Page 101 1 A. A few months ago. I don't remember exactly 2 date. 3 Q. Who else has a copy of this book? 4 A. I don't know who has one. 5 Q. Well, you do or you did. How about 6 7 A. I think she read it. It was kept in my, in my 8 file in my office so it was -- 9 Q. So, is it your understanding that there is 10 only one copy of this book? 11 A. Could be another one in the office in New 12 York. I don't know. 13 Q. Okay. Who was the author of that book, do 14 you know? 15 A. I don't know. 16 Q. I mean did Mr. Epstein write it himself? 17 A. I have no idea. 18 Q. Okay. 19 A. I don't know who made those things. 20 Q. Is this a manual that's universal for the 21 organization, and by that I mean, used in the New 22 York house the New Mexico house, Florida house? 23 A. Could be. I'm not sure. 24 Q. Is it your understanding that prior to the 25 execution of the search warrant that in addition to (561) 832-7500 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) (561) 832-7506 NUSaNdam4MSae22454O182AN 3507.011 Page 101 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006765 EFTA00158350
Page 102 1 the young females that would come to Mr. Epstein's 2 West Palm house or Palm Beach house, if Mr. Epstein 3 was in New York, similarly young females would come 4 to that house to give him a massage, and similar to 5 that, same thing would happen in New Mexico and 6 elsewhere? 7 A. I don't know. 8 MR. GOLDBERGER: Form. 9 BY MR. EDWARDS: 10 Q. You just don't know. 11 A. No. 12 Q. Not something that you ever discussed with 13 anybody? 14 A. No. 15 Q. All right. Going back to the message 16 pads; there are three locations where these massage 17 pads were situated within the house, right? 18 A. Right. 19 Q. The one in the kitchen was always by the 20 phone? 21 A. Yes, or close to the phone or on the counter 22 somewhere, you know. Usually what I did, I grab any 23 piece of paper, write down the name who calling and 24 write down on this message -- 25 Q. Okay. (561) 832-7500 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) (561) 832-7506 2W5a9W4eaa42113-m224,MUTIWWle 3507-011 Pagc 102 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006766 EFTA00158351
Page 103 1 A. -- book. 2 Q. So, sometimes people would call and you 3 would take messages on something other than the 4 message pad that we're familiar with? 5 A. Yeah. 6 Q. All right. But you know what I am talking 7 about when I am referring to this message pad, 8 right? 9 A. Yes, yes. 10 Q. It has a carbon copy sheet? 11 A. Right. 12 Q. And for the most part that's where most of 13 the messages were taken down? 14 A. Yes. 15 Q. So, there is one in the kitchen somewhere 16 near the phone? 17 A. (Witness nods head). 18 Q. Right? 19 THE COURT REPORTER: You have to say yes 20 or -- 21 THE WITNESS: Yes. 22 BY MR. EDWARDS: 23 Q. Remember we have her here? 24 A. Yes. Now, I remember. 25 Q. I am understanding you. But there is one (561) 832-7500 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) (561) 832-7506 205891d-Uaa-42b3-ae22-bSd30182dle 3507-011 Page 103 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006767 EFTA00158352
Page 104 1 in your office by your desk presumably also by a 2 telephone? 3 A. Yes. 4 Q. And there is one in the office near the 5 kitchen? 6 A. Right. 7 Q. Also near a telephone? 8 A. Yes. 9 Q. And you've taken those messages down when 10 some of these young females would call, right? 11 A. Anybody, yes. 12 Q. Yeah. But you know, I realize a lot of 13 people probably call Mr. Epstein. 14 A. Right. 15 Q. For the purposes of this case, I am not 16 all that interested in all the messages he gets. I 17 really want to go focus on the message he gets from 18 someone like Or III . Or or somebody that 19 you recognize as being one of these young females 20 reportedly coming over to give him a massage. Okay? 21 MR. GOLDBERGER: Form. 22 THE WITNESS: Okay. 23 BY MR. EDWARDS: 24 Q. So, are you familiar with certain messages 25 where somebody will call and say this is III., I (561) 832-7500 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) (561) 832-7506 2d75a9td4eaa42b3-m224MUTIMMU 3507.011 Pagc 104 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006768 EFTA00158353
Page 105 1 have a girl for Mr. Epstein? 2 MR. GOLDBERGER: Form. 3 THE WITNESS: No. 4 BY MR. EDWARDS: 5 Q. Okay. You don't remember any messages 6 like that? 7 A. No. 8 Q. Do you remember ever there being a 9 circumstance where somebody called and said I have 10 girls for him or I have a friend that would like to 11 come over and see him? 12 A. No. 13 Q. All right. If you had taken down any of 14 those messages, that may have been alarming to you 15 or told you that, hey, there is something going on 16 here that may not necessarily be perfectly legal? 17 A. I don't know how, you know, how to -- 18 Q. That's just not something you ever saw, 19 right? 20 A. Never saw it. 21 Q. Okay. When the police came into the house 22 to execute the search warrant, where were the 23 message pads? 24 A. In the same places as I recall because they, 25 they usually be around the phone. So, I assume they (561) 832-7500 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) (561) 832-7506 2d75891d-3eaa-42b3-8e22-b5d3c7182dle 3507-011 Pagc 105 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA _00006769 EFTA00158354
Page 106 1 were still on the places next to the phone in each room. 2 Q. You don't remember the message pads being 3 removed from the property prior to the police 4 arriving to execute the search warrant? 5 A. No. 6 Q. So, it's your belief that the police 7 obtained or confiscated the message pads at the time 8 they executed the search warrant? 9 A. Yes. 10 Q. Do you know that to be a fact? 11 A. No. 12 Q. You're just going based on they were 13 always there; we didn't know the police were coming; 14 the police came, and they confiscated a bunch of 15 stuff and if the message pads were there, they 16 confiscated the message pads? 17 A. Yes. 18 Q. Just logical reasoning? 19 A. Right. 20 Q. Did the police ever question you about the 21 messages that were taken down on this message pad 22 from these young females that were at the house to 23 give Mr. Epstein a massage? 24 MR. GOLDBERGER: Form. 25 THE WITNESS: Yes. FBI showed me some (561) 832-7500 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) (561) 832-7506 2d7Sagl d-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Pagc 106 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006770 EFTA00158355
Page 107 1 copies of my writing those messages, and they 2 ask me if they, if it was me who took those 3 message. 4 BY MR. EDWARDS: 5 Q. And some of the messages you took down? 6 A. Yes. 7 Q. So, some of the times these young females 8 would call and you would be the one to answer the 9 phone? 10 A. Yes. 11 Q. And what do you remember these young 12 females saying to you as their purpose for calling? 13 A. As I recall, a couple of them that they call 14 that they cannot show up at a certain time and they have 15 to do something else. So this was the messages I 16 remember I wrote down on those messages. 17 Q. I don't have great photos here, but I just 18 want to show you this photo. Tell me if you 19 recognize that person. 20 A. No. 21 Q. Okay. Show you this photo and tell me if 22 you recognize that person. 23 A. No. 24 Q. Okay. This is an updated photograph of 25 Do you recognize her now that I tell you that (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 Nff5a9M-3eaa42b3-m224MUMMU 3507.011 Page 107 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000677I EFTA00158356
Page 108 1 that is III.? 2 A. No. I, I recognize I remember the name, 3 but I don't recognize the face. I will not connect, no, 4 name with the faces. 5 Q. Okay. I mean, it's 2010 now. So this is 6 a photograph that was taken of a person who you 7 would have seen five years ago? 8 A. Right. But still, I don't, I don't recognize 9 her. 10 Q. Okay. Have you talked to Jeffrey Epstein 11 personally about the criminal investigation or any 12 of the things that have been told to you happened 13 inside the bedroom aside from the massage? 14 MR. GOLDBERGER: Form. 15 THE WITNESS: No. 16 BY MR. EDWARDS: 17 Q. Do you ever intend to talk to him about 18 that? 19 A. No. 20 Q. It really, as part of your employment, 21 it's not really of any concern to you what he does 22 up in his bedroom? 23 A. Right. 24 Q. I mean, that's basically your position, 25 right? (561) 832-7500 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) (561) 832-7506 2d75a91dJean-42b3-ae22-b5d3c7192dle 3507-011 Page 108 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006772 EFTA00158357
Page 109 1 A. Yes. 2 Q. I mean, if something is going on inside 3 the house that is illegal, that's not something 4 that's really your job duty to investigate, 5 6 7 8 discover, or tell anybody about, right? MR. GOLDBERGER: Form. THE WITNESS: Yes. BY MR. EDWARDS: 9 Q. I mean that statement that I made is true? 10 MR. GOLDBERGER: Form. 11 THE WITNESS: That if I would know that 12 something is going on I would be -- 13 BY MR. EDWARDS: 14 Q. Yeah. I mean if you knew that something 15 was going on inside the house that was illegal -- 16 A. Right. 17 Q. -- that's not something that really should 18 be of any concern to you, right? 19 MR. GOLDBERGER: Form. 20 THE WITNESS: I would be concerned I would 21 say. If something was going illegal, I would 22 be concerned. 23 BY MR. EDWARDS: 24 Q. Well, I mean you're aware at this point in 25 time that he has pled guilty to several felonies (561) 832-7500 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) (561) 832-7506 aff5a9W4ezia42113-m224:6(1.1a1WWle 3507-011 Pagc 109 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006773 EFTA00158358
Page 110 1 related to what was going on inside the bedroom? 2 MR. GOLDBERGER: Form. 3 THE WITNESS: Right. 4 BY MR. EDWARDS: 5 Q. And that's not something that you're 6 obviously holding against him in any way. You still 7 working for him? 8 A. Yes. 9 Q. Is that something that's factored into 10 your employment with Jeffrey Epstein or the way you 11 think about him or anything else? 12 MR. GOLDBERGER: Form. 13 THE WITNESS: I mean, it's some concern 14 but at the same time, you know, I think it's 15 happened without, I would say, his intended to 16 do on a purpose I would say. 17 BY MR. EDWARDS: 18 Q. What do you mean by that? I don't 19 understand? 20 A. That he for example he having the affair 21 with the underage girls, right? 22 Q. Okay. 23 A. So, I assume he didn't know. 24 Q. He didn't know? 25 A. The age of those girls. (561) 832-7500 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) (561) 832-7506 2d75891d-Uaa-42b3-ae22-bSac7182dle 3507-011 Page 110 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006774 EFTA00158359
Page 111 1 Q. Okay. You're, you're thinking that or 2 hoping or whatever, believing that Mr. Epstein 3 didn't know the age of the girls that were coming 4 over? 5 A. Yes. 6 MR. GOLDBERGER: Form. 7 BY MR. EDWARDS: 8 Q. Okay. But you're -- so would your opinion 9 change if -- you know, it really doesn't matter what 10 your opinion is. Never mind. Not that I don't care 11 about your opinion, it just doesn't matter a whole 12 lot with respect to the case. 13 In terms of the accumulation of these 14 young females who were coming to the house, you were 15 told that they were coming only for a massage, 16 right? 17 A. Right. 18 Q. And at some point in time you learned that 19 there was a lot more going on than a massage, but 20 you don't think that Mr. Epstein knew that they were 21 underage? 22 MR. GOLDBERGER: Form. 23 THE WITNESS: No. I learn after. I 24 didn't learn anything before; after. 25 (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Pagc l 11 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006775 EFTA00158360
