Juan Patricio Alessi — Direct/Cross/Voir Dire
1,793 linesDIRECT EXAMINATION BY MS. COMEY:
MS. COMEY: Good afternoon, Mr. Alessi.
JUAN PATRICIO ALESSI: Good afternoon.
MS. COMEY: How old are you?
JUAN PATRICIO ALESSI: I gonna be 72 couple weeks.
MS. COMEY: Where were you born?
JUAN PATRICIO ALESSI: I was born in Quito, Ecuador.
MS. COMEY: Where did you grow up?
JUAN PATRICIO ALESSI: I grew up to 19 in Quito, Ecuador.
MS. COMEY: Where did you go after you turned 19?
JUAN PATRICIO ALESSI: I came to the United States.
MS. COMEY: How far did you go in school?
JUAN PATRICIO ALESSI: I have one year of premed student.
MS. COMEY: What kind of work did you do after coming to the United States?
JUAN PATRICIO ALESSI: I only had three jobs before -- when I came to the United States. One was in a bottling company, perfume company, and another one was the largest dairy in New Jersey.
MS. COMEY: Mr. Alessi, I'm going to ask you to get closer to the microphone please and make sure it points towards your mouth. I want to make sure everyone can hear you.
JUAN PATRICIO ALESSI: Okay. This better now?
MS. COMEY: Thank you. After you worked in New Jersey, where did you go next
JUAN PATRICIO ALESSI: We moved to Florida.
MS. COMEY: What kind of work do you do now?
JUAN PATRICIO ALESSI: Now? I am retire.
MS. COMEY: About when did you move to Florida?
JUAN PATRICIO ALESSI: We move early 1994.
MS. COMEY: What type of work did you do after moving to Florida?
JUAN PATRICIO ALESSI: I work for a very wealthy family in the city of Palm Beach. They have a multiple properties, and I was a maintenance guy for those properties.
MS. COMEY: What did you do after that?
JUAN PATRICIO ALESSI: After that I start to work at -- for myself doing the same work, the same repairman service for different families in Palm Beach.
MS. COMEY: For about how long were you self-employed working for different families in Palm Beach?
JUAN PATRICIO ALESSI: About a year and a half.
MS. COMEY: What did you do after that?
JUAN PATRICIO ALESSI: After that I was a -- I work for Mr. Jeffrey Epstein.
MS. COMEY: About when did you meet Jeffrey Epstein?
JUAN PATRICIO ALESSI: I meet Mr. Epstein in early 1990.
MS. COMEY: How did you meet Jeffrey Epstein?
JUAN PATRICIO ALESSI: He -- he contact me because I was referred to him by one of his friends, Mr. Meister, and I went to -- also, I was working at Mr. Wexner's mother's house, and I was contacted by Mr. Epstein.
MS. COMEY: Ms. Drescher, would you please pull up what's in evidence as Government Exhibit 112. Looking at the screen in front of you, Mr. Alessi, do you recognize the person in this Exhibit?
JUAN PATRICIO ALESSI: Yes, that's Mr. Jeffrey Epstein.
MS. COMEY: Thank you. We can take that down, Ms. Drescher. What was your job title when you first started working for Mr. Epstein?
JUAN PATRICIO ALESSI: I was just a self-contractor to do the dismantling of the house. He just purchase a house.
MS. COMEY: What house was that?
JUAN PATRICIO ALESSI: At 358 El Brillo Way.
MS. COMEY: Was that in Palm Beach, Florida?
JUAN PATRICIO ALESSI: Palm Beach, Florida.
MS. COMEY: For about how long were you involved in renovating Mr. Epstein's house?
JUAN PATRICIO ALESSI: I was working as a self-contractor for about a year.
MS. COMEY: Just to get the timeline, about what year did you first start working for Mr. Epstein?
JUAN PATRICIO ALESSI: I start working for him around 1990.
MS. COMEY: And about when did you stop working for him?
JUAN PATRICIO ALESSI: I start -- I stop working for Mr. Epstein December -- at the end of December 2002.
MS. COMEY: At first, during the first couple years you worked for Mr. Epstein, what were your job responsibilities?
JUAN PATRICIO ALESSI: When I start working for him, my responsibility was doing repairs in the house, the dismantling of many rooms in the house. That's it.
MS. COMEY: About how long did those renovations on the house take?
JUAN PATRICIO ALESSI: It took it about a year.
MS. COMEY: And during that time, was Mr. Epstein able to stay in the house?
MS. COMEY: About when were the renovations completed?
JUAN PATRICIO ALESSI: I would think, I will say it's 1991.
MS. COMEY: After that, were there any other renovations on Mr. Epstein's Palm Beach house?
JUAN PATRICIO ALESSI: Yes, it was done by a big company. They did huge extension -- extensive -- expensive and extensive renovation.
MS. COMEY: About when were those renovations completed?
JUAN PATRICIO ALESSI: They were completed around 1994.
MS. COMEY: Over the time that you worked for Mr. Epstein how, if at all, did your job responsibilities change?
JUAN PATRICIO ALESSI: My job responsibilities change when Mr. Epstein asked me to work full time only for him and leave all my clients that I had in Palm Beach and to work full time for him only.
MS. COMEY: About when was that?
JUAN PATRICIO ALESSI: 1991.
MS. COMEY: And then what were your job responsibilities?
JUAN PATRICIO ALESSI: My job responsibilities changed gradually during the years. From being a contractor outside, I went to work inside the house for Mr. Epstein.
MS. COMEY: What was your job title?
JUAN PATRICIO ALESSI: I was in charge of the running of the house.
MS. COMEY: And what does that mean to be in charge of the running of the house?
JUAN PATRICIO ALESSI: I was responsible for overseeing the -- the cleanliness, the maintenance, the shopping for the house, the taking care of the people who work outside the house: The gardeners, the pool man.
MS. COMEY: When you were responsible for the house and Mr. Epstein was staying in Palm Beach, what hours did you work?
JUAN PATRICIO ALESSI: Too many hours.
MS. COMEY: Can you approximate for us?
JUAN PATRICIO ALESSI: My job starts between 5:00 in the morning, and we finish around 9:00, 10:00 at night.
MS. COMEY: Why did you have to work such long hours?
JUAN PATRICIO ALESSI: It was required by my position.
MS. COMEY: When Mr. Epstein was in Palm Beach, where did you sleep?
JUAN PATRICIO ALESSI: Most of the time I sleep in the staff quarters. I had a room at the house.
MS. COMEY: Who else worked in the house with you during your employment with Mr. Epstein?
JUAN PATRICIO ALESSI: After three years working for him, I bring my wife to help me. She would stay with me, and also there was other girls that was constantly flying with them -- with Mr. Epstein and Ms. Maxwell to the house.
MS. COMEY: Focusing on your wife, about when did she start working for Mr. Epstein?
JUAN PATRICIO ALESSI: I think it was 1995.
MS. COMEY: And until when did she work for Mr. Epstein?
JUAN PATRICIO ALESSI: She left at the same time I did.
MS. COMEY: In December 2002?
MS. COMEY: When Mr. Epstein was not in Palm Beach, where would you stay?
JUAN PATRICIO ALESSI: Most of the times I stayed -- we had an apartment across the bridge in West Palm Beach.
MS. COMEY: Would you please describe what Mr. Epstein's Palm Beach house looked like during the time you worked for him?
JUAN PATRICIO ALESSI: Yes. It was very large residence. It had, I think, was ten bathrooms, around six bedrooms, a very large property. It had a pool house we used to call the cabana. When I start working for him, that's it.
MS. COMEY: How many structures were on Mr. Epstein's Palm Beach property?
JUAN PATRICIO ALESSI: In the beginning, it was just the main house and the pool house. At the end -- almost at the end of my staying there, they constructed a staff quarters. There was a house separate from the main residence, and it was in there there were three bathrooms, three bedrooms, a small living room, dining room, and it was a very large laundry room, the staff house.
