactly date, I cannot remember. But it was Page 12 1 Q. And when Ms. Maxwell started assuming 2 responsibility for the house, did your duties change at 3 that time? 4 A. Not much. 5 Q. Okay. 6 A. Not much. 7 Q. And at that time when Ms. Maxwell started 8 taking responsibility for the house, what were your 9 duties? 10 A. Basically I was still doing the maintenance 11 work. 12 Q. Okay. 13 A. Was doing -- they were trying to remodel the 14 home and they would told mc. okay. tear down this wall. 15 We want to see how it's going to look. Or put this 16 windows and tear down -- we had a fishing tank. We took 17 it out -- I took it out. A kitchen on the second floor. 18 I took it out. So it was basically dismantling the 19 house. 20 Q. Okay. And about how long a period of time did 21 that project last? 22 A. I would says, six to seven months. 23 Q. Okay. And after the remodeling slacked off or 24 stopped, did your duties then change? 25 A. Yeah. Increasingly they change. 3 (Pages 9 to 12) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401.377.676.2895) Electronically signed by Sandra Townsend (401.377.676.2896) 76ef6648-4a1c-kle447ac-479898cc7004 EFTA00188912

Case 9:08-cv-80736-KAiv, Document 291-17 Entered on FLt. Docket 01/21/2015 Page 5 of 8 Page 45 1 MS. EZELL: I'm going to ask -- I don't know 2 whether you've still been serially designating 3 Exhibits or whether we're doing them separately for 4 deposition. 5 MR. CRITTON: I think we cannot trust that 6 people will do them serially. I'd do them with 7 each one. 8 MS. EZELL: Then would you mark this, please, 9 as Exhibit I to this deposition. 10 And I'm just going to state on the record that 11 I will keep that original. We will not attach it 12 to the deposition. 13 (Exhibit number I was marked for 14 identification purposes and retained by Counsel for the 15 Plaintiffs.) 16 TI IE WITNESS: Yes, that's -- 17 BY MS. EZELL: 18 Q. Can you identify that -- the young woman in 19 those pictures? 20 A. Yes. 21 Q. Who is it? 22 A. That's'. -- I. Now that you says R., that 23 is M. definite, a hundred percent. 24 MR. CRITTON: Let me just note my objection, 25 as I did in A. Rod's deposition or Mr. Rodriguez's Page 47 1 2 3 4 5 6 8 7 10 11 12 13 14 ages -- 15 A. No. 16 Q. -- of the young women that came there? 17 A. Absolutely not. Absolutely not. 18 Q. And, so, you never really focused on that or 19 particularly thought about it if they seemed young? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't -- I didn't see that 22 many young girls, you know, young, underage girls 23 at the house. I never saw except the two girls 24 that I mentioned that I think it was underage was 25 N. for sure because she was still in high school. THE WITNESS: Could have been. But, you know I am not -- I don't think 1 am a very good judge of ages. If you ask me how old you arc. I really couldn't tell you. MR. CRITTON: Kathy thinks she's 25. MS. EZELL: In my dreams. TIIE WITNESS: Now, again. I must tell you, I was never told to check any i.d.s on any of the people who work at the house. BY MS. EZELL: Q. I understand that. And. so. I think I'm just trying to establish that you didn't consider it part of your job description to worry about or consider the Page 46 1 deposition, that I know you're going to confiscate 2 Exhibit number I. I think it's inappropriate. I 3 think I should be allowed to have a copy of 4 Exhibits that arc being used in deposition. But S I'll file a motion with the Court so we don't get 6 into a pulling match over your Exhibits. 7 MR. BERGER: I would ask that the court 8 reporter initial that. 9 MS. EZELL: Sure. 10 Oh, you did? 11 MR. WILLITS: She marked it. 12 MR. BERGER: Did she put her initials or did 13 she just put a number or a letter? 14 MR. CRITTON: She's nodding that she did 15 everything that she usually does, which means, 16 initials, date and number. 17 MR. MERMELSTEIN: You can talk. 18 MR. WII.LITS: But when you talk, use your 19 initials. 20 BY MS. EZELL: 21 Q. How old did you think M. was at the time she 22 began coming to Mr. Epstein's home? 23 A. She could have been 17, 18, 19. 24 Q. Could she have also been 15? 25 MR. CRITTON: Form. Page 48 1 And she -- she had dinner with her mother, a couple 2 times with her mother. And she become an actress. 3 She's an actress and she has done movies. And he 4 help her in her career. 5 That's the only girl that I knew she was young 6 because she was going to high school and I pick her 7 up from high school sometimes. But she was not a 8 massage therapist. She will go for dinner. And 9 they will go for the movies and she sang sometimes 10 because she was a singer. So she sung at the 11 house. Beautiful girl. Very talented. 12 That's the only girl that I know that it 13 was -- I would says, underage. 14 BY MS. EZELL: 15 Q. Okay. Did -- who told you that was a 16 massage therapist? 17 A. Nobody. 18 Q. Did you assume that she was a massage 19 therapist because you were told 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 girl,,., 12 (Pages 45 to 48) PROSE COURT Electronically signed by Sandra Townsend (401.377.676-2895) Electronically signed by Sandra Townsend (401-377.676.2895) REPORTING AGENCY, INC. 76e1564a4a1c-4dee-B7ac-479898cc7004 EFTA00188913

Case 9:08-cv-80736-KAlvi Document 291-17 Entered on FLS,. Docket 01/21/2015 Page 6 of 8 Page 69 1 MR. CRITTON: Fonn. 2 THE WITNESS: No, not that I can remember. 3 BY MS. EZELL: 4 Q. Do you know if he and Mr. Epstein were 5 involved in any businesses together? 6 A. Mr. Epstein, I never knew what businesses he 7 was involved. He will -- I was completely shut off of 8 all of the business, except for the office, transfer of 9 communications or faxes. But I have no idea of the 10 relationship with other business partners. 11 Q. Did you ever have to deal with his -- the 12 office in New York with someone named Lesley in New 13 York? 14 A. The secretary? 15 Q. Yes. 16 A. Yeah. I would call -- I would call Lesley 17 almost every day or other secretaries, they live in New 18 York. Basically it came a point when Mr. Epstein will 19 call New York and New York call me to do things for 20 Mr. Epstein. But he was on the phone or busy or 21 something and he would call the office and the office 22 will send me an c-mail or call me or -- it was a 23 constant report with the office in New York. 24 Q. And did you in turn sometimes call New York to 25 get a message to Mr. Epstein? 1 2 3 4 5 6 8 7 10 11 12 13 14 15 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 else? I don't think I can remember anymore. Q. David Copperfield, the magician? A. No, I never saw him. Q. You never saw him. Now, would these -- the people that you named were all people that you saw visiting in the home? A. Yes. Also was a Noble Prize winners, the -- I can't remember his name. It was an old gentleman. He was a Noble Prize, chemistry, I think, or mathematics. There was a couple -- a couple of those, very -- also, we had at one time at the house, it was a reunion of very Noble Prize winners. But I don't know. They're not famous, I guess. I can't remember their names. Very important people. Q. Was that a dinner or a reception? A. I think it was a lunch. Q. A lunch. President Clinton, did you ever -- Page 70 1 A. Yes. 2 Q. Did you ever overhear Mr. Epstein talking to 3 any people that you would consider celebrities? 4 A. Yes. I knew some -- many celebrities. 5 Q. Who -- what celebrities did you understand 6 that he spoke with? 7 A. He spoke to it? 8 Q. Ycs. 9 A. I don't know who he spoke to because I never 10 listen to his conversations. But I saw guests at the 11 house that were celebrities. 12 Q. Who did you see at house? 13 A. Many. It was senators. It was Senator 14 Mitchell. George Mitchell. It was Prince Andrew. It 15 was Princess Sarah. 16 Q. Princess? 17 A. Sarah. the wife of Andrew. 18 Q. Sarah Ferguson? 19 A. Ferguson. 20 And it was a couple Misses. Misses Yugoslavia, 21 Miss Germany that I don't even know the names. But they 22 were a lot of queens and other famous people that I 23 can't remember. It was a very famous lawyers that I'm 24 sure you know. Alan Dershowitz, who spend at the house 25 couple times. And he slept them. Ile -- Princess Page 72 1 A. I met President Clinton on Mr. Epstein's plane 2 in the last, I think it was the last month or just 3 before I left -- I left. I met President Clinton in 4 Miami at his plane. We drove him to Miami. 5 Q. And do you know, was that a trip -- were they 6 going on a trip to Africa? 7 A. I hear about it, but it was not when I was 8 there. 9 Q. So that was not the time that you drove -- 10 A. No, I was already out. 11 Q. And Kevin Spacey, did you ever meet him? 12 A. No. I hear about it on the news, but I never 13 met him. 14 Q. Were Prince Andrew and Princess Sarah friends 15 of Ms. Maxwell? 16 A. Both of them. 17 Q. Both Ms. Maxwell and Mr. Epstein? 18 A. Yeah. 19 Q. Did -- did they ever have massages when they 20 were there? 21 A. Prince Andrew did. I think Sarah was there 22 only once and for a short time. I don't think she slept 23 in there. I cannot remember. I think she was visiting 24 Wellington and she came to the house and we met her. 25 But Prince Andrew, yes, Prince Andrew spent weeks with 18 (Pages 69 to 72) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401.377.678.2895) Electronically signed by Sandra Townsend (401-377478-2895) 76e1564a-4a1c-4dee-87ac-479898cc7004 EFTA00188914

Case 9:08-cv-80736-KAIvi Document 291-17 Entered on FLL.. Docket 01/21/2015 Page 7 of 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 73 us. Q. Where would he sleep? A. In the main room, the main guest bedroom. That was the blue room. Q. And, so, when he would come and slay, during that time would he frequently have massages? MR. CRITTON: Form. THE WITNESS: I would says, daily massages. They have a daily massage. BY MS. EZELL: Q. Was it sometimes more than one a day? A. I can't remember if he had more than one, but I think it was just a massage for him. We set up the tables and -- Q. Do you have any recollection oft. coming to the house when Prince Andrew was there? A. It could have been, but I'm not sure. Q. Not sure. When Mr. Dershowitz was visiting, -- A. Uh-huh. Q. -- how often did he come? A. He came pretty -- pretty often. I would says, at least four or five times a year. Q. And how long would he stay typically? A. Two, three days. Page 75 1 MR. LANGINO: Go ahead. Sure. 2 BY MS. EZELL: 3 Q. You said that you set up the massage tables. 4 And would you also set up the oils and the towels? 5 A. Yes, ma'am. 6 Q. And I think I read one time you said they used 7 40 or 50 towels a day? 8 MR. CRITTON: Form. 9 THE WITNESS: That's correct. There was a 10 tremendous amount of work in the house, especially 11 laundry towels, because they were -- we have 12 towels, piles of towels. And they use in the pool. 13 There was a lot of people in the pool and there 14 were a towel that went in the floor, we have to go 15 and pick it up, wash it. So it was — it was a lot 16 of towels, yes. 17 BY MS. EZELL: 18 Q. And did you ever have occasion to go upstairs 19 and clean up after the massages? 20 A. Yeah, uh-huh. 21 Q. Did you ever find any vibrators in that area? 22 A. Yes. I told him, yes. 23 MS. EZELL: And did you ask that? I'm sorry. 24 MR. CRITTON: Ycs. 25 MS. EZELL: I don't know how I missed that. Page 74 1 Q. Did he have massages sometimes when he was 2 there? 3 A. Yes. A massage was like a treat for 4 everybody. If they want it, we call the massage and 5 they have a massage. 6 Q. Now, Mr. Trump had a home in Palm Beach, 7 correct? 8 A. Uh-huh. 9 Q. So he didn't come and stay there, did he? 10 A. No, never. 11 Q. He would come for a meal? 12 A. He would come, have dinner. He never sat at 13 the table. He eat with me in the kitchen. 14 Q. Did he ever have massages while he was there? 15 A. No. Because he's got his own spa. 16 Q. Sure. 17 MS. EZELL: I don't have any other questions 18 right now. I'd just like to reserve if something 19 comes up to ask. But, otherwise, you may go ahead. 20 MR. LANGINO: It is noon, so I don't know what 21 everybody else's schedule is. I don't know how 22 you're feeling. 23 THE WITNESS: I am fine. 24 MS. EZELL: I do have another question. May I 25 ask it? Page 76 1 BY MS. EZELL: 2 Q. Since I did miss it, if you don't mind, let me 3 just ask you again. 4 Would you describe for me what kinds of 5 vibrators you found? 6 A. I'm not familiar -- not too familiar with the 7 names, but they were big dildos, what they call the big 8 rubber things like that (indicating). And I used to go 9 and put my gloves on and pick them up, put them in the 10 sink, rinse it off and put it in Ms. Maxwell -- 11 Ms. Maxwell had in her closet, she had, like, a laundry 12 basket, one of those laundry basket that you put laundry 13 in. She have full of those toys. And that was -- and 14 that was me being professional, leaving the room ready 15 for bed when he would come back to the room again. 16 Q. Okay. 17 A. That happened a few times, few times. 18 Q. Were there other sex toys that you found in 19 the area -- 20 A. No. 21 Q. -- sometimes? You mentioned she kept them in 22 a basket in her closet? 23 A. She kept them in her basket. She had some 24 videos there and she have a costume there. I know that 25 she bought it, that she brought it with her. 19 (Pages 73 to 76) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401377476.2895) Electronically signed by Sandra Townsend (401-377-676-2895) 76ef564a4a1e-4doe-87ac-479898cc7004 EFTA00188915

Case 9:08-cv-80736-KAivi Document 291-17 Entered on FLL., Docket 01/21/2015 Page 8 of 8 Page 77 1 Q. What kind of costume? 2 A. I don't know. It was a black, shiny costume. 3 I never saw it on her. 4 Q. Was it leather? 5 A. No. I think it was like a vinyl. But we were 6 very fussy about touching any of that stuff. We just... 7 MS. EZELL: No other questions. Thank you, B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 sir. THE WITNESS: You're welcome. MR. LANGINO: I shouldn't have more than a half hour's worth of questions, if everybody is okay to power through. MR. BERGER: I probably have a half hour to an hour. MR. LANGINO: Okay. MR. BERGER: Unless you cover what I cover. MR. MERMELSTEIN: I could say the same thing, so probably less than that. MR. LANGINO: So I guess my question is -- MR. BERGER: I think we ought to take a break. MR. LANGINO: That was my question. MR. BERGER: We're going to take a break. Do you have any problem with that? THE WITNESS: No. Whatever you guys want to do. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 79 CERTIFICATE OE OATH STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that JUAN ALESSI personally appeared before me and was dul sworn on the 8th day of September, 2009. Dated this 19th day of September. 2009. ciaMtlikl VV aAA est/ Sandra W. Townsend, Court Reporter Notary Public - State of Florida My Commission Expires: 6/26/12 My Commission No.: DD 793913 2 3 4 5 6 7 8 9 0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Lunch recess.) (Continued to Volume II.) Page 78 CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 Sandra W. Townsend. Cow Reporter and Notary Public in and for the State of Florida at Large. 6 do hereby certify tint the aforementioned witness was by me first duly sworn to testify the whole trutli. that I 7 was authonzed to and did report said deposition in stenotype; and that the foregoing pages numbered Ito a 78. inclusive. are a nue and correct transenption of my shorthand notes of said deposition. I further certify that said deposition was 10 taken at the time and place htteinabove set forth and Mal the taking of said deposition was commenced and 11 completed as hereinabove set out. 12 I further certify that lam not attorney or counsel of any of the parties. nor am I a relative or 13 employee Many attorney or counsel of party connected with the action. nor am I financially interested in the 14 84,808. 16 The foregoing certification of this transcript does not apply to any reproduction of the same by any 16 means unless under the direct control and/or direction of the certifying reposer. 9 17 18 19 20 Dated this 19th day of September. 2009. 21 22 21 24 25 Sandra W Townsend, Cowl Reposer Page 80 20 (Pages 77 to 80) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676.2896) Electronically signed by Sandra Townsend (401-377.676.2895) 7640564.4alcakkke-87m47989Occ7004 EFTA00188916

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Case 9:08-cv-80736-KAm Document 291-18 Entered on FL- _, Docket 01/21/2015 Page 1 of 14 EXHIBIT 19 EFTA00188918

Case 9:08-cv-80736-KfrA Document 291-18 Entered on FL—J Docket 01/21/2015 Page 2 of 14 1 2 Page i UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 3 JANE DOE NO. 2, Case No: 08-CV-80119 4 Plaintiff, 5 Vs 6 JEFFREY EPSTEIN, 7 Defendant. / 8 JANE DOE NO. 3, Case NO: 08-CV-80232 9 10 Plaintiff, Vs 11 JEFFREY EPSTEIN, 12 Defendant. / 13 JANE DOE NO. 4, Case No: 08-CV-80380 14 15 Plaintiff, Vs. 16 17 JEFFREY EPSTEIN, Defendant. 18 / 19 JANE DOE NO. 5, Case No: 08-CV-80381 20 Plaintiff, 21 Vs 22 JEFFREY EPSTEIN, 23 Defendant. / 24 25 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188919