Page 112 1 BY MR. EDWARDS: 2 Q. So, at the very least you know that when 3 you were being told that it was only a massage, you 4 were being misled to some extent, right? 5 MR. GOLDBERGER: Form. 6 THE WITNESS: I, I, I didn't know what to, 7 what was going on. So either misled or not 8 misled, you know, I -- 9 BY MR. EDWARDS: 10 Q. Fair enough. Were you aware of these 11 photographs that were inside his closet of 12 apparently, I will just say young females? It was 13 a, I guess a collage of some sort of photographs? 14 A. Yes. 15 Q. All right. Did you see them? 16 A. Yes. 17 Q. Did you know any of the girls in the 18 photographs? 19 A. No. 20 Q. Did you recognize any of the girls in the 21 photographs as being girls that you saw coming over 22 to his house to provide massages? 23 A. No. 24 Q. Do you ever remember seeing photographs of 25 the girls who were coming over to provide massages (561) 832-7500 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) (561) 832-7506 2e5aMd-Usa-2b3-ae22-bSacflUdle 3507-011 Page 112 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006776 EFTA00158361
Page 113 1 anywhere? 2 A. No. 3 Q. Did you ever see pornographic images on 4 any of the computers? 5 A. No. 6 Q. Other than your own computer, you didn't 7 look at the other computers, right? 8 A. Right. 9 Q. Okay. Were you ever made aware or told by 10 the police or reading reports or anything else that 11 these young females that would come to the house 12 would oftentimes tell Mr. Epstein that they were 15 13 years old or 16 years old or in high school or 14 things like that? 15 A. No. 16 Q. Okay. Since him pleading guilty and going 17 to jail and things of that nature, have you thought 18 back on what was happening back in 2005 and tried in 19 your own mind to figure out where he met these 20 girls, how he was getting them to his house, who 21 they were working for, things of that nature, or is 22 that something that you just haven't bothered 23 thinking about? 24 A. I don't quite understand your question. 25 Q. Well, I mean, I guess, I guess my question (561) 832-7500 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) (561) 832-7506 2d7Sa9ld-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Pagc 113 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006777 EFTA00158362
Page 114 1 is you know, at the time that it was happening, you 2 thought that it was only massages going on, so it 3 wasn't really alarming you no matter what? 4 A. Right. 5 Q. But at some point in time, then you were 6 told and understood that there were other things 7 going on in the bedroom that ultimately led to a 8 guilty plea on Mr. Epstein's behalf, right? 9 A. Right. 10 MR. GOLDBERGER: Form. 11 BY MR. EDWARDS: 12 Q. So, then after that did you go back and 13 think, you know, think back to the times where you 14 saw these young girls and realize, hey, now I 15 understand why they were there and what they were 16 doing? 17 A. Yes. 18 Q. Okay. And just to take that one step 19 further, did you then try to figure out where did 20 they come from, how did he know them, how was he 21 getting them over to his house, things like that? 22 MR. GOLDBERGER: Form. 23 THE WITNESS: I, I would say don't concern 24 me what, where they came from, what they were 25 doing, just, you know, this is his personal, I (561) 832-7500 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) (561) 832-7506 2d7SafIld-3eaa-4263-ae2265d3c7182dle 3507.011 Page 114 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA _00006778 EFTA00158363
Page 115 1 would say, life so -- 2 MR. EDWARDS: Okay. I don't have any 3 other questions for you right now. I 4 appreciate your time. 5 I think that Mr. Mermelstein probably will 6 have some questions for you. 7 MR. MERMELSTEIN: I do have some 8 questions. Why don't we take a five minute 9 break. 10 MR. GOLDBERGER: Yeah. Five minutes. 11 (A brief recess was held.) 12 CROSS (JANUSZ BANASIAK) 13 BY MR. MERMELSTEIN: 14 Q. Did Mr. Epstein provide you with a vehicle 15 for your use? 16 A. I mean, I used the vehicle he owns for my 17 purpose sometimes. 18 Q. How many vehicles does he own? 19 A. Right now? 20 Q. Let's go back to when you started in 2005. 21 A. Let me see. Go back. There were two 22 Mercedes S500, one Cadillac Escalade and one Chevrolet 23 Suburban. 24 Q. What was the first car? I'm sorry. 25 A. Two Mercedes. (561) 832-7500 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) (561) 832-7506 2d75a9td-3eaa-42b3-m22-b5d3c71WWle 3507.011 Pagc 115 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006779 EFTA00158364
Page 1 Q. Two Mercedes? 2 A. Yeah, S500. 3 Q. Was there a car that you typically used or 4 you drove? 5 A. Yes. Most of the time I used the Chevrolet 6 suburban. 7 Q. And would you run errands for the 8 household in this suburban? 9 A. Yes. 10 Q. And what kind of errands would you 11 perform? 12 A. I was buying groceries, flowers for the house, 13 and I would say anything to pick up whatever was 14 necessary in the house. 15 Q. Was there a person who instructed you as 16 to what to do on these errands? 17 A. Yes. Either or Ghislaine Maxwell, they 18 give me some point, what kinds of grocery, what kind of 19 food Jeffrey Epstein preferred, what kind of flowers he 20 likes. So, I was following instruction from them for a 21 few weeks until I got it by myself. 22 Q. Would you say was a supervisor of 23 you as well as Ms. Maxwell? 24 A. Yes, yes. 25 Q. Was there an occasion when you rented a (561) 832-7500 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) (561) 832-7506 Nff5a9M-3eaa42b3-m224AilialWWle 3507-011 Pagc 116 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006780 EFTA00158365
Page 117 1 car on behalf of Mr. Epstein? 2 A. Yes. 3 Q. Tell me how that came about. 4 A. I rent the car for one of the girl. I don't 5 remember name right now. I think for a couple of months 6 or more. 7 Q. And who asked you to rent the car? 8 A. 9 10 11 12 13 14 15 16 17 18 19 20 21 Q. And what did she tell you? A. She told me to rent a car for, for this person. Q. And who did she tell you this person was? A. She mention name, Q. And did she explain why you were renting a car for A. No. Q. Did you ask her why am I renting this car? A. No. Q. And do you remember the rental car agency you went to, to rent the car? A. Dollar. I'm not sure. 22 Q. You think it was Dollar? 23 A. Just one of the rental in the airport, Palm 24 Beach airport. 25 Q. All right. (561) 832-7500 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) (561) 832-7506 2d75891d4eaa-Ob3tUflUdle 3507-011 Page 117 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006781 EFTA00158366
Page 118 1 A. Either Dollar or Rent-a-Car, or I don't 2 remember the company. 3 Q. So, would you take a cab to the airport or 4 did someone drive you there to pick up the car? 5 A. I don't remember how this was arranged. I 6 think dropped me at the airport. 7 Q. And you rented the car in your own name 8 A. Yes. 9 Q. -- correct? And you say it was -- were 10 you instructed to rent it in your own name? 11 A. Yes. 12 Q. And did tell you to do that? 13 A. Yes. 14 Q. Did you have a problem with putting 15 A. No. 16 Q. -- the car on -- it was on your own 17 credit, correct? 18 A. Yes. 19 Q. There was no company card or organization 20 card, credit card that you had, correct? 21 Mr. Epstein didn't give you a credit card? 22 A. Yes. He gave me a credit card. 23 Q. Oh he did. What kind of credit card was 24 it? 25 A. I think Master Card or Visa. I don't (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-412b3-ae2265d3c7182dle 3507.011 Page 118 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006782 EFTA00158367
Page 11S 1 remember. 2 Q. And was the Master Card or Visa in his 3 name? 4 A. My name. 5 Q. But he paid the bills? 6 A. Yes. 7 Q. And was it understood that this credit 8 card was to be used for household expenses? 9 A. Right. 10 Q. And is that how you paid for the car? 11 A. Yes. 12 Q. You don't remember if it was a Master Card 13 or a Visa? 14 A. I think Visa. 15 Q. So, you went and you believe that 16 brought you to the Palm Beach airport. You rented 17 the car and then drove it back to the house? 18 A. Yes. 19 Q. The house in Palm Beach, correct? 20 A. Correct. 21 Q. And di then come and pick 22 up the car? 23 A. Yes. 24 Q. And how did she get to the house on that 25 occasion? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2W5a9W-308a42b3-m224MUTIMMU 3507-011 Page 119 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006783 EFTA00158368
Page 120 1 A. I don't remember how she got to the house. 2 Probably somebody drove her, either a friend or somebody 3 she knew. 4 Q. And then did you hand her the keys to the 5 car? 6 A. Yes. 7 Q. Did you tell her how long she had the car 8 for? 9 A. Yes. Because there was a rental agreement 10 think for 30 days or something else. 11 Q. Did come to the house to 12 give Epstein a massage? 13 A. Yes. 14 Q. Okay. How many occasions do you recall 15 her coming to the house to give Epstein a massage? 16 A. I don't remember. 17 Q. Many occasions? 18 A. I don't know. I cannot tell right now. It's, 19 it's -- I didn't count exactly how many times she was in 20 house. 21 Q. She was someone who would come more than 22 once, correct? 23 A. Correct. 24 Q. You saw her -- well, strike that. 25 There were girls who came for massages, I (561) 832-7500 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) (561) 832-7506 2c175a91c1-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Pagc 120 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006784 EFTA00158369
Page 121 1 take it, who would be there once and you wouldn't 2 see them again; is that fair to say? 3 A. Yes. 4 Q. And there are girls who came for massages 5 who you would see come repeatedly over a period of 6 time? 7 A. Right. 8 Q. Okay. And was one of the 9 girls that came repeatedly over a period of time? 10 A. Yes. 11 Q. Did you observe Mr. Epstein meeting or 12 speaking with 13 A. No. 14 Q. When she came she would come into the 15 kitchen like the other girls who would give 16 massages? 17 A. Yes. 18 Q. And then or someone would, is it 19 your understanding take her upstairs? 20 A. Yes. 21 Q. On the occasions she came to pick up her 22 car, did she to your understanding give Epstein a 23 massage on that occasion? 24 A. I don't remember this day if she was there, 25 but I know that when she arrive I give her the keys. (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Pagc 121 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006785 EFTA00158370
1 Page 122 But if she left right away or she went to give massage, 2 I don't remember this day. 3 Q. Okay. Do you know 's last 4 name? 5 A. No. 6 Q. If I told you her name was 7 would that ring a bell? 8 A. No. 9 Q. Do you recall instances where 10 called the house? 11 A. No. 12 Q. Do you recall other girls that 13 came with on any occasions? 14 A. I don't remember exactly, you know, what, what 15 how many times she was there. 16 Q. More than ten? 17 MR. GOLDBERGER: Form. 18 THE WITNESS: I cannot tell you the truth. 19 BY MR. MERMELSTEIN: 20 Q. Let me show you a photograph and ask you 21 if you recognize that girl. 22 A. No. 23 Q. Is that 24 A. I am not sure. I know she 25 but I don't recognize her face. (561) 832-7500 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) (561) 832-7506 2d75a9td4eaa42b3-m22-bMUTIOIMU 3507.011 Pagc 122 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006786 EFTA00158371
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 Q. Page 123 Let me show you some other photos. Do you recognize this girl? MR. GOLDBERGER: You better start marking these? MR. MERMELSTEIN: What? MR. GOLDBERGER: We're going to have to start marking them. How are we going to know what you're talking about? (A discussion was held off the record.). MR. GOLDBERGER: All right. So, I'm marking the first one as your Exhibit No. 1, the 1. 2. both. MR. MERMELSTEIN: We'll mark it as Exhibit MR. GOLDBERGER: The second one as Exhibit MR. EDWARDS: His answer is the same for MR. GOLDBERGER: You can do them as a composite one if you like. MR. MERMELSTEIN: Why don't we do that. MR. GOLDBERGER: You're going to need to make a photocopy of that so we have something. MR. MERMELSTEIN: These are photocopies. Can you indicate before I show him the (561) 832-7500 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) (561) 832-7506 2e5aMd4eaa-2b3-ae22-bSacflUdle 3507-011 Page 123 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006787 EFTA00158372
