[0:00]SPEAKER_00:or another man and woman, or another man or woman, may consider to be unusual or overly aggressive.
[0:06]SPEAKER_02:Objection for one.
[0:07]SPEAKER_01:True.
[0:09]SPEAKER_01:Depends on the point of view.
[0:11]SPEAKER_00:That's what I mean.
[0:11]SPEAKER_00:Everyone has a different point of view about sex and what may be considered typical sexual activity for someone.
[0:19]SPEAKER_00:Someone else may consider that's a bit adventurous.
[0:21]SPEAKER_02:True.
[0:23]SPEAKER_00:Yes.
[0:24]SPEAKER_00:And I'm not trying to make you a sex expert here, so...
[0:30]SPEAKER_00:Also, I assume that when you've been in CVS or Walgreens and, for that matter, Publix or even Winn-Dixie, I assume that you've...
[0:40]SPEAKER_00:I don't want to assume anything.
[0:41]SPEAKER_00:You've ever been in an aisle where actually you've seen condoms being sold?
[0:45]SPEAKER_00:Yes.
[0:45]SPEAKER_00:Okay.
[0:46]SPEAKER_00:And where lubricants are being sold?
[0:48]SPEAKER_00:Yes.
[0:49]SPEAKER_00:All right.
[0:49]SPEAKER_00:And as well, massage oils and other types of oils actually are sold in those kinds of stores?
[0:54]SPEAKER_00:Yes.
[0:55]SPEAKER_00:All right.
[0:55]SPEAKER_00:And they're available so that...
[0:58]SPEAKER_00:someone walking through Walgreens or Publix or CVS could actually take it off the shelf, put it in their cart, go up and pay for it, and take it home?
[1:08]SPEAKER_00:Yes.
[1:09]All right.
[1:14]SPEAKER_00:In the photographs that you talked about, and if I understood you correctly, at least during the time that you were there, Mr. Rodriguez, in 2004 and 2005, you said that there were, I think you said downstairs, and I'm talking about really from the kitchen area up the back stairway, or what would be the kitchen stairway to the upper floor, there was, I think you said, but correct me if I'm wrong, please, that you don't recall seeing...
[1:39]SPEAKER_00:there being any pictures or photographs of any nude women is that correct they were not nude women in the staircase that's right that's all i'm talking about right now in that area you never saw any pictures or photographs paintings any type of depiction of a nude woman
[1:54]SPEAKER_00:No.
[1:55]SPEAKER_00:On that staircase going upstairs, correct?
[1:58]SPEAKER_00:Correct.
[1:58]SPEAKER_00:And I think you said downstairs you saw a picture of, the only picture that you saw of a, I'd say, of a younger child that displayed some form of, I don't want to say nudity because it's probably not that, but of some portion of their body that was exposed, and I think you described it as her cheek.
[2:19]SPEAKER_00:Yeah, that's upstairs.
[2:20]SPEAKER_00:That's upstairs.
[2:21]SPEAKER_00:Upstairs.
[2:22]SPEAKER_00:And that was...
[2:24]SPEAKER_00:There's a picture where someone, it looked like, was pulling on their swimsuit.
[2:27]SPEAKER_00:Yes.
[2:28]SPEAKER_00:Have you ever seen the old Coppertone?
[2:30]SPEAKER_00:Yes.
[2:31]SPEAKER_00:Let me ask the question.
[2:32]SPEAKER_00:I know you know what this is.
[2:33]SPEAKER_00:Have you ever seen the old Coppertone commercials and billboards that actually used to be plastered all over, certainly Florida and other places, where there's a cute little girl, appears to be two, three, four years old, and someone's pulling down at least a portion of her swimsuit, so she's exposing, or a small portion of her cheek is exposed?
[2:52]SPEAKER_00:Yes.
[2:52]SPEAKER_00:Okay.
[2:52]SPEAKER_00:Is that...
[2:53]SPEAKER_00:What the picture of the young girl looked like, that is Mr. Epstein's guy.
[2:57]SPEAKER_01:More or less, yes.
[2:58]SPEAKER_00:All right.
[3:02]SPEAKER_00:And downstairs in the kitchen, were there any pictures of women in any stage of undress?