MS. COMEY: That third structure, that staff house, about when was it built?
JUAN PATRICIO ALESSI: I have to say 1999, 2000.
MS. COMEY: Do you remember the cabana being on the property the entire time you worked for Mr. Epstein?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: What color was the main house when you first started working for Mr. Epstein?
JUAN PATRICIO ALESSI: The main house was white, and I painted, and it was pink after I painted.
MS. COMEY: Was it still pink when you left in 2002?
JUAN PATRICIO ALESSI: Yes, it was still pink.
MS. COMEY: Other than Mr. Epstein, who else, if anyone, gave you instructions about your job responsibilities during your employment?
JUAN PATRICIO ALESSI: Ms. Maxwell.
MS. COMEY: About when did you first meet Ms. Maxwell?
JUAN PATRICIO ALESSI: I met Ms. Maxwell around 1991.
MS. COMEY: Do you know her full name?
JUAN PATRICIO ALESSI: Ms. Ghislaine Maxwell.
MS. COMEY: When you first met Ms. Maxwell, what did she look like?
JUAN PATRICIO ALESSI: She was a pretty girl, tall, brunette.
MS. COMEY: For how long did you know Ms. Maxwell?
JUAN PATRICIO ALESSI: Since I -- since she came to the house until I left.
MS. COMEY: In 2002?
MS. COMEY: Do you think you would recognize her if you saw her in person again?
MS. COMEY: Do you see her in the courtroom today?
JUAN PATRICIO ALESSI: Yes, I think she is with a black sweater.
MS. COMEY: Would you please point her out?
JUAN PATRICIO ALESSI: (Indicating) At the corner.
MS. COMEY: Would the record please reflect that the witness has identified the defendant?
JUDGE NATHAN: The record so reflects.
MS. COMEY: Mr. Alessi, about how often did you interact with Ms. Maxwell while you were working for Mr. Epstein?
JUAN PATRICIO ALESSI: On a daily basis.
MS. COMEY: Why did you interact with her on a daily basis?
JUAN PATRICIO ALESSI: Because I had all the orders from Mr. Epstein where I suppose it was passed to Ms. Maxwell, and she would interact with me directly.
MS. COMEY: So did you primarily receive your instructions from Ms. Maxwell?
JUAN PATRICIO ALESSI: Yes, I did.
MS. COMEY: What, if any -- what kinds of instructions do you remember Ms. Maxwell giving you over the time that you worked for Mr. Epstein?
JUAN PATRICIO ALESSI: Many, many instructions. From cleaning the house to the way we should serve, the way the kitchen should be handled, the way the shopping list should be done and the cleanliness of the house.
MS. COMEY: By what name did Ms. Maxwell call you?
JUAN PATRICIO ALESSI: She call me John.
MS. COMEY: Is that your name?
JUAN PATRICIO ALESSI: Well, my name is -- she call me John, and Mr. Epstein called me John, but my name is Juan.
MS. COMEY: Do you know where she call you John instead of Juan?
JUAN PATRICIO ALESSI: John is translation for Juan.
MS. COMEY: Over your years of employment, based on your observations of Ms. Maxwell and Mr. Epstein, what was your understanding of the nature of their relationship?
JUAN PATRICIO ALESSI: They were -- Ms. Maxwell was the girlfriend of Mr. Epstein. I understand she was the lady of the house.
MS. COMEY: What, if anything, did Ms. Maxwell tell you about her role in Mr. Epstein's life?
JUAN PATRICIO ALESSI: From the day she came to the house, she -- she right away took over, and she mentioned to me that she was going to be the lady of the house, and also she was in charge of other homes, other properties.
MS. COMEY: Whose other properties was she in charge of according to her?
JUAN PATRICIO ALESSI: Of Mr. Epstein.
MS. COMEY: What was your relationship with Mr. Epstein like before you met Ms. Maxwell?
JUAN PATRICIO ALESSI: It was cordial.
MS. COMEY: How, if at all, did that change after you met Ms. Maxwell?
JUAN PATRICIO ALESSI: It changed gradually from being cordial to be more -- more -- just professional, in a professional manner. Our conversation with him were less and less and less.
MS. COMEY: What, if anything, did Ms. Maxwell tell you about whether you could speak directly to Mr. Epstein?
JUAN PATRICIO ALESSI: Well, only I was supposed to speak to Mr. Epstein when he asked me questions.
MS. COMEY: What, if anything, did Ms. Maxwell tell you about eye contact?
JUAN PATRICIO ALESSI: At the end of my stay, it was a time when she says Jeffrey doesn't like to be looked at his eyes. You should never look at his eyes. Just look at another part of the room and answer to him.
MS. COMEY: During your time working for Mr. Epstein, how often was Mr. Epstein at the Palm Beach residence?
JUAN PATRICIO ALESSI: It was almost every weekend of the year. All the holidays he'd spend it in Palm Beach. Usually he left Palm Beach either on a Monday or a Tuesday, and he was back in Palm Beach either Thursday or Friday. The whole weekend we have to be there.
MS. COMEY: Was there a set schedule for when Mr. Epstein would be in Palm Beach?
MS. COMEY: How much notice would you typically receive before he came to Palm Beach?
JUAN PATRICIO ALESSI: Sometimes one day, sometimes couple hours before.
MS. COMEY: When you heard Mr. Epstein was coming to Palm Beach, what were you required to do?
JUAN PATRICIO ALESSI: It was extensive preparations. It was very hectic, very -- a lot of work, a lot of work.
MS. COMEY: What kind of work?
JUAN PATRICIO ALESSI: From cleanliness of the house, to make the -- change the sheets in his room, to change the sheets in all the guest rooms, prepare the guest rooms, prepare food, do the shopping, and the cars, taking care of the cars. Make sure the cars were clean. Make sure the cars have money -- hundred dollar bills in the car in every car. The cars they have to be immaculate. The house needs to be -- he run the house like a five-star hotel.
MS. COMEY: About how often was Ms. Maxwell at the Palm Beach residence during the time you worked there?
JUAN PATRICIO ALESSI: Can you repeat the question?
MS. COMEY: About how often was Ms. Maxwell at the Palm Beach residence during the time you worked there?
JUAN PATRICIO ALESSI: I would say she was with Mr. Epstein 95 percent of the times.
MS. COMEY: Ms. Drescher, could we please pull up what's been marked for identification as Government Exhibit 298. Mr. Alessi, I think that's a binder up next to you. You're welcome, with the Court's permission, to look at a paper copy of 298 if that's easier than the screen.
JUAN PATRICIO ALESSI: No, I think I prefer the screen.
MS. COMEY: Do you recognize this exhibit?
JUAN PATRICIO ALESSI: Yes, this is a --
JUDGE NATHAN: Sir, I need you to speak to the microphone. Thank you. A. Yes, this is the main floor of the house, the first floor of the house.
MS. COMEY: Is this a fair and accurate depiction of the layout of the first floor of Mr. Epstein's Palm Beach residence?
JUAN PATRICIO ALESSI: Yes, very accurate.
MS. COMEY: Your Honor, I offer this in evidence.
MR. PAGLIUCA: No objection.
JUDGE NATHAN: PX-298 is admitted.
(Government's Exhibit 298 received in evidence)
MS. COMEY: Ms. Drescher, can we please publish this?
JUDGE NATHAN: You may.
MS. COMEY: Oh, excuse me. Thank you, your Honor.
BY MS. COMEY:
MS. COMEY: Mr. Alessi, can you please walk us through the layout of this house using Government Exhibit 298?
JUAN PATRICIO ALESSI: Can I use my finger?
JUDGE NATHAN: I think you have to describe it with your words. Maybe start in the left-hand corner.