Page 124 1 second one that that's Exhibit 2, and that this 2 is Exhibit 1. Why don't we do that. Is that 3 all right? That way we'll be able to tell, 4 distinguish them. Can you hand this to the 5 court reporter so she could mark them. 6 (Plaintiffs' Exhibit No's 1 and 2 were 7 marked for identification.) 8 BY MR. MERMELSTEIN: 9 Q. Let me show you another photo. Do you 10 recognize this girl? 11 A. No. 12 Q. Do you recall a girl by the name of 13 14 A. No. 15 MR. GOLDBERGER: Excuse me. Let's go off 16 the record. 17 (A discussion was held off the record.) 18 (Plaintiffs' Exhibit No. 3 was marked for 19 identification.) 20 BY MR. MERMELSTEIN: 21 Q. Let me show you Exhibit 3, and ask you if 22 you can identify this girl? 23 A. No. 24 MR. MERMELSTEIN: Let's mark that. 25 (561) 832-7500 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) (561) 832-7506 2d7Sagld-3eaa-4263-ae2265d3c7182dle 3507.011 Page 124 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006788 EFTA00158373
Page 125 1 (Plaintiffs' Exhibit No. 4 was marked for 2 identification.) 3 BY MR. MERMELSTEIN: 4 Q. And I will show you Exhibit 4 and ask you 5 if you recognize this girl. 6 A. No. 7 (Plaintiffs' Exhibit No. 5 was marked for 8 identification.) 9 BY MR. MERMELSTEIN: 10 Q. Do you remember a girl by the name of 11 ho would come to house to give Epstein 12 massages? 13 A. Yes, I remember name 14 Q. You remember . What do you 15 remember about 16 MR. GOLDBERGER: Form. 17 THE WITNESS: Just the name. 18 BY MR. MERMELSTEIN: 19 Q. Do you remember a girl named 20 who would come to the house and give Epstein 21 massages? 22 MR. GOLDBERGER: Form. 23 THE WITNESS: Yes. 24 BY MR. MERMELSTEIN: 25 Q. And she was a girl who would, who came (561) 832-7500 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) (561) 832-7506 MiMeiftlaw42113-m224.5c1WIWWle 3507.011 Pagc 125 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006789 EFTA00158374
Page 126 1 2 3 4 5 6 7 more than once like A. Yes. Q • did? Do you recall approximately how many times A. No. Q • would come to give Epstein a massage? You mentioned in response to Mr. Edwards' questioning the manual to the house. Was there 8 policies in the manual regarding contacting police 9 and in the event there was an indication to do so? 10 A. Yeah. It was I think on the last page there 11 was an emergency contact information, address of 12 hospital and 911. 13 Q. Were you ever given instruction that you 14 should not call the police? 15 A. No. 16 Q. That was never anything that was told to 17 you? 18 A. No, no. 19 Q. You have been employed by Mr. Epstein 20 since February, 2005, correct? 21 A. Correct. 22 Q. And how do you receive your income, do you 23 receive it by direct deposit into your account? 24 A. Yes. 25 Q. Do you remember receiving a paycheck by (561) 832-7500 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) (561) 832-7506 2d75891d-3eaa-42b3-8e22-b5d3c7182dle 3507-011 Pagc 126 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006790 EFTA00158375
Page 127 1 hand? 2 A. By mail. 3 Q. By mail. Okay. By mail to where? Oh, 4 I'm sorry. The mail, does it come from New York? 5 A. Yes. 6 Q. And what is the name of the account on the 7 check? 8 A. HBRK Associates. 9 Q. HBRK Associates. And what is your 10 understanding of what that stands for? 11 A. I don't know. Just, I guess, initials. 12 Q. Is it your understanding that HBRK 13 Associates was your employer or is your employer? 14 A. Yes. 15 Q. But you have been testifying today that 16 your employer was Mr. Epstein. What is your 17 understanding of the relationship between HBRK 18 Associates and Mr. Epstein? 19 A. I think that's his company. 20 Q. It's his company? 21 A. Right. 22 Q. And to your understanding are the other 23 people in the organization employed by HBRK 24 Associates? 25 MR. GOLDBERGER: Form. (561) 832-7500 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) (561) 832-7506 205891d-Usa-42b3tU7182dle 3507-0 I I Page 127 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006791 EFTA00158376
Page 128 1 THE WITNESS: Yes. 2 BY MR. MERMELSTEIN: 3 Q. And you have been employed by HBRK 4 Associates since you started in October, since you 5 started in February 2005? 6 A. I don't know to tell you the truth if this was 7 the organization that was, hire me. 8 Q. That was the organization that hired you? 9 A. No, I'm not sure. 10 Q. Okay. You're not sure if that was the 11 organization? 12 A. Right. 13 Q. Was there a different organization at the 14 time you were hired? 15 A. I don't remember. Maybe there was also, I 16 remember there was a household account on the face of my 17 paycheck. 18 Q. Jeffrey Epstein household account? 19 A. Right. 20 Q. And you think at some point it may have 21 switched to HBRK Associates? 22 A. Right. 23 Q. But you don't remember when that was? 24 A. No. 25 Q. Was it shortly after you started? (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Pagc 128 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006792 EFTA00158377
Page 129 1 MR. GOLDBERGER: Form. 2 THE WITNESS: Could be. 3 BY MR. MERMELSTEIN: 4 Q. Any idea? 5 A. After two years maybe, after three years. I 6 don't remember. 7 Q. After two years or so. So, it would have 8 been 2007, 2008? 9 A. Could be. 10 Q. Do you ever have conversations with 11 Mr. Epstein about things going on in your lives 12 and -- 13 A. No. 14 Q. Friendly conversation? 15 A. No, we don't talk. 16 Q. No. Do you, do you have days off? 17 A. Yes. 18 Q. Where do you go? 19 MR. GOLDBERGER: Form. 20 THE WITNESS: Where do I go? 21 BY MR. MERMELSTEIN: 22 Q. Where do you go? Do you have someplace 23 else that you live? 24 A. No, I live on the property. 25 Q. So, even on your days off, you're still on (561) 832-7500 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) (561) 832-7506 2d7SaMd4eaa-2b3-ae22-bSacflUdle 3507-011 Page 129 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006793 EFTA00158378
Page 130 1 the property? 2 A. Sometimes I go, sometime I take some vacation. 3 I go away for a time of my vacation. 4 Q. But there are days when you're staying on 5 the property but you're not working? 6 A. Yes. 7 Q. Is that fair to say? 8 A. Yes. 9 Q. So, no one asks you to do anything during 10 that time? 11 A. No. My day off, they don't bother me. They 12 know I am not working. 13 Q. Okay. Now, you said that when you were 14 hired, your salary was $58,000? 15 A. Yes. 16 Q. What is it today? 17 A. Sixty-two. 18 Q. Sixty-two? 19 A. Yes. 20 Q. When is the last time you got a raise? 21 A. I would say two years ago. 22 Q. And do you know why you haven't gotten a 23 raise in two years? 24 A. Economic condition. Everybody suffer. 25 Q. Is that something you've discussed with (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2d75891d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Page 130 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006794 EFTA00158379
?age 131 1 Mr. Epstein? 2 A. No. 3 Q. You just assumed that it's economics? 4 A. No. I think somebody from, from the, from the 5 office told me that there would be no increase -- 6 Q. Someone from -- 7 A. -- or bonuses for last year because of the 8 situation, stock market went down. 9 Q. Someone from the office in New York? 10 A. Yes. 11 Q. You don't remember who? 12 A. I think Rich, Rich Kahn. 13 Q. And do you get bonuses too? 14 A. Yes. 15 Q. And when was the last time you got a 16 bonus? 17 A. Like two years ago. 18 Q. And how much was that? 19 A. I don't remember. The last one was $10,000. 20 Q. Okay. So, your income for that year would 21 have been 72,000 if I am understanding? 22 A. Yes. 23 Q. Which would have been $62,000 salary and 24 $10,000 bonus, correct. 25 A. Right. (561) 832-7500 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) (561) 832-7506 2d7Sag I d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Pagc 131 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J)0006795 EFTA00158380
Page 132 1 Q. Does stay at the house? 2 A. Yes. 3 Q. And does she sleep in the same bedroom as 4 Mr. Epstein? 5 A. Yes. 6 Q. When Mr. Epstein travels, who does he 7 travel with? When he comes from New York or some 8 other location, who does he come with? 9 A. 10 Q. Anyone else? 11 A. Igor. 12 Q. Who is Igor? 13 A. He is personal trainer. 14 Q. Does he have any other jobs? 15 A. Pardon me? 16 Q. Does he have any other job s or functions? 17 A. No. 18 Q. He is the personal trainer? 19 A. Yes. 20 Q. For exercise? 21 A. Yes. 22 Q. Anyone else travel with him? 23 A. I don't know. 24 Q. Does he have a guest who travels with him? 25 A. I really don't know. Sometimes he brings (561) 832-7500 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) (561) 832-7506 2d75891d-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Pagc 132 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006796 EFTA00158381
Page 133 1 guests, but I, I don't recall, no, which day on which 2 occasion. 3 Q. Were there occasions when he brought young 4 girls as guests? 5 A. No. I don't remember bringing from his 6 airplane any girls to the house. 7 Q. The only young girls you remember coming 8 to the house were, came to the kitchen door for 9 massages? 10 A. Right. 11 Q. Do you recall instances where two girls 12 would come to the house? 13 A. Yes. 14 Q. And what would happen on occasions when 15 two girls came? 16 MR. GOLDBERGER: Form. 17 THE WITNESS: Yeah. I remember one was 18 waiting in the kitchen for her one of her 19 friends, and she told me she's waiting for her? 20 Either she gave her a ride to the house or they 21 have something to do together. I don't know. 22 BY MR. MERMELSTEIN: 23 Q. Do you remember who that was? 24 A. No. 25 MR. GOLDBERGER: We're going to take a (561) 832-7500 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) (561) 832-7506 2d7Sa91d-3eaa42b3-3922-b5d3c7182dle 3507.011 Page 133 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006797 EFTA00158382
Page 134 1 lunch break at 1:00. We'll be going three 2 hours now. 3 MR. EDWARDS: I understand. Are we close? 4 MR. MERMELSTEIN: Yes, we're close. 5 MR. GOLDBERGER: If he's almost done and 6 you have a little bit. 7 MR. EDWARDS: I will. I will. So, let's 8 just take a lunch break whenever you're ready. 9 I don't care. I don't think there is any way 10 to avoid a lunch break is what I am saying. I 11 was hoping we could, but that's all right. 12 MR. GOLDBERGER: Do you want to finish 13 yours, is that what you want to do? 14 MR. MERMELSTEIN: It doesn't matter. 15 MR. GOLDBERGER: Okay. We'll just go now. 16 Do you want to do 20 minutes? 17 (A brief recess was held.) 18 BY MR. MERMELSTEIN: 19 Q. So, you testified regarding this occasion 20 where two girls arrived at the house and one of the 21 girls gave a massage, correct? 22 A. Yes. 23 Q. And one of the girls waited for the girl 24 who gave the massage, correct? 25 A. Yes. (561) 832-7500 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) (561) 832-7506 VPUMclago42b3-m22-bM3c7182the 3507-011 Pagc 134 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006798 EFTA00158383
;'acje 135 1 Q. And the girl waited in the kitchen? 2 A. Yes. 3 Q. Do you remember other occasions where that 4 happened? 5 A. No. 6 Q. Is one occasion you remember that 7 happening? 8 A. Yes. 9 Q. Did you know these girls received money in 10 exchange for giving messages? 11 A. Yes, yes. 12 Q. Were you responsible for paying them? 13 A. Yeah. I pay some of them. 14 Q. Okay. And how did you pay them? 15 A. I either -- I get a phone call from Cr 16 and they mention name that such a girl show up 17 at the house and I should give them money. 18 Q. Okay. So, I think you testified before 19 that you would get a, you would get a call or you 20 would be advised that there is a girl coming to give 21 a massage, correct? 22 A. Right. 23 Q. And that you should let her in when she 24 comes, right? 25 A. Yes. (561) 832-7500 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) (561) 832-7506 2W5a9W4eaa4211.1-m224,MUTIWWle 3507.011 Pagc 135 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006799 EFTA00158384
Page 136 1 Q. And in that same phone call were you told 2 that you're supposed to pay the girl and how much 3 you're supposed to pay her? 4 A. No, another phone call. 5 Q. A different phone call? 6 A. Different phone call. 7 Q. While the girl was there? 8 A. I don't recall if I pay somebody when she 9 comes to the massage. I recall when I got the phone 10 call that I have to pay those girls who show up at the 11 house and I should give them money. 12 Q. I'm sorry. I didn't -- 13 A. So, otherwise, what I try to say is that I did 14 pay, you know, after the massage. I give to her money. 15 Most of the time what I pay nobody was in the house. 16 For example, Mr. Epstein was away and I got the phone 17 call from either or and they would show up 18 and I would give them money. 19 Q. Okay. When Mr. Epstein was away? 20 A. Yes. 21 Q. Okay. So, you mean when he was not in the 22 house? 23 A. Right. 24 Q. So, what were the occasions where girls 25 would get paid when Mr. Epstein was not in the (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Page 136 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006800 EFTA00158385