[3:08]SPEAKER_01:No.
[3:09]SPEAKER_00:And then I think you said as you walk upstairs or as you walked up the stairway from the kitchen at the top of the...
[3:17]SPEAKER_00:the landing.
[3:18]SPEAKER_00:And I think you described it as a foyer.
[3:20]SPEAKER_00:Yes.
[3:21]SPEAKER_00:But it's really the landing, the upstairs landing.
[3:24]SPEAKER_00:I think you said that there were or was a three-by-five picture or pictures of women in some stage of undress.
[3:34]SPEAKER_00:Yes.
[3:36]SPEAKER_00:And when you say three-by-five, I assume you meant...
[3:39]SPEAKER_00:Three feet by five feet.
[3:41]SPEAKER_00:So they're large.
[3:42]SPEAKER_00:Were they photographs?
[3:43]SPEAKER_00:Yes, they were photographs.
[3:44]SPEAKER_00:And I think you also told us that you didn't recognize who those people were.
[3:48]SPEAKER_00:Is that correct?
[3:50]SPEAKER_00:I knew this particular girl because...
[3:55]SPEAKER_00:Okay.
[3:56]SPEAKER_00:And is that the picture you're talking about?
[3:59]SPEAKER_00:This is the picture I'm talking about.
[4:01]SPEAKER_00:Okay.
[4:01]SPEAKER_00:And that was a three by five?
[4:02]SPEAKER_00:Yes.
[4:03]SPEAKER_00:All right.
[4:04]SPEAKER_00:Was there...
[4:05]SPEAKER_00:And the only thing that you could see was a portion that is of her, other than, say, her waist or her shoulders or her arms or something.
[4:12]SPEAKER_00:That's one where you could see kind of like the Coppertone commercial, the picture of her cheek.
[4:16]SPEAKER_01:Yes, part of her buttocks.
[4:19]SPEAKER_00:OK. And was there another picture at the top of the foyer, large one, or is that the only one that you can recall?
[4:27]SPEAKER_01:And there were two of the same girl in the different poses.
[4:31]SPEAKER_01:But this showed the same thing?
[4:33]SPEAKER_00:Yes.
[4:33]SPEAKER_00:Okay.
[4:35]SPEAKER_00:As you walked through into... Then, if I understood it correctly, you go pretty much to the end of the hallway, and then you go through another small vestibule, double doors, two sets of double doors.
[4:49]SPEAKER_00:And as you go straight ahead, then you make a left around the bed, and then you end up in the bathroom.
[4:54]SPEAKER_00:Yes.
[4:54]SPEAKER_00:In the bathroom or in that location, were there any pictures of any women in any stage of undress?
[5:04]SPEAKER_00:Yes.
[5:05]SPEAKER_00:All right.
[5:05]SPEAKER_00:And were any of those pictures, did they involve...
[5:10]SPEAKER_00:Or were they of any of the girls that have been described as women who came over purportedly to give Mr. Epstein a massage?
[5:20]SPEAKER_00:Yes.
[5:21]SPEAKER_00:Okay.
[5:21]SPEAKER_00:And do you remember who any of the names of any of those people were?
[5:24]SPEAKER_00:No, sir.
[5:25]SPEAKER_00:Okay, and the pictures you saw, where were they located?
[5:28]SPEAKER_00:Inside his closet, the walk-in closet.
[5:31]SPEAKER_00:Okay, and those pictures, and was it, I think you called it a mosaic?
[5:35]SPEAKER_00:Yes.
[5:37]SPEAKER_00:And of the mosaic, approximately how many pictures were in the mosaic?
[5:48]SPEAKER_00:16 or 20.
[5:48]SPEAKER_00:Okay, and of those pictures, how many did you recognize?
[5:55]SPEAKER_00:By three or four.
[5:58]SPEAKER_00:And were they, as to who those people were, you don't know, you just recognized three or four of them?
[6:04]SPEAKER_01:Mr. Epstein, when he was younger, and then different girlfriends, but I didn't recognize except the ones I... And you said three or four of those were pictures of the girls who came over to give the massage?
[6:19]SPEAKER_00:Yes.
[6:20]SPEAKER_00:But as to who those girls were, you don't know as you sit here today?