Case 9:08-cv-80736-Kt,ivi Document 291-18 Entered on FL—J Docket 01/21/2015 Page 3 of Page 2 Page 4 i JANE DM NO. 6, Case No: 08EV-80994 1 VIDEOTAPED 2 Plaintiff, 2 DEPOSITION 3 Vs 3 of 4 JEFFREY EPSTEIN, 4 ALFREDO RODRIGUEZ 5 Defendant. 5 / 6 taken on behalf of the Pleintiffs pursuant 6 7 to a Re•Notice of Taking Deposition (Duces return) JANE DOE NO. 7, Case No. 08-CV-B0993 8 7 9 ... Plaintiff, 10 APPEARANCES: 8 II Vs MERMELSTEIN & HOROWITZ, P.A. 9 12 BY: STUART MEFtMELSTEIN, ESQ. 10 JEFFREY EPSTEIN, Defendant il I 14 Attorney on ane 2, 3, 4, 5, 12 13 C.M.A., Case No: 08U40811 Plaintiff, 6, and 7. II Vs IS 15 JEFFREY EPSTEIN, 16 ROTHSTEIN ROSENFELDT ADLER 16 Defendant. BY: BRAD J. EDWARDS, ESQ., and / 17 CARA HOLMES E 17 JANE ME, Case No: 08-CV-80893 18 19 Plaintiff, Attoa or Jane Doe an Vs 20 20 21 21 JEFFREY EPSTEIN, 22 POOHURST ORSECX BY: KATHERINE W. EZELL Defendant. 22 / I 23 24 24 Attorney ane 101 and 102. 25 25 Page 3 Page 5 1 JANE DOE NO. II, Case No: 08-CV-80969 1 2 Plaintiff, APPEARANCES: 3 Vs 2 4 3 LEOPOLD-KLNIN JEFFREY EPSTEIN, 5 Defendant. 4 SQ. I 6 I JANE DOE NO. 101, Case No: 09-CV-80591 Attorney or 7 6 Plaintiff, 7 T 8 Vs 8 9 9 Attorney or . A JEFFREY EPSTEIN, to 10 BURMAN, LLITTIER & Defendant. I I L IPTON, C COLEMAN, IP 11 i Y. RT CCITT N ESQ. 12 JANE DOE NO. 102, Case No: 09-CV-80656 12 13 14 IS Plaintiff, Vs JEFFREY EPSTEIN, 13 Attorney o• /e ley pst n. 16 Defendant. :.: / It 17 ALSO PRISENI: 18 17 19 JOE IANGSAM, VIDEOGRAPHER 20 18 19 ■ 20 22 11:00 a.m. to 5:30 p.m. 21 22 23 23 24 24 25 25 2 (Pages 2 to 5) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188920

Case 9:08-cv-80736-10-vi Document 291-18 Entered on FL-...) Docket 01/21/2015 Page 4 of 4 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 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 2 missing which Jane Doe this is. 3 They're all different case numbers. Do 4 you want me to go through each case number? 5 MR. CRITTON: I'm going to note my 6 objection. Obviously if this deposition 7 gets played -- not obviously, I'm going to 8 object to the litany of each one so I don't 9 know how we can separate it out. Maybe if 10 and when at the time of trial and depending 11 on how the Court determines what comes in 12 and what doesn't with regard to the 13 consolidated aspects of this. I have no 14 great idea other than just saying Jane Doe 15 versus Epstein, et al, or something like 16 that, or Jane Doe, et al. 17 MS. EZELL: Couldn't we just say and 18 those cases which have been consolidated 19 with it for Discovery purposes? 20 MR. EDWARDS: Although there is cases 21 here that have cross noticed this from state 22 court that haven't been consolidated so that 23 may not work. You may have to read them 24 all, if it works out your way that will just 25 get edited out, at least he will have read 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 7 Deposition taken before PAYNE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is the case of Jane Doe No. 2, plaintiff, versus Jeffrey Epstein, defendant. Jane Doe No. 3, plaintiff, versus Jeffrey Epstein, defendant. Jane Doe No. 4, plaintiff, versus Jeffrey Epstein, defendant. And Jane Doe No. 5, plaintiff, versus Jeffrey Epstein, defendant. Jane Doe No. 6, plaintiff, versus Jeffrey Epstein, defendant. Jane Doe No. 7, plaintiff, versus Jeffrey Epstein, defendant. CMA, plaintiff, versus Jeffrey Epstein, defendant. And Jane Doe, plaintiff, versus Jeffrey Epstein, et al, defendant. And Jane Doe -- is there a shorter thing that we can do here? It's also missing this one right here. MR. MERMELSTEIN: Do we have a problem with saying Jane Doe 2 and the Epstein and related cases? THE VIDEOGRAPHER: I'm missing this Jane Page 9 1 that caption, every caption. Right? Is 2 there a better suggestion? 3 MR. CRITTON: No. There may be a better 4 suggestion if he starts this is such and 5 such day, it's the deposition of Mr. 6 Rodriguez in the case such and such, and we 7 can almost fill it in depending on which 8 tape it goes, how it fills in, at least 9 well have the context of the first and 10 depending on whether the Judge reads it in 11 from a consolidated or they all come 12 related, I have no great idea. 13 MR. EDWARDS: I was thinking if he read 14 every one of them and it was the seventh in 15 line then you just would edit it so you 16 would only read that one. 17 MR. CRITTON: I'm okay with that too. 18 THE VIDEOGRAPHER: On page number three 19 there is something missing on the top here. 20 Do you want me to read each case number 21 separately? 22 MR. MERMELSTEIN: I don't think it's 23 necessary. 24 MR. EDWARDS: I don't think it's 25 necessary either. 3 (Pages 6 to 9) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188921

Case 9:08-cv-80736-K,..A Document 291-18 Entered on FL. J Docket 01/21/2015 Page 5 of 14 Page 10 1 THE VIDEOGRAPHER: So just go through 2 just the names. 3 MR. MERMELSTEIN: That's sufficient. And 4 there is a cross notice for one of the state 5 cases? 6 MR. LANGINO: That would be our case. 7 MR. MERMELSTEIN: So he's got that 8 notice? Off the record. 9 (Thereupon, a discussion was held off the 10 record.) 11 THE VIDEOGRAPHER: This is the case of 12 Jane Doe No. 2, plaintiff, versus Jeffrey 13 Epstein, defendant. Jane Doe No. 3, 14 plaintiff, versus Jeffrey Epstein, 15 defendant. Jane Doe No. 4, plaintiff, 16 versus Jeffrey Epstein, defendant. Jane Doe 17 No. 5, plaintiff, versus Jeffrey Epstein, 18 defendant. Jane Doe No. 6, plaintiff, 19 versus Jeffrey Epstein, defendant. Jane Doe 20 No. 7, plaintiff, versus Jeffrey Epstein, 21 defendant. CMA, plaintiff, versus Jeffrey 22 Epstein, defendant. Jane Doe, plaintiff, 23 versus Jeffrey Epstein, et al, defendant. 24 Jane Doe 3, plaintiff, versus Jeffrey 25 Epstein, et al, defendant. Jane Doe No. Page 12 1 Jeffrey Epstein. 2 MR. WILLITS: Richard Willits on behalf 3 of plaintiff C.M.A. 4 MR. EDWARDS: And Brad Edwards on behalf 5 of plaintiffs M. and M. 6 Thereupon, 7 ALFREDO RODRIGUEZ, 8 having been first duly sworn or affirmed, was 9 examined and testified as follows: 10 DIRECT EXAMINATION 11 BY MR. MERMELSTEIN: 12 Q. Can you state your full name for the 13 record, please? 14 A. My name is Alfredo Rodriguez. 15 Q. And where do ou live? 16 A. I live in 18 Q. Are you currently employed? 19 A. No. 20 Q. Okay. When was the last time you were 21 employed? 22 A. December of 2008. 23 Q. Was there a time you were employed in 24 Palm Beach, Florida? 25 A. Yes, I was. Page 11 1 101, plaintiff, versus Jeffrey Epstein, 2 defendant. Jane Doe No. 102, plaintiff, 3 versus Jeffrey Epstein defendant. •, 4 plaintiff, versus Jeffrey Epstein, 5 defendant. 6 This is in the Circuit Court of the 15th 7 Judicial Circuit in and for Palm Beach 8 County, Florida. 9 This is the deposition of Alfredo 10 Rodriguez. Today is July the 29th, starting 11 time -- the year 2009, starting time 12 approximately 11:16 a.m. 13 Will attorneys please state their 14 appearance? 15 MR. MERMELSTEIN: Stuart Mermelstein for 16 plaintiffs Jane Doe 2, Jane Doe 3, Jane Doe 17 4, Jane Doe 5, and Jane Doe 6, and Jane Doe 18 7. 19 MR. EDWARDS: Brad Edwards for plaintiff 20 Jane Doe. 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 several employers 5 in Palm Beach. One of them was Jeffrey Epstein. 6 Q. By several employers in Palm Beach you 7 mean -- 8 A. Different employers. 9 Q. At the same time? 10 A. No, different times. From 2005 to 2006 I 11 was employed by Dana Hammond. 12 Q. Donna Hammond? 13 A. D-A-N-A, Hammond. Or Aimes is her single 14 name. Dana Aimes Hammond. 15 Q. Dana Aimes Hammond? 16 A. Yeah. 17 Q. That was in Palm Beach? 18 A. Yes. 19 Q. And in September 2004 you were employed 20 by whom? 21 A. Jeffrey Epstein. 22 Q. Did Mr. Epstein employ you as an 23 individual or through any business or corporate 24 entity? 25 A. As an Individual. 4 (Pages 10 to 13) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188922

Case 9:08-cv-80736-I(..../I Document 291-18 Entered on FL—J Docket 01/21/2015 Page 6 of Page 194 Page 196 1 Q. Sure, go ahead and answer however you 1 A. No, exactly. 2 want. 2 MR. CRITTON: Form. 3 MR. CRITTON: Form. 3 BY MR. EDWARDS: 4 THE WITNESS: I don't think it was right. 4 Q. I think that the next time you're 5 BY MR. EDWARDS: 5 mentioned in the report, I believe it's page 70. 6 Q. Did you ever voice that opinion that you 6 MS. EZELL: Off the record briefly. 7 didn't think that it was right that these young 7 (Thereupon, a discussion was had off the 8 girls were over behind dosed doors upstairs with 8 record.) 9 Mr. Epstein In his bedroom? 9 BY MR. EDWARDS: 10 MR. CRITTON: Form. 10 Q. Page 64. It says, Alfredo Rodriguez 11 THE WITNESS: I been asked that question 11 resides in Miami had eluded, meaning you were 12 before. 12 trying to evade or avoid service of process 13 BY MR. EDWARDS: 13 servers previously and was not served the 14 Q. Excuse me? 14 investigative subpoena. 15 A. I been asked that question before. 15 This is an investigator saying you just 16 Q. By whom? 16 weren't home or something. Right? 17 A. Palm Beach Police Department. 17 A. But I never elude anybody. 18 Q. Did you give the same answer that you did 18 Q. You never intentionally tried to avoid 19 not think it was right? 19 the police officers? 20 MR. CRITTON: Form. 20 A. No, no, never. 21 THE WITNESS: Yes. 21 Q. Okay. 22 BY MR. EDWARDS: 22 MR. CRITTON: So much for the police 23 Q. And what about it to you aside from the 23 report. 24 fact that you had a daughter roughly the same age, 24 BY MR. EDWARDS: 25 what besides that told you that it wasn't right? 25 Q. All right. The bottom of page 70 says, I Page 195 Page 197 1 MR. CRITTON: Form. 1 brought Mr. Rodriguez to the interview room. 2 THE WITNESS: Ask me your question again. 2 Were you taken to an interview room, to a 3 BY MR. EDWARDS: 3 room in the police department? 4 Q. My question is, why is it your opinion 4 A. This was in the District Attorney's 5 that it wasn't right for these young girls to be 5 Office. 6 up in Mr. Epstein's -- 6 Q. Oh, it was at the State Attorney's 7 A. It wasn't. 7 Office? 8 MR. CRITTON: Form. 8 A. Yes. 9 BY MR. EDWARDS: 9 Q. Okay. Was a State Attorney there as 10 Q. It wasn't right? 10 well? 11 A. It wasn't. 11 A. Yes, Mrs. Weiss. 12 Q. And why not? 12 Q. Daliah Weiss? 13 MR. CRITTON: Form. 13 A. Young lady, Weiss. D-E-I-S-S. 14 THE WITNESS: Because I'm a father, I 14 Q. Okay. I have D-A-L-I-A-H, Daliah Weiss, 15 have two daughters. 15 W-E-I-S-S. 16 BY MR. EDWARDS: 16 A. Yes. 17 Q. And given Mr. Epstein's wealth and power 17 Q. That's her? 18 and influence, is that something that you as a 18 A. Yeah. 19 father could have seen your daughters doing at 19 Q. Okay. Did she ask you any questions? 20 that age? 20 A. Both of them. 21 MR. CRITTON: Form. 21 Q. Okay. So it was both -- if there is a -- 22 THE WITNESS: I don't think that my 22 I think you said earlier there is a taped 23 daughters would be doing that. 23 statement, there is a tape of this? 24 BY MR. EDWARDS: 24 A. Yes. 25 Q. You would hope not. 25 Q. If we listen to that tape if we ever get 50 (Pages 194 to 197) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188923

Case 9:08-cv-80736-K. .A Document 291-18 Entered on FL-0 Docket 01/21/2015 Page 7 of 4 Page 198 1 that tape it's going to be Assistant Attorney 2 Weiss and Detective Recarey asking questions? 3 A. Yes. 4 Q. It says, during the sworn taped statement 5 Mr. Rodriguez stated he was employed by Jeffrey 6 Epstein for approximately six months. 7 I think we already talked about that. 8 I'm skipping ahead a little bit. 9 If Rodriguez needed to relay a message to 10 Epstein he would have to notify Epstein's 11 secretary Lesley in New York who would then notify 12 Epstein's personal assistant Sarah who would relay 13 the message to Epstein. 14 A. Yeah. 15 MR. CRITTON: Form. 16 BY MR. EDWARDS: 17 Q. That's pretty much the process you 18 described? 19 A. Yes, it was normal procedure. 20 Q. Rodriguez stated Epstein did not want to 21 see or hear the staff when he was in the 22 residence? 23 MR. CRITTON: Form. 24 THE WITNESS: That's correct. 25 BY MR. EDWARDS: Page 200 1 friends, I will say, yeah. 2 Q. Then you mentioned that you typed into 3 Google, I guess you Googled Prince Andrew and Bill 4 Clinton. Why would you pick those names, were 5 they associated with Mr. Epstein? 6 A. Yes. 7 Q. And what is your understanding as to how 8 Prince Andrew is associated with Jeffrey Epstein? 9 A. Because there were pictures with him 10 together. 11 Q. In the house? 12 A. Yes. 13 Q. Many pictures or are we talking about 14 one? 15 A. Many pictures. 16 Q. Were these pictures that looked that 17 appeared to be at social events, at Mr. Epstein's 18 house or where? 19 A. Mrs. Maxwell took him to England to 20 introduce him to the royalty. 21 Q. Is it's your understanding that Ghislaine 22 Maxwell knew Prince Andrew and introduced -- 23 A. Yes. 24 Q. Is it also your understanding that at 25 some point in time Ghislaine dated or had a Page 199 I Q. That's something you agree with? 2 A. Yes. 3 MR. CRITTON: Form. 4 BY MR. EDWARDS: 5 Q. Rodriguez advised Mr. Epstein had many 6 guests. 7 In addition to the girls who are roughly 8 C. and T. age who had come to the house to have a 9 good time, who were some of the other guests that 10 you know of, if you know their name? 11 MR. CRITTON: Form. 12 THE WITNESS: I mentioned Alan 13 Dershowit. 14 BY MR. EDWARDS: 15 Q. That's a lawyer from Harvard? 16 A. Yes. The magician, David Copperfield, 17 some other lawyers from New York, you know. There 18 were some other guests. 19 Q. And how frequently would these other 20 guests come over? 21 A. Once a month, something like that. 22 Q. Okay. So If it's only once a month and 23 you were only there six months you're saying you 24 only saw six guests come over In addition to -- 25 A. They have people, you know, they have Page 201 1 romantic relationship with Prince Andrew? 2 MR. CRITTON: Form. 3 THE WITNESS: I don't know that. 4 BY MR. EDWARDS: 5 Q. Do you know around what time period it 6 was that Mr. Epstein was introduced to Prince 7 Andrew? 8 A. 2003, I believe. 9 Q. How do you know that? 10 A. I've heard dates. 11 Q. From people in the Epstein group? 12 A. Yes. 13 Q. Okay. 14 MR. CRITTON: Let me note my objection, 15 move to strike, it's based on -- his 16 testimony is based on hearsay. 17 BY MR. EDWARDS: 18 Q. During the six month period of time when 19 you worked directly for Mr. Epstein, how often did 20 Mr. Epstein get together with or hangout with 21 Prince Andrew; if you know? 22 A. I didn't see him once. 23 Q. You never saw Prince Andrew at the house? 24 A. No, no, he called. 25 Q. I'm sorry, how often would he call? 51 (Pages 198 to 201) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188924

Case 9:08-cv-80736-K. „1 Document 291-18 Entered on FL.") Docket 01/21/2015 Page 8 of 14 2 3 4 Page 270 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO: 08-CV-80119 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant. 8 9 JANE DOE NO. 3, CASE NO: 08-CV-80232 10 Plaintiff, Vs. CONDENSED 11 12 JEFFREY EPSTEIN, 13 Defendant. 14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. 19 20 JANE DOE NO. 5, CASE NO: 08-CV-80381 21 Plaintiff, 22 VS 23 JEFFREY EPSTEIN, 24 Defendant. 25 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188925

Case 9:08-cv-80736-K. .../1 Document 291-18 Entered on FL_ J Docket 01/21/2015 Page 9 of 14 Page 271 1 JANE DOE NO. 6, CASE NO: 08-CV-80994 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant 6 JANE DOE 110. 7, CASE IC: 08CV•80993 7 Pain" 8 Vs. 9 JEFFREY EPSTEIN, 10 Defendant. 11 12 C.M.A., CASE NO: 08CV-80811 13 Ptaindff, 14 Vs. 15 JEFFREY EPSTEIN, 16 Defendant. 17 JANE DOE, CASE NO: 06-0/.80893 18 Mkt" 19 Vs. 20 JEFFREY EPSTEIN, 21 Defendant. 22 13 24 25 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR 2 PALM BEACH COUNTY, FLORIDA 3 CASE NO. 502008CA037319)COCXMB AB 4 B.B., S Plaintiff, 6 Vs. 7 JEFFREY EPSTEIN. 8 Defendant. 9 10 11 12 1031 Ives Dairy Road Suite 228 13 North Miami, Florida August 7, 2009 14 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 of 20 ALFREDO RODRIGUEZ 21 22 taken on behalf of the Plaintiffs pursuant 23 to a Re-Notice of Taking Continued Videotaped 24 Deposition (Duces Tecum) 25 - - • Page 273 Page 272 1 JANE DOE NO. II, CASE NO: 08-CV-80469 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant. JANE DOE NO. 101 CASE NO: 08-CV-80591 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant 11 12 JANE DOE NO. 102, CASE NO: 08-CV-80656 13 Plaintiff, 19 Vs. 15 JEFFREY EPSTEIN, 16 Defendant. 6 7 8 9 10 17 18 19 20 21 22 23 29 25 1 APPEARANCES: 2 3 MERME€STEIN & HOROWITZ, PA 5 omeg or ane 2, 3, 4, 5, 6 6, and 7. 7 8 ROTTSIFIN ROSENFELDT AMER ESQ. and 9 10 11 • nor orJane an 12 And 13 14 PCOHURST ORSEOC 15 IligiCLL, ESQ. 16 me/ or ne 101 and 102. 17 18 tEOPOLD-KUVIN IS ESQ. 20 21 rney or 22 23 24 25 Page 274 2 (Pages 271 to 274 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188926