Page 137 1 house? I am trying to understand. 2 A. Just give them the money. 3 Q. Oh, just give them money? 4 A. Yes. 5 Q. Was this money for massages? 6 A. Yes. 7 Q. So, but this wasn't just after they 8 completed the massage? 9 A. Yes. 10 Q. It was or it wasn't? I am not clear. 11 A. After, yeah. 12 Q. After they gave the massage. 13 A. Right. 14 Q. What I am unclear is that you said 15 Mr. Epstein wasn't in the house. 16 A. Yeah. On a few occasion, you know, 17 Mr. Epstein was in the house and I got the phone call 18 that this girl show up and I should pay her money. 19 Q. Okay. 20 A. So, I assume either she didn't get paid before 21 or you know what I mean. 22 Q. I see. This wasn't where the girl had 23 come to the house, given the massage, and then left. 24 This is she came separately -- 25 A. Right. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2d7Segld-3eafrab3-ae22-Wid3c7182dle 3507-011 Page 137 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006801 EFTA00158386
Page 138 1 Q. -- to receive money for giving a massage 2 that she had already given at some prior time? 3 A. Yes, yes. 4 Q. Okay. And that's the occasion where you 5 paid her? 6 A. Yes. 7 Q. And you were told that this was payment 8 for the girl who had given Epstein a massage? 9 A. It wasn't mention massage. It wasn't 10 mentioned just for a massage, but just give her money. 11 Q. It was mentioned for a massage or it was? 12 A. I don't, I don't remember. 13 Q. But you don't -- 14 A. I don't remember massage, but I was told to 15 give her money. 16 Q. Do you remember who it was that you gave 17 money to? 18 A. I don't recall the name. 19 Q. Okay. Do you recall giving money to 20 21 A. No. Could be but I don't remember. I dor 22 remember. I cannot recall which girl I pay. 23 Q. How often was it that a girl would come 24 back to the house to get money? 25 MR. GOLDBERGER: Form. (561) 832-7500 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) (561) 832-7506 2e6a91d4esa-42b3-m22-b5d3c716IMU 3507.011 Pagc 138 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006802 EFTA00158387
Page 139 1 THE WITNESS: I would say like maybe six, 2 eight times. 3 BY MR. MERMELSTEIN: 4 Q. Were there different girls on each 5 occasion or was it -- 6 A. Different girls. 7 Q. Different girls on each occasion. And 8 these were all girls who at some prior time had 9 given Epstein a massage? 10 A. Yes. 11 Q. And then they came back at a later time to 12 get money? 13 A. Correct. 14 Q. And for that purpose only? 15 A. Correct. 16 Q. And Mr. Epstein wasn't in the house at 17 that time? 18 A. Right. 19 Q. Was it your understanding that when 20 Mr. Epstein was in the house and the girl had come 21 to give him a massage that he paid her at that time? 22 A. I don't know. I haven't seen, you know. 23 Q. How much did you -- on each of these eight 24 or so occasions that you gave a girl money who came 25 to the house, how much did give her? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2d75a91d4eaa42b3-m22-b5d3O18IMIe 3507.011 Page 139 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006803 EFTA00158388
Page 140 1 A. From two to 400, from 200 to 400. 2 Q. 200 to $400? 3 A. Right. 4 Q. Did you have any understanding as to what 5 6 the reason was for the difference in the amounts? A. No. 7 Q. Did you have any understanding of the 8 strike that. Is it fair to say these girls who 9 would come to the house to give Epstein massages 10 were not professional masseuses? 11 MR. GOLDBERGER: Form. 12 THE WITNESS: I don't know. 13 BY MR. MERMELSTEIN: 14 Q. Did it appear to you that they were not 15 professional? 16 A. I cannot tell. 17 MR. GOLDBERGER: Form. 18 THE WITNESS: I didn't know their 19 backgrounds, whether they were trained or not 20 trained. 21 BY MR. MERMELSTEIN: 22 Q. I am sorry, they what? 23 MR. GOLDBERGER: Trained or not trained? 24 THE WITNESS: I didn't know if they were 25 trained or not trained. (561) 832-7500 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) (561) 832-7506 2d7Sagl d-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Pagc 140 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006804 EFTA00158389
Page 141 1 MR. MERMELSTEIN: You didn't know if they 2 were trained or not trained? 3 THE WITNESS: Right. 4 BY MR. MERMELSTEIN: 5 Q. Did you know if they worked for a 6 particular company? 7 A. No. 8 Q. You didn't, you didn't have reason to 9 believe that there was any particular company that 10 was sending masseuses to Epstein's house? 11 A. No. 12 Q. So, as far as you know they were all 13 independent? 14 A. Yes. 15 Q. And you have no idea why all these 16 independent girls or how it was that they were 17 coming to give Epstein massages? 18 A. Yes. 19 Q. Now, you mention that had removed 20 those three computers from the house. And you also 21 testified that you had your own computer in your 22 office which was in the other, in the adjacent 23 living quarters, correct? 24 A. Yes, correct. 25 Q. In the -- in the main house were there any (561) 832-7500 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) (561) 832-7506 2d75891d-3eaa-42b3-8e22-b5d3c7182dle 3507.011 Pagc 141 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006805 EFTA00158390
Page 142 1 2 3 4 5 6 7 computers left after these three were taken? left. A. Yeah. I think one was left, the small one. Q. A. 4. A. Was that the laptop? No, small computer. Why do you call it a small computer? I would say a 15-inch screen monitor. One was 8 Q. Where was that computer located? 9 A. It was in his office next to the kitchen. 10 Q. And do you know if that computer was 11 linked to the others? 12 A. I don't know. 13 Q. And was that computer there when the 14 police came to execute their search warrant? 15 A. Yes. 16 Q. And they took that computer? 17 A. Yes. 18 Q. That was the only computer that they took 19 to your knowledge? 20 A. Yes. 21 Q. You mentioned Bella Klen and Richard Kahn, 22 correct? 23 A. Correct. 24 Q. They were both accountants in New York to 25 your understanding? (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507-011 Page 142 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006806 EFTA00158391
Page 143 1 2 3 4 A. Yes. Q• And they are both employed by HBRK Associates; is that your understanding? A. Yes, yes. 5 Q. And is one supervisor of the other? Is 6 one higher up than the other? 7 A. I think Rich Kahn is, I would say has the 8 higher position. 9 Q. Have you met Mr. Kahn? 10 A. Yes. 11 Q. Has he been to Palm Beach? 12 A. Yes. 13 Q. What was the occasion for him to come to 14 Palm Beach? 15 A. That they met with Jeffrey Epstein's office. 16 Q. Does Mr. Kahn handle business matters 17 outside the household to your knowledge? 18 A. I don't think so. 19 Q. You think he just handles household 20 matters? 21 A. No. He handle, I would say, investment. 22 Q. Which is, which is Mr. Epstein's, to your 23 understanding, prime business, correct? 24 A. Right. 25 Q. And that's what Mr. Kahn handles? (561) 832-7500 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) (561) 832-7506 2W5Ald-3eaa-42b3-m22-b5d3c716:Wle 3507-011 Page 143 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006807 EFTA00158392
Page 144 1 A. Correct. 2 Q. Would you say that Mr. Kahn is a key 3 employee like a right-hand man of Mr. Epstein? 4 MR. GOLDBERGER: Form. 5 THE WITNESS: Yes. 6 BY MR. MERMELSTEIN: 7 Q. Is he still employed with Mr. Epstein? 8 A. Yes. 9 Q. You mentioned that when you were 10 questioned by the FBI, that was the first time that 11 you learned that there were surveillance cameras in 12 the house, correct? 13 A. Correct. 14 Q. Anything else from the questioning by the 15 FBI that you learned for the first time? 16 17 18 19 20 21 22 MR. GOLDBERGER: Form. 23 THE WITNESS: Yes. 24 BY MR. MERMELSTEIN: 25 Q. Is there anything that you told them that MR. GOLDBERGER: Form. THE WITNESS: No. BY MR. MERMELSTEIN: Q. That was it? That was the only thing, piece of information that they gave to you essentially during the course of that questioning? (561) 832-7500 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) (561) 832-7506 2C5a9M-Uaa42b3-m224:6(13a1WWle 3507.011 Pagc 144 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006808 EFTA00158393
Page 145 1 they indicated to you that, gee, that's the first 2 time we heard that? 3 MR. GOLDBERGER: Form. 4 THE WITNESS: I don't understand. 5 BY MR. MERMELSTEIN: 6 Q. Is there any new information to your 7 knowledge that you gave to them that they didn't 8 previously have? 9 A. No. 10 MR. GOLDBERGER: Form. 11 THE WITNESS: No. 12 BY MR. MERMELSTEIN: 13 Q. No. Anything you told them they already 14 new, is that your understanding? 15 MR. GOLDBERGER: Form. 16 THE WITNESS: Yes. 17 BY MR. MERMELSTEIN: 18 Q. You testified that there were a few 19 occasions where you picked up the massage room 20 upstairs. You put the massage table away, correct? 21 A. Correct. 22 Q. And on any of those occasions did you 23 observe a vibrator? 24 A. No. 25 Q. Did you observe any massage tools? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) (561) 832-7506 2W5a9W4en42113-m224.5(13a1WWle 3507.011 Pagc 145 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006809 EFTA00158394
Page 146 1 MR. GOLDBERGER: Form. 2 THE WITNESS: I don't remember, no. 3 MR. MERMELSTEIN: You just -- 4 THE WITNESS: I don't remember. 5 BY MR. MERMELSTEIN: 6 Q. Okay. You don't remember? 7 A. If I saw, I saw, I saw in -- I think one of 8 the drawers that I recall massage lotion. They call it 9 a personal massage. 10 Q. And could you describe that? 11 A. It was for massage, muscle massage with rubber 12 head, vibrate when you press the button. You can buy 13 them in Brookstone's. I saw them. 14 Q. Anything -- so you opened the drawer to 15 put something away and you saw that? 16 A. Yes. 17 Q. Anything else you see at that time? 18 A. No. 19 MR. MERMELSTEIN: All right. I am going 20 to defer to Mr. Edwards. 21 REDIRECT (JANUSZ BANASIAK) 22 BY MR. EDWARDS: 23 Q. Just so that I understand what you were 24 telling Mr. Mermelstein about paying the girls, you 25 were saying that sometimes you would pay them and (561) 832-7500 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) (561) 832-7506 2c175891c1-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Pagc 146 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006810 EFTA00158395
Page 147 1 Mr. Epstein was out of town, right? 2 A. Right. 3 Q. And this would either be -- well, it would 4 be a situation where you were told that if somebody 5 comes over, some certain female comes over, then 6 just pay her, right? 7 A. Right. 8 Q. Would it be initiated by you in that, you 9 know, the person would come to the door, you're not 10 expecting them, you call and she says just pay 11 them? 12 A. No. 13 Q. You were always forewarned, hey, this 14 person is going to come over, pay them? 15 A. Right, right. 16 Q. Do you know whether it was they had a 17 scheduled appointment but Mr. Epstein wasn't in town 18 and he was saying just pay them anyway, or she had 19 performed a massage at some point in time, not been 20 paid and was back to receive her money, do you know 21 which one? 22 A. No. 23 Q. Okay. So, it could have been either 24 situation 25 A. Yes. (561) 832-7500 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) (561) 832-7506 2d75891d-Uaa-42b3-ae22-bSd30182dle 3507-011 Page 147 of 2.(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006811 EFTA00158396