[6:23]SPEAKER_00:No, sir.
[6:23]SPEAKER_00:And as to what their ages were, you don't know?
[6:25]SPEAKER_00:No, sir.
[6:26]SPEAKER_00:That's correct?
[6:27]SPEAKER_00:That's correct.
[6:28]SPEAKER_00:And as to what they depicted in the photographs of the girls, were they in different stages of undress?
[6:38]SPEAKER_00:Yes.
[6:39]SPEAKER_00:Was everyone undressed to some degree?
[6:42]SPEAKER_00:That is, they were described as nudes, or at least the questions have asked, were these people nude?
[6:47]SPEAKER_00:Were they actually nude, or someone may have had their top off?
[6:51]SPEAKER_00:There were two girls completely naked in the shower.
[6:55]SPEAKER_00:Okay.
[6:55]SPEAKER_00:In a sexual act.
[6:57]SPEAKER_00:And is that the one that you, when Mrs. Zell asked you questions, that's one of the photographs that you were talking about?
[7:03]SPEAKER_00:No, sir.
[7:04]SPEAKER_00:That was a different?
[7:05]SPEAKER_00:Different one.
[7:06]SPEAKER_00:Okay.
[7:06]SPEAKER_00:And in the mosaic that you saw, where you saw two girls involved in a sexual act, was that, do you know where that photograph was taken?
[7:13]SPEAKER_01:I think it was taken in one of the rooms in the house because it's an oval bathtub, but I don't know which room, sir.
[7:20]SPEAKER_01:Okay.
[7:20]SPEAKER_01:Did you recognize both the girls or just one of the girls?
[7:23]SPEAKER_00:The two girls.
[7:24]SPEAKER_00:All right.
[7:31]SPEAKER_00:And then there was one or two other photographs of girls that you recognized?
[7:36]SPEAKER_00:Yes.
[7:36]SPEAKER_00:And were they fully unclothed or did they have some degree of clothes on?
[7:42]SPEAKER_00:They were naked.
[7:47]SPEAKER_00:And all of the remaining pictures, at least within that mosaic, were of individuals that you did not know?
[7:51]SPEAKER_00:No, sir.
[7:51]SPEAKER_00:And that you did not recognize as having been at the house, is that correct?
[7:56]SPEAKER_00:Yes, that's correct.
[8:09]SPEAKER_00:You also asked about some... Let me switch for just a minute.
[8:17]SPEAKER_00:You asked about a vibrator that you saw, and I think you described it as a back massager that was approximately 18 inches long that had a couple of rotating heads on it.
[8:27]SPEAKER_00:Yes.
[8:28]SPEAKER_00:And I think you ultimately came...
[8:30]SPEAKER_00:up with the idea that it's something that you had seen at a sharper image store?
[8:34]SPEAKER_00:Yes, sir.
[8:35]SPEAKER_00:Have you ever seen one of those types of devices that is a back massager with the rotating heads also?
[8:41]SPEAKER_00:Let me ask you this.
[8:42]SPEAKER_00:Let me strike that last question.
[8:43]SPEAKER_00:Have you ever been to Brookstone?
[8:44]SPEAKER_00:Yes.
[8:45]SPEAKER_00:Have you ever seen a massager like that at Brookstone?
[8:47]SPEAKER_00:Yes.
[9:05]SPEAKER_00:You were asked whether Ms. Maxwell kept the names of any of the girls who came to give massages on.
[9:23]SPEAKER_00:Let me ask it this way, because I don't have a full recollection of it.
[9:29]SPEAKER_00:I think you were asked whether Ms. Maxwell ever kept the names of any of the girls who came to give massages.
[9:34]SPEAKER_00:And I think your response was yes.
[9:35]SPEAKER_00:Yes.
[9:36]SPEAKER_00:Did she keep them on a pad of paper?
[9:38]SPEAKER_00:Did she keep them in a notebook?
[9:39]SPEAKER_00:Did she keep them in a computer?
[9:44]SPEAKER_01:We used to have internal books.
[9:47]SPEAKER_01:for pilots, masseuses, chefs.
[9:50]SPEAKER_01:So she had a copy of the Black Book with herself and as well as the computer.