MS. COMEY: Your Honor, is the touch screen available on the witness's screen?
JUDGE NATHAN: I'm not sure.
MS. COMEY: May I ask Ms. Drescher to check, please?
JUDGE NATHAN: Sure.
MS. COMEY: Thank you. A. Okay. I gonna describe the front entrance going into the main house, and I will describe the back entrance going from the garage section of the --
MS. COMEY: Mr. Alessi, I'm going to stop you there. I don't think the touch screen is working, so I'm going to work with Ms. Drescher to zoom in on the parts we're talking about.
JUDGE NATHAN: Actually, we have our jurors' lunch, so we can break if Ms. Williams is ready. Let me just check. We'll break and then you can work on that during the break. Members of the jury, see you in about 45 minutes. Thank you. Enjoy your lunch.
(Jury not present)
JUDGE NATHAN: You may be seated. Matters to take up, counsel?
MS. COMEY: Not at this time, your Honor.
MR. PAGLIUCA: No, your Honor.
JUDGE NATHAN: You can work on the touch screen, but do be mindful that we need to describe it for the record as well.
MS. COMEY: Yes, of course, your Honor.
JUDGE NATHAN: Let's resume in 45, please. Thank you.
(Luncheon recess)
(Continued on next page) A F T E R N O O N S E S S I O N 1:30 P.M.
JUDGE NATHAN: Matters to take up?
MS. COMEY: No, your Honor.
MR. PAGLIUCA: No, your Honor.
JUDGE NATHAN: All right. We'll bring in the jury.
(Jury present)
JUDGE NATHAN: Just a moment while we wait for one more juror. All right. Good afternoon, jurors. I hope you had a nice lunch. Thank you for your continued diligence and attention. Ms. Comey, you may continue with your direct examination of Mr. Alessi.
MS. COMEY: Thank you, your Honor. JUAN PATRICIO ALESSI, resumed.
BY MS. COMEY:
MS. COMEY: Good afternoon, Mr. Alessi.
JUAN PATRICIO ALESSI: Good afternoon.
MS. COMEY: I'd like to pick back up with Government Exhibit 298.
MS. COMEY: Ms. Drescher, would you please pull that exhibit up.
MS. COMEY: Mr. Alessi, I'm going to try to use the touch screen to draw your attention to particular parts of this exhibit. So first, I'm going to circle the room labeled foyer. Can you see that?
MS. COMEY: And that's at the center of this page. Can you describe this area of the house for us please.
JUAN PATRICIO ALESSI: Yes, this is the front entrance.
JUDGE NATHAN: I'm sorry. Mr. Alessi, could you pull up the microphone, please. Thank you.
JUAN PATRICIO ALESSI: Put it closer?
JUDGE NATHAN: That's good. Thank you. A. Okay. This is the front entrance. And it's a single door, very tall. At the left of the door was a stairway going to the second floor. Coming into the foyer, to the right is going into the lake room or living room. To your right you have Mr. Epstein desk --
MS. COMEY: I'm going to pause you right there, Mr. Alessi.
MS. COMEY: I'm going to clear the markings and circle now the room labeled lake room. Can you please continue describing that room.
JUAN PATRICIO ALESSI: Yes. Coming into the lake room, to the right against the wall, there was Mr. Epstein desk. Behind the desk is where stereo equipment and hundreds and hundreds of books of all the way to the wall. This are -- is sliding doors. All the sliding door is glass.
MS. COMEY: And for the record, are you indicating the far right wall on this exhibit?
MS. COMEY: Please continue.
JUAN PATRICIO ALESSI: In here was a large couch and different chairs and small couches in the living room.
MS. COMEY: Thank you. Let's move up now to the garden room which I've just circled. Would you please describe that for us.
JUAN PATRICIO ALESSI: Yes. The garden room was a long and kind of narrow room. On the left-hand side was Ms. Maxwell's desk. All this rear wall was all the sliding doors. It was a couch in here and these are sliding doors.
MS. COMEY: Okay. Thank you. Now I'm going to circle the room labeled dining room.
MS. COMEY: Would you please describe that room for us.
JUAN PATRICIO ALESSI: The dining room had access to the -- to the lake room, to Ms. Maxwell's desk, to the left, and an entry to the pantry room.
MS. COMEY: Let's move now to the left, the areas labeled kitchen and pantry. Would you please describe those for us.
JUAN PATRICIO ALESSI: Yes. Coming from the pantry, it was a stove. This is the pantry room, it has countertops, and it was a sink by this window. Coming into the kitchen at the right was a stove and range oven. Here was a refrigerator. And they have an island in the middle with a sink, a dishwasher. This was a sliding doors going to the kitchen patio. Here was a AC unit. And here was the entrance to the -- to the back foyer.
MS. COMEY: Thank you. I'm going to pause you there, clear the screen. And I'm going to circle the area around the room labeled staff. Would you please describe this area of the first floor for us.
JUAN PATRICIO ALESSI: Yes. Well, the staff quarter -- the staff where my office was, was there. It had a large window facing the front of the -- to the street. It had a small bathroom with a shower, this here. It had a closet for utilities and a door here. The elevator, this was the elevator going to the second floor. And this is the back stairway, the steps going to the second floor that was used only for -- for the staff.
MS. COMEY: There were two staircases in the house?
JUAN PATRICIO ALESSI: Yes, one in the front and the main staircase, and the back staircase. And also was one outside going to the rear balcony to the second floor, a metal stair -- winding stairway.
MS. COMEY: And I've just circled the top right corner of this exhibit. Is that where the metal circular stairway was?
JUAN PATRICIO ALESSI: Yes, it was right here.
MS. COMEY: Which staircase were you supposed to use?
JUAN PATRICIO ALESSI: We were supposed to use the -- the staff stairway.
MS. COMEY: Which one was that?
JUAN PATRICIO ALESSI: Right here.
MS. COMEY: And you're indicating the stairway to the left of this --
MS. COMEY: -- exhibit?
JUAN PATRICIO ALESSI: Mm-hmm. Right here.
MS. COMEY: Ms. Drescher, we can take that down. Thank you. I'd like to now pull up just for the witness, the Court, and the parties, Government Exhibit 297.
MS. COMEY: Mr. Alessi, do you recognize this?
JUAN PATRICIO ALESSI: Yes, this is the layout for the second floor.
MS. COMEY: Does this fairly and accurately depict the second floor of Mr. Epstein's Palm Beach residence?
JUAN PATRICIO ALESSI: Yes, it is.
MS. COMEY: Your Honor, the government offers this in evidence.
MR. PAGLIUCA: No objection, your Honor.
JUDGE NATHAN: Thank you. GX-297 is admitted.
(Government's Exhibit 297 received in evidence)
JUDGE NATHAN: You may publish.
MS. COMEY: Thank you, your Honor. Ms. Drescher, would you please publish this exhibit.
MS. COMEY: Mr. Alessi, I want to walk through this exhibit the same way we just walked through Exhibit 298. I'm going to circle the spiral in or about the center of this page. Can you tell us what that is?
JUAN PATRICIO ALESSI: Yes, that's the main stairway going into the second floor.
MS. COMEY: And when you got up to the top of the stairs and you turned right --
JUAN PATRICIO ALESSI: Yes, this was --
MS. COMEY: -- what would be to your right?
JUAN PATRICIO ALESSI: It was a hallway, all the way towards Mr. Epstein's bedroom. It was a two sets of double doors, one here and one here. And it also was his door. I think his door, if I remember correctly, was a single door going into his room.
MS. COMEY: Let me clear this. I'm going to circle the rectangle slightly to the right of the spiral. Can you tell us what that area is?
JUAN PATRICIO ALESSI: This is the hallway. That is a hallway. I think it was a table with some lights.
MS. COMEY: And where does that hallway lead to?