Case 9:08-cv-80736-Kr,i0 Document 291-18 Entered on FL. J Docket 01/21/2015 Page 10 of 14 1 APPEARANCES: 2 3 I 6 7 8 ARD W LUIS ESO. nomey forC.M.A. Appeared via telephone. BURMAN, CRITTON, RIMER & COLEMAN, LLP ESQ. 9 or 11 12 13 ALSO PRESENT: 14 3OE LANGSAM, VIDEOGRAPHER 15 16 17 18 19 20 21 22 23 24 25 Page 275 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 277 Deposition taken before AYNE, Court 1 6PDAYNE, Reporter and Notary Pub n an r the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is a continuation of the deposition of Alfredo Rodriguez. Today is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in the witness? Thereupon, ALFREDO RODRIGUEZ, having been first duly sworn or affirmed, was examined and testified as follows: MR. CRITTON: Before we get started just with regard to Ms. Ezell represents Jane Doe 101 and 102, the alleged time of her Incidents as of least have been plead In the complaint for 101 is '99 -- I'm sorry, '98 through 2002, with Jane Doe 102 the Spring of -- Spring/Summer of 2003. Mr. Rodriguez never even began employment until '04 and '05. I think her questioning I think -- I can't say she doesn't have standing based on the court order, but I would say It's 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 as CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ (By Ms. Ezell) 278 441, 467 (By Mr. Willits) 334 453, 469 (By Mr. Crltton) 338 464 (By Mr. Edwards) 419, 459, 468 (By Mr. Langlno) 452 CONTINUED INDEX OF EO118115 PlAINTIFFS PAGE 3 Drawing 315 Photograph 327 5 Photograph 331 6 Photograph 331 7 Photograph 331 8 Photograph 331 9 Report 446 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. Ezell.) Page 276 Page 278 1 completely irrelevant and immaterial and has 2 no probative value 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 clients whose 8 cases have not been filed and I believe we 9 do have standing to ask questions, and I do 10 intend to do that today. 11 EXAMINATION 12 BY MS. EZELL: 13 Q. Mr. Rodriguez, you stated last time that 14 there were guests at the house, frequent guests, 15 friends from Harvard. 16 Do you remember that testimony? 17 A. Yes, ma'am. 18 Q. And was there a lawyer from Harvard named 19 Alan Dershowitz? 20 A. Yes, ma'am. 21 Q. And are you familiar with the fact that 22 he's a famous author and famous lawyer? 23 A. Yes, ma'am. 24 Q. How often during the six months or so 25 that you were there was Mr. Dershowitz there? 3 (Pages 275 to 278 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188927

Case 9:08-cv-80736-K,..4I Document 291-18 Entered on FL.....L.) Docket 01/21/2015 Page 11 of 14 Page 279 1 A. Two or three times. 2 Q. And did you have any knowledge of why he 3 was visiting there? 4 A. No, ma'am. 5 Q. You don't know whether or not he was a 6 lawyer -- acting as a lawyer or whether he was 7 there as a friend? 8 A. I believe as a friend. 9 Q. Were there also young ladies in the house 10 at the time he was there? 11 MR. CRITTON: Form. 12 THE WITNESS: Yes, ma'am. 13 BY MS. EZELL: 14 Q. An a have Included for 15 instance, and 16 A. Yes, ma am. 17 Q. Were there other young ladles there when 18 Mr. DershowItz was there? 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 BY MS. EZELL: 22 Q. Do you have any idea who those young 23 women were? 24 A. No, ma'am. 25 Q. Were any of those the young women that Page 281 1 Q. Can you tell me where those were? 2 A. One in the kitchen, and the one in the 3 formal -- the main entrance. And there was one 4 more added later on, but there is two when I was 5 working there. 6 Q. Could you just give me a rough sketch of 7 the house of where the main entrance was and where 8 the kitchen was? 9 A. I'm not an architect but It's something 10 like this. This is the kitchen, this Is the main 11 entrance. 12 Q. Will you mark the kitchen with a K, 13 please, and the main entrance with ME? 14 A. This Is the pool. 15 Q. The pool? 16 A. Yes, ma'am. 17 Q. And In the upper left? 18 A. In the terrace, yeah, there was a balcony 19 here. 20 Q. And where were the staircases? 21 A. This is one, the kitchen, one in the 22 foyer, and the pool. 23 Q. Okay. And would you Just put an F where 24 the foyer staircase began? And KS where the 25 kitchen staircase began. Page 280 1 you have said came to give massages? 2 A. Yes, ma'am. 3 Q. And do you have any Idea whether or not 4 Mr. Dershowitz was also receiving massages? 5 A. I don't know, Ma'am. 6 Q. I want to ask you to take this piece of 7 paper, please, and a pencil -- 8 MR. WILLITS: Can anybody hear me? 9 MS. EZELL: Yes. Can you hear me? 10 MR. WILLITS: I've heard nothing for 11 about a minute or so. 12 MR. CRITTON: Can you hear me now? 13 MR. WILLITS: Yes. 14 MS. EZELL: I'm asking questions, I'm 15 sorry. 16 MR. CRITTON: Why don't we go off the 17 record for a second. 18 (Thereupon, a discussion was held off the 19 record.) 20 THE VIDEOGRAPHER: We're back on the 21 record. 22 BY MS. EZELL: 23 Q. Mr. Rodriguez, you indicated that there 24 were several staircases in the house? 25 A. Yes, ma'am. •••••••S. Page 282 1 And you said that later another staircase 2 was added? 3 A. Yeah, we rehabilitated this, you know, 4 but you asked me how many stairs there were, to 5 answer your question there were three. 6 Q. Three. So where was the third one? 7 A. The pool, this leads to the pool. 8 Through the outside master bedroom you could go 9 downstairs to the pool. 10 Q. Okay. A stairway then from the outside, 11 from outside the master bedroom? 12 A. Yes, ma'am. 13 Q. Down to the pool? 14 A. Yes, ma'am. 15 Q. One of your duties was to answer the 16 door. Is that correct? 17 A. Yes, ma'am. 18 Q. Which door would you answer? 19 A. Mainly the kitchen. 20 Q. And why was that, why would people mainly 21 come to the kitchen? 22 A. I'll say it was for practicable reasons 23 because not to go to the main -- it was shorter 24 because the entrance was here, so this was the 25 driveway and we used to take into the back door of Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 4 (Pages 279 to 282) EFTA00188928

Case 9:08-cv-80736-K,..4 Document 291-18 Entered on FL—J Docket 01/21/2015 Page 12 of 14 Page 383 1 you about having driven'. and you recalled 2 having had her In the Su rban specifically. 3 A. Yes. 4 Q. Do you remember any of the other girls, 5 women who came to give massages ever having driven 6 them, or is.. the only one that you remember? 7 MR. EDWARDS: Form. 8 THE WITNESS: I only remember M. right 9 now for the fact that I was driving by the 10 airport and I showed her Mr. Epstein's 11 plane. 12 BY MR. CRITTON: 13 Q. All right. Which really takes me back to 14 really where I started with this series of 15 questions. 16 You saw the girls, the women who came In 17 to give the massages, when they came in If you 18 were advised or if you heard conversation and you 19 saw them you would see them when they left? 20 A. Yes. 21 Q. And you saw M. because she was In the 22 Suburban on at least one occasion? 23 A. Yes. 24 Q. And, therefore, you never saw these 25 girls, these women who gave the massages in the Page 385 1 Q. All right. Ms. Ezell asked you about Mr. 2 Dershowitz being present in Mr. Epstein's home, 3 and I think she asked -- and I think that you said 4 Mr. Epstein was a -- and he and Mr. Dershowitz 5 were friends? 6 A. Yes. 7 Q. She also I think asked was Mr. Dershowitz 8 ever there when one of the women who gave a 9 massage was present in the home? 10 A. I don't remember that. 11 Q. That's what I want to clear up. Is it 12 your testimony that Mr. Dershowitz was there when 13 any of the women came to Mr. Epstein's home to 14 give a massage? 15 A. Yes. 16 MR. EDWARDS: Form. 17 BY MR. CRITTON: 18 Q. As to whether any of those women were 19 ever associated with Mr. Dershowitz would it be a 20 correct statement that you have absolutely no 21 knowledge? 22 A. I don't know, sir. 23 Q. You don't know? 24 A. I don't know, sir. 25 MS. EZELL: Form. Page 384 1 dining room or the library. Would that be a fair 2 statement? 3 A. That's correct. 4 MR. EDWARDS: Form. 5 BY MR. CRITTON: 6 Q. All rig fore, the pictures 7 that you saw taking of girls, women, 8 either in the in ng room or library, those were 9 other individuals other than those who may have 10 given or who came for massages. Is that correct? 11 MS. EZELL: Form. 12 MR. EDWARDS: Form. 13 THE WITNESS: It's confusing, sir, 14 because there were a bunch of girls. I 15 don't know which one they were but I saw her 16 taking pictures of the groups. 17 BY MR. CRITTON: 18 Q. As to whether they were people who came 19 In on the planes or there may have been a massage 20 girl or more than one woman who gave a massage, 21 you just don't know as you sit here, you'd just be 22 speculating. Is that correct? 23 MR. EDWARDS: Form. 24 THE WITNESS: I don't know. 25 BY MR. CRITTON: Page 386 1 BY MR. CRITTON: 2 Q. Okay. Were you in any way attempting in 3 your response to Ms. Ezell to imply that Mr. 4 Dershowitz had a massage by one of these young 5 ladies? 6 A. I don't know, sir. 7 Q. You have no knowledge? 8 A. No, sir. 9 Q. And you certainly weren't implying that 10 that occurred, you just have no knowledge. 11 Correct? 12 MR. EDWARDS: Form. 13 THE WITNESS: I don't know. 14 BY MR. CRITTON: 15 Q. Sorry? 16 A. I don't know. 17 Q. I think in response to one of Ms. Ezell's 18 questions you responded that -- let me ask it this 19 way. 20 You never saw Mr. Epstein ever take 21 photographs of anyone. Would that be a correct 22 statement? 23 A. Yes. 24 Q. Would It be a correct statement you never 25 saw Mr. Epstein initiate a phone call to anyone? 30 (Pages 383 to 386) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188929

Case 9:08-cv-80736-K,-..vl Document 291-18 Entered on FL—‘) Docket 01/21/2015 Page 13 of 14 Page 423 1 York house? 2 A. He will have massages. 3 MR. CRITTON: Form. 4 BY MR. EDWARDS: 5 Q. And are we still talking about a habit of 6 two a day? 7 MR. CRITTON: Form. 8 THE WITNESS: I don't know that. 9 BY MR. EDWARDS: 10 Q. Okay. So for the time period when you 11 have been familiar with Mr. Epstein and known his 12 habits, is it fair to say that he would have 13 roughly two girls a day in that same age group 14 wherever he was? 15 A. Yes. 16 MR. CRITTON: Form. 17 BY MR. EDWARDS: 18 Q. All right. And have you talked to 19 anybody that has given you similar Information 20 from his Island home? 21 A. No. 22 Q. Do you know any of the girls that have 23 been over to his Island? 24 A. Yes. 25 Q. And who are they? Page 425 1 Q. And is your understanding that Mr. 2 Epstein was intimate with any of those girls? 3 MR. CRITTON: Form. 4 THE WITNESS: Yes. 5 BY MR. EDWARDS: 6 Q. With all of them? 7 MR. CRMON: Form. 8 THE WITNESS: Yes. 9 BY MR. EDWARDS: 10 Q. With Sarah as well? 11 A. Yes. 12 MR. CRITTON: Form. 13 BY MR. EDWitit 14 Q. With ? 15 A. Yes. 16 MR. CRITTON: Form. 17 BY MR. EDWARDS: 18 Q. And the girls who would come over on the 19 airplane? 20 MR. CRITTON: Form. 21 THE WITNESS: Yes. 22 BY MR. EDWARDS: 23 Q. Did you ever have occasion to go into the 24 bedroom and find the vibrators or back massagers 25 out after Mr. Epstein was in the room with any of Page 424 1 A. the girls who used to stay at the 2 home in Brillo used to go over there to the 3 Island. 4 Q. When he would have these girls -- I guess 5 we've kind of categorized them as the girls who 6 would come over with him on an airplane and stay 7 at the house. 8 A. Yes. 9 Q. When they would be staying at the house 10 would he also have the local Palm Beach girls 11 coming over that you were told to call masseuses? 12 A. Yes. 13 Q. So these girls that came on the airplane 14 with him, were they also -- did they also have 15 knowledge that these young girls were coming over 16 to give massages? 17 MR. CRITTON: Form. 18 THE WITNESS: Yes, sir. 19 BY MR. EDWARDS: 20 Q. Okay. Who Me girls from the 21 airplane other than that you remember? 22 A. Sarah. There were so many, sir 't 23 recall right now. But Sarah Is for sure, 24 was one of the main girlfriends, but I dont 25 remember that. Page 426 1 the girls that came over on the plane? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes. 4 BY MR. EDWARDS: 5 Q. So that's something that would be out 6 after the girls that came over on the plane or the 7 girls that came over for the massages? 8 A. Yes. 9 MR. CRITTON: Form. 10 8Y MR. EDWARDS: 11 Q. And at the time when you were house 12 manager you had a 15-year old daughter? 13 A. Yes. 14 Q. Did she live down here? 15 A. In New Jersey. 16 Q. Okay. When Alan Dershowit was at the 17 house I understood you to say that these local 18 Palm Beach girls would come over to the house 19 while he was there but you're not sure if he had a 20 massage from any of those girls. 21 A. Exactly. 22 Q. And what would he do while those girls 23 were at the house? 24 MR. CRMON: Form. 25 THE WITNESS: He will read a book with a 40 (Pages 423 to 426 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188930

Case 9:08-cv-80736-k•A Document 291-18 Entered on FL..,D Docket 01/21/2015 Page 14 of 14 Page 427 1 glass of wine by the pool, stay inside. 2 BY MR. EDWARDS: 3 Q. Did he ever talk to any of the girls? 4 A. I don't know, sir. 5 Q. Certainly he knew that they were there? 6 MR. CRITTON: Form. 7 THE WITNESS: I don't know, sir. 8 BY MR. EDWARDS: 9 Q. Do you know how, knows Mr. 10 Epstein? 11 A. No, sir. 12 Q. Or how long she's known him? 13 MR. CRITTON: Form. 14 THE WITNESS: She was on board two years 15 or a year and a half before I came on board. 16 BY MR. EDWARDS: 17 Q. Okay. 18 A. So it's probably 2003 or 2. 19 Q. All right. You mentioned this Ctrix 20 system. 21 A. Yes. 22 Q. Is that a system that was used to operate 23 the phones and the computers? 24 A. The computers mainly. 25 Q. All right. But you then also riPseribed Page 429 1 usually it's Yahoo dot corn or at Bellsouth dot 2 net. 3 A. 4 sir. 5 Q. Did everybody in the -- I think you 6 called it the organization, did everybody have 7 e-mails? 8 A. Yes. 9 Q. Okay. Would that include? 10 A. Yes. 11 Q. All right. And did Mr. Epstein have an 12 e-mail? 13 A. Yes. 14 Q. Did you ever correspond with Mr. Epstein 15 by e-mail? 16 A. Yes. 17 MR. EDWARDS: You can go ahead. 18 THE WITNESS: That's the only one that I 19 remember. 20 THE VIDEOGRAPHER: Okay, we're off the 21 record. 22 (Thereupon, a recess was had.) 23 THE VIDEOGRAPHER: We're back on the 24 record with tape number four. 25 BY MR. EDWARDS: It was very uncommon. I don't remember, Page 428 1 some system where someone would call on the 2 telephone and that would be automatically 3 downloaded to the computer? 4 A. Yeah, you can retrieve who called in a 5 transcript written who called, what's the message, 6 the time so you have it on a piece of paper, you 7 can print it out. 8 Q. Is it your understanding that is also 9 part of the Citrix system? 10 A. Yes. 11 Q. All right. Did you have an e-mail? 12 A. Right now, yes. 13 Q. No, when you were working at -- 14 A. Yes, I did. 15 Q. -- Mr. E stein? 16 And did have an e-mail? 17 A. Yes. 18 Q. And did all of the e-mails end the same 19 way such as Epstein's house dot corn or something? 20 A. Yes. 21 Q. Okay. What was e-mail? 22 A. I don't remember. 23 Q. What was your e-mail? 24 A. Staff house -- I don't remember, sir. 25 Q. Do you recall how It ended? I mean Page 430 1 Q. Mr. Rodriguez, what was Mr. Epstein's 2 e-mail? 3 A. Jeep project at something -- Jeep 4 project -- I can't remember it right now. 5 Q. Okay. In the course of this next 10 or 6 15 minutes -- 7 A. I can recall. 8 Q. -- if it comes to you just tell me. So 9 it was Jeep project -- 10 A. Like Jeep, the brand name Jeep, Jeep 11 project at -- I can't remember. 12 Q. Okay. Was that his only e-mail to your 13 knowledge? 14 A. No. 15 Q. He had other e-mail addresses? 16 A. Yes. 17 Q. Do you know what any of his other e-mail 18 addresses were? 19 A. No, I don't remember. 20 Q. Do you know who the carriers were for the 21 other e-mail addresses owned by Jeffrey Epstein? 22 A. No, sir. 23 Q. Whether it was Yahoo or hot mail or -- 24 A. No, none of those. 25 Q. Okay. Was this Jeep project e-mail run 41 (Pages 427 to 430) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00188931

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Case 9:08-cv-80736-KAm Document 291-19 Entered on FL .., Docket 01/21/2015 Page 1 of 2 EXHIBIT 20 EFTA00188933

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Case 9:08-cv-80736-Kmm Document 291-20 Entered on FL Docket 01/21/2015 Page 1 of 8 EXHIBIT 21 EFTA00188936