[9:55]SPEAKER_00:Did you ever go on Ms. Maxwell's computer to see what she had in it?
[9:59]SPEAKER_00:Yes.
[10:00]SPEAKER_00:And was that something that you were allowed to do?
[10:03]SPEAKER_00:No.
[10:04]SPEAKER_00:You actually went in her office?
[10:05]SPEAKER_00:Yes.
[10:06]SPEAKER_00:And was her computer on so that you didn't need to access the password?
[10:11]SPEAKER_00:It was off.
[10:13]SPEAKER_00:So you just turned it on?
[10:15]SPEAKER_00:Yes, sir.
[10:15]SPEAKER_00:And then you were able to access her computer?
[10:17]SPEAKER_00:Exactly.
[10:18]SPEAKER_00:And what possessed you to go in and to access her personal computer?
[10:24]SPEAKER_01:I needed to send some documents to the New York office, and it was the only computer working in the house.
[10:29]SPEAKER_00:On how many occasions did you use her computer?
[10:33]SPEAKER_01:Several times.
[10:34]SPEAKER_00:Was she ever aware that you used her computer?
[10:36]SPEAKER_00:I don't think so.
[10:39]SPEAKER_00:Did you ever ask Ms. Maxwell for permission to use your computer?
[10:43]SPEAKER_01:I was the house manager, I believe.
[10:46]SPEAKER_01:I was supposed to use everything in the house to accomplish my duties.
[10:51]SPEAKER_01:In that case, sending financial reports or emails.
[10:57]SPEAKER_00:And so would you have then, did you ever use Mr. Epstein's computers?
[11:02]SPEAKER_00:No.
[11:03]SPEAKER_00:But you used Ms. Maxwell's computer.
[11:05]SPEAKER_00:Yes.
[11:05]SPEAKER_00:Did you ever use ?
[11:08]SPEAKER_00:Yes.
[11:10]SPEAKER_00:And looking at Ms. Maxwell's, so you went into Ms. Maxwell's computer with at least the idea of sending some documents up to New York.
[11:18]SPEAKER_00:Yes.
[11:19]SPEAKER_00:And were you going to PDF them?
[11:20]SPEAKER_00:Yes.
[11:21]SPEAKER_00:And did she have a fax machine, not a fax machine, a copy machine in her office as well?
[11:26]SPEAKER_00:Yes.
[11:27]SPEAKER_00:So you were going to go, and how would you generally do that?
[11:30]SPEAKER_00:Would you do that through a Microsoft program?
[11:33]SPEAKER_00:Citrix.
[11:34]SPEAKER_00:Through Citrix, all right.
[11:35]SPEAKER_00:And with the Citrix, that is...
[11:38]SPEAKER_00:If you said you saw some names of individuals on her computer, if you were just going to PDF some documents up to New York, what would have caused you to have seen any names on her computer?
[11:58]SPEAKER_01:All the calls that they came to 358 El Brillo, they came through a telephone.
[12:06]SPEAKER_01:They have a transcript somehow with some technique to the computer.
[12:09]SPEAKER_01:So you can pull it and you register the time, who called, who didn't call, and you can pull this at your request.
[12:17]SPEAKER_01:So I used to use that to go back to some calls that they were requesting, especially when the hurricane season happened.
[12:27]SPEAKER_00:Okay, so if I understand you, is that even the computer you used would have had that same feature?
[12:34]SPEAKER_01:No.
[12:35]SPEAKER_01:No, it was totally different.
[12:36]SPEAKER_01:Mine was slower and all the time was breaking down.
[12:39]SPEAKER_01:That's why we have the guy from Ohio came and fixed the computers.
[12:43]SPEAKER_00:Okay, and were there other computers that you used that had that feature?
[12:47]SPEAKER_00:That is, that would... No, only... Mrs. Maxwell and the staff house.
[12:54]SPEAKER_00:Staff house being yours?
[12:55]SPEAKER_00:The guest house, yes, my office, yeah.
[12:57]SPEAKER_00:Okay, so you could go out to your guest house then and look for the same information?
[13:02]SPEAKER_00:No.
[13:04]SPEAKER_00:All right, I don't understand, but why don't we take a break because we're almost out of tape.