Page 148 1 Q. -- to the best of your knowledge? And 2 when you would pay these girls or would pay 3 them or whoever would pay them, would it always be 4 in cash? 5 A. Yeah. I pay them all with cash. 6 Q. You didn't write checks to them? 7 A. No, just cash. 8 Q. Ever wire any money to any of them? 9 A. No. 10 Q. Western Union or anything like that? 11 A. No. 12 Q. Did you ever withdraw money from the ATM, 13 was that one of your responsibilities that would 14 later be used to pay the girls? 15 A. No. 16 Q. Do you know who withdrew the money? 17 A. No. 18 Q. Do you know whose responsibility it was to 19 go to the ATM for Mr. Epstein to have cash on hand? 20 A. Yeah, part was my responsibility. I mean, not 21 to withdraw from the ATM. I went to the bank so we have 22 cash for spending, household cash. 23 Q. All right. 24 A. So, I always kept cash, you know, for myself, 25 for household, for grocery. So, whatever I need the (561) 832-7500 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) (561) 832-7506 2d75891d-Uaa-42b3-ae22-bSd30182dle 3507-011 Page 148 of 2.(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006812 EFTA00158397
Page 149 1 money, I go to the bank to withdraw some money and I 2 kept it with me. 3 Q. Okay. And you just give the receipt to 4 somebody so they know how much you took out? 5 A. Right. 6 Q. And typically what would you take out of 7 the bank in terms of cash to keep on hand? 8 A. About $2,000. 9 Q. All right. So, you would go to the bank. 10 Is $2,000 an amount that was told to you as an 11 appropriate amount to take out? 12 A. I mean, it was my decision how much money I 13 need. But most of the time I withdraw $2,000 and 14 whatever I spend, I go and draw another one. 15 Q. I understand that at some point in time 16 you realize that that was a decision that you could 17 make. But let's say the first time you go to the 18 bank, you don't just make the decision to take out 19 $2,000, do you? I mean, somebody gives you some 20 guidance? 21 A. No. 22 Q. Okay. They give you authority, they say 23 go to the bank and get out some money and you decide 24 on your own that $2,000 is an appropriate amount? 25 A. Yes. (561) 832-7500 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) (561) 832-7506 2d7Sagld-3eaa-4263-ae2265d3c7182dle 3507.011 Page 149 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006813 EFTA00158398
Page 150 1 Q. All right. What bank do you go to? 2 A. Colonial Bank on Worth Avenue. 3 Q. All right. And what account are you 4 withdrawing the money from or are there multiple 5 accounts? 6 A. One account, Jeffrey Epstein household 7 account. 8 Q. And what is the name on the account? 9 A. Jeffrey Epstein household account. 10 Q. Okay. That's the name of the account? 11 A. Yes. 12 Q. Is that the only account that you ever 13 withdrew money from? 14 A. Yes. 15 Q. All right. And then when you -- is that 16 the cash that you would use or is that also cash 17 that you would distribute to, let's say, 18 or Jeffrey Epstein? 19 A. No. This is only for my expenditure. 20 Q. That's not then the money that was used to 21 pay these young females? 22 A. Yes. 23 Q. It is? 24 A. Yes. 25 Q. So, would you always be the one paying (561) 832-7500 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) (561) 832-7506 2d75891d-Uaa42b3-m22-b5d3c7182dte 3507.011 Pagc 150 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006814 EFTA00158399
l'acje 151 1 them? 2 A. On a few occasions, yes, but not, not, not 3 always. 4 Q. Okay. Oftentimes was paying them or 5 somebody else in the house? 6 A. I assume. 7 Q. And the money that was using to pay 8 them with, do you know where she got it or what 9 account she withdraw it from? 10 A. No. 11 Q. All right. If Jeffrey Epstein was paying 12 them personally, you don't know what account he 13 withdrew it from? 14 A. I don't know. 15 Q. I thought I overheard you, I may be wrong 16 but I thought when we were walking out to lunch I 17 overheard you say you don't need to get your card 18 stamped because you have a card or something? 19 A. Yes. 20 Q. What is that? 21 A. This is parking access to garage downstairs. 22 Q. Okay. Have you been to this building 23 before? 24 A. Yes, very often. 25 Q. Very often. And it's -- where do you (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507-011 Pagc 151 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006815 EFTA00158400
Page 152 1 park? I mean I know where I parked, but I don't 2 know, where do you park when you get -- do you have 3 an assigned space or something? 4 A. No, just whatever I find a space, I park. 5 Q. What floor do you park on? 6 A. Right now on first level. 7 Q. On the first level. All right. And what 8 does the card give you access to? 9 A. This is a card that we get for the office. 10 Q. Just to get in and out of the garage? 11 A. Right. 12 Q. Or does it also give you access to Jeffrey 13 Epstein's office, that being the Florida Science 14 Foundation? 15 A. For the garage. 16 Q. For the garage. 17 A. There are keys for office. 18 Q. Okay. And when you come over from the 19 garage to the building, is that on the second floor 20 or first floor or how do you get in? 21 A. First floor. 22 Q. And that's always the routine that you 23 take? 24 A. Yes. 25 Q. All right. (561) 832-7500 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) (561) 832-7506 2W5a9W4eaa42b3-m22-bUft71WWle 3507.011 Pagc 152 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006816 EFTA00158401
Page 153 1 A. Sometimes I park in front of the building, but 2 if there is no space I go to the garage. 3 Q. But there is no set parking spaces 4 assigned to Jeffrey Epstein? 5 A. No. 6 Q. Or to you or to anybody else? 7 A. No, no. 8 Q. All right. In the police report, you 9 know, there are several females that talk about 10 being in the bedroom with Mr. Epstein and also 11 at times being in the bedroom, and Mr. Epstein 12 requesting that use strap-on penises or 13 vibrators or dildos or something on these young 14 girls while Epstein stands by and masturbates and it 15 goes into detail. But my question is, have you ever 16 seen any of these strap-on or vibrator devices in 17 the house? 18 MR. GOLDBERGER: Form. 19 THE WITNESS: No. 20 BY MR. EDWARDS: 21 Q. Okay. Were you aware that there were 22 times where these young females we've been 23 discussing as people that you were led to believe 24 that were providing massages were up in the bedroom 25 with Mr. Epstein and (561) 832-7500 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) (561) 832-7506 2d75a91d4esa42b3-m22-bMtic71WWle 3507.011 Pagc 153 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006817 EFTA00158402
Page 154 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 A. No. MR. GOLDBERGER: BY MR. EDWARDS: Q. And observations, girlfriends I intimate with Jeffrey A. Q. have mean Form. you known, just based on your to have girlfriends? And by girlfriends that she would be in addition to being the girlfriend of Epstein? No. Do you Luc Brunel? A. Yes. Q. How do A. He was times. Q. A. Q. A. Q• a Tuesday. know somebody you know him? by the name of Jean in the house like, I guess, a few When? When? When was the last A week ago. Today is, what, time you saw him there? February 16th, and this is So, when we are saying a week ago, are you saying it was last Tuesday, Wednesday, Thursday, Friday, do you remember? A. I don't remember the date but he stay maybe three days, I think, in the house. (561) 832-7500 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) (561) 832-7506 2W5a9W4eaa42113-m224,WWIWWle 3507.011 Pagc 154 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006818 EFTA00158403
Page 155 1 Q. So, if he arrived on Tuesday, he stayed 2 through Thursday or Friday and -- 3 A. Yes. 4 Q. Do you know what the occasion was for him 5 to come in town? 6 A. No. 7 Q. Where did he stay in the house last week? 8 A. One of the bedrooms upstairs. 9 Q. And was Mr. Epstein also staying in the 10 house? 11 A. 12 Q. 13 company 14 A. 15 Q. 16 A. 17 Q. 18 A. 19 point. 20 Q. And where did he -- I assume he flew in 21 from somewhere? 22 A. Yes. 23 Q. Picked up from the airport, safe 24 assumption? He didn't just drive to the airport. 25 (A discussion was held off the record.) Yes. All right. Did Mr. Brunel bring any with him? No. It was him alone? Yes. How did he get to the house? I think he has been picked up by Igor at this (561) 832-7500 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) (561) 832-7506 2d75891d-Uaa-42b3-ae22-bSac7182dle 3507-0 I 1 Page 155 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006819 EFTA00158404
Page 156 1 BY MR. EDWARDS: 2 Q. So, do you know where it was that 3 Mr. Brunel flew in from? 4 A. No. 5 Q. Do you know where Mr. Brunel generally 6 lives? I mean is it New York, is it -- 7 A. I know that he spends some time in Florida, in 8 Miami, but exactly where he is, I don't know. 9 Q. But obviously he wouldn't fly here to Palm 10 Beach from Miami, right, so he had to be coming from 11 somewhere else you would assume? 12 A. Yes, I assume. 13 Q. Were you told -- similar to the way that 14 you have been describing throughout the deposition, 15 you're told who is coming in town. Were you told he 16 was going to be at the house? 17 A. Yeah. Usually he requires to be picked up, so 18 I know that he is coming. 19 Q. Okay. We'll go through some other 20 instances where you had occasion to pick him up or 21 break plans, but talking specifically about last 22 week: When were you first told that Mr. Brunel was 23 going to be coming into town? 24 A. I think Igor told me that he has to go and 25 pick him up. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2d75a91d4esa42b3-m22-b5dUrifIlMie 3507.011 Pagc 156 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006820 EFTA00158405
Page 157 1 Q. How did he -- 2 A. It was my day off, I guess, because usually I 3 am the one who pick up people. So, I guess it was my 4 days off and Igor was working, so he went to pick him 5 6 up. Q. Okay. It wouldn't be picking 7 him up? 8 A. No. 9 Q. So, to the best of your recollection Igor 10 picked up Jean Luc Brunel sometime last week from 11 the airport and took him to the house? 12 A. Right. 13 Q. Do you know what car he took to pick him 14 up? 15 A. I think Cadillac Escalade. 16 Q. The black Escalade? 17 A. Yes. 18 Q. And what did Mr. Brunel and Mr. Epstein do 19 for the three day stay when Mr. Brunel was staying 20 at Mr. Epstein's house last week? 21 MR. GOLDBERGER: Form. 22 THE WITNESS: I don't know. 23 BY MR. EDWARDS: 24 Q. Did you interact, communicate with 25 Mr. Brunel? (561) 832-7500 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) (561) 832-7506 2d75a91thleaa-02b3-ae22-bSd3c7182dle 3507-011 Page 157 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000682I EFTA00158406
1 2 3 4 A. 4. Page 158 Yes. And what did he say as to why he was here? MR. GOLDBERGER: Form. THE WITNESS: Good morning. How are you? 5 Exchange handshake. And I saw him in the 6 kitchen and he was cooking something and that's 7 it. 8 BY MR. EDWARDS: 9 Q. When you say he was cooking something, he 10 was personally cooking? 11 A. Yes. 12 Q. All right. So, this is a house that he is 13 familiar enough with and he is a regular enough 14 guest that he makes himself at home? 15 A. Yes. 16 Q. Okay. And last week do you remember 17 anything in the three-day period that Mr. Brunel was 18 staying at the house that Mr. Brunel did from the 19 time he woke up to the time that he went to sleep? 20 MR. GOLDBERGER: Form. 21 BY MR. EDWARDS: 22 Q. I mean did go to the movies? Did he go to 23 the beach? Did they just hang out around the house 24 and walk? 25 A. Yeah. I think he walked outside to the beach. (561) 832-7500 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) (561) 832-7506 2d7Sa91d-3eaa-42b3-ae22-b5d3c7182d1e 3507-011 Pagc 158 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006822 EFTA00158407
Page 159 1 He was swimming in the pool, talking on the phone just 2 what I remember. 3 Q. Okay. During the three-day stay last 4 week, how often were -- I mean, I assuming that he 5 came in town to see Mr. Epstein; is that true? 6 A. Yes. 7 Q. And so the majority of his time during 8 that three days was spent hanging around with 9 Mr. Epstein? 10 A. Yes. 11 Q. All right. Did you see them talking with 12 one another? 13 A. Yes. 14 Q. Where were they talking with one another? 15 A. In the cabana, outside sitting next to the 16 pool. 17 Q. All right. And when you said that 18 Mr. Brunel walked to the beach, did Mr. Epstein walk 19 to the beach with him? 20 A. No. 21 Q. Mr. Brunel walked alone? 22 A. Yes. 23 Q. Who else was in the house last week while 24 Mr. Brunel was in the house? 25 A. , and , I think. (561) 832-7500 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) (561) 832-7506 2W5a9W4en42113-m224M3O182Ale 3507.011 Page 159 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006823 EFTA00158408