Case 9:08-cv-80736-Kmio Document 291-20 Entered on FL J Docket 01/21/2015 Page 2 of 8 Page 1 Page 3 UNITED STATES DISTRICT COURT 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT SOUTHERN DISTRICT OF FLORIDA 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 08-CIV-801 19-MARRA/JOHNSON 3 CASE NO. 502008CA028051XXXXMB AB 4 JANE DOE NO. 2, Plaintiff, 5 Plaintiff, VOLUME I OF III 6 -vs- VOLUME I OF III JEFFREY EPSTEIN, 7 JEFFREY EPSTEIN, Defendant. 8 Defendant. / / 9 Related CUM 10 08-80232, 0848380, 08-8038 I, 08-80994 11 08-80993, 08-80811, 08-80893, 09-80469 12 VIDEOTAPED DEPOSITION OF 09-80591, 09-80656, 09-80802, 09-81092 13 / 14 VIDSMISITION OF 15 Wednesday, March 24, 2010 10:37 • 6:51 p.m. 16 Wednesday, March 24, 2010 17 10:37 - 6:5I p.m. 18 I 21. 22 Reported By: Cynthia Hopkins, RPR, FPR Reported By: 23 Notary Public, State of Florida Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Prose Court Reporting Services 2 4 Job No.: 1484 Job No.: 1484 2 5 Page 2 Page 4 1 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. 502008CA028058XXXXMB AD 2 CASE No.502008CA0373 19XX XXIAB AB 3 3 4 n. 4 S S Plaintiff, Plaintiff, 6 -vs- VOLUME 1 OF III 5 7 6 7 -vs- VOLUME I OF III JEFF... 8 JEFFREY EPSTEIN, AND Defendant. 8 9 / Defendants 10 9 VI ITION OF 11 12 13 VIDEOTAPED DEPOSITION OF 10 11 12 14 Wednesday, March 24, 2010 13 15 10:37 -6:51 p.m 14 Wednesday, March 24, 2010 10:37 - 6:51 p.m. 16 1 5 17 I ill 18 19 19 20 20 21 21 22 Reported By: 22 Reported By: Cynthia Hopkins, RPR, FPR Cynthia Hopkins, RPR, FPR 23 Notary Public, State of Florida 23 Notary Public, State of Florida Prose Court Reporting Services Prose Court Reporting Services 24 Job No.: 1484 24 Job No.: 1484 25 25 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. EFTA00188937

Case 9:08-cv-80736-KMIVI Document 291-20 Entered on FL.. Docket 01/21/2015 Page 3 of 8 Page 5 Page 7 1 APPEARANCES: 1 2 On behalf of the Plaintiffs,t 2 IN-D-E X 3 SPENCER t KUVIN, IRE 3 4 LD K YIN 4 I --- EXAMINATION DIRECT CROSS REDIRECT I 6 7 7 On behalf of the Plaintiffs, in. and BY MR. KUVIN 9 Jane Doe: 8 8 9 9 MATTHEW WEISSING. ESQUIRE to EXHIBITS FARMER, JAFFE, WEISSING, EDWARDS 10 FISTOS & LEHRMAN P L ■ EXHIBIT DESCRIPTION PAGE PLAINTIFF'S EX. 1 PHOTO 16 0 On behal of Jane s I through t 1 ) PLAINTIFF'S EX. 2 JEGE, INC., 24 ADAM D. HOROWITZ. ESQUIRE PASSENGER MANIFEST W1TZ. P A 16 PLAINTIFFS EX. 3 HYPERION AIR, INC., 15 PASSENGER MANIFEST ■ PLAINTIFF'S EX. 6 PHOTO 63 I PLAINTIFF'S EX. 7 PHOTO 65 . PLAINTIFFS EX. 8 PHOTO 68 . 9 PLAINTIFF'S EX. PHOTO 71 1 II On o e atm% s. . I 19 PLAINTIFFS EX. 1 0 PHOTO 100 19 KATHERINE W. EZELL, ESQUIRE PLAINTIFF'S EX. II PHOTO 101 AMY JOSEFSBERG EDERI, ESQUIRE 20 PLAINTIFF'S EX. 12 PHOTO 103 20 R PLAINTIFF'S EX. 4 PHONE MESSAGE PADS 21 PLAINTIFF'S EX. 5 CELLPHONE RECORDS PLAINTIFFS EX. 13 PHOTO 144 22 one: 22 23 (Via tekpbone) 23 24 24 25 25 Page 6 Page 8 I Appearances contimied... 1 PROCEEDINGS 2 On behalf of the Plaintiff. Jane Doe II: 3 ISIDRO MANUEL GARCIA, ESQUIRE 2 — — — GARCIA EI.K1NS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video 4 I record. This is Media No. 1 in the videotaped 5 deposition of in the matter of 6 Jane Doc versus Jeffrey Epstein, et al. Today 7 On behalf of the Defendant: 8 JACK ALAN GOLDBERGER, ESQUIRE 7 is Wednesday, March 24th, 2010. It is ATTERBURY GOLDBERGER & WEISS, P.A. 8 10:36 a.m. We are here at Prose Court 9 Reporting, 250 South Australian Avenue, West il Palm Beach, Florida. 11 My name is Joe Kozak. I'm the 11 12 12 videographer. The reporter is Cindy 13 On behalf of the Witness: 13 Hopkins from Prose Court Reporting Agency. 14 BRUCE E. REINHART. ESQUIRE 14 Would counsel please introduce LAW OFFICE OF BRUCE E. REINHART 15 yourselves, and then the court reporter will swear in the witness. 17 MR. KUVIN: Good morning. Spencer Kuvin 1, 18 on behalf of one of the Plaintiffs. 18 19 19 MR. HOROWITZ: Adam Horowitz on behalf c 20 ALSO PRESENT: 20 Jane Does 2 through 8. And just for the record 21 Jessica Cadwell, Paralegal 21 purposes, the deposition is also being taken in Duman. Critton, Luther & Coleman, P.A. 22 Joseph Kozak, Videopapha 22 the federal cases, I believe, case being Prose Court Reponing Services 23 Jane Doe 2 versus Jeffrey Epstein. 23 24 24 MR. WEISSING: Man Weissing on behalf of 25 25 three of the Plaintiffs. 2 (Pages 5 to 8) PROSE COURT REPORTING AGENCY, INC. EFTA00188938

Case 9:08-cv-80736-Krovl Document 291-20 Entered on Docket 01/21/2015 Page 4 of 8 Page 207 1 BY MR. KUVIN: 2 . Have you ever used the alias of 3 4 MR. RHEINHART: Objection to the --I'm 5 sorry. Instruct the witness not to answer 6 based on Fifth Amendment privileges. 7 THE WITNESS: Upon the instruction of my 8 lawyer, I must invoke my Fifth Amendment right 9 BY MR. KUVIN: 10 Q. Do your parents live in North Carolina? 11 MR. RHEINHART: Instruct the witness not 12 to answer the question based on her Fifth 13 Amendment privilege. 14 THE WITNESS: On instruction of my lawyer 15 I must invoke my Fifth Amendment right. 16 BY MR. KUVIN: 17 Q. Do you have any brothers and sisters? 18 MR. RHEINHART: Same instruction as the 19 previous question. 20 THE WITNESS: On the instruction of my 21 lawyer, I must invoke my Fifth Amendment right 22 BY MR. KUVIN: 23 Q. Have your parents met Jeffrey Epstein? 24 MR. RHEINHART: Objection to the form. 25 Standing objection and also instruct the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 209 compound, instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right BY MR. KUVIN: Q.Q. Have ou ever used illegal drugs with MR. RHEINHART: Same objection and instruction as to the previous question. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right BY MR. KUVIN: Q. Did you ever use the phone number of MR. RHEINHART: Instruct the witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right BY MR. KUVIN: Q. Have ou ever used the phone number MR. RHEINHART: Thank you. THE WITNESS: I don't recognize that number. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 208 witness not to answer based on her Fifth Amendment privilege. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right BY MR. KUVIN: Q. Do your parents know what you've done with Jeffrey Epstein as it relates to this case? MR. RHEINHART: Objection to the form as stated to the previous question, and same instruction. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right BY MR. KUVIN: Q. Have you ever used illegal drugs with Jeffrey Epstein? MR. RHEINHART: Objection to the form. Standing objection, instruct the witness not to answer. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right BY MR. KUVIN: Q. Have you ever used illegal drugs with Ghislaine Maxwell? MR. RHEINHART: Objection to the form, assumes knowledge of Ghislaine Maxwell. It's Page 210 1 BY MR. KUVIN: 2 Q. Okay. When the police entered Jeffrey 3 Epstein's home, they took something that's called a 4 bottle of Peach Flavored Joy Jelly. Just a 5 foundation of what I'm about to ask you. 6 Have you ever seen anything called Peach 7 Flavored Joy Jelly ever anywhere, first of all? 8 Have you ever seen that before anywhere? 9 MR. RHEINHART: Just so I am clear about 10 your question -- 11 MR. KUVIN: Not necessarily in a home, 12 just anywhere in her entire life has she ever 13 seen a bottle of something called Peach 14 Flavored Joy Jelly. 15 THE WITNESS: No, I have not. 16 BY MR. KUVIN: 17 Q. Okay. Also taken from the home were, was 18 an adult sex toy called a Twin Torpedo which, 19 according to Detective Recarey during his depositior 20 was a double-headed dildo. Not with respect to 21 Mr. Epstein, but in your life, have you ever seen 22 something called a Twin Torpedo or double-headed 23 dildo? 24 A. No, I have not 25 Q. Also confiscated from the home was soap in 6 (Pages 207 to 210) PROSE COURT REPORTING AGENCY, INC. EFTA00188939

Case 9:08-cv-80736-1O-A Document 291-20 Entered on FL. i Docket 01/21/2015 Page 5 of 8 Page 211 Page 213 1 the shape of a penis and vagina. Once again, not 1 THE WITNESS: On the instruction of my 2 necessarily with respect to Mr. Epstein's home, in 2 lawyer, I must invoke my Fifth Amendment right 3 your entire life have you ever seen soap in the 3 BY MR. KUVIN: 4 shape of a penis and vagina? 4 Q. Do you agree that these corporations that 5 A. Not that I recall. 5 I just mentioned were utilized by Jeffrey Epstein in 6 Q. Do you ever recall being in Ohio? 6 an attempt to have sexual relationships with 7 MR. RHEINHART: Ever in her life? 7 underage girls? 8 MR. KUVIN: The slate, ever in her life. B MR. RHEINHART: Objection to the form as 9 BY MR. KUVIN: 9 to compound, and also assumes knowledge of 10 Q. Let's start there, recall being in the 10 Mr. Epstein, asks for more than one answer to 11 State of Ohio for any reason? 11 the question. I would instruct her not to 12 A. Maybe for a layover, but not that 1 12 answer based on her Fifth Amendment privilege 13 specifically remember. 13 because the question assumes knowledge of 14 Q. Okay. Do you know an Ivan Robles? 14 Mr. Epstein. 15 A. No. 15 THE WITNESS: Upon instruction of my 16 Q. Have you seen a gentleman by the name o ' 16 lawyer I must invoke my Fifth Amendment right. 17 Alan Dershowitz at the home of Jeffrey Epstein 17 MR. KUVIN: I think I am done. Hang on 18 before? 18 one second. 19 MR. RHEINHART: Objection to the form. 19 All right. I appreciate it. That's all 20 Standing objection, presumes knowledge of 20 the questions I have at this time. Reserve the 21 Jeffrey Epstein or his home. Instruct the 21 right to ask any follow-up questions if other 22 witness not to answer. 22 attorneys raise new and different issues by 23 THE WITNESS: On the instruction of my 23 their questioning. 24 lawyer, I must exercise my Fifth Amendment 24 MR. RHEINHART: Understood. 25 right. 25 MR. KUVIN: Pass the witness at this time. Page Page 214 1 BY MR. KUVIN: 1 Who wants to go? Mr. Horowitz, do you have a 2 Q. Have you ever heard of the El Zorro Ranch 2 microphone? 3 Corporation? 3 MR. HOROWITZ: I do. 4 MR. RHEINHART: Instruct the witness not 4 CROSS ( ) 5 to answer based on her Fifth Amendment 5 BY MR. IIOROWITZ: 6 privilege. 6 Q. Ms. did ou use the telephone 7 TIIE WITNESS: On the instruction of my 7 number, the at any time between 2001 8 lawyer I must exercise my Fifth Amendment B and 2006? 9 right. 9 A. On the advice of my lawyer, I must exercise m 10 BY MR. KUVIN: 10 Fifth Amendment right 11 12 Q. Have you ever heard of the New York Strategy Group? 11 12 . Didyou use the telephone number between 2001 and 2006 at Jeffrey 13 MR. RHEINHART: Same instruction. 13 Epstein's expense? 14 THE WITNESS: On the instruction of my 14 MR. RHEINHART: Objection to the form in 15 lawyer, I must invoke my Fifth Amendment right 15 that it assumes knowledge of Jeffrey Epstein. 16 BY MR. KUVIN: 16 Standing objection as previously stated with 17 Q. Have you ever heard of the Ghislaine 17 Mr. Kuvin. Instruct the witness not to answer, 18 Corporation? 18 based on her Fifth Amendment right. 19 MR. RHEINHART: Same instruction. 19 THE WITNESS: On the instruction of my 20 THE WITNESS: On the instruction of my 20 lawyer, I must exercise my Fifth Amendment 21 lawyer, I must invoke my Fifth Amendment right 21 right. 22 BY MR. KUVIN: 22 BY MR. HOROWITZ: 23 24 Q. Have you ever heard of the Financial Strategy Group? 23 24 . Didyou use the telephone number at Jeffrey Epstein's direction? 25 MR. RHEINHART: Same instruction. 25 MR. RHEINHART: Same objection as the 7 (Pages 211 to 214) PROSE COURT REPORTING AGENCY, INC. EFTA00188940

Case 9:08-cv-80736-Krwil Document 291-20 Entered on FL_J Docket 01/21/2015 Page 6 of 8 Page 315 So can we focus on the specific questions 2 that she can answer or from which you can draw 3 an adverse inference if asked properly, and 4 let's move it along. 5 MS. EZELL: Each young woman's case is an 6 individual case, and we have the right to ask, 7 ask whatever questions that we need to with 8 regard to each one. 9 MR. RHEINHART: I -- 10 MR. GOLDBERGER: Let's just go forward 11 until 5:00 and see where we're at. 12 BY MR. WEISSING: 13 Q. Did you know that Jeffrey Epstein received 14 sexual gratification from directing others to 15 sexually abuse minor children? 16 MR. RHEINHART: Objection to the form. 17 THE WITNESS: On the instruction of my 18 lawyer, l must invoke the Fifth Amendment 19 right. 20 BY MR. WEISSING: 21 Q. Did you know that Jeffrey E stein received 22 sexual gratification from directing to 23 sexually abuse minor children? 24 MR. RHEINHART: Objection to the form. It 25 assumes knowledge of a person named Page 317 1 THE WITNESS: On the instruction of my 2 lawyer, I must invoke my Fifth Amendment 3 privilege. 4 BY MR. WEISSING: 5 Q. Do you know Alan Dershowitz? 6 MR. RHEINHART: The question was asked and 7 answered about three-and-a-half hours ago. 8 THE WITNESS: On the instruction of my 9 lawyer, I must invoke my Fifth Amendment 10 privilege. 11 BY MR. WEISSING: 12 Q. Do you know David Copperfield? 13 MR. RHEINHART: That question was asked 14 about three-and-a-half-hours ago. 15 THE WITNESS: On the instruction of my 16 lawyer, I must invoke my Fifth Amendment 17 privilege. 18 BY MR. WEISSING: 19 Q. In addition to his place at, in Palm 20 Beach, are you aware that Jeffrey Epstein has an 21 apartment located at 301 East 66th Street, Apartment 22 14O through E in New York? 23 MR. RHEINHART: That question was asked 24 about four hours ago. It's been asked and 25 answered. Page 316 1 It is otherwise compound and objectionable. 1 2 THE WITNESS: On the instruction of my 2 3 lawyer, I must invoke my Fifth Amendment right. 3 4 MR. WEISSING: Let's go off the record for 4 5 a moment. 5 6 THE VIDEOGRAPHER: Arc we all good with 6 7 going off the record? 7 MR. RHEINHART: Yeah, that's fine. 8 9 MR. HOROWITZ: Yes. 9 10 THE VIDEOGRAPHER: We're now off the 10 11 record at 4:22 p.m. 11 12 (A brief recess was held.) 12 13 THE VIDEOGRAPHER: We are now on the 13 14 record. It is 4:24 p.m. 14 15 BY MR. WEISSING: 15 16 Q. Do you know 16 17 MR. KUVIN: 17 18 THE WITNESS: On the instruction of my 18 19 lawyer, I must invoke my Fifth Amendment 19 20 privilege. 20 21 BY MR. WEISSING: 21 22 Q. Do you know -- have you procured minor 22 23 children to have sexual relations with 23 29 at Jeffrey Epstein's mansion? 24 25 MR. RHEINHART: Objection to the form. 25 Page 318 THE WITNESS: At the instruction of my lawyer, I invoke my Fifth Amendment privilege BY MR. WEISSING: Q. While in New York, have you procured underage minor children to engage in sexual acts with Jeffrey Epstein at that location? MR. RHEINHART: Object to the form. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. With regard to the minor children procured for him at that location, were they school children in the New York area? MR. RHEINHART: The previous question, objection to the form. The same as all the previous questions, it assumes a fact that's not been established. It can't fairly be answered. THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment privilege. BY MR. WEISSING: Q. Did Jeffrey Epstein have sexual encounters with underage people while at that apartment? 33 (Pages 315 to 318) PROSE COURT REPORTING AGENCY, INC. EFTA00188941