JUAN PATRICIO ALESSI: That hallway leads to Mr. Epstein's door, bedroom.
MS. COMEY: Is that hallway separated from the staircase by double doors?
MS. COMEY: I'd like to move now to the master bedroom, which I've circled on the right side of this exhibit. Would you please describe the master bedroom for us.
JUAN PATRICIO ALESSI: Yes, it was a very large master bedroom. At the left of the -- the bed was situated right here in the center. To the left of the room was the entrance with a door into his bathroom.
MS. COMEY: Whose bathroom was that?
JUAN PATRICIO ALESSI: Mr. Epstein's bathroom.
MS. COMEY: Thank you. Would you please go back to the master bedroom to describe that a bit more.
JUAN PATRICIO ALESSI: Okay. The master bedroom had a -- if I remember correctly, it was a corner TV right there and also was a projection TV that it came down from the ceiling in front of the bed. These doors were all sliding doors going into the balcony facing the pool.
MS. COMEY: Thank you. Now, Mr. Alessi, if you walked into the master bedroom and instead of turning left you turned right, what would you see?
JUAN PATRICIO ALESSI: Yes. If I coming into the master bedroom to the right, it was the entrance with a door to Ms. Maxwell's bathroom. Her bathroom, it had a closet with double doors.
MS. COMEY: I'm going to pause you right there. I'm going to circle what is identified as bath number four on this exhibit. Whose bathroom was this, first of all?
JUAN PATRICIO ALESSI: This was Ms. Maxwell's bathroom.
MS. COMEY: And can you please describe Ms. Maxwell's bathroom for us.
JUAN PATRICIO ALESSI: It was a very large, very nice room. It had a double room -- a double closet. It had a vanity, it had a bathtub. Her toilet was in this corner. And here were several drawers, and here was a door going to the front balcony of the residence.
MS. COMEY: Thank you. I'd now like to circle what's indicated as bath number five up above the room we were just talking about. Whose bathroom was that?
JUAN PATRICIO ALESSI: That was Mr. Epstein's bathroom.
MS. COMEY: And just to clarify, did both Ms. Maxwell's bathroom and Mr. Epstein's bathroom attach to the master bedroom?
JUAN PATRICIO ALESSI: Yeah, they were attached, but they were not -- not separated by -- they were separated by two walls, this hallway and this hallway.
MS. COMEY: But they were both -- they both came off of the master bedroom?
JUAN PATRICIO ALESSI: Yes, they did.
MS. COMEY: Thank you. Can you please describe Mr. Epstein's bathroom.
JUAN PATRICIO ALESSI: Mr. Epstein's bathroom was basically the same dimension as Ms. Maxwell's bathroom. It had a dresser. Coming into the left there was -- coming into the room from the left there was a dressing room with four or five set of drawers. On top was a countertop. That was for storage of oil, perfumes, for the massages. And in this wall it had a vanity. And then it had a door going -- the door so long ago --
JUDGE NATHAN: Mr. Alessi, could you pull up the microphone again, please. Thank you.
MS. COMEY: I'm going to redraw the circle for you, Mr. Alessi.
JUAN PATRICIO ALESSI: Yeah.
MS. COMEY: Go ahead.
JUAN PATRICIO ALESSI: So the bathroom had a vanity. And the garden side, it had a -- his toilet was here. This was his closet. This was a steam room, and this was a shower, a double shower. And in here they had a couch.
MS. COMEY: Do you remember what color the couch was?
JUAN PATRICIO ALESSI: I think it was green, if I remember correctly.
MS. COMEY: Okay. Thank you. I'm going to clear that. And now I'm going to circle at the bottom left-hand corner the area labeled housekeeper bedroom. What was that?
JUAN PATRICIO ALESSI: Yes, that was my bedroom.
MS. COMEY: Could you describe where your bedroom was in relation to the master bedroom, please.
JUAN PATRICIO ALESSI: My bedroom was here, and the master bedroom was on the opposite side of the house.
MS. COMEY: Thank you.
MS. COMEY: We can take that down. Thank you, Ms. Drescher. I'd like to now show the witness, the Court, the parties what's been marked for identification as Government Exhibit 299.
MS. COMEY: Mr. Alessi, do you recognize what's depicted in this exhibit?
JUAN PATRICIO ALESSI: Yes. This was the structure of the main house. The main house was -- I'm going to --
MS. COMEY: Well, Mr. Alessi, before you start marking on it, I'm just going to ask you, is this a fair and accurate depiction of the layout of the structures on Mr. Epstein's Palm Beach property before the third structure was constructed?
MS. COMEY: Your Honor, the government offers this in evidence.
MR. PAGLIUCA: No objection.
JUDGE NATHAN: Thank you. GX-299 is admitted.
(Government's Exhibit 299 received in evidence)
MS. COMEY: May we publish, your Honor?
JUDGE NATHAN: You may.
MS. COMEY: Thank you. Ms. Drescher, would you please put this up for the jury.
MS. COMEY: Mr. Alessi, I'm circling the rectangle at the top of the page labeled cabana. What was this?
JUAN PATRICIO ALESSI: This was also called the pool house, the cabana. It had -- was a pretty large structure. It had his -- Mr. Epstein desk was situated in here. It had a couch here. In here was a sliding door. And in the front were sliding doors. It had the stereo equipment right here. This closet had a door to the outside of the patio, and it was a closet for utilities for the pool tables, the pool cushions, etc. And in here it was -- this section here was the yoga apparatus, they were hanging from the ceiling. And this was his bathroom, a vanity, and a shower.
MS. COMEY: Thank you. I'll clear the screen. I'm circling the rectangle in the center of the page. What was that?
JUAN PATRICIO ALESSI: That is the pool.
MS. COMEY: And then the shape all the way to the left of this exhibit that I just circled, what was that?
JUAN PATRICIO ALESSI: That is the main house. That is the main outside walls of the house, of the main house. This is the stairway -- the entrance.
MS. COMEY: Thank you. And then focusing on the line to the right of this diagram, what was to the right of that?
JUAN PATRICIO ALESSI: To the right of this diagram was the intercoastal lake way.
MS. COMEY: A waterway?
JUAN PATRICIO ALESSI: Waterway. And it was a dock for the boats and jet skis right here.
MS. COMEY: Mr. Alessi, could you please indicate for us on this exhibit where the third structure was built on Mr. Epstein's property?
JUAN PATRICIO ALESSI: Yes. It was -- it was located at the right -- at the right of the --
MS. COMEY: Indicating the -- well, are you indicating the top left right now?
JUAN PATRICIO ALESSI: The helper's quarters.
MS. COMEY: And is that at the top left of this exhibit?
MS. COMEY: Okay.
JUAN PATRICIO ALESSI: And also it was a wall that I used to call the Berlin Wall, that it was all -- was constructed all the way to the fence and the structure was here.
MS. COMEY: After that structure was built, where did you spend the night when Mr. Epstein was in Palm Beach?
JUAN PATRICIO ALESSI: After this structure was finished, I moved from my room in the second floor to a room in the back of the structure.
MS. COMEY: And the wall you described, what view did it obstruct?
JUAN PATRICIO ALESSI: It obstruct the whole view of the garden and the pool, so it was no view from the staff quarters to the rest of the house.
MS. COMEY: Thank you. I'll clear that and we can take that down, Ms. Drescher. When Ms. Maxwell was in Palm Beach, where would she sleep at night?
JUAN PATRICIO ALESSI: 99 percent --
MR. PAGLIUCA: Your Honor, I'm going to object to the foundation of this question. We're lacking a date certain here.
JUDGE NATHAN: Sure.
MS. COMEY: Sure.
MS. COMEY: Between approximately when you first met Ms. Maxwell in 1991 and when you stopped working for Jeffrey Epstein in 2002, where did you understand Ms. Maxwell to be sleeping when she was in Palm Beach?