Page 160 1 Q. 2 A. Yes. 3 Q. And 4 A. Yes. 5 Q. Okay. Who else, Igor? 6 A. Igor. I guess that's it. 7 Q. Did you overhear any of the substance of 8 the conversations that Mr. Brunel was having with 9 Mr. Epstein? 10 A. No. 11 Q. All right. What is your understanding as 12 to the relationship between Mr. Brunel and 13 Mr. Epstein? 14 A. I guess they are friends. 15 Q. Okay. In addition to being friends 16 well, let me ask this question first: Do you know 17 when they became friends? 18 A. No. 19 Q. You don't know how long they have known 20 each other? 21 A. No. 22 Q. You don't know who introduced them? 23 A. No. 24 Q. They could have met since they were five 25 years old or they could have met five years ago for (561) 832-7500 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) (561) 832-7506 2C5aMd-Usa-42b3-ae22-b5d3c7182dle 3507-011 Page 160 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006824 EFTA00158409
Page 161 1 all you know? 2 A. Yes. 3 Q. In addition to being friends, do you know 4 them to be -- have a business relationship with one 5 another? 6 A. I don't know. 7 Q. Do you know what Mr. Brunel does for a 8 living? 9 A. I think he has some modeling agency, owner of 10 some modeling agency. I don't know exactly where, which 11 one. 12 Q. Why do you think that? Why do you think 13 he is involved with a modeling agency? 14 A. I think somebody told me. 15 Q. Okay. That's fair enough. Who? 16 A. I don't remember who. 17 Q. Would it be or Mr. Epstein? 18 A. It could be. 19 Q. And whether it was or -- whoever 20 told you about this was one of the people that you 21 have previously described as being within the 22 Jeffrey Epstein organization? 23 A. Yes. 24 Q. And as you sit here today, you can't say 25 definitely it was one person within the organization (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa02b3-3922-101d3c7182dle 3507.011 Page 161 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006825 EFTA00158410
Page 162 1 but it was one of those people you named? 2 A. Correct. 3 Q. Most likely 4 A. Yes. 5 Q. Okay. And do you remember in what context 6 she told you Mr. Brunel is in -- is involved in the 7 modeling industry or modeling agency? 8 A. No. 9 Q. Would you know the name of his modeling 10 agency? 11 A. No. 12 Q. Have you heard the name, MC Squared or 13 MC2? 14 A. Yes. 15 Q. And where have you heard that? 16 A. In one of the magazines it mentions, I read an 17 article about modeling. It mentioned a couple of them 18 Casablanca, MC2 and. 19 Q. Casablanca? 20 A. Yeah. They are some other agencies. 21 Q. Casablanca, where have you heard that name 22 before? 23 A. I heard that in one of the magazines, I think. 24 Q. Is there a person with that last name that 25 is also friends with Brunel that you're aware of? (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Pagc 162 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006826 EFTA00158411
Page 163 1 A. Yeah. I don't know. Yeah, John Casablanca. 2 Q. He is friends with Jean Luc Brunel? 3 A. I don't know. That was the fourth modeling 4 agency I think. 5 Q. And have you ever seen John Casablanca? 6 A. No. 7 Q. Okay. But you know him to be associated 8 with a modeling agency? 9 A. I mean I heard the name. I heard about his 10 agency, modeling agency, but I don't know who he is. 11 Q. Did you hear his name from Jean Luc Brunel 12 or Mr. Epstein? 13 A. No. 14 Q. Okay. So, other then seeing Jean Luc 15 Brunel at the house last week and talking with 16 Mr. Epstein by the pool or by the cabana or around 17 the house, did you make any other observations as to 18 what Mr. Brunel was doing in town? 19 A. No. 20 Q. Did you overhear anything else that 21 Mr. Brunel was speaking to Mr. Epstein about or 22 vice-versa? 23 A. No. 24 Q. In addition to when you would see 25 Mr. Epstein and Mr. Brunel talking or communicating (561) 832-7500 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) (561) 832-7506 2d75891d3eaa42b3-m224MUTISIMU 3507.011 Pagc 163 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006827 EFTA00158412
Page 164 1 with one another, who else was usually around? 2 A. I don't see anybody. 3 Q. I mean, was with them or or 4 anybody else? 5 A. Yeah. I guess, yes. He sometimes ask for 6 coffee or tea, so either or bring him a tea 7 or coffee. So, probably they -- it was a moment when 8 they were together talking and either or 9 brought them something to drink, but I don't know. I 10 don't see them. 11 Q. During his three-day stay did you see any 12 other females around the house aside from and 13 ? 14 A. Yeah. There was one. What's her name, III . 15 Q. .7 16 A. -. 17 Q. 18 A. Yeah. 19 Q. What's her last name? 20 A. I don't know her last name. 21 Q. And was she with Mr. Brunel? 22 A. No. She was also picked up by Igor from the 23 airport. 24 Q. Do you know where she came from? 25 A. No. (561) 832-7500 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) (561) 832-7506 205aMd-Uaa-42b3-ae22-bSd3c7182dle 3507-011 Page 164 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006828 EFTA00158413
Page 165 1 Q. Were you told that she was coming in town? 2 A. Igor told me because he has to pick her up. 3 It was my day off. 4 Q. All right. I don't think that I am 5 familiar with that person, III. Is that somebody 6 who has been to the house before? 7 A. No. 8 Q. First time that you saw her was last week? 9 A. Yes. 10 Q. Okay. And did she seem to know Jean Luc 11 Brunel? 12 A. I don't know. 13 Q. You couldn't tell by the interactions or 14 anything like that? 15 A. No. 16 Q. To you they could have been complete 17 strangers, or they could have known each other 18 forever? 19 A. Yes. 20 Q. Okay. Do you go out of your way not to 21 observe? I mean, is that -- that's a bad way to ask 22 the question. Is it your job when people are around 23 the house to kind of stay away or stay in the 24 background? 25 MR. GOLDBERGER: Form. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2W5a9W4eaa42b3-m22-bMUTIMMU 3507.011 Pagc 165 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006829 EFTA00158414
Page 166 1 THE WITNESS: I mean, it's not, I try to 2 not be around them. You know, it's not -- my 3 job is to make sure that everything is what 4 they ask for. I don't want to be around them 5 and listen when they are talking and looking at 6 whom they are talking. I try to stay away, 7 yes, as long as possible. 8 BY MR. EDWARDS: 9 Q. And when I ask questions about your 10 knowledge based on your observations, I mean 11 obviously you've seen me talking with your attorney, 12 Jack Goldberger, today and you can tell that we've 13 talked at some point in time in the past, right; 14 that today isn't the first time we've ever talked to 15 one another. 16 And that's kind of what I am asking you 17 about this person III. Just based on your 18 observations and common sense, could you tell that 19 this person, III, knew Jean Luc Brunel before last 20 week? 21 A. I don't think so. 22 Q. Okay. How old would you estimate or 23 approximate this person III to be assuming you don't 24 know her age? 25 A. I think in her 30's or late 20's. (561) 832-7500 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) (561) 832-7506 2d7Sa91d-3eaa-412b3-se2265d3c7182dle 3507.011 Page 166 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006830 EFTA00158415
Page 167 1 Q. And was she a model? Is she a model? 2 A. I don't know. 3 Q. What did you see her do -- strike that. 4 How long did she stay at the house? 5 A. Four days, I think. 6 Q. Do you know how Mr. Epstein knows III? 7 A. No. 8 Q. Is III friend or friend or 9 Mr. Epstein's friend? Who was she there to see? 10 A. I would say Mr. Epstein's friend. 11 Q. All right. And where did she sleep while 12 she was in town? 13 A. One of the guest rooms. 14 Q. Based on your observations could you tell 15 if Mr. Epstein was romantically or intimately 16 involved with III? 17 A. No. 18 Q. Based on your observations could you tell 19 if Jean Luc Brunel was intimately involved with III? 20 A. No. 21 Q. No. You can't tell or, no, they were not? 22 A. No, I cannot tell. 23 Q. Okay. So, is there anything more that you 24 can tell me about what her possible purpose for 25 being in town or why she was there? (561) 832-7500 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) (561) 832-7506 2d75a9td4eaa42b3-m2245d3c7182dle 3507.011 Page 167 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006831 EFTA00158416
Page 168 1 A. No. She was a guest, I assume. 2 Q. Any reason why there would be an overlap 3 between her staying at the house and Jean Luc 4 staying at the house, or it was just coincidence as 5 far as you could tell? 6 A. I don't know. 7 Q. Okay. And is there anywhere where you've 8 written down or documented what last name is? 9 A. No. 10 Q. Did you take her back to the airport? 11 A. Yes. 12 Q. And what day did you take her to the 13 airport? 14 A. Yesterday. 15 Q. Yesterday. So, she was here four days. 16 She got here last Thursday or Friday? 17 A. I think Friday. 18 Q. And she was at the house for a period of 19 time when Jean Luc Brunel was at the house? 20 A. Yeah. I mean, last week, yes. 21 Q. Okay. So, she got there Friday. When did 22 Jean Luc Brunel finally leave Mr. Epstein's house? 23 A. I think Monday, yeah, Monday. He left Monday. 24 Q. That's yesterday? 25 A. Or Sunday. (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Page 168 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006832 EFTA00158417
Page 169 1 Q. Today is Tuesday. 2 A. Today is Tuesday. Yes, I think Sunday. 3 Q. Okay. So, on Sunday Jean Luc Brunel left 4 and on Monday III left? 5 A. Yes. 6 Q. All right. Did you take Jean Luc Brunel 7 to the airport? 8 A. No. 9 Q. All right. Did Igor? 10 A. 11 Q. . And do you know where he 12 was flying to? 13 A. No. 14 Q. You don't know where he came from or where 15 he was flying to? 16 A. Right. 17 Q. Right. And as of right now you have no 18 knowledge as to where he primarily resides, whether 19 that -- I know you said that he spends some time in 20 Miami, but whether he primarily resides in Miami or 21 New York or Antartica, you have no idea? 22 A. No. 23 Q. Okay. Other than last week, when was the 24 last time that you saw this gentleman Jean Luc 25 Brunel at Jeffrey Epstein's house? (561) 832-7500 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) (561) 832-7506 2W5a9W4eaa42b3-m22-bSonerMIWU 3507.011 Page 169 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA _00006833 EFTA00158418
Page 170 1 A. He was here -- I don't remember exactly, maybe 2 like a month, two months ago. 3 Q. So, it's February 16th, right now. Do you 4 think that it was sometime in January of 2010? 5 A. Could be. 6 Q. All right. And would this be at the 7 beginning of January, the middle or the end of 8 January 2010, if you remember? 9 A. No, I don't remember. 10 Q. And did you pick him up from the airport 11 on that occasion? 12 A. Yes, I think so. 13 Q. All right. And what airport was that? 14 A. I think it was Palm Beach Airport. 15 Q. Do you know where he flew into that time? 16 A. No. 17 Q. And did he fly a private jet or a 18 commercial airline? 19 A. Commercial. 20 Q. Does he always fly commercial when he 21 comes into town? 22 A. Yes, most of the time. 23 Q. Have you ever known him to fly on one of 24 Jeffrey Epstein's airplanes? 25 A. I think on one occasion he went with him to (561) 832-7500 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) (561) 832-7506 2d75891d-Uaa42b3-m22-bMUTIVAte 3507.011 Page 170 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006834 EFTA00158419
Page 171 1 New York. 2 Q. Okay. And is it your understanding that 3 the modeling agency that he is associated with is a 4 modeling agency based out of New York? 5 A. I don't know. New York or Miami. I'm not 6 sure. 7 Q. Okay. Well, MC Squared is a modeling 8 agency that has an office in New York and Miami. 9 A. Oh, oh. 10 Q. Is that something that you know is 11 consistent with your observation and your knowledge? 12 A. No. 13 Q. You don't know? 14 A. No, I don't know. 15 Q. You say New York or Miami because those 16 are the only two cities that you associate Jean Luc 17 Brunel with in terms of what you know? 18 A. Yes. 19 Q. How do you know that he spends a 20 considerable amount of time in Miami? 21 A. I have no idea. 22 Q. Just from word around the house or 23 something? I mean, you had to know that from 24 something, right? 25 A. No. On one occasion I know that he was going (561) 832-7500 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) (561) 832-7506 2C5aMd4eaa-Ob3-802-bSacflUdle 3507-01I Page 171 of 2.(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006835 EFTA00158420