Case 9:08-cv-80736-Ki-ovl Document 291-20 Entered on FL J Docket 01/21/2015 Page 7 of 8 Page 433 1 know what the Edge Group was, but whatever, you car 2 answer the question. 3 THE WITNESS: At the instruction of my lawyer, 4 I must choose to invoke my Fifth Amendment right. S BY MS. EZELL: 6 Q. Do you know Max Brockman? 7 MR. REINHART: Pm sorry, can you repeat? 8 BY MS. EZELL: 9 Q. Do you know a Max Brockman? 10 MR. REINHART: I believe that was asked and 11 answered already, but -- 12 THE WITNESS: At the instruction of my lawyer, 13 I must invoke my Fifth Amendment right. 14 BY MS. EZELL: 15 Q. Have you ever been photographed with Max 16 Brockman at an Edge Science dinner? 17 A. At the instruction of my lawyer, I must invoke 18 my Fifth Amendment right. 19 MR. REINHART: You should let me -- I need to 20 object to the form of the question first, but go 21 ahead. I know we all want to get out of here. Go 22 ahead. 23 THE WITNESS: Say it again. 24 MR. REINHART: No, you arc okay. Go ahead, 25 Ms. Ezell. Thank you. Page 435 1 BY MS. EZELL: 2 Q. Do you want to respond? I didn't give you 3 time. 4 MR. REINHART: I've instructed her not to 5 answer the question. Let's move on. 6 BY MS. EZELL: 7 Q. Do you recall a dinner at El Brillo Way 8 attended by David Copperfield where Jane No. 103 was 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 right. 16 BY MS. EZELL: 17 Q. What is the relationship between Jeffrey 18 Epstein and David Copperfield? 19 MR. REINHART: Objection to form, lack of 20 foundation as to her knowledge of either one of 21 those people. Instruct her not to answer. 22 THE WITNESS: At the instruction of my lawyer, 23 I must invoke my Fifth Amendment right. 24 BY MS. EZELL: 25 Q. To your knowledge, do they recruit girls for 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 434 BY MS. EZELL: Q. Do you know whether Jeffrey Epstein attended the Edge Science dinner in Monterey, California? MR. REINHART: Objection to the form, lack o foundation. Instruct the witness not to answer. THE WITNESS: At the instruction of my lawye I must invoke my Fifth Amendment right. BY MS. EZELL: Q. You testified a moment ago that you were photographed nude by your boyfriend or a former boyfriend and that you hoped there are no photographs disseminated elsewhere. At what age were those photographs taken? MR. REINHART: I'm going to instruct her not to answer that. It has nothing to do with anything. It's not reasonably calculated to lead to discoverable evidence. We can move on. BY MS. EZELL: Q. Were you in any way damaged by that experience? MR. REINHART: Same instruction. Let's move on. BY MS. EZELL: Q. Do you have any regrets? MR. REINHART: Same instruction. Move on. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 436 one another? MR. REINHART: Object to the form, compoun and again, lack of foundation. Instruct her not to answer. THE WITNESS: At the instruction of my lawye-, I must invoke my Fifth Amendment right. BY MS. EZELL: Q. To your knowledge, are they involved in any sexual trafficking of young women? MR. REINHART: Object to the form for the reasons previously stated. Also calls for a legal conclusion as to what sexual trafficking is. Instruct her not to answer. THE WITNESS: At the instruction of my lawye- I must invoke my Fifth Amendment right. BY MS. EZELL: Q. I believe you asked about Allen Dershowitz earlier. MR. REINHART: Twice. BY MS. EZELL: Q. And were instructed not to answer. MR. REINHART: Twice. BY MS. EZELL: Q. All right. I'm going to ask again on behalf of my client. Are you aware of the friendship between 18 (Pages 433 to 436) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.272417.4627) 905d1499-0cd8-46994280-6d3a827b68c6 EFTA00188942

Case 9:08-cv-80736-K...v1 Document 291-20 Entered on FL_ J Docket 01/21/2015 Page 8 of 8 Page 437 Page 439 1 Allen Dershowitz and Jeffrey Epstein? 1 BY MS. EZELL: 2 MR. REINHART: And for the third time, I'll 2 Q. Do you know that when David Copperfield is in 3 object to the form and instruct her not to answer 3 town, he gives Jeffrey Epstein tickets and Jeffrey gives 4 the question. 4 some to young women to attend those shows? 5 THE WITNESS: For the third time, I take the 5 MR. REINHART: Object to the form, multiple, 6 advice of my lawyer and invoke my Fifth Amendment 6 compound question, and a complete lack of 7 right. 7 foundation. Instruct the witness not to answer. 8 BY MS. EZELL: B THE WITNESS: At the instruction of my lawyer, 9 Q. When Allen Dershowitz comes to Palm Beach, he 9 I must invoke my Fifth Amendment right. 10 stays at the El Brillo mansion, doesn't he? 10 BY MS. EZELL: 11 MR. REINHART: Objection to the form. There 11 Q. And do you know that those girls are invited 12 is no foundation for her having any knowledge of 12 back stage after the show? 13 anything having to do with a person by the name of 13 MR. REINIIART: Same objection, complete lack 14 Allen Dershowitz. I instruct her not to answer. 14 of foundation, and standing objection previously 15 THE WITNESS: At the instruction of my lawyer, 15 stated. 16 I must invoke my Fifth Amendment right. 16 THE WITNESS: At the instruction of my lawyer. 17 BY MS. EZELL: 17 I must invoke my Fifth Amendment right. 18 Q. When Allen Dershowitz, or has Allen Dershowitz 18 BY MS. EZELL: 19 ever been there when young ladies came to give massages'? 19 Q. Do you remember on or about, in or about March 20 MR. REINHART: Same objection stated to the 20 of 2005 having conversations with one of the young wome 21 previous question. Same instruction. 21 who came to the house to give massages about her 22 THE WITNESS: At the instruction of my lawyer, 22 conversations with Jane No. 103? 23 I must invoke my Fifth Amendment right. 23 MR. REINHART: Objection to the form, standing 24 BY MS. EZELL: 24 objection, lack of foundation. Instruct the 25 Q. Has Allen Dershowitz ever been the beneficiary 25 witness not to answer, because the question implies Page 438 Page 440 1 of those massages? 1 that she has any knowledge at all of El Brillo Way. 2 MR. REINHART: Same objection and same 2 BY MS. EZELL: 3 instruction. 3 Q. Same question — sorry. 4 THE WITNESS: At the instruction of my lawyr, 4 A. At the instruction of my lawyer, I must choose 5 I must invoke my Fifth Amendment right. 5 to invoke my Fifth Amendment privilege. 6 BY MS. EZELL: 6 Q. Same question as to March of 2006. 7 Q. Do you know John Casablanca? 7 MR. REINHART: Same objection and same 8 A. Never heard that name before. 8 instruction. 9 Q. Have you ever heard of a world-famous 9 THE WITNESS: At the instruction of my lawyer, 10 illusionist whose stage name is David Copperfield? 10 I must choose to invoke my Fifth Amendment 11 MR. REINHART: That's also been asked at leas 11 privilege. 12 three times. I'll instruct her again not to answer 12 BY MS. EZELL: 13 the question. 13 Q. Do you have any recollection of a conversation 14 THE WITNESS: At the instruction of my lawyc, 14 in which one of the young women told Jane No. 103 tha 15 I must invoke my Fifth Amendment right. 15 those girls who, those girls who would help Jeffrey in 16 BY MS. EZELL: 1.6 regard to the investigation would be compensated and 17 Q. Have you ever gone to one of David 17 those who would not or who would hurt him in the 18 Copperfield's shows? 18 investigation would be dealt with? 19 MR. REINHART: Objection to form, lack of 19 MR. REINHART: Objection to the form, lack of 20 foundation as to knowledge of any person by the 20 foundation, compound question. Instruct the 21 name of David Copperfield. Instruct her not to 21 witness not to answer, because the question implies 22 answer. 22 some knowledge of anything relating to a person by 23 THE WITNESS: At the instruction of my lavge-, 23 the name of Jeffrey Epstein. 24 1 must invoke my Fifth Amendment right. 24 THE WITNESS: At the instruction of my lawyer 25 25 1 must invoke my Fifth Amendment right. 19 (Pages 437 to 440) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-8174627) 906d1409-0cd8-4599-a2a0-6d38827b680 EFTA00188943

I EFTA00188944

Case 9:08-cv-80736-i ,%/1 Document 291-21 Entered on F .D Docket 01/21/2015 Page 1 of 7 EXHIBIT 22 EFTA00188945

Case 9:08-cv-807364, 0.1 Document 291-21 Entered on F D Docket 01/21/2015 Page 2 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-8-591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF TAKEN ON BEHALF OF THE PLAINTIFF DATE: April 13, 2010 U.S. Legal Support (561) 835-0220 EFTA00188946

Case 9:08-cv-RIITze-t l Donnrnent 291-21 Entered on F iD Docket 01/21/2015 Page 3 of 7 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 April 13,2010 INDEX WITNESS DIRECT CROSS REDIRECT RECROSS 3 BY MR. EDWARDS 5 98 BY MR. HOROWITZ 65 BY MR. LANGINO 77 BY MS. EZELL 81 EXHIBITS PLAINTIFF'S FOR IDENTIFICATION I Message elated August 21,2005. PAGE 45 2 5 ft 9 14 15 16 APPEARANCIES (CONTINUED) LEOPOLD-KUVIN Altai ncys (or and CE fst) BY: ADAM J. LANGINO, ESQ, PODIIURST.ORSECK Attorneys for Jane Doss I awl 3 Cit Nainmel Bank Building. Suite 88 ii i. • : . EZELL ESQ. • BURMAN, CRIITON, to & COLEMAN. LIP Alaaneys rot Defendant Jemn Epstein BY: DAVID YARC14A. ESQ. ROBERT CRIT ION, ESQ. ATIERBURY. GOLDBERGER & WEISS 17 Co Conrad for Defendants U 20 21 22 23 24 25 ACK A. GOLOUEROCR,ESQ• ALSO PRESEPIC JESSICA CADWELL JOE ROVNER, Videographee (U.S. Legal) 4 3 1 3 The videotaped deposition of 2 in the above-entil.numbcred cause, was to en before me, TERRI BECKER, a 4 Registered Professional Reporter and Notary 5 Public for the State of Florida at Large, at 444 6 West Railroad Avenue, in the City of West Palm 7 Beach, Palm Beach County, in the State of 8 Florida, beginning at the hour of 10:00 o'clock 9 a.m., pursuant to the Notice in said cause for 10 the taking of said deposition which is annexed to 11 the court file herein, on behalf of the PLAINTIFF 12 in the above-entitled action pending in the 13 above-named court. 14 The appearances at said lime and place 15 were as follows: 16 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL. 17 Attorneys for PinintilTs June Does, L.N. and 10 • c: 524-2820 20 BY: BRADLEY J. EDWARDS, ESQ. 21 MERMELSTEIN & HOROWITZ, P.A. 22 Attorneys for Plaintiffs Jane Does, numbers 2 throu I 21 Tel: (305)931-2200 25 BY: ADAM D. HOROWITZ, ESQ. 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 THEREUPON, 2 3 being by Terri Becker first duly sworn to tell 4 the whole truth, as hereinafter certified, 5 testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: Q Can you tell us your name. A Q What is your date of birth? A Q What is your Social Security number? A Under advice of my counsel, I invoke my privileges under the Fifth and Sixth Amendments to the United States Constitution and respectfully decline to answer the question. Q Where were you bona A I'm sorry, though I would like to unmetr your question, I must invoke my Fifth and Sixth Amendment privileges and refuse to answer your questions. Q What is your current address? MR. GOLDBERGER: There is going to be a continual, obviously, you anticipate I'm sure, continued invocation of Fifth 5 2 (Pages 2 to 5) U.S. Legal Support (561) 835-0220 EFTA00188947

Case 9:O8-cv-8O736-L A rthrlimpnt 7411-21 Pntprrari nn nnrkPt 0112112(115 PagP A of 7 1 2 3 4 5 6 7 6 Amendment privileges. If it is okay with all counsel, in shorten things, I'll simply have the witness say lift; if that satisfies everyone's interest. MR. EDWARDS: That is line with me. MR. GOLDBERGER: Okay, with that Cathy? MS. EZELL: Yes. 1 2 3 4 5 6 7 0 A The Fifth. Q Do you know a lady by the name of Maritsa Vazques? A The Fifth. Q Is this somebody who helped to falsify a visa for you? MR. YAREMA: Object to the form. MR. HOROWITZ: Yes. 8 A The Fifth. 9 Q reask the question, what's your 9 Q Do you know Evelyn Velasaques? 10 current address? 0 A The Fifth. 11 A Fifth. 11 Q Were you ever a working model In the 12 Q Are you currently living at 358 El 12 United States? 13 Brill° Way with a man named Jeffrey Epstein? 13 A The Fifth. 14 A The Fifth. 14 Q Can you tell us yout: parents' names? 15 Q Arc you also familiar with all address In 5 A The Fifth. 16 New York,301 East 66th Street? 6 Q How Is It that you have supported 17 A The Fifth. 7 yourself financially, since you have been in this 18 Q When Mr. Epstein was Incarcerated in 8 country? 19 jail, you went to visit him on numerous 9 MR. YAREMA: Object to the form. 20 occasions; is that correct? 0 A The Fifth. 21 MR. YAREMA: Objection. 1 Q Have you supported yourself financially? 22 A The Fifth. 2 A The Fifth. 23 Q When you went to visit him you indicated 3 Q What Is the last grade you completed in 24 to jail personnel your address was 301 Enst 66th 4 school? 25 Street, apartment WO in New York City, New York; 5 A The Fifth, I take the Fifth Amendment. 7 is that correct? 9 Q Are you in school now? 2 MR. YAREMA: Objection. 2 A The Fifth. 3 A Fifth. 3 Q Have you ever attended any school in the 4 Q Isn't it true when Mr. Epstein was in 4 United States? 5 Jail, you visited him on more than 50 occasions? 5 A The Fifth. 6 MR. YAREMA: Form objection. 6 Q Have you ever been employed since 7 Q True? 7 residing in the United States? 8 A The Fifth. 8 A The Fifth. 9 Q How long have you been in the United 9 Q Is Jeffrey Epstein your sole means of 10 States, Ms. Marcinkova? 10 ❑nancial support today? 11 A The Fifth. 11 MR. YAREMA: Object to the form. 12 Q Who brought you to the United States? 12 A The Fifth. 13 MR. YAREMA: Form objection. 13 Q Since coming to this country, hasn't 14 A The Fifth. 14 Jeffrey Epstein always been your sole means of 15 Q What is your current status in this 15 financial support? 16 country? 16 MR. YAREMA: Object to the form. 17 A The Fifth. 7 A The Fifth. 18 MR. YAREMA: Form objection. 18 Q Flow much does Jeffrey Epstein pay you 19 MR. GOLDBERGER: Lel me take a half a 19 today? 20 second. 20 MR. YAREMA: Object to the form. 21 (Witness and her counsel confer.) 21 A The Fifth. 22 Q Are you a U.S. citizen? 22 Q What does every Epstein pay you for? 23 A The Fifth. 23 MR. YAREMA: Object to the form. 24 Q What type of visa are you here on? 24 A The Fifth. 25 MR. YAREMA: Form objection. 25 Q Does he pay you specifically to be his 3 (Pages 6 to 9) U.S. Legal Support (561) 835-0220 EFTA00188948

Case 9:O8-cv-ff1716 6„ A nor' tmonf 797-71 Cott:triad na.a nnrket f11/91/7O15 Page 5 of 7 54 56 1 A Fifth. 1 Jeffrey Epstein specifically Dew to Palm Beach 2 Q Do you know Bill Clinton? 2 for the purposes of engaging in sex acts with 3 A Fifth. 3 Jane Doe? 4 Q You have been on Jeffrey Epstein's 4 MR. YAREMA: Object to the fonn. 5 airplane with Bill Clinton? S A Fifth. 6 MR. YAREMA: Object to the fonn. 6 Q Generally, isn't It true Jeffrey Epstein 7 A Filth. 7 would fly from place to place fur the purpose of 8 Q isn't take true you have been on Jeffrey 8 engaging In sexual activity with minors at his 9 Epstein's airplane with Dung Band, Bill Clinton's 9 destination? 10 'thalami man? 10 MR. YAREMA: Object to the fonn. 11 MR. YAREMA: Object to the fonn. 11 A Fifth. 12 A Fifth. 12 Q Isn't it true that he employed numerous 13 Q Have you witnessed Improper sexual 13 people for the sole purpose of scheduling 14 activity between Jeffrey Epstein and minors, 14 appointments with underage minor females at each 15 while he was in the presence of Bill Clinton? 15 destination he landed? 16 MR. YAltEMA: Object to the form. 16 MR. YAREMA: Object to the fonn. 17 A Fifth. 17 A Fifth. 18 Q How many limes have you ridden on the 18 Q Whnt is Jeffrey Epstein's relationship 19 airplane with Jean Luc Brunel? 19 with Sandy Berger? 20 MR. YAREMA: Object to the form. 20 MR. YAREMA: Object to the tbnn. 21 A Fifth. 21 A Fifth. 22 Q Each time that Jean Luc Brunel visits 22 Q Do you know what Jeffrey Epsteltes 23 Jeffrey Epstein's house, does he bring underage 23 relationship is with Alan Dershowitz? 24 minors to Jeffrey Epstein's house to engage in 24 MR. YAREMA: Object to the fonn. 25 sex with? 25 A Fifth. 55 57 1 MR. YAREMA: Object to the form. 1 Q That's somebody who you know to have 2 A Fifth. 2 stayed at Jeffrey Epstein's house on ninny 3 Q Do you know Glenn Dubin? 3 occasions, correct? 4 A Fifth. 4 MR. YAREMA: Object to the fonn. 5 Q Do you know I lr? 5 A Fifth. 6 A Fifth. 6 Q And also somebody who you know to have 7 Q Is that somebody that was a sexual abuse 7 been at the house when M. was in Jeffrey 8 victim nt one point In time of Jeffrey Epstein 8 Epstein's bedroom getting sexually abused, 9 and Jean Luc Brunel? 9 correct? 10 MR. YAREMA: Object to the fonn. 10 MR. YAREMA: Object to the form. 11 A Fifth. 11 A Fitlh. 12 Q Between 2002 and 2005 when M. was 12 Q Alan Dershowitz Is also somebody that 13 abused by Jeffrey Epstein sexually, isn't It true 13 you also know to have been at the house wham.. 14 that Jeffrey Epstein took flights to Palm Bench 14 was being sexually abused in Jeffrey Epstein's 15 for the purposes of sexually abusing..? 15 bedroom, correct? 16 MR. YAREMA: Object to the !bon. 16 MR. YAREMA: Object to the tom. 17 A Fifth. 17 A Filth. 18 Q And between those same years of 2002 and 18 Q Generally, Alan Dershowitz is familiar 19 2005, Isn't It true that Jeffrey Epstein look 19 with Jeffrey Epstein's habit of engaging In 20 airplane flights to PnIni Beach from places 20 sexual acts with minors on a daily basis, 21 outside of the State, to engage in sexual nets 21 correct? 22 with M.? 22 MR. YAREMA: Object to the foram. 23 MR. YAREMA: Object to the form. 23 A Fifth. 24 A Fifth. 24 Q When Alnn Dershowitz was in town, 25 Q From 2003 through 2005, isn't It true 25 Jeffrey Epstein did not break Ids schedule for 15 (Pages 54 to 57) U.S. Legal Support (561) 835-0220 EFTA00188949