JUAN PATRICIO ALESSI: She was sleeping at Mr. Epstein's bedroom.
MS. COMEY: And was that the master bedroom that we saw on the diagram earlier?
MS. COMEY: How many desks did Mr. Epstein have in his home in Palm Beach?
JUAN PATRICIO ALESSI: In his home he had three desks. One at the right-hand side of his bedroom, one by the lake room in the first floor, and one desk by the pool house, on the south part of the pool house.
MS. COMEY: How many desks did Ms. Maxwell have at the Palm Beach residence between 1991 and 2002?
MS. COMEY: Where was that?
JUAN PATRICIO ALESSI: That was in the garden room, close to the pantry.
MS. COMEY: Over your years working for Mr. Epstein, what, if any, females did you observe coming to his Palm Beach residence?
JUAN PATRICIO ALESSI: Many, many, many females.
MS. COMEY: How old did most of them appear to be?
JUAN PATRICIO ALESSI: Most of them appear to be in the late twenties, twenties.
MS. COMEY: What did you see those females do when they came to Mr. Epstein's home?
JUAN PATRICIO ALESSI: They went into the --
MR. PAGLIUCA: Your Honor, again, I need to object because we were talking about a wide time frame here and we're now lumping in many people over a very wide time frame. I think it needs to be more specific.
JUDGE NATHAN: Okay. Ms. Comey?
MS. COMEY: I'm happy to rephrase, your Honor.
BY MS. COMEY:
MS. COMEY: Over the years that you worked for Mr. Epstein, about how many times do you remember seeing the female guests by the pool?
JUAN PATRICIO ALESSI: Oh, many, many times. Over the 12 years that I work there, hundreds of times.
MS. COMEY: And over those hundreds of times, about what percentage of the time were those females topless?
JUAN PATRICIO ALESSI: I would say 75, 80 percent probably.
MS. COMEY: Did you ever see any of those females fully naked?
MS. COMEY: Those females that you saw by the pool who were topless, who did you see them spend time with?
JUAN PATRICIO ALESSI: They spend time by the pool and they spend time inside the house, inside the main house, and also by the -- in the pool house.
MS. COMEY: And who did you see them interact with, if anyone?
JUAN PATRICIO ALESSI: Mr. Epstein and Ms. Maxwell.
MS. COMEY: What, if any, trips did you personally take to any of Mr. Epstein's other properties?
JUAN PATRICIO ALESSI: Yes. I took a trip to the ranch, Zorro Ranch in Santa Fe, New Mexico. There was supposed to be --
MS. COMEY: I'm going to stop you there. About when did you go to New Mexico?
JUAN PATRICIO ALESSI: I would say 1994, '95.
MS. COMEY: Who invited you to travel to Zorro Ranch?
JUAN PATRICIO ALESSI: Ms. Maxwell and Mr. Epstein.
MS. COMEY: Did they tell you why they wanted you to come to the ranch?
JUAN PATRICIO ALESSI: Yes, they did.
MS. COMEY: What did they say?
JUAN PATRICIO ALESSI: They said it was going to be like a symposium. And this lady was going to teach all the personnel of the different homes how to clean the houses.
MS. COMEY: How did you travel from Florida to New Mexico for that symposium?
JUAN PATRICIO ALESSI: I fly commercial from West Palm Beach to Albuquerque, New Mexico. And I was picked up by the house ranch manager at the ranch.
MS. COMEY: What did the ranch look like when you visited it?
JUAN PATRICIO ALESSI: Oh, it was a huge, huge property. I don't remember how many, but it was thousands and thousands of acres. And the entrance, it was a couple homes for the ranch people, it was an office, and it was the cowboy quarters. And the guest rooms, they were in a structure at the right-hand side of the ranch. And it was a -- a big, long gravel and dirt road going up the mountain. And on top of the mountain was -- they were construction -- they were still under the construction of the main house. And also was a mobile home to the right. And it was also a little cabana house at the end of the -- at the end of this mountain.
MS. COMEY: Were you able to go inside the main house?
JUAN PATRICIO ALESSI: Yes. Very, very briefly they show us the house, and I saw very little bit. I know that it was a huge structure and it had -- it was like a Spanish style construction with a patio in the center and the rooms were all around. I only saw Mr. Epstein's -- I think it was his office or living room office, and it was --
MS. COMEY: If the main house was still under construction, how were you able to go inside of it?
JUAN PATRICIO ALESSI: They were still -- they were in the finishing phases of the construction. And we were able to walk to the kitchen. We saw very few rooms. I think it was only two rooms that we saw inside.
MS. COMEY: And were people able to stay in that house overnight even though it was still under construction?
JUAN PATRICIO ALESSI: I don't know.
MR. PAGLIUCA: Objection. Leading.
JUDGE NATHAN: All right. Sustained. A. I don't know.
JUDGE NATHAN: Sorry. Sustained. The jury will disregard the answer.
MS. COMEY: What other homes did you understand Mr. Epstein owned during the time you worked for him?
JUAN PATRICIO ALESSI: During the time we work for him, he own Zorro Ranch. He own the private island in the Caribbean, Little St. James, that we used to call Little St. Jeff, and right outside St. Thomas. Also he had a home that I never visit in New York, a very large home in New York. And he had a home in Paris, France. And I think they have -- he had a home at Columbus, Ohio.
MS. COMEY: During the approximately ten years when you worked for Mr. Epstein, do you know how he traveled to his different homes?
JUAN PATRICIO ALESSI: He traveled on his private planes.
MS. COMEY: How many times have you flown on Mr. Epstein's private planes?
JUAN PATRICIO ALESSI: None. I'm sorry. I flew with Ms. Maxwell in a small plane, the first plane that he purchase, he had, it was a -- I think it's called a Hawker, Hawker. Small plane. We flew with Ms. Maxwell to an engagement in Miami and flew back. That's it. That's the only time I flew with him.
MS. COMEY: Other than the New Mexico property and the Palm Beach property, have you visited any other of Mr. Epstein's properties?
JUAN PATRICIO ALESSI: The island.
MS. COMEY: About when did you visit the island?
JUAN PATRICIO ALESSI: The island I visit for maybe two hours.
MS. COMEY: I'm sorry, about what year or approximately?
JUAN PATRICIO ALESSI: I can't remember.
MS. COMEY: Was it during your employment with Mr. Epstein?
JUAN PATRICIO ALESSI: Yes, of course.
MS. COMEY: For about how long were you on the island?
JUAN PATRICIO ALESSI: Oh, for two hours. We --
MS. COMEY: Mr. Alessi, could you speak into the microphone, please.
JUAN PATRICIO ALESSI: We went to a vacation with my wife in a cruise line. And the cruise line was supposed -- it did stop in St. Thomas. And the people from the island pick us up and they show us the island. Very, very exclusive, beautiful island.
MS. COMEY: Could you describe the island.
JUAN PATRICIO ALESSI: Yes. The island had -- the main structures of the island was not one house, but there were different pavilions, different parts of the house. And it had a -- I think it was in the center, it had the pool, and the kitchen/dining room area was the biggest structure that I saw when I went there. It was the kitchen/dining room area.
MS. COMEY: What properties, if any, of Ms. Maxwell's did you visit during your employment with Mr. Epstein?
JUAN PATRICIO ALESSI: I visit Ms. Maxwell's townhome in London.
MS. COMEY: About when was that?
JUAN PATRICIO ALESSI: I cannot tell you exactly what year, but it was also before my departure.
MS. COMEY: Was it sometime when you were still working for Mr. Epstein?
JUAN PATRICIO ALESSI: Of course. Yes.
MS. COMEY: How did you come to visit Ms. Maxwell's home in London?
JUAN PATRICIO ALESSI: She invite us to see her house.