Page 172 1 2 3 4 5 to Miami. Q. Okay. A. But how long he stay in Miami, how long he stays outside of Miami, I have no idea. Q• And when was that occasion where you know 6 that Jean Luc Brunel was in Miami or spending time 7 in Miami? 8 A. I think at one point I drove him to Miami. 9 Q. And when was that? 10 A. I think the time he was here in this month of 11 January. I think I drove him back to Miami from, from 12 the Palm Beach, Palm Beach house. 13 Q. Okay. So, that time in January he flies 14 into the Palm Beach airport from some undisclosed or 15 unknown location, you take him to the Palm Beach 16 house, right? 17 A. Right. 18 Q. How long does he stay on that occasion? 19 A. Maybe three days. 20 Q. And during that three-day period were any 21 other -- did any females accompany him to the Palm 22 Beach house? 23 A. No. I don't remember. I don't recall. 24 Q. Well, maybe this will jog your memory: 25 When you drove him to Miami, did you drive him (561) 832-7500 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) (561) 832-7506 2d7Sag I d-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Pagc 172 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006836 EFTA00158421
Page 173 1 alone -- 2 A. Yes. 3 Q. -- or did you drive him with somebody 4 else? 5 A. Alone. 6 Q. Okay. And where did you take him to in 7 Miami? 8 A. I don't know. He left -- he told me his car, 9 one of his friends somewhere in Miami Beach, so I 10 dropped him over there and he pick up his car over 11 there. 12 Q. And who is his friend, do you know? 13 A. I don't know. 14 Q. So, his car was in Miami? 15 A. Yes. 16 Q. What kind of car was that? 17 A. Mercedes. 18 Q. All right. And do you remember where it 19 was in Miami that his car was parked? 20 A. Some -- I don't remember the others, but 21 somewhere in Miami Beach. 22 Q. All right. At a condo, at an apartment, 23 on the side of the road, a house? 24 A. No. It was a private house. 25 Q. A private house on Miami Beach. Do you (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 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) 2d7Saald-3eaa-42b3-ae22-115d3c7182dle 3507-01I Page 173 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006837 EFTA00158422
Page 174 1 know the name of the person that lived at that 2 house? 3 A. No. 4 Q. All right. In talking about this person 5 Jean Luc Brunel, would -- you said he came here last 6 week. He came here in January. Stayed three or 7 four days each time, two consecutive months. Since 8 Mr. Epstein has been out on house arrest is Jean Luc 9 Brunel one of the people that visits on a monthly 10 basis? 11 A. No. 12 Q. Okay. 13 A. There was no regular visit. It's just 14 occasionally I would say. 15 Q. Okay. So, prior to the January visit, 16 when is the previous time that Jean Luc Brunel was 17 at Mr. Epstein's house? 18 A. I don't remember. I don't remember. 19 Q. Is he one of the people who frequently 20 calls Mr. Epstein? 21 A. Yes. 22 Q. And Mr. Epstein frequently calls him? 23 A. I don't know. 24 Q. Okay. Well, I guess you would only know 25 the calls that come in and you take messages, right? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2d7Sa91d-3eaa-42b3-ae22-b5d3c7182d1e 3507-011 Pagc 174 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006838 EFTA00158423
Page 1 A. Right. 2 Q. How times would you estimate -- I know you 3 told us two times in 2010. Let me ask it this way: 4 In 2010 were there only those two occasions where 5 6 Mr. Brunel was staying at Mr. Epstein's house in Palm Beach? 7 A. Yes, as far as I remember. 8 Q. Okay. How many occasions, in addition to 9 those two, would you estimate that Mr. Brunel has 10 stayed at the Palm Beach house since Mr. Epstein has 11 been out on house arrest and also staying at that 12 house? 13 A. It's hard to tell. I would say maybe three 14 times. 15 Q. Three times in addition to the two times 16 this year, five times total? 17 A. No, three times total. 18 Q. Okay. So, one time this month, one time 19 last month, and then for the period of time from -- 20 I don't remember when he was on house arrest, maybe 21 July. So from July to December you think that there 22 was only one other occasion when Mr. Brunel was at 23 the house? 24 A. You know, it's hard to remember but I think 25 so. He was maybe totally three times for the last few (561) 832-7500 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) (561) 832-7506 2d75891d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Page 175 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006839 EFTA00158424
Page 176 1 months. I don't really recall how many times. 2 Q. Okay. Did Mr. Brunel ever stay at the 3 Palm Beach house while Mr. Epstein was in jail? 4 A. No. 5 Q. Did anybody stay at the house while 6 Mr. Epstein was in jail? 7 A. No. 8 Q. Including or 9 A. I mean, when he was in jail, the house wasn't 10 finished completely yet. So, there was no visitors. 11 The house was finished before he got released. So I, I 12 don't think, I don't recall that anybody was -- it was 13 impossible to have somebody, you know, stay in the 14 house. 15 Q. Do you know when Mr. Brunel is going to 16 come back to the Palm Beach house? 17 A. No. 18 Q. You haven't been told? 19 A. No. 20 Q. All right. We've gone over a lot of 21 individuals that come to Mr. Epstein's house at 22 various times, and I think you have given me a 23 pretty good list. But from the time he was out on 24 house arrest, who else that we have not talked about 25 has stayed the night at Mr. Epstein's house? (561) 832-7500 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) (561) 832-7506 2d75a91d4eaa-42b3-8922-bSd3c7182dle 3507-011 Page 176 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006840 EFTA00158425
Page 177 1 Meaning if Alan Dershowitz stayed there, I want to 2 know. If some girls flew in from New York, I want 3 to know. And I am just giving you generic examples. 4 A. As far as I recall it was -- one girl, her 5 name was 6 Q. That's another girl, right? That's a 7 separate girl? 8 A. Right. And I guess that's it. 9 Q. Okay. How many times has been to 10 Mr. Epstein's house since Mr. Epstein has been on 11 house arrest? 12 A. Two or three times. 13 Q. Do you know where she comes from? 14 A. No. 15 Q. Do you pick her up from the airport? 16 A. Yes. 17 Q. So, she flies in from out of town? 18 A. Right. 19 Q. Your understanding is that it's New York 20 or you really have no idea? 21 A. No idea. 22 Q. How about 23 A. Same things. 24 Q. Been two or three times, comes from out of 25 town, you don't know where she's coming from? (561) 832-7500 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) (561) 832-7506 2d75891d-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Page 177 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006841 EFTA00158426
?age 173 1 A. Right. 2 Q. How old are these people, and 3 4 A. In their 20's. 5 6 Q. And when they come, do they, do either of them sleep with Mr. Epstein? 7 A. No. 8 Q. Both sleep in different rooms? 9 A. Right. 10 Q. Is it your understanding based on your 11 observations that either of them are intimately 12 involved with Mr. Epstein? 13 A. No. 14 Q. No idea? 15 A. No idea. 16 Q. Any reason to believe that either of them 17 are intimately or romantically involved with 18 or 19 A. No. 20 Q. Okay. Do you know the purpose for them 21 coming in town? 22 A. No. 23 Q. Do you know the last name of or 24 25 A. No. (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Pagc 178 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006842 EFTA00158427
Page 179 1 Q. All right. And you told me that while he 2 was in jail nobody came to the house. So, let's 3 back up before that from the search warrant to him 4 going to jail, he was not at the house, Jeffrey 5 Epstein was not at the house, right? 6 A. Right. 7 Q. So, we can back this time table up to you 8 beginning to work in February of 2005 through search 9 warrant executed on October 20th, 2005, which gives 10 us ten or so months there. 11 In those ten months, how many times has 12 Jean Luc Brunel come to visit? 13 A. I don't know. Maybe twice, once. He wasn't 14 very often visiting him. 15 Q. You think he what? 16 A. He wasn't very often visiting him. 17 Q. Okay. And on those occasions was it 18 similar in that he would stay three or four days or 19 would he stay longer? 20 A. No, three or four days no longer. 21 Q. And even back then in 2005, did you know 22 where he was coming from? 23 A. No. 24 Q. And on those occasions prior to the search 25 warrant being executed, were females in the house (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) Electronically signed by cynthla hopkins (601.051-976.2934) (561) 832-7506 2d75a9Ithleaa-42b3-ae22-bSd3c7182dle 3507-011 Page 179 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006843 EFTA00158428
Page 180 1 along with Jean Luc Brunel that you remember? 2 A. Yeah. I think that was -- was there. I 3 think some other guests too, but I don't remember 4 Q. What about the -- 5 A. -- who was there and how long they were 6 staying. 7 Q. How about the young females that were 8 providing massages, did any of them ever provide a 9 massage to Mr. Brunel that you remember? 10 A. No, I don't remember. 11 Q. Okay. Is that something that you're 12 saying never happened or you just don't remember 13 whether it happened or it didn't? 14 A. I just don't recall, you know, having those 15 massage girls coming and having him being in the house. 16 Q. Okay. Well, we have gone, kind of gone 17 through the frequency with which these girls came. 18 And at least in terms of Mr. Epstein being at the 19 house, if he was there for four days then they would 20 come three days or relatively that's the ratio we've 21 talked about. 22 So, if Mr. Brunel was there for a period 23 of four days straight, you know, just given 24 Mr. Epstein's massage schedule, so to speak, does 25 that help to remind you or refresh your recollection (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182dle 3507-011 Pagc 180 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006844 EFTA00158429
Page 181 1 as to whether or not these girls were in the house 2 at the same time that Mr. Brunel was in the house? 3 A. Could be. 4 Q. But if they came over, you don't remember 5 whether Mr. Brunel was also given a massage? 6 A. No, I don't, I don't remember. I don't even 7 know. 8 Q. Other than massages for Mr. Epstein by 9 these young females, are you able to say that 10 anybody else received a massage from any of these 11 girls? 12 MR. GOLDBERGER: Form. 13 THE WITNESS: I don't know. 14 BY MR. EDWARDS: 15 Q. Are you saying it could have happened, it 16 might not have happened; you just don't remember? 17 A. I haven't seen, no -- 18 MR. GOLDBERGER: Form. 19 THE WITNESS: -- or being told it. 20 MR. EDWARDS: Okay. 21 THE WITNESS: This other person has some 22 kind of massage. 23 BY MR. EDWARDS: 24 Q. Okay. Did Mr. Brunel ever arrive with 25 other females to stay on any of the occasions back (561) 832-7500 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) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e 3507.011 Pagc 181 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006845 EFTA00158430
Page 182 1 in 2005? 2 A. I don't remember. I haven't seen him. 3 Q. Excuse me? 4 A. I don't remember. I haven't seen him coming 5 with the other, I would say guests or other company, or 6 I have seen him coming alone. Every time I pick him up, 7 he was alone. 8 Q. Did you talk to him when you would give 9 him rides to and from the airport or to and from 10 Miami? 11 A. Yeah. We talk on the way to Miami. 12 Q. Would he tell you why he was here or what 13 he was doing, business? 14 A. No. Just, you know, pep talk I would say. 15 Q. Pep talk? Who was giving who the pep 16 talk? 17 A. He was the one who talk a lot. 18 Q. It's my understanding that Mr. Epstein 19 does not drink, right? 20 A. Right. 21 Q. And by that I mean I am talking about 22 alcohol, obviously. 23 A. Yes. 24 Q. How about Mr. Brunel? 25 A. I haven't seen him drinking either. (561) 832-7500 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) (561) 832-7506 2C5a91d4eaa-0113tUflUdle 3507-011 Page 182 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006846 EFTA00158431