Case 9:08-cv-§nTIR-k A nnri iment 2q1-21 PritPfPrI nn P nnrkrat n1 /21/2nic Page 6 of 7 1 2 3 4 5 6 58 Alan Dershowitx, meaning he continued to sexually abuse minors despite Alan Dershowitz being a guest In the house? MR. YAREMA: Object to the fonn. A Filth. Q Atnn Dershowitz never engaged in any 1 2 3 4 6 60 Q What was the purpose of that flight? MR. YAREMA: Object to the fbrm. A Fifth. Q Did you sign a confidentiality agreement with Jeffrey Epstein? MR. YAREMA: Object to the font 7 sexual activity with these underage minors; isn't 7 A Fifth. 8 that true? 8 Q When is the last time that you observed 9 MR. YAREMA: Object to the fonn. Jeffrey Epstein have sex with n minor? 10 A Fifth. 10 MR. YAREMA: Object to the font 11 Q Have you been Inside to hove sex with 11 A Fifth. 12 Chislaine Maxwell? 12 Q Since being on probation, has Jeffrey 13 MR. YAREMA: Object to the fonn. 13 Epstein been able to, or has he flown to his 19 A Fifth. 14 Island? 15 Q Do you know 15 MR. YAREMA: Object to the fonn. 16 A Filth. 16 A Fifth, 17 Q Similar to you being Jeffrey Epstein's 17 Q To your knowledge, has Jeffrey Epstein 18 sex slave. is or was 18 flown to New York while on probation or community 19 Chislaine Maxwell's sex slave? 19 control? 20 MR. YAREMA: Object to the fonn. 20 MR. YAREMA: Object to the form. 21 A Fifth. 21 A Fifth. 22 Q Chislaine Maxwell is somebody who you 22 Q Isn't it true that he has flown both to 23 know to be bl-sexual, true? 23 New York and to his island, and you have 24 MR. YAREMA: Object to the fonn. 24 accompanied him on those trips, since he was on 25 A Fifth. 25 community control? 59 61 1 Q You know that Chislakte Maxwell engaged 1 MR. YAREMA: Object to the form. 2 in sexual acts with underage minor females, true? 2 A Fifth. 3 MR. YAREMA: Object to the form 3 Q Isn't it also true that Jeffrey Epstein A Fifth. 4 has indicated to you that he will always engage 5 Q This is yet another friend of Jeffrey 5 in sex acts with underage minor females? 6 Epstein's that is into the act of molesting 6 MR. YAREMA: Object to the fonn. 7 underage minor females, right? 7 A Fifth. 8 MR. YAREMA: Object to the feint Q In fact, that's something that he has 9 A Fifth. 9 told you, that he believes he is entitled to do; 10 Q Now, you are the next participant in 10 isn't that right? 11 that activity, meaning you have been groomed to 11 MR. YAREMA: Object to the fonn. 12 enjoy and appreciate the nets of sex with 12 A Fifth. 13 underage minors, true? 13 Q Isn't it true that Jeffrey Epstein 14 MR. YAREMA: Object to the form. 19 believes and has told you that if he doesn't 15 A Fifth. 15 physically force the underage minor female Into 16 Q Has Jeffrey Epstein instructed you to 16 any act, then he is entitled to engage in sex 17 lie to his Probation Officer in any way? 17 with any underage minor female despite the age? 18 MR. YAREMA: Object to the form. 18 MR. YAREMA: Object to the fonn. 19 A Fifth. 19 A Filth. 20 Q Mr. Visoski testified that you took a 20 Q What is the youngest female you have 21 helicopter flight within the last year with 21 witnessed or observed Jeffrey Epstein to engage 22 Jeffrey Epstein to Miami. Do you remember that 22 in sex with? 23 flight? 23 MR. YAREMA: Object to the form. 24 MR. YAREMA: Object to the form. 24 A Fifth. 25 A Fifth. 25 Q Do you have n bank account at Chase flank 16 (Pages 58 to 61) U.S. Legal Support (561) 835-0220 EFTA00188950

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 9:08-cv-F979A-K A flnrument 991-71 Entered nn P 98 1 2 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Fifth. Q Did you know that Jeffrey Epstein gave A.D. n digital camera? MR. YAREMA: Object to the form. A Fifth. MS. EZELL: I don't have any other questions. Thank you. MR. GOLDBERGER: You still hove your microphone on. You must have something on your mint, Bind. REDIRECT EXAMINATION BY MR. EDWARDS: Q Ms. through the whole day you've taken the Fifth on just about every single question. Is there any reason why we should not presume that the answer to these questions would Incriminate you? MR. YAREMA: Object to the form. A The Fifth. Q The reason that you have taken the Fifth Is because the questions you have been asked would have been answered In the affirmative and you're afraid of prosecution for your Involvement, true? MR. GOLDBERGER: Don't answer that 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 rinrkpt nt /91 OM c Pagp 7 of 7 100 1.11E STATE OF FLORIDA) COUNTY OF PALM BEACH) TEltRI DECKER, a Registered Professional Reporter and Notary Public for the State of Florida at Large, do hereby cenift, that I reported the videotaped deposition or the WITNESS, called by the PLAINTIFF in the above-entitled action; that the witness was duly sworn by Inc; that the foregoing pages, numbered from Ito 104, inclusive, constitute a true record of the deposition by said witness. I further comity that I am not attorney or counsel of any of the parties, nor a relative or employee of any attorney or counsel commit'', with the action, nor financially interested in the action. WITNESS MY HAND and official seal in the City of West Palm Beach, County of Palm Beach, State of Florida, this 19th day of April 38 W. rr— 'TERRI DECKER, Registered Professional Reporter and Notary Public, State of Florida at Large. My Commission expires March 13,2011. 99 1 question. It interferes with the 2 attorney/client relationship that I have 3 with Ms. and any discussions she 4 and I may have had would come under that 5 privilege. 6 You can try and dance around that, but 7 I'm simply not going to allow her to answer 8 that question. If you want to bring it up with the Judge, you can. MR. EDWARDS: Thanks, Jack. MR. GOLDBERGER: Okay. THE VIDEOGRAPHER: Off the video record at I:41 p.m. THE COURT REPORTER: You're ordering this, Brad? MR. EDWARDS: Yes. Copies? MS. EZELL: Yes. MR. YAREMA: Yes: THE COURT REPORTER: And Adam wanted ik is that right? MR. EDWARDS: Yes. (Tune noted: 1:45 p.m.) 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE STATE OF FLORIDA) COUNTY OF PALM BEACH) The foregoing certificate was acknowledged before me this day of 2010. 101 Notary Public, State of Florida. My conunission No. Expires March 13, 201 t. 26 (Pages 98 to 101) U.S. Legal Support (561) 835-0220 EFTA00188951

EFTA00188952

Case 9:08-cv-80736-K,..A Document 291-22 Entered on FL -3 Docket 01/21/2015 Page 2 of 7 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. DEPOSITION OF ADRIANA ROSS Volume 1 of 1 Pages 1 through 138 Videotaped Monday, March 15, 2010 10:13 a.m. - 12:42 p.m. U.S. Legal Support 515 East Las Olas Boulevard, 3rd Floor Fort Lauderdale, Florida 33301 Stenographically Reported By: Janet L. McKinney, RPR, FPR, CLR Registered Professional Reporter Florida Professional Reporter Certified LiveNote Reporter U.S. Legal Support (954) 463-2933 EFTA00188953

Case 9:08-cv-80736-k. .A Document 291-22 Entered on FL J Docket 01/21/2015 Page 3 of 7 2 APPEARANCES: ON BEHALF OF THE PLAINTIFF: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN BY: BRADLEY EDWARDS, ESQ. ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: BURMAN, CRITTON, LUTTIER & COLEMAN, LLP BY: MICHAEL J. PIKE, ESQ. ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES: MERMELSTEIN & HOROWITZ, P.A. 305.931.2200 [email protected] BY: STUART S. MERMELSTEIN, ESQ. ON BEHALF OF THE WITNESS: ROBBINS, TUNKEY, ROSS, AMSEL, RABEN & WAXMAN, P.A. BY: ALAN S. ROSS, ESQ. Also Present: Sean McGuire, Videographer U.S. Legal Support U.S. Legal Support (954) 463-2933 EFTA00188954

Case 9:08-cv-80736-k. Document 291-22 Entered on FL J Docket 01/21/2015 Page 4 of 7 36 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Jane Doe 102 ultimately escaped from him and left to , is that your understanding? A. I refuse to answer. MR. PIKE: Form. Q. Have you ever spoken with Jane Doe 102? A. I refuse to answer. Q. On one of Epstein's birthdays a friend of Jeffrey Epstein sent to him 12 -- three 12-year-old girls from France who spoke no English for Epstein to sexually exploit and abuse and after doing so he sent them back to France the next day. Are you familiar with that? MR. PIKE: Form. A. I refuse to answer. Q. Isn't that something that is fairly common for Mr. Epstein? A. I refuse to answer. MR. PIKE: Form. Q. Who are the friends that send to Jeffrey Epstein underage minor females for his birthday so that he can abuse? A. I refuse to answer. MR. PIKE: Form. Is one of those friends Jean Luc Brunel? Q• A. I refuse to answer. U.S. Legal Support (954) 463-2933 EFTA00188955

Case 9:08-cv-80736-k, ..A Document 291-22 Entered on FL-) Docket 01/21/2015 Page 5 of 7 37 1 2 3 4 5 6 7 9 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Have you ever met Prince Andrew? A. I refuse to answer. Q. Has Prince Andrew been involved with underage minor females to your knowledge? A. I refuse to answer. Q. Have you ever met Alan Dershowitz? A. I refuse to answer. Q. When Alan Dershowitz stays at Jeffrey Epstein's house isn't it true that he has been at the house when underage minor females have been in the bedroom with Jeffrey Epstein? A. I refuse to answer. Q. Has -- are you familiar with the media publication or online resource RadarOnline? A. I refuse to answer. Q. Is that something that you assisted Mr. Epstein with when he purchased RadarOnline? A. I refuse to answer. Q. And do you know his business partner in that endeavor? A. I refuse to answer. Q. Isn't it also true that he used RadarOnline as another way to gain access to underage minor females for sex? MR. PIKE: Form. U.S. Legal Support (954) 463-2933 EFTA00188956

Case 9:08-cv-80736-K. Document 291-22 Entered on FL Docket 01/21/2015 Page 6 of 7 81 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 friends? MR. PIKE: Form. A. I refuse to answer. Q• Who is Sandy Berger? A. I refuse to answer. Q. That's somebody else that was affiliated with Bill Clinton at one point in time, correct? A. I refuse to answer. Q. A close friend of Jeffrey Epstein's? MR. PIKE: Form. A. I refuse to answer. Q. He called the house within three weeks of the search warrant being executed. Did he tip off Jeffrey Epstein? MR. PIKE: Form. A. I refuse to answer. Q. Is he somebody that's involved with underage minors? A. I refuse to answer. Q. Do you know Igor Zinoviev? A. I refuse to answer. Q. A. I refuse to answer. Q. Have you flown on the airplane with Alan Dershowitz before? U.S. Legal Support (954) 463-2933 EFTA00188957

Case 9:08-cv-80736-K, Document 291-22 Entered on FL J Docket 01/21/2015 Page 7 of 7 82 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PIKE: Form. A. I refuse to answer. Q. And Jean Luc Brunel is somebody who you have been on the airplane with several times, correct? A. I refuse to answer. MR. PIKE: Form. And when Jean Luc Brunel is on this airplane Q. there are underage minor minor females on the airplane with you, correct? MR. PIKE: Form. A. I refuse to answer. Q. Is there a back room to this airplane? Is there any sort of separation or is it all one big room? MR. PIKE: Form. A. I refuse to answer. Q. So if Jeffrey Epstein and Jean Luc Brunel are engaged in sex acts with underage minors did you -- A. I refuse -- Q. Sorry -- did you observe any of those acts? A. I refuse to answer. MR. PIKE: Form. Q. And on numerous of the flights the flight logs indicate someone's name then oftentimes initials, but sometimes it would just say "three females". Do you know why? U.S. Legal Support (954) 463-2933 EFTA00188958

EFTA00188959

Case 9:08-cv-80736-r.AM Document 291-23 Entered on i _SD Docket 01/21/2015 Page 1 of 6 EXHIBIT 24 EFTA00188960

Case 9:08-cv-80736-I.AM Document 291-23 Entered on I _SD Docket 01/21/2015 Page 2 of 6 Page 1 IN THECIRCUITCOURT OF TIIE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM DEACFI COUNTY, FLORIDA CASE No.502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff , SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and , individually, Defendants. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 _ _ _ EXHIBITS . . - NUMBER DESCRIPTION PAGE Exhibit number I Eyeglasses 133 VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Wednesday. March 17, 2010 RE I7a.m.- 1:27 p.m. Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida West Palm Beach Office Job #1358 Page 2 Page 4 1 APPEARANCES: 1 PROCEEDINGS 2 1 On behalf of the Plaintiff: MICHAEL PIKE, ESQUIRE. 2 - - - BURMAN CRiTTON LUTTIER & COLEMAN, LLP 3 Deposition taken before Sandra W. Townsend, Court 4 4 Reporter and Notary Public in and for the Stale of 5 5 Florida at Large, in the above cause. 6 6 _ _ - 7 e On behalf of the Defendant Bradley Edwards: JACK SCAROLA, ESQUIRE 7 VIDEOGRAPHER: We are now on video record. SEARCY DENNEY SCAROLA BARNHART& SHIPLEY B This is media number one in the videotaped 9 9 deposition of Jeffrey Epstein in the matter of io 10 Jeffrey Epstein versus Scott Rothstein, Bradley 11 On I:chalk:if the Defendant r 11 Edwards and ■. 12 BRADLEY EDWARDS: ESQUIRE FARMER, JAFFE, WEISSING: EDWARDS, FISTOS, 12 Today is Wednesday, March 17,2010 at 13 13 10:17 a.m. 14 14 We arc at the law offices of Burman, 15 Critton n -- of Burman Critton on 15 16 16 Also Present: 17 STEVEN JAFFE, ESQUIRE 17 FARMER, JAFFE, WEISSING. EDWARDS, FISTOS. 18 The court reporter is Sandra Townsend from Prose 18 19 Court Reporting Agency. 19 20 Would Counsel please introduce yourselves and 21 then the court reporter will swear in the witness. 21 20 22 MR. SCAROLA: My name is Jack Scarola. I am 22 23 Counsel on behalf of Brad Edwards in his capacity, 23 24 24 both as Defendant and Counter-Plaintiff in this 25 25 action. Mr. Edwards is present with me. 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401.377.676.2895) Electronically signed by Sandra Townsend (401-377-676-2895) 1ddctb84-b324-4437-a670-765e29067145 EFTA00188961

Case 9:08-cv-80736-.AM Document 291-23 Entered on . ._SD Docket 01/21/2015 Page 3 of 6 Page 89 Page 91 1 Amendment Rights as provided by the U.S. 1 about. The one in which your deposition is being taken 2 Constitution. 2 today. 3 BY MR. SCAROI.A: 3 Do you know who brought those persons' names 4 Q. Does a flight log kept for a private jet used 4 into this lawsuit? 5 by you contain the names of celebrities, dignitaries or 5 A. As a reaction, and only as a reaction to total 6 International figures? 6 misbehavior on Mr. Edwards' part, and the Complaint we, 7 A. At least today, sir. I'm going to have to 7 obviously written by my attorneys, sir. 8 respectfully decline to answer based on my Fifth, Sixth 8 Q. So you know that those names are in your 9 and 14th Amendment Right, though I'd like to answer that 9 Complaint, right? 10 question. 10 A. Yes, sir. 11 Q. Have you ever had a personal relationship with 11 Q. Okay. So because those names are in your 12 Donald Trump? 12 Complaint, I'm asking you about the people you named. 13 A. What do you mean by *personal relationship," 13 Have you had a social relationship with Tommy 14 sir? 14 Mottola? 15 Q. Have you socialized with him? 15 A. The names in my Complaint are strictly as a 16 A. Yes, sir. 16 reaction to the abusive discovery process by 17 Q. Yes? 17 Mr. Edwards, his partners, Scott Rothstein, who sits in 18 A. Yes, sir. 18 jail, in an attempt to imperil my friendships. 19 Q. Have you ever socialized with Donald Trump in 19 But, yes, I have socialized with Mr. Mottola. 20 the presence of females under the age of 18? 20 Q. Have you ever socialized with Mr. Mottola in 21 A. Though I'd like to answer that question, at 21 the presence of females under the age of 18? 22 least today I'm going to have to assert my Fifth, Sixth 22 MR. PIKE: Form. 23 and 14th Amendment Right, sir. 23 TIIE WITNESS: At least today, the typical to 24 Q. Have you socialized with Alan Dershowitz? 24 the Edwards contention of bringing cases of a 25 A. Yes, sir. He's my attorney, as well as a 25 malicious nature where his partner sits in jail for Page 90 Page 92 1 friend. 1 this --just this type of behavior, the answer is, 2 Q. Have you ever socialized with Alan Dershowitz 2 today, at least, I must assert my Fifth, Sixth and 3 in the presence of females under the age of 18? 3 14th Amendment Right, though I'd like to answer 4 MR. PIKE: Form. 4 each and every one of your questions, Mr. Scarola. 5 THE WITNESS: Sir, at least here today, I'm 5 BY MR. SCAROLA: 6 going to have to assert my Fifth Amendment, Sixth 6 Q. Have you had a social relationship with David 7 Amendment and 14th Amendment Rights. 7 Copperfield? 8 BY MR. SCAROLA: 8 A. As a reaction to, once again, the abusive 9 Q. Have you ever socialized with Tommy Mottola`. 9 discovery process of bringing in names of people that 10 A. This is the type of questions where people who 10 have absolutely nothing to do with any of Mr. Edwards', 11 have nothing to do with this case whatsoever have been 11 Mr. Rothstein's or their clients' claims, by bringing in 12 brought into the case by Mr. Edwards in an attempt to 12 the names of friends of mine strictly in an attempt to 13 simply imperil my relationships with social friends and 13 stress my relationships, imperil my business 14 serves as an example of why this case has been brought 14 relationships, I'm going to say, yes, I do know 15 against Mr. Edwards and his firm, sir. 15 Mr. Copperfield. 16 MR. PIKE: Form as well. 16 Q. Have you ever socialized with David 17 BY MR. SCAROLA: 17 Copperficld? 18 Q. Well, do you know who brought those persons' 18 A. Again, as -- 19 names into this lawsuit? 19 MR. PIKE: Form. 20 MR. PIKE: Form. 20 THE WITNESS: Sorry. 21 And just to be clear, what Mr. Scarola, I 21 It's a typical Edwards/Rothstein strategy of 22 believe, talking about this lawsuit, Epstein versus 22 trying to involve well-known people in maliciously 23 RRA? 23 fabricated cases in order to fleece investors out 24 BY MR. SCAROLA: 24 of millions of dollars. They brought up names in 25 Q. Yes, sir, that's the lawsuit I'm talking 25 attempts at abuse of discovery process to try and 23 (Pages 89 to 92) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401477476.2895) Electronically signed by Sandra Townsend (401.317.676.2895) lddctb84-b324-4437-a670-765e29067145 EFTA00188962