MS. COMEY: For about how long were you there?
JUAN PATRICIO ALESSI: Five minutes.
MS. COMEY: Can you describe what you saw?
JUAN PATRICIO ALESSI: I saw -- I think it was a townhome, two floors. I think the -- the front door was either red, a red front door, and we saw just the living room. And we went upstairs and it was a -- I think it was a bathroom. And we saw her bedroom upstairs. It was a pretty small place. There was not a big structure.
MS. COMEY: What, if any, rules did Ms. Maxwell tell you to follow as an employee of Mr. Epstein's?
JUAN PATRICIO ALESSI: Oh, there were many, many, many rules.
MS. COMEY: What are some that you remember?
JUAN PATRICIO ALESSI: From rules about presentation of the dishes, presentation of the table; there were rules about the way we should be dressed; there were rules about how we are to address Mr. Epstein, address Ms. Maxwell; rules about cleanliness; there was rules about what to shop, what the shopping list. There were tremendous amount of instructions were given to me.
MS. COMEY: Were those oral rules or written rules?
JUAN PATRICIO ALESSI: Most of it oral rules.
MS. COMEY: Were there ever any written rules?
JUAN PATRICIO ALESSI: Yes. At the end of my stay, I think it was at the last year, 2001, maybe 2002, I receive from Ms. Maxwell this booklet. There were rules how to handle the houses. It was not only for the house in Palm Beach, it was also written for the other properties.
MS. COMEY: Who gave you that booklet of rules?
JUAN PATRICIO ALESSI: I think it was Ms. Maxwell.
MS. COMEY: And what did she tell you when she gave you that booklet?
JUAN PATRICIO ALESSI: This is what we're going to do it, and this is what has to be done from now on.
MS. COMEY: Did you read the entire booklet?
MS. COMEY: What do you remember being in the booklet?
JUAN PATRICIO ALESSI: It was like 30 pages, probably more of checklist, incredible amount of work, enough work for ten people, not for one and a half. It was -- it was -- I'm sorry to say, but it was very degrading to me. Most of the pages, they were just unbelievable to me. They were written for the employees. And it was -- I wasn't hire to do that type of work.
MR. PAGLIUCA: Your Honor, I'm going to object to the narrative at this point.
JUDGE NATHAN: Sustained.
MS. COMEY: We'll move on.
MS. COMEY: Mr. Alessi, you mentioned checklists.
MS. COMEY: What do you mean by checklists?
JUAN PATRICIO ALESSI: Well, I have the instructions and there was a checkmark, check square under each instruction. And different -- different items from -- from the cleanliness of the cars to the shopping list.
MR. PAGLIUCA: Again, your Honor, narrative.
JUDGE NATHAN: Sustained.
MS. COMEY: What are the different topics of checklists that you remember seeing in this booklet?
JUAN PATRICIO ALESSI: There were everything. Cleanliness, the way we should address Mr. Epstein, the way we should ask Mr. Epstein, the way we should ask Ms. Maxwell, the way we should be presented ourselves, the way we should not to --
MR. PAGLIUCA: Again, your Honor, we're into a narrative here.
MS. COMEY: Your Honor, I think he's listing out the checklist. He said that this was at least 30 pages.
JUDGE NATHAN: All right.
MR. PAGLIUCA: They are not checklists, your Honor.
JUDGE NATHAN: Well, not your turn to testify, counsel. Overruled.
MS. COMEY: Are there any others you remember?
JUAN PATRICIO ALESSI: There were, many, many, many pages that I cannot remember. This is about 20 -- 23 years ago, so I cannot remember every -- every page. I cannot remember. But it was an incredible amount of work used to checklist.
MS. COMEY: Thank you, Mr. Alessi. What, if any, conversations do you remember having with Ms. Maxwell about this booklet?
JUAN PATRICIO ALESSI: I told her that I will not confirm, I will not -- I will not do it.
MS. COMEY: And how did she respond?
JUAN PATRICIO ALESSI: Well, she says -- I can't remember her response, but I was not able to do this checklist and this amount of work with all the work that I have to do and perform every day.
MR. PAGLIUCA: Your Honor, narrative.
JUDGE NATHAN: Sustained. Let's move on.
MS. COMEY: Ms. Drescher, could we please pull up for the witness, the Court, and the parties what's been marked for identification as Government Exhibit 606.
MS. COMEY: And Mr. Alessi, I think there's a paper copy of this in the binder in front of you, 606. Please let us know when you have it in paper copy, Mr. Alessi.
JUDGE NATHAN: Can I have a paper copy?
MS. COMEY: Yes, your Honor.
JUAN PATRICIO ALESSI: Where it says household -- household --
MS. COMEY: Hold on one second, Mr. Alessi.
MS. COMEY: May I approach, your Honor?
JUDGE NATHAN: You may. Thank you. You may proceed.
MS. COMEY: Mr. Alessi, would you flip through this exhibit and tell us about how many pages long it is.
JUAN PATRICIO ALESSI: It's 58 pages.
MS. COMEY: And have you looked through this before coming here to testify today?
JUAN PATRICIO ALESSI: Yes, I did.
MS. COMEY: Do you recognize it?
MS. COMEY: What does it appear to be?
JUAN PATRICIO ALESSI: Well, this is all the instructions that we're supposed to -- that I was supposed to follow up to maintain the house.
MS. COMEY: And Mr. Alessi, does this appear to be a version of the booklet that you were just testifying about?
MS. COMEY: Now, I want you to look at the date at the bottom left of each page.
MS. COMEY: Is that date before or after you left Mr. Epstein's employment?
JUAN PATRICIO ALESSI: This list -- this --
MS. COMEY: Mr. Epstein -- excuse me, Mr. Alessi, Mr. Alessi, was this before or after --
JUAN PATRICIO ALESSI: After I left.
MS. COMEY: You left employment?
JUAN PATRICIO ALESSI: I left my employment.
MS. COMEY: But in reviewing this, did you recognize portions of it?
MR. PAGLIUCA: Objection. Leading.
JUDGE NATHAN: Sustained.
MS. COMEY: Mr. Alessi, I'd like to ask you to go through this page by page and tell us what portions you recognize and what portions you don't recognize. And I'd like you to do it without reading any of the portions aloud. Let's start with page 1.
JUAN PATRICIO ALESSI: I recognize them.
MS. COMEY: Everything on the page?
MS. COMEY: Let's go to page 2. Do you recognize that?
MS. COMEY: Everything on the page?
MS. COMEY: Let's go to page 3. Do you recognize that?
MS. COMEY: Everything on the page?
MS. COMEY: How about page 4?
MS. COMEY: Everything on the page?
MS. COMEY: Page 5?
MS. COMEY: How about page 6?
MS. COMEY: Now, page 7? And remember, I'd like you to look through and let us know if there are any portions that you do not remember from the version of the booklet you just testified about.
JUAN PATRICIO ALESSI: Page 7, I recognize the whole page.
MS. COMEY: I'm sorry?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: And page 8?
JUAN PATRICIO ALESSI: I do.
MS. COMEY: What about page 9?
JUAN PATRICIO ALESSI: Yes, page 9, I recognize it.
MS. COMEY: How about page 10?
MS. COMEY: Page 11?
MS. COMEY: Page 12?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: Page 13?
MS. COMEY: Page 14?
JUAN PATRICIO ALESSI: I don't remember this page with all the -- the different brands of --
MS. COMEY: Without reading it, are there portions of this particular page that you don't remember?
MS. COMEY: Okay. Let's turn -- but do you recognize some portions of this page?
JUAN PATRICIO ALESSI: I do.
MS. COMEY: Let's go now to page 15.
MS. COMEY: How about page 16?
JUAN PATRICIO ALESSI: I recognize most of it. But some items on this list I did never see it before.