Page 183 1 Q. Okay. Also my understanding Mr. Epstein 2 doesn't smoke, use drugs, any of those things? 3 A. That's true, yes. 4 Q. Mr. Brunel, have you seen him? 5 A. No. 6 Q. Have you seen him smoke? 7 A. Yeah, he smokes. 8 Q. He does? 9 A. Yes. 10 Q. Use drugs? 11 A. (Witness shakes head.) 12 Q. Not that you've seen? 13 A. No. 14 Q. Have you ever gone on any of the airplanes 15 that are owned by Mr. Epstein? 16 A. Yes. I was once when I got this job first 17 time because I came here first time without my 18 belongings. So, I told them can I get a ride to New 19 York, pick up my stuff and I went here. So, one time I 20 flew from here to New York. 21 Q. Was anybody else on the airplane that 22 time? 23 A. Yeah. It was , him, . That's it . 24 Q. And is it your understanding that 25 has ever been intimately involved with Mr. Epstein? (561) 832-7500 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) (561) 832-7506 2d75891d-3eaa-42b3-ae22-b5d3c7182dle 3507.011 Page 183 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J)0006847 EFTA00158432
Page 184 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 A. No. Q. How about Ghislaine Maxwell? A. No. Q. To the best of your knowledge you never knew anything about that? A. I don't know what's going on. Q. All right. Have you ever heard the name A. No. Q. , do you know who that is? A. No. Q. , do you know her? A. Yes. Q. How do you know A. She works for Ghislaine Maxwell, her assistant. Q. In New York? A. In New York. Q. And have you ever known to have been linked to Mr. Epstein in a physical relationship? A. No. Q. What do you think that she does for Ghislaine Maxwell? A. I guess she organize her schedule and do some, (561) 832-7500 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) (561) 832-7506 2C5aMd4eaa-2b3-ae22-bSacflUdle 3507-011 Page 184 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006848 EFTA00158433
Page 185 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 23 24 25 some stuff for her. Q. Well, what does Ghislaine Maxwell do that needs organizing, do you know? A. I guess she has a lot of social events. Q. Okay. Have you ever met? A. Put down -- Q. I'm sorry. A. She has to put down everything. Q. Have you ever met A. Yes. Q. Was that at the Palm Beach house? A. She was here a few times, and I met her up in New York. Q. When was the last time that you met Dana Burns or saw A. I would say two years ago. Q. A. Q. A. Just before Mr. Epstein was in jail? Or after. Where did you see her? Yeah. I think, yeah, she was here for a few days working Q. And is that during the time period when Mr. Epstein was out on work release? A. Yes. (561) 832-7500 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) (561) 832-7506 2C5aMd4eaa-2b3-ae22-bSacflUdle 3507-011 Page 185 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006849 EFTA00158434
Cade 18(' 9 10 11 12 13 14 16 17 18 19 23 24 Q. Nobody. So, when was working do you know what she was doing? A. She was in the office answering phone calls, doing some e-mails, answering mail I guess. Q. Okay. And you saw her A. Yes. Q. Okay. Did she stay at or at when she was in town? A. No, no. Q. What is your, what is your understanding as to the names of the employees that work for= Mr. Epstein, who else? (561) 832-7500 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) (561) 832-7506 2d7Sagld-3eaa-4263-ae2265d3c7182dle 3507-011 Page 186 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006850 EFTA00158435
Page 187 1 2 3 4 5 6 7 8 9 10 11 12 13 14 16 A. Yes. 17 Q. And Mr. 18 A. Yes. 19 Q. And Ms. 20 A. Yes. 21 Q. And who 22 their own office 23 A. Nobody. 24 conference room. 25 Q. Okay. A. Q. A. Do you know what he does? is involved too. Q. Do you know what does for the Florida Science Foundation? A. No. Q. That's just somebody who you've seen working A. Yes. Q. When you've had occasion to go there, and I am assuming you have been there numerous times, right? A. Right. Q. The people who have offices within III are Mr. Epstein? ? I am asking. else within that office has, has There are three offices, one (561) 832-7500 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) (561) 832-7506 2dnaMd-Usa-42b3-ae22-bSacflUdle 3507-011 Page 187 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006851 EFTA00158436
Page 188 1 A. So, one is for another is for 2 3 Q. So, to the best of your knowledge the 4 regular employees, based on your observations, are 5 Mr. Epstein, Mr. and Ms. 6 A. Yes. 7 Q. Okay. And at least on a couple of 8 occasions you have seen there? 9 A. Right. 10 MR. EDWARDS: All right. 11 RECROSS (JANUSZ BANASIAK) 12 BY MR. MERMELSTEIN: 13 Q. I have just one follow-up question. What 14 is the reason that you come to the office on a 15 regular basis 16 A. I bring Mr. Epstein from jail. 17 Q. You bring him from jail? 18 A. Right, to the office and take him back to 19 jail. 20 Q. That was when he was on work release, 21 right? 22 A. Right. 23 Q. Is there any other occasion that you 24 for that purpose you were given a card for access to 25 the garage? (561) 832-7500 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) (561) 832-7506 2d75a9td4eaa42b3-m224MUTIWWle 3507.011 Pagc 188 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006852 EFTA00158437
Page 189 1 A. Yes, yes. 2 Q. Before Mr. Epstein was in jail, were there 3 occasions where you came to the office here? 4 A. Before jail? 5 Q. Before jail. 6 A. Yeah. I was, I was the one who organize, you 7 know, put everything together, bring furniture, bring 8 some things over there. 9 Q. You set up the office? 10 A. Yes. 11 Q. When was that? 12 A. Oh, I don't remember exactly. When he was in 13 jail. 14 Q. Before he was in jail or during the time 15 he was in jail? 16 A. I think before. 17 Q. How long before he went to jail did you 18 set up the office? 19 A. A few months, two, three. I don't remember. 20 Q. After you set up the office, were there 21 occasions where you would come to the Florida 22 Science Foundation office? 23 A. Yes, very often. 24 Q. What would you come for? 25 A. They call me to bring some food for them, (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthla hopkins (601-051-976-2934) (561) 832-7506 2d75a91d-3eaa-42b3-ae22-b5d3c7192dle 3507-011 Page 189 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006853 EFTA00158438
Page 190 1 lunch, pick up some, bring some papers, office supplies. 2 That's it 3 Q. You would run errands for the office? 4 A. Yes. 5 MR. MERMELSTEIN: Nothing further. 6 MR. EDWARDS: All right. Are you going to 7 read or waive? 8 MR. GOLDBERGER: We will read. All right. 9 THE COURT REPORTER: Did you want to order 10 this? 11 MR. EDWARDS: Yes, please. 12 THE COURT REPORTER: Did you want a copy, 13 Mr. Mermelstein? 14 MR. MERMELSTEIN: Yes. 15 THE COURT REPORTER: Mr. Goldberger, do 16 you want a copy? 17 MR. GOLDBERGER: Yes. Send it to Critton. 18 Bill him, seriously. 19 (Witness excused.) 20 (Deposition was concluded.) 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, 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) (561) 832-7506 2dnaMd-Usa-2b3-ae22-b5d3c7182dle 3507-011 Page 190 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006854 EFTA00158439
Page 191 1 CERTIFICATE OF OATH 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 JANUSZ BANASIAK personally appeared before me 8 and was duly sworn on the 16th day of February, 9 2010. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Dated this 28th day of February, 2010. AS Cynthia Hopkins, RPR, FPR Notary Public - State of Florida My Commission Expires: February 25, 2011 My Commission No.: DD 643788 (561) 832-7500 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) (561) 832-7506 2e5aMd-Usa4a63-ae22-b5d3crindle 3507-01 Page 191 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006855 EFTA00158440
Page 192 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, Cynthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Notary 6 Public in and for the State of Florida at large, do hereby certify that I was authorized to and did 7 report said deposition in stenotype; and that the foregoing pages are a true and correct transcription 8 of my shorthand notes of said deposition. 9 I further certify that said deposition was taken at the time and place hereinabove set forth 10 and that the taking of said deposition was commenced and completed as hereinabove set out. 11 I further certify that I am not attorney or 12 counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party 13 connected with the action, nor am I financially interested in the action. 14 The foregoing certification of this transcript 15 does not apply to any reproduction of the same by any means unless under the direct control and/or 16 direction of the certifying reporter. 17 Dated this 28th day of February, 2010. 18 19 20 AA 21 C4/61 AJAS C thia Hopkins, R R, FPR 22 23 24 25 (561) 832-7500 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) (561) 832-7506 2d75891d-Uaa-42b3-ae22-bSa0182dle 3507-0II Page 192 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006856 EFTA00158441
Page 193 1 5 6 DATE: February 28th, 2010 TO: JANUSZ BANASIAK c/o Jack Alan Goldberger, Esquire ATTERBURY, GOLDBERGER & WEISS, P.A. IN RE: III. vs. Epstein CASE NO.: 502008CA028051XXXXMB AB Please take notice that on Tuesday, the 16th of February, 2010, you gave your deposition in the above-referred matter. At that time, you did not waive signature. It is now necessary that you sign your deposition. As previously agreed to, the transcript will be furnished to you through your counsel. Please read 11 the following instructions carefully: At the end of the transcript you will find an 12 errata sheet. As you read your deposition, any changes or corrections that you wish to make should 13 be noted on the errata sheet, citing page and line number of said change. DO NOT write on the 14 transcript itself. Once you have read the transcript and noted any changes, be sure to sign 15 and date the errata sheet and return these pages to me. 16 If you do not read and sign the deposition within a reasonable time, the original, which has 17 already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish 18 to waive your signature, sign your name in the blank at the bottom of this letter and return it to us. 19 Very truly yours, 20 21 Cynthia Hopkins, RPR, FPR 22 23 I do hereby waive my signature. 24 25 JANUSZ BANASIAK (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hooking (601-051-976-2934) Electronically signed by cynthia hooking (601-051-976-2934) Electronically signed by cynthia hooking (601-051-976-2934) (561) 832-7506 2W5a9W4eaa42113-m224,MUTIMMU 3507.011 Page 193 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006857 EFTA00158442
Page 194 1 CERTIFICATE 2 - - - 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are true and correct to the best of 8 my knowledge and belief, with the exception of any 9 corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2010. 14 15 16 17 18 19 JANUSZ BANASIAK 20 Job #1317 21 22 23 24 25 (561) 832-7500 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) (561) 832-7506 2C5aMd4eaa-42b3-ae22-bSa0lUdle 3507-0 I I Page 194 of 2(X) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006858 EFTA00158443
Page 195 1 ERRATA SHEET 2 IN RE: III. VS. EPSTEIN CR: Cynthia Hopkins 3 DEPOSITION OF: JANUSZ BANASIAK TAKEN: February 16, 2010 4 JOB NO.: 1317 5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE # LINE # CHANGE REASON 6 7 8 9 10 11 12 13 14 15 16 17 Please forward the original signed errata sheet to this office so that copies may be distributed to all 18 parties. 19 Under penalty of perjury, I declare that I have read my deposition and that it is true and correct 20 subject to any changes in form or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 (561) 832-7500 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) (561) 832-7506 2W5a9W-308a42113-m224M3O182Ale 3507.011 Page 195 of 200 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006859 EFTA00158444
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