Case 9:08-cv-80736-.AM Document 291-23 Entered on -SD Docket 01/21/2015 Page 4 of 6 Page 16 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. 502008CA037319XXXXMB AB M. s Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. CONTINUED DEPOSITION OF JEFFREY EPSTEIN VOLUME II Thursday, October 8, 2009 10:07 - 1:03 p.m. Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Agency, Inc. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Riccluti (601-280-428-9381) Electronically signed by Joana RIccluti (601.280.428.9381) aalcaccd-2433-45cb-b5a2-c08425252119 EFTA00188963

Case 9:08-cv-80736.. AM Document 291-23 Entered on . -SD Docket 01/21/2015 Page 5 of 6 Page 121 1 respect to the charges brought against you in Palm Beach 2 for having sex with underaged girls and soliciting 3 underaged girls for prostitution? 4 (Interruption in the proceedings.) 5 MR. GOLDBERGER: Thank you. 6 Hey Kathy, it's Jack Goldberger. You're back 7 on. 8 MS. EZELL: Okay, good. Thanks, Jack. 9 MR. GOLDBERGER: Okay. 10 MS. EZELL: I'm putting the mute on. 11 MR. GOLDBERGER: Okay. 12 THE WITNESS: Can you read me the question? 13 MR. KUVIN: Sure. Could you read it back, 14 please? 15 (A portion of the record was read by the 16 reporter.) 17 THE WITNESS: No. 18 BY MR. KUVIN: 19 Q. Isn't it true that you pledged $30 million to 20 Harvard University in 2003, which is shortly before 21 charges were brought against you in Palm Beach? 22 A. I'll answer that question the same way I've 23 answered most of your other questions here today, which 24 is, I fully intend to respond to all relevant questions 25 regarding this lawsuit; however, at the present time, my PROSE COURT REPORTING AGENCY, INC. Electronically signed by Joana Iticcluti (601-280-428-9381) Electronically signed by Jeana Riccluti (601.280-428-9381) a41caccd•2433-45cb-b5a2-c08425252179 EFTA00188964

Case 9:08-cv-80736 .,AM Document 291-23 Entered on . _SD Docket 01/21/2015 Page 6 of 6 Page 122 1 attorneys have counseled me I cannot provide answers to 2 any questions relevant to this lawsuit. I must accept 3 this advice or risk losing my 6th Amendment right to 4 effective representation. Accordingly, I assert my 5 federal constitutional rights as guaranteed by the 5th, 6 6th and 14th Amendment to the US Constitution. 7 Q. And isn't it true also that you have retained 8 Alan Dershowitz to defend you in the criminal charges 9 that were brought against you in Palm Beach? 10 MR. GOLDBERGER: Attorney-client. 11 MR. PIKE: Attorney-client, work product. 12 BY MR. KUVIN: 13 Q. Isn't it also true that Alan Dershowitz works 14 on staff at Harvard University as a professor? I mean, 15 if you know. 16 A. I'm going to answer that question like I've 17 answered most of your other questions here today, which 18 19 20 21 22 23 right to effective representation. Accordingly, I 24 assert my federal constitutional rights as guaranteed by 25 the 5th, 6th and 14th Amendment to the US Constitution. is, I fully intend to respond to all relevant questions regarding this lawsuit; however, at the present time, my attorneys have counseled me I cannot provide answers to any questions that may be relevant to this lawsuit. I must accept this advice or risk losing my 6th Amendment PROSE COURT REPORTING AGENCY, INC. Electronically signed by Joana Ricoh:9 (601-280-428-9381) Electronically signed by Jeana Riccluti (601.280.428.9381) a41caccd-2433-45cb-b6a2-c08425262f79 EFTA00188965

! i EFTA00188966

Case 9:08-cv-80736 ..AM Document 291-24 Entered on . -SD Docket 01/21/2015 Page 1 of 3 EXHIBIT 25 EFTA00188967

• Case 9:08-cv-80736-../AM Document 291-24 Entered on -SD Docket 01/21/2015 Page 2 of 3 JEGE, INC. PASSENGER MANIFEST Registration Number N988JE Type: Tonal DATE: d- -3 2005 FROM Ttr in /0 Lg_S PASSENGERS Arrival Time Pilots: Dave Rodgers, Larry Vbeskl Plight Engineer: Larry Morrison cm* TO 70 ‘. -1- ;b6,--C; ) =Mr 3 /42 4. Coe 5. t,/b Mucieza 7. 8. 1-..44.14) ? 9. 10. 11. 12. 11. 14. 15. 16. 17. Is. 19. FROM Identifier Defined City CO(..tiv er-r State or Country 0 Cie TO Identifier Defined city Lcia 6- Peleat 3PP State or Country Nautical Milos 9/0 statute was 93/ canons Pound* ce4P1-5- Flight Tirool_a t Altitude PL 20. 21. 22. 23. 24. 25. 26. AIRFRAME 33 06 b Night T/L IMC j.1 Approach SAO01561 EFTA00188968

Case 9:08-cv-80736-..AM Document 291-24 Entered on _SD Docket 01/21/2015 Page 3 of 3 JEGE, INC. PASSENGER MANIFEST Regbtration Number: N90$JE Type: B-727.01 DATE: 3 - fa . 2005 FROM /IC nit . Dern Arrival Titre : PM 'rime /2 : VS' gi PASSENGERS I. Jeffrey Eparsin 4. 5. 6. 7, 8. 9. 10. 1t. 12. I3. 14. is, 16. 17. 18. 19. pat 4814e4 * Pilots: Duristiedgera, Lam Viseskt Flight Engineer: Larry Morrison to AAA / 7* Number 3 3 f PROM Identifier Defined City Ater so y ode State or Country ivy TO Identifier Defined City Wtt, AX-. Sate or Country fi t— Nautical Miles cg' Statute Miles C 0 IS' Gallons 3Yeitr e Founds 2 3 ohl Flight Time te at • Allinxie FL 349O AIRFRAME 3.3Oaq./ .Z .3045t(„P 20. Night 21. 7/1. 22. IMC 23. Approach 24. 25. 26. SAO01570 EFTA00188969

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Case 9:08-cv-80736 .AM Document 291-25 Entered on . _SD Docket 01/21/2015 Page 1 of 9 EXHIBIT 26 EFTA00188971

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Case 9:08-cv-80736-KAM Document 291-26 Entered on FLSD Docket 01/21/2015 Page 1 of 2 EXHIBIT 27 EFTA00188981

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Case 9:08-cv-80736-KAM Document 291-27 Entered on FLSD Docket 01/21/2015 Page 1 of 5 EXHIBIT 28 EFTA00188984

Case 9:08-cv-80736-KAM Document 291-27 Entered on FLSD Docket 01/21/2015 Page 2 of 5 Page 1 IN THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502008CA037319 XXXX MB AB a Plaintiff, vs. JEFFREY EPSTEIN, Defendant. VOLUME I VIDEO-TAPED DEPOSITION OF MICHAEL REITER A WITNESS TAKEN BYTilE PLAINTIFF DATE: November 23. 2009 TIME: 10:12 a.m. - 7:38 p.m. Page 3 1 The deposition of MICI IA EL REITER. a witness in the 2 aittled and numbered cause was taken before me, 3 . Archer, Court Reporter, Notary Public for the 4 State of Florida at Large. at 2925 PGA Boulevard, Palm Beach 5 Gardens, Florida, on the 23rd day of November. 2009, 6 pursuant to Notice in said cause for the taking of said 7 deposition on behalf of the Plaintiff. 8 9 APPEARING ON BEHALF OF PLAINTIFF la 10 SPENCER T. KUVIN, ESQ. 11 12 13 APPEARING ON BEHALF OF PLAINTIFFS' JANE DOES 2.8 14 ADAM HOROWITZ, ESQ. is 16 17 APPEARING ON BEHALF OF PLAINTIFF C.A. 18 JACK HILL ARNHART& SHIPLEY. PA 19 20 21 APPEARING ON BEHALF OF PLAINTIFF. 22 ISIDRO GARCIA, Esq. 23 a 25 Page 2 1 2 November 23.2009 3 MICHAEL REITER 4 DIRECT CROSS REDIRECT RECROSS I 7 9 10 11 12 Plaintiffs Exhibit No. I 16 11 (Palm Beach PD Intelligence Report 11/28/041 Plaintiff's Exhibit No. 2 31 14 (Incident Reports) Plaintiffs Exhibit No. 3 99 15 (Letter to Bally Krischer) Plaintiffs Exhibil No. 4 131 16 (Photographs of El Brillo Way) Plaintiffs Exhibit No. 5 132 17 (Photo of 358 El Brillo Woy) By Mr. Ktmn 8 352 By Mr. Garcia 155 364 By Mr. Onion 190 Exitiuns Marked 218 Plaintiffs Exhibit No 7 356 19 (Money Transfers) Plaintiffs Exhibit No 8 357 20 (Flight Summary) 21 Unified Question: Page 160. Line 10 22 23 24 Letter to John Randolph. E-sq. 25 Errata Sheets (to be forwarded upon complebon) Page 1 APPEARING ON BEHALF OF DEFENDANT: 2 ROBERT D. CRITTON, ESQ. COLEMAN. LLP. 3 4 5 JACK GOLDBERGER, ESQ. 6 DSON & WEISS, P.A. 7 8 APPEARING ON BEHALF OF WITNESS: 9 JOANNE (YCONNOR. ESQ. JOHN RANDOLPH, ESQ. 10 BBS, P.A. 11 12 13 14 15 16 18 19 20 21 22 23 24 25 ALSO PRESENT: JEFFREY EPSTEIN VIDEOGRAPHERS: MICHAEL D. DOWNEY EDDIE GUERRERO Sim 1 (Pages 1 to 4) Pleasanton, Gr nd Associates EFTA00188985

Case 9:08-cv-80736-KAM Document 291-27 Entered on [-LSD Docket 01/21/2015 Page 3 of 5 Page 53 1 And at what point did you learn that 2 Mr. Epstein, in fact, did become aware of the 3 investigation? 4 A I think the point that I actually knew 5 that it was, it was reported to me by one of the 6 detectives that one of the victims had been 7 contacted by a private investigator that the 8 department believed was employed by a lawyer of -- 9 employed by Mr. Epstein. 10 Q On that topic, at some point did you 11 become aware that Mr. Epstein was actually 12 investigating you? 13 MR. CRITTON: Form. 14 THE WITNESS: Yes. 15 BY MR. KUVIN: 16 Q Tell me about that? 17 A Well I heard through various individuals 18 that one of his lawyers, Mr. Dershowitz, had been 19 contacting private investigators in the area to 20 perform background investigations on me. I know 21 that there was a public records law demand filed by 22 several private investigators on the Town of Palm 23 Beach for my personnel records. And I actually ran 24 into one of the private investigators very early 25 on -- you asked me when I first became aware -- Page 54 1 Q Yeah. 2 A -- that basically told me that. I also -- 3 I mean I saw surveillance a number of times. I 4 didn't know precisely who had hired those persons, 5 but I mean I had surveillance for a fairly long 6 period of time. 7 Q There was surveillance you noticed on you? 8 A Yes. 9 Q Do you know why? 10 A No, no, I don't. It would be an 11 assumption. In general sense, you know, there's an 12 attack on the case and if that doesn't work there's 13 an attack on the investigators. I don't know. I 14 don't know. Shouldn't say that. 15 MR. CRITTON: Form, move to strike. 16 BY MR. KUVIN: 17 Q You were working as a police officer for 18 twenty-eight years and then as a chief -- well -- 19 A And two years prior to that actually. 20 Q Right. During your entire history as a 21 police officer, can you ever recall someone going to 22 that length? In other words, a suspect conducting 23 an investigation on you such as the lengths that 24 occurred in this case which include surveillance on 25 you? Page 55 1 A No. 2 Q First time ever? 3 MR. CRITTON: Form. 4 BY MR. KUVIN: 5 Q First time you can recall it going to this 6 extent? 7 A The only time I ever recall anyone ever 8 going to this extent. 9 Q How long were you aware there was 10 surveillance on you personally? 11 A Well, you know, I just took the approach 12 that I have nothing to hide, and I just lived my 13 life so I tried not to look around every corner. I 14 felt like it was around three months. 15 Q At any time during the investigation, did 16 you become aware that investigators were also 17 surveilling and investigating potential victims? 18 A That had been reported to us by victims. 19 And the lead investigator in the case also felt like 20 he was being surveilled, people were picking up his 21 trash and so on. 22 Q Is that Detective Recarey? 23 A Yes. 24 Q So there was a time that your officers 25 became aware it was being investigated on? Page 56 1 MR. CRITTON: Form. 2 THE WITNESS: One officer, one detective. 3 BY MR. KUVIN: 4 Q To the extent they were picking up his trash? 6 A Yes. 7 Q Were you aware of that ever occurring in 8 your career to officers working under you? 9 A I didn't say it never occurred to this 10 degree. 11 Q Got you. 12 A I think if you're asking the question do I 13 know of any other law enforcement officers who know 14 as part of their job somebody investigated them and 15 picked up their trash, not that I can specifically 16 recall. 17 Q Okay. 18 A Other than the police department itself, 19 we've had private investigators take trash at the 20 police department itself, we've caught people doing 21 that. 22 Q Obviously at some point Mr. Epstcin was 23 tipped off as to the investigation because of the 24 investigators that you became aware of. Did you 25 ultimately know how he became tipped off? 14 (Pages 53 to 56) Pleasanton, Greenhill, Meek and Associates EFTA00188986

Case 9:08-cv-80736-..AM Document 291-27 Entered on . 3D Docket 01/21/2015 Page 4 of 5 Page 101 1 MR. CRITTON: Form. 2 THE WITNESS: Well, early on I had -- when 3 I first told him about the case and I realized 4 that it was a serious case, there were multiple 5 victims, that the suspect was very well known, 6 I told him about it. And we were -- it was in 7 person, I talked to him after a meeting that he 8 and I were both involved in. And I had known 9 him to be a victim advocate and to protect the 10 rights of children. Well I know that he even 11 wrote a portion of the statute that addresses 12 those issues. And when I told him about it 13 originally he said let's go for it, this is an 14 adult male in his fifties who's had sexual 15 contact with children of the ages of the 16 victims. He said this is somebody who we have 17 to stop. And whatever we need, he said, in the 18 State Attorney's Office, we have a unit that's 19 equipped to investigate and prosecute these 20 kinds of cases. I think he probably mentioned 21 Lanna's name to me and anything that you need 22 and, you know, this is basically a case that 23 needs to be prosecuted. 24 And I didn't have too many facts early on 25 when I talked with him, but I knew that there Page 103 1 directly? 2 MR. CRITTON: Form. 3 THE WITNESS: He told me that he had 4 conversations with Mr. Dershowitz. I know Roy 5 Black. At least the news media reporter was 6 involved in this and I think that he said that 7 he had a conversation with him. I think Roy 8 Black had another case with that circuit around 9 the same time and maybe even other lawyers that 10 represented Mr. Epstein, and they were 11 obviously discussing the case. And he 12 basically told me that he looked at Facebook 13 pages of some of the victims and that he felt 14 like they were incredible. 15 And I have never felt like prosecutions, 16 evidence should be weighed outside of the 17 judicial process. I just don't -- we wouldn't 18 cover our ears and eyes when a person under 19 investigation's lawyer would bring forward 20 exculpatory evidence, but on the other hand 21 we're not the weigher of fact in these things. 22 We reach the standard of probable cause and 23 beyond, and that's when a judge, or in this 24 particular case a State Attorney, should make 25 those decisions. Page 102 1 were multiple victims and to our detectives 2 they were believable. So when time went on and 3 Mr. Epstein became aware of the investigation 4 and his lawyers contacted the State Attorney's 5 Office, they told me that. 6 And from that point on, and I believe it 7 was Mr. Dershowitz initially, the tone and 8 tenor of the discussions of this case with 9 Mr. Krischer changed completely. One point he 10 suggested that we write him a notice to appear 11 which would be for a misdemeanor. He just 12 completely changed from not only our first 13 conversation about this and he didn't know the 14 name Jeffrey Epstein, till when he had been 15 informed on Mr. Epstein's reputation and his 16 wealth, and I just thought that very unusual. 17 I feel like I know him or knew him very 18 well, the State Attorney, and I just felt like 19 he could not objectively make decisions about 20 this case; that is why I wrote it. 21 BY MR. KUVIN: 22 Q Was there anything that you learned 23 through discussions with him that led you to believe 24 maybe his objectivity had been altered in some 25 regards; in other words, anything he told you Page 104 1 And he had been meeting with them without 2 the presence of our investigators. I don't 3 mean he personally but at least -- probably he 4 personally but definitely members of his 5 office, and he hadn't been sharing that 6 information with us. 7 He hadn't, you know -- he characterized it with me but he didn't show us the things, at 9 least not exhaustively, that had been given to 10 him by Mr. Epstein's attorneys. I just felt 11 like that was wrong. Those are the reasons. 12 BY MR. KUVIN: 13 Q Have we exhausted the reasons why you felt 14 that this case, at least you put in your letter, 15 was the handling of this case was highly unusual? 16 Was there anything else that you felt was highly 17 unusual regarding the investigation? 18 A Well the Dahlia Weiss being involved in 19 this case with her husband as a lawyer for I'm 20 not saying that anything happened there, but there's 21 certainly an appearance of impropriety. I felt like 22 that alone should have been reason enough. First of 23 all for her to be disqualified as soon as she became 24 aware that a law firm that -- not disqualified but 25 removed from the case as soon as she became aware 26 (Pages 101 to 104) Pleasanton, Greenhill, Meek and Associates EFTA00188987