MS. COMEY: Okay. So there are some items on here that you don't remember from the booklet that you received from Ms. Maxwell?
MS. COMEY: Let's turn now to page 17.
MS. COMEY: Page 18?
MS. COMEY: Page 19?
JUAN PATRICIO ALESSI: And page 19, I don't remember some of the items that are listed in here.
MS. COMEY: But do you recognize -- so is it fair to say you recognize some, but not all, of the items on 19?
MS. COMEY: How about page 20?
MS. COMEY: Page 21?
MS. COMEY: Page 22?
MS. COMEY: Page 23?
MS. COMEY: Page 24?
MS. COMEY: Page 25?
MS. COMEY: Page 26?
MS. COMEY: Page 27?
MS. COMEY: Page 28?
MS. COMEY: Page 29?
JUAN PATRICIO ALESSI: Page 29, most of these items, that were -- I never remember seeing in the list.
MS. COMEY: Mr. Alessi, are you saying that the majority of the items on page 29 were not in the booklet that Ms. Maxwell gave you?
MS. COMEY: Were some of the items on page 29 in the booklet that Ms. Maxwell gave you?
JUAN PATRICIO ALESSI: Yes, but I -- yes.
MS. COMEY: Let's go to page 30.
JUAN PATRICIO ALESSI: The same thing in this page. Some of the stuff I don't remember purchasing or seeing it before.
MS. COMEY: But were some of them in the booklet that you remember Ms. Maxwell giving you?
MS. COMEY: Let's go to page 31.
JUAN PATRICIO ALESSI: Same thing.
MS. COMEY: Same thing?
JUAN PATRICIO ALESSI: Same thing. These items -- some of these items I -- I never -- I was never given this list of shopping.
MS. COMEY: But are there some items on here that you remember from a page --
MS. COMEY: -- in a booklet that Ms. Maxwell gave you?
JUAN PATRICIO ALESSI: Absolutely. Except for the liquor.
MS. COMEY: Please don't describe the content of the document. Let's go to page 32.
MS. COMEY: Page 33?
JUAN PATRICIO ALESSI: This -- this page, I don't remember any of this page.
MS. COMEY: You don't remember anything on page 33?
MS. COMEY: Okay. Page 34?
MS. COMEY: Page 35?
MS. COMEY: Page 36?
MS. COMEY: Page 37?
MS. COMEY: Page 38?
MS. COMEY: Page 39?
MS. COMEY: Page 40?
MS. COMEY: Page 41?
MS. COMEY: Page 42?
JUAN PATRICIO ALESSI: I don't remember seeing this page.
MS. COMEY: Anything on the page you don't remember?
JUAN PATRICIO ALESSI: No, because most of the stuff I -- it was -- I had to do it anyway, so -- but I don't remember this page.
MS. COMEY: Okay. Let's go to page 43.
MS. COMEY: Page 44? I'm sorry, page 44? I think I --
JUDGE NATHAN: Just a moment. My copy goes from page 42 to page 49.
JUAN PATRICIO ALESSI: Yeah, so do mine.
JUDGE NATHAN: Actually, counsel, it's out of order.
MS. COMEY: I apologize, your Honor.
JUAN PATRICIO ALESSI: Oh, wait.
JUDGE NATHAN: Just a second please. Wait till you're asked a question. Thank you.
MS. COMEY: So we stopped at page 42. The next page in your copy, does it say page 49?
MS. COMEY: Okay. Do you recognize that page?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: Does the next page say page 50?
MS. COMEY: Do you recognize that page?
MS. COMEY: Does the next page say page 51?
JUAN PATRICIO ALESSI: Yes, I recognize it.
MS. COMEY: And does the next page say 43?
JUAN PATRICIO ALESSI: That's correct.
MS. COMEY: Do you recognize that page?
MS. COMEY: And does the next page say 47?
JUAN PATRICIO ALESSI: I recollect some of these items being in the list, but not all of them.
MS. COMEY: And is this the page that has 47 at the bottom?
MS. COMEY: Let's go to the next page. Does the next page in your copy say 44?
JUAN PATRICIO ALESSI: That's correct.
MS. COMEY: Do you recognize that?
JUAN PATRICIO ALESSI: Some of these items, I don't recollect it.
MS. COMEY: Let's go now to page -- the next page, does it say page 45?
JUAN PATRICIO ALESSI: This page I don't recollect seeing in my booklet that was given to me.
MS. COMEY: How about the page that says page 48?
JUAN PATRICIO ALESSI: Yes, they were.
MS. COMEY: And does the next page say page 46? Yes or no, Mr. Alessi, does the next page say 46?
MS. COMEY: And do you recognize what's on this page as being in the booklet Ms. Maxwell gave you?
MS. COMEY: Let's go to the next page. Does your next page say 52?
JUAN PATRICIO ALESSI: That's correct.
MS. COMEY: And do you recognize what's on this page as being in the booklet that Ms. Maxwell gave you?
MS. COMEY: I think we're back in order. Is the next page 53? Mr. Alessi?
MS. COMEY: Is the next page 53?
MS. COMEY: Do you recognize it?
MS. COMEY: How about the next page, 54?
MS. COMEY: How about 55?
MS. COMEY: 56?
MS. COMEY: 57?
MS. COMEY: And 58?
MS. COMEY: Your Honor, the government offers Exhibit 606 in evidence.
MR. PAGLIUCA: May I inquire, your Honor?
JUDGE NATHAN: You may. VOIR DIRE EXAMINATION
BY MR. PAGLIUCA:
MR. PAGLIUCA: Good afternoon, Mr. Alessi.
JUAN PATRICIO ALESSI: Good afternoon, sir.
MR. PAGLIUCA: You left Mr. Epstein's employment in 2001; correct?
JUAN PATRICIO ALESSI: 2002.
MR. PAGLIUCA: December of 2001; correct?
JUAN PATRICIO ALESSI: No, December 2002.
MR. PAGLIUCA: Okay. And when you left --
JUDGE NATHAN: You can take your mask off.
MR. PAGLIUCA: Thank you, your Honor. It's becoming a habit wearing it.
MR. PAGLIUCA: When you left in 2002, you didn't have in your possession Government Exhibit 606, which is dated different dates, but beginning in February of 2005; is that correct?
JUAN PATRICIO ALESSI: No. I -- I had it in my possession, a booklet with the dates. It didn't have dates when I was given to it.
MR. PAGLIUCA: Okay. But you left, you say, in 2002?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: So if something was made after 2002, you would not have had it; correct?
JUAN PATRICIO ALESSI: Absolutely, no.
MR. PAGLIUCA: All right. Okay. And so whatever you had in 2002 was not Government Exhibit 606, which was created, at least by the date on it, after that date; correct?
MS. COMEY: Objection. Compound.
MR. PAGLIUCA: I don't think that's a compound question.
JUDGE NATHAN: Overruled.
MR. PAGLIUCA: You wouldn't have had 606 because assuming the date on 606 is even accurate, it's after you left; correct?
MR. PAGLIUCA: Okay. And so you, Mr. Alessi, don't have any personal knowledge about, first of all, how 606, this exhibit, came into existence; correct? Because this is not whatever it was that you had?
JUAN PATRICIO ALESSI: No, I did not have it.
MR. PAGLIUCA: Right. Okay. And you, Mr. Alessi, didn't have this Exhibit 606 with you after you left. You threw whatever was given to you away, as I understand it; correct?
JUAN PATRICIO ALESSI: Yes, I did.
MR. PAGLIUCA: Because you didn't agree with whatever was given to you?
MS. COMEY: Objection, your Honor. This is voir dire.
JUDGE NATHAN: Just a moment. I'll sustain with respect to the last question.
MR. PAGLIUCA: Okay.
MR. PAGLIUCA: But so we're clear, whatever you were given, you threw it away and didn't keep it after you left in 2002?