Case 9:08-cv-80736-..AM Document 291-27 Entered on . 3D Docket 01/21/2015 Page 5 of 5 Page 105 1 that her husband's law firm had represented Mr. 2 Epstein. And maybe even done damage to the point 3 that because that happened it should be handled by 4 another circuit. 5 This was a case that I felt 6 absolutely needed the attention of the State 7 Attorney's Office, that needed to be prosecuted in 8 state court. It's not generally something that's 9 prosecuted in a federal court. And I knew that it 10 didn't really matter what the facts were in this 11 case, it was pretty clear to me that Mr. Krischer 12 did not want to prosecute this case. 13 Q Did he, in fact, make that clear to you at 14 some point verbally? 15 A Not in those exact words. But the 16 suggestion that multiple victims and some of the 17 crimes, felonies, that he should write a notice to 18 appear for a misdemeanor and the scheduling of a 19 grand jury on an issue like this is extremely rare. 20 The fact that he and I had an 21 excellent relationship. I was the speaker at his 22 swearing in ceremony. And that he wouldn't return 23 my phone calls, I mean it was clear to me by his 24 actions that he could not objectively look at this 25 case. Page 106 1 Q At some point, did you feel, or did you 2 become aware, that maybe he had been threatened in 3 some regard, either regarding his job or personally 4 in any regard? A No. 6 MR. CRITTON: Form. 7 BY MR. KUVIN: Q You're aware that obviously his position 9 is an elected position? 10 A lam aware. 11 Q Did you know whether or not he had had any 12 discussions with anyone about his political career 13 if this case did not go a certain way; did you ever 14 become aware of that in any regard? 15 MR. CRITTON: Form. 16 THE WITNESS: No. He had already publicly 17 announced he wasn't running for re-election. 18 MR. KUVIN: All right. This is actually a 19 good stopping point for a quick lunch if you 20 want to take a quick one, I just have to eat. 21 I'm hopefully not far from concluding. 22 THE VIDEOGRAPHER: We're off the record at 23 12:35. This is the end of tape 2. 24 (Recess) 25 THE VIDEOGRAPHER: We're back on the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 107 record at 1:44. This is the beginning of tape 3. BY MR. KUVIN: Q Okay. When we left off we were talking about Barry Krischer's office. And before I move on from that subject I just have one other question. Are you aware of any contact that was made with Mr. Krischer's office from anyone in the democratic party or the DNC at all? MR. CRITTON: Form. THE WITNESS: Relative to this case? BY MR. KUVIN: Q Yes, relative to the Epstein case? A No. Q Are all of the officers that were involved in the investigation listed or contained within the incident report that we've marked as Exhibit 2, and were there any additional officers that were involved that may not be listed in there? A Typically and generally when you say involved, I mean that could encompass all sorts of different people. It might be -- I don't even know that this was the case but it might ask the patrol officer in the area to collect license tags from a street or something like that. I mean if they Page 108 1 aren't writing a report and they aren't doing 2 something that's probably important later on as a 3 witness, they might not appear in there. But the 4 detectives who conducted the investigation are 5 listed in there from what I recall the last time I 6 read it, and it's been a while, but as far as I 7 know. 8 Q At any point, did you have to remove for 9 any reason anyone in your department from the 10 investigation for any reason? 11 A No. It took place over a fairly long 12 period of time so people were transferred and so on, 13 but I didn't personally remove someone for any 14 reason. 15 Q And it may not have been you personally, 16 but just to make sure that it encompasses all 17 potential iterations of that question, was anyone 18 removed for any reason other than just someone 19 transferring out? 20 A Do you mean for -- I think you have to 21 explain that. 22 Q Were any of the investigating police 23 officers removed for any potential conflicts, 24 refusal to follow direction, any reason, other than 25 just a transfer out of the department for some Pleasanton, 27 (Pages 105 to 108) Greenhill, Meek and Associates EFTA00188988

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Case 9:08-cv-80736-. .44 Document 291-28 Entered on . 3D Docket 01/21/2015 Page 1 of 5 EXHIBIT 29 EFTA00188990

Case 9:08-cv-80736....AM Document 291-28 1 2 3 4 5 Page 2 ROMA IN THE CIRCUIT COURT OF THE ENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, CASE No.502008CA037315900004B AB 6 VOLUME! OF II 7 JEFFREY EPSTEIN 6 AND 9 Defendants. 10 11 12 DEPOSMON OF 13 DETECTIVE. JOSEPH RECAREY 14 Friday, March 19, 2010 15 16 17 18 19 20 21 22 Reported By: 23 Cynthia Hopkins, RPR, FPR Notary Public, State of Florida 24 Prose Can Reporting Job No.: 1509 25 "a".. 1 Page 3 2 UNTIED STATES DISTRICT COURT 3 SOUTHERN DISTRICT OF FLORIDA 4 CASE NO. 10-80309 5 JANE DOE NO. 103, 6 7 -vs- VOLUME I OF II 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 12 DEPOSITION OF 13 DETECTIVE JOSEPH RECAREY 14 Friday, March 19, 2010 15 9:37 - 5:12 m 16 17 18 19 20 21 22 Reported By: 23 Cynthia Hopkins, RPR, FPR Notary Public, State of Florida 24 Prose Court Reporting Job No.: 1509 25 Entered on . .SD Docket 01/21/2015 Page 2 of 5 1 APPEARANCES: 2 Oa Mho/ford= Plaintiffs," 3 SPENCER T. KUVrN, UfRE K I 6 7 On behalf of the Plaintiff:1.u.. and lane Doe: a 9 BRADLEY J. @WARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS 10 IRMAN 13 On owe 1 dutch 8: 14 JESSICA ARBOUR, ESQUIRE .t.,410WITZ. P.A. 15 16 17 18 19 20 ICAIIIERINE W. EZELL, ESQUIRE 21 22 23 in 24 25 Sera& Ahatowildasexabiseatanney.con On behalf ache Hatt Jane Does 101, 102/M 103: Page .; Page 1 Appeantnces oontirhted.. 2 On Wulf of the Pluntiffs. 3 ISIDRO MANUEL GARCIA, PIQIIIRE MUNGER 4 7 TARA A FINNIGAN, ESQUIRE GAN, P.A. 8 10 11 12 On betalfofthe Defendant kIlier EPOS: MICIIAEL PIKE ESQUIRE 13 , LUITER & COLEMAN, LLP 15 16 and 17 JACK ALAN GOLDBERGER. ESQUIRE ER ER & WEISS, P.A. 18 20 21 and 22 MILTON 0. WEINBERG, ESQUIRE OF MILTON O. WEINBERG 23 25 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA00188991

Case 9:08-cv-80736-.,AM Document 291-28 Entered on _SD Docket 01/21/2015 Page 3 of 5 Page 279 1 Q. I mean, I'm sorry for such a bad question, 2 but in looking at these property receipts, I just 3 don't see where it tells me how much time each 4 interview had taken. So, I mean, is there an 5 average? 6 A. That's not going to indicate on any property 7 receipt. There is no... B Q. Right. Okay. Have you ever seen the 9 nonprosecution agreement? 10 A. No. 11 Q. Have you ever seen the attached list of 12 victims that was attached as an addendum to the 13 nonprosecution agreement? 14 MR. PIKE: Form. 15 THE WITNESS: I believe the Chief had a 16 copy of it. He may have, you know, done one of 17 these, but, no, not in my physical hands. 18 MR. PIKE: And just for the record when 19 the witness said — 20 THE WITNESS: I held it up. 21 MR. PIKE: -- one of these, he held up 22 Exhibit 29. 23 MR. EDWARDS: Which said memorandum. 24 MR. PIKE: Memorandum. 25 THE WITNESS: I just held it up. Page 281 1 A. I remember getting documents from Alan 2 Dershowitz which were flight logs pertaining to 3 Mr. Epstein's plane. And I subpoenaed the information 4 from Jet Aviation, but I don't, I don't recall preparing 5 a flight log. 6 Q. Okay. Do you remember receiving 7 information from Jet Aviation directly? 8 MR. PIKE: Form. 9 THE WITNESS: Jet Aviation does not keep 10 records according to them as to who flies on 11 what plane. I guess you can just drive up to a 12 plane, board it. They have no idea who's on 13 the, who is flying on the plane. They have 14 records of when the plane comes in, if the 15 plane is serviced, and when the plane leaves. 16 BY MR. EDWARDS: 17 Q. Did you ever attempt to check with customs 18 or FAA on any of the passengers that have ever been 19 on international flights with Jeffrey Epstein or on 20 his planes? 21 MR. PIKE: Form. 22 THE WITNESS: I'm trying to recall. 23 BY MR. EDWARDS: 24 Q. At the current time do you have any 25 knowledge of that being done by either the U.S. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 280 BY MR. EDWARDS: Q. If a memorandum exists and it is the attached addendum to the nonprosecution agreement containing the names of the underage victims, would that be something in the possession currently of the Palm Beach Police Department? MR. PIKE: Form. THE WITNESS: I don't believe so. BY MR. EDWARDS: Q. Is that something that's been destroyed or also -- MR. PIKE: Form. THE WITNESS: I never received a copy of it so... BY MR. EDWARDS: Q. Have you ever seen it? A. Like 1 said, I may have seen it. I may have been shown it, you know, and just by holding it up and I am only using this exhibit as an example. It may have been just shown to me like this but not in my hands where I actually read the entire document. MR. PIKE: Move to strike. BY MR. EDWARDS: Q. In your investigation, did you prepare a flight log summary? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 282 Attorney's office or the FBI? A. I have no idea what the FBI does. They are primarily one way. You give them the information and nothing comes back, so... Q. I am starting to get that idea. I am understanding that. Okay. A. But you know, and I work with them almost on a daily basis, so I am in direct contact with them. And still I have yet to see information come back the other way. Q. Just so the record is clear, when you say you're working with them on a daily basis, when you're in the Organized Crime Unit on other cases, correct? A. Yeah, and I am also assigned to the JTTF, the Joint Terrorism Task force here in West Palm Beach. Q. My understanding from reading your reports is that you also subpoenaed phone records of numerous individuals, correct? A. Correct. Q. One of those individuals is Jeffrey Epstein? A. I believe so. A. Yes. 39 (Pages 279 to 282) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkIns (601-051.976.2934) Electronically signed by cynthia hopkIns (601-051.976.2934) sa2a5ddb-fa81-O(6-b3b7-dcda51494142 EFTA00188992

Case 9:08-cv-80736-..AM Document 291-28 Entered on —.3D Docket 01/21/2015 Page 4 of 5 Page 299 1 stuck around just to assist the victims. 2 BY MR. EDWARDS: 3 Q. And when you talk about the statement that 4 you provided, did you present testimony related to 5 all of the minor females that you discovered to have 6 come in contact with Jeffrey Epstein or only the 7 four or five names that ultimately were at the end 8 of your probable cause affidavit? 9 MR. PIKE: Form and compound. 10 'NE WITNESS: As far as my testimony at 11 the grand jury, I only answered the questions 12 that were asked of me by the state. At that 13 point it was Lanna Belohlavek. 14 I'm sorry about the last name. Won't 15 know how to spell her last name. 16 BY MK EDWARDS: 17 Q. And in talking with the State Attorney's 18 Office during the investigation, did you indicate to 19 them the number of underage females that you were 20 aware had come in contact sexually with Mr. Epstein? 21 MR. PIKE: Form and assumes facts not in 22 evidence. 23 THE WITNESS: Yes, they were aware of the 24 probable cause affidavit which indicated all 25 the facts. Page 301 1. between the Palm Beach Police Department and the 2 State Attorney's Office? 3 A. Yes, there was. 4 Q. And -- 5 A. This case was originally brought to their 6 attention very early on in the investigation to which 7 they were, you know, very gung-ho, very let's go, let's 8 do this, up until, up until, up until the meeting with 9 Alan Dershowitz and the State Attorney. And then it, it 10 all took a turn. 11 Q. Were you at that meeting? 12 A. 1 attended one meeting where I believe it 13 Dershowitz, Krischer, and Belohlavek. 14 MR PIKE: Object to form. 15 BY MR. EDWARDS: 16 Q. What was said during that meeting? 17 MR. PIKE: All right. With regard to this 18 line of questioning, I just want to be clear 19 that I have form objections to this line of 20 questioning. And the fact that under various 21 Federal Rules, I believe it's 408, 410 as well 22 as various rules under Florida Evidence Code, 23 some of these discussions are protected as 24 potential plea negotiations. So, having said 25 that... 1 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 300 BY MR. EDWARDS: Q. And can you recall what their position was on the various acts that are related in the probable cause affidavit? And ultimately I am asking why is it that they were not interested in hearing from all of the girls and only a select few? MR. PIKE: Form and compound. THE WITNESS: That's a question that you're going to have to ask Lanna Belohlavek because she was aware of all the people that I submitted to her, and yet she choose three people to appear before the grand jury, one knowing that she was not going to be able to appear. MR. PIKE: Move to strike. BY MR. EDWARDS: Q. And who was the person that was not going to be able to appear? A. That would have been Jane Doe No. 103. Q. Do you know why she was unable to appear? A. Because it was finals week in her university and the limited time that they had scheduled the grand jury and the time that it would have been for her to make arrangements to come down was very short. Q. Was there a disagreement about this case Page 302 1 BY MR. EDWARDS: 2 Q. What was said during these, this meeting 3 that you attended? 4 A. Several of the girls' MySpaces were discussed. 5 MySpace being the social network. They all had 6 MySpaces. And the girls, the girls were actually who 7 had the MySpaces had inputted, you know, various 8 different things regarding alcohol use or marijuana use 9 or that kind of thing. 10 Q. And what was brought up at that meeting as 11 to the relevance of whether or not these females 12 that had been to Jeffrey Epstein's house while 13 underage used alcohol or drugs? What was the point 14 of that? 15 MR. PUCE: Form. 16 THE WITNESS: To show that the character 17 of the girls were not, was not to be believed. 18 BY MR. EDWARDS: 19 Q. Okay. It was specifically to attack their 20 credibility? 21 MR. PIKE: Form, move to strike. 22 THE WITNESS: Correct. 23 BY MR. EDWARDS: 24 Q. So, at that point in time who was making 25 those arguments on behalf of Jeffrey Epstein? PROSE COURT REPORTING Electronically signed by cynthla hopktns (601-051-976-2934) Electronically signed by eynthia hopkins (601-051.976-2934) Electronically signed by cynthla hopkins (601-051.976.2934) 44 (Pages 299 to 302) AGENCY, INC. aa2a5ddb-1481-06-b3b7-deda51494142 EFTA00188993

Case 9:08-cv-80736...AM Document 291-28 Entered on . .SD Docket 01/21/2015 Page 5 of 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 307 attorneys have been unanswered and messages remain unreturned. Is that a statement that you agree with? A. Absolutely. Q. How many messages do you think that you left the State Attorney's Office that were unreturned? A. Quite a few. I actually showed up at Lanna's office because I had left her several messages and didn't, didn't return get a return phone call. And it was during the time where: We're going to the grand jury, no, we're not going to grand jury-, yes, we're going; no, we're not. And it was, I believe, the following day when we were supposed to go to the grand jury and I still had not heard from her as to what time nor had I received a subpoena So, I had contacted her numerous times during that day. I would say three to four times during that day. In the afternoon actually showed up at her office where she was sitting in her office. Q. Did you speak with her? A. Yes, I did. Q. And what happened within that conversation? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 309 1 A. Correct. MR. PIKE: Form. BY MR. EDWARDS: Q. So, are you talking about A.D., C.L., S.G., and Jane Doe No. 103? MR. PIKE: Form. THE WITNESS: From S.G.'s family I had gotten multiple phone calls during that day. BY MR. EDWARDS: Q. During any of the meetings -- how many meetings are you aware of that Mr. Dershowitz participated in with the State Attorney's Office? A. There were a couple. Like I said, I attended one. MR. PIKE: Form. THE WITNESS: I didn't attend the second one. I want to say two to three. BY MR. EDWARDS: Q. And he is a person who also is found in the message pad as somebody who has called Jeffrey Epstein's home, correct? A. As far as I can recall, yes. Q. And did he ever indicate to them that he was actually at the home on various occasions when some of these underage girls would come over to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 308 MR. PIKE: Form. TI-LE WITNESS: There was actually a time where there was a plea negotiation being discussed where it was to one count of felony, five years probation, and I believe no one had been contacted regarding to that negotiations. BY MR. EDWARDS: Q. When you say no one, are you speaking about the police or victims? MR. PIKE: One second. Form. I'm going to move to strike and I am going to continue to assert the same privileges under the Federal Rules 408, 410, and 401.9. I'm sorry. Go ahead. BY MR. EDWARDS: Q. When you say no one had been contacted, are you speaking about no police officers that were on the case or no victims? A. Both the police officers and the victims because I was getting phone calls from the victims' parents as to what time are we needed. Q. And when you say we were getting phone calls from the victims' parents, are those the victims that ultimately were listed as victims in the, in the plea that transpired? Page 310 1 Mr. Epstein's house? 2 MR. PIKE: Form. 3 THE WITNESS: Not that I recall. 4 BY MR. EDWARDS: 5 Q. In fact, was he trying to convey to the 6 State Attorney's office that you should not believe 7 these girls that they were at his house at all 8 because they have credibility problems? 9 MR. PIKE: Form, asked and answered. 10 THE WITNESS: That's, that was the 11 impression I received, yes. 12 MR. EDWARDS: The next portion is going to 13 take a long time. I mean it's getting into the 14 juice of it. So, are we at a point that you 15 want to stop rather than getting into something 16 that's going to take a long time? 17 MS. O'CONNOR: How long? 18 MR. EDWARDS: Couple of hours. 19 MS. (YCONNOR: I need to stop. 20 MR. KUVIN: Okay. 21 MR. PUCE: All right. So we are going to 22 break. We have an agreement on the record that 23 Detective Recarey, and correct me if I am 24 wrong, Ms. O'Connor will get back to us through 25 you sometime next week with a few available 46 (Pages 307 to 310) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) aa2aftddb-fa81-41%-b3b74/cda61494142 EFTA00188994

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Case g:08-cv-00,S6 ...I Document 291-29 Enle... _SD...01/MM Page 1 of 1 SEALED DOCUMENT EXHIBIT 30 EFTA00188996