JUAN PATRICIO ALESSI: There was no reason to keep it.
MR. PAGLIUCA: I understand. And so you don't have any personal knowledge about how this document, assuming it's accurate, was maintained after you left Mr. Epstein's employment in 2002; correct?
JUAN PATRICIO ALESSI: I have no personal knowledge.
MR. PAGLIUCA: Okay.
MR. PAGLIUCA: I object, your Honor. Lack of foundation.
MS. COMEY: Your Honor, I believe we've established a foundation certainly as to the pages that Mr. Alessi recognizes. I think the rest of the document, based on its context --
JUDGE NATHAN: Okay. Ms. Comey, not the place for that. I'm overruling the objection. 606 is admitted.
(Government's Exhibit 606 received in evidence)
MS. COMEY: May we publish, your Honor?
JUDGE NATHAN: You may.
BY MS. COMEY:
MS. COMEY: Mr. Alessi, taking a look at the very first page of this, do you recognize the address at the bottom -- going back, the address at the bottom of the page?
MS. COMEY: What is that address?
JUAN PATRICIO ALESSI: That is the address of Mr. Epstein's residence.
MS. COMEY: Let's turn now to the second page, please, the page that has page 1 on it. I'm circling a bullet point close to the middle of the page. Would you please read that aloud for us.
JUAN PATRICIO ALESSI: Daily duties while Mr. Epstein, Ms. Maxwell, and guests are on residence.
MS. COMEY: And what is listed below that?
JUAN PATRICIO ALESSI: Morning preparation, pool area, the cabana, the kitchen, downstairs areas, master bedroom, master bathroom, Ms. Maxwell's bathroom, guest rooms, early evening, before you leave at night.
MS. COMEY: What was your understanding of what you were supposed to do with all of those places based on the instructions you received from Ms. Maxwell?
JUAN PATRICIO ALESSI: That I was supposed to do these duties, perform these duties.
MS. COMEY: Let's turn to the next page please. And now let's turn to page -- the page marked page 3. Would you please read this aloud for us, Mr. Alessi.
JUAN PATRICIO ALESSI: Yes. This manual is designed to give you the proper guidance and assistance to perform your duties to the best of your ability, while ensuring a consistently high level of service. Gathering as much information as possible will help you with the day-to-day running of the home. By using your communications skills, listening and observing, you will be able to anticipate the needs of Mr. Epstein, Ms. Maxwell, and their guests. Checklists will assist you in making sure that all tasks have been completed and that not even the smallest details have been overlooked.
(Continued on next page) LC2Qmax5 - corrected Alessi - Direct BY MS. COMEY: (Continued)
MS. COMEY: Thank you, let's please go to the page marked page 4. I'd like you to first please read the first bullet point on this page?
JUAN PATRICIO ALESSI: Try to anticipate the needs of Mr. Epstein, Ms. Maxwell, and their guests.
MS. COMEY: Would you please now read the fourth bullet point on this page?
JUAN PATRICIO ALESSI: Do not discuss personal problems with guests.
MS. COMEY: What did you understand this instruction to mean when Ms. Maxwell gave you this booklet?
JUAN PATRICIO ALESSI: Well, this instruction told me that any personal problem I have, I was not supposed to discuss with anybody.
MS. COMEY: Thank you. I'd like to now go to the seventh bullet point on this page. Would you please read that allowed?
JUAN PATRICIO ALESSI: Remember that you see nothing, hear nothing, say nothing, except to answer a question directed to you. Respect their privacy.
MS. COMEY: Mr. Alessi, when Ms. Maxwell gave you this booklet, what did you understand this rule to mean?
JUAN PATRICIO ALESSI: It means a kind of warning that I was supposed to be blind, deaf and dumb to say nothing of their lives.
MS. COMEY: Let's go now please to the page marked 8. Thank you. Would you please read the first bullet point on this LC2Qmax5 - corrected Alessi - Direct page?
JUAN PATRICIO ALESSI: Unless otherwise instructed, never disclose Mr. Epstein or Ms. Maxwell's activity or whereabouts to anyone. If the caller is insistent, you simply ask to take a message, a time, a number where the caller can be reached. Do not -- do not be bullied and do not show any reaction or impatience, simply be firm.
MS. COMEY: Can we please go now to the page marked page 10. Mr. Alessi, what are we looking at on this page?
JUAN PATRICIO ALESSI: This is a list of things that have to be done before the arrival of Mr. Epstein or Ms. Maxwell.
MS. COMEY: There's a reference on this page to JE and GM telephone directories.
MS. COMEY: What were those?
JUAN PATRICIO ALESSI: These were booklets with JE and GM. I think they were in the front or in the binding of the --
JUDGE NATHAN: Mr. Alessi, could you talk into the microphone please.
MS. COMEY: Mr. Alessi, what were these directories, JE and GM telephone directories to your understanding?
JUAN PATRICIO ALESSI: This would mean Jeffrey Epstein and Ghislaine Maxwell.
MS. COMEY: What are the directories?
JUAN PATRICIO ALESSI: The directories were books with hundreds and hundreds of names and their telephone numbers and contacts, directions, LC2Qmax5 - corrected Alessi - Direct addresses.
MS. COMEY: What did the books look like?
JUAN PATRICIO ALESSI: The book -- the books, they were type of hard binding, either blue or black. I can't remember which one was blue, which one was black, but they were thick, I would say two inches thick, and the size of a large telephone.
MS. COMEY: What was inside?
JUAN PATRICIO ALESSI: Inside was a list by alphabetical order of all the people, friends and families and business with Mr. Epstein and Ms. Maxwell.
MS. COMEY: I'd like to go now, please, to page 13. What do we see on this page?
JUAN PATRICIO ALESSI: Same thing, instructions for Ms. Maxwell's bathroom.
MS. COMEY: Is this a list of things you were supposed to do for Ms. Maxwell's bathroom?
MS. COMEY: When were you supposed to do these things?
JUAN PATRICIO ALESSI: Before their arrival, and after that every day they were in.
MS. COMEY: Every day who was in?
JUAN PATRICIO ALESSI: Mr. Epstein and Ms. Maxwell.
MS. COMEY: Let's go now to page 14, please. I'm sorry, I meant page 20, excuse me. Let's go to page 20. Could you read the bullet point that's the second from the bottom on this page, please. Could you read that aloud for LC2Qmax5 - corrected Alessi - Direct us, please?
JUAN PATRICIO ALESSI: Check the fence for holes where Max can get out.
MS. COMEY: Who is Max?
JUAN PATRICIO ALESSI: Max was this little dog that Ms. Maxwell owned. Her name was Max. It was a little Yorkie.
MS. COMEY: When do you remember first seeing Max?
JUAN PATRICIO ALESSI: I remember seeing Max probably when she came the first time, but I'm not sure.
MS. COMEY: When who came the first time?
JUAN PATRICIO ALESSI: Ms. Maxwell came to Palm Beach.
MS. COMEY: Remind us about what year that was.
MS. COMEY: 1991?
MS. COMEY: Did Ms. Maxwell still have this dog Max when you left Mr. Epstein's employment in 2002?
MS. COMEY: Do you know whether Max traveled with Ms. Maxwell or stayed in Palm Beach?
JUAN PATRICIO ALESSI: No, she traveled with Ms. Maxwell all the time.
MS. COMEY: How do you know that?
JUAN PATRICIO ALESSI: Because I took Max, she had to have a bath before she leave, and every time they -- there was wheels up, the poor dog shake like crazy because she didn't like to be in the plane.
MS. COMEY: Let's turn now, please, to page 23. I'd like to look at LC2Qmax5 - corrected Alessi - Direct the center portion of this page, please. This says Ms. Maxwell's desk. What is that referring to?
JUAN PATRICIO ALESSI: The DSL computer --
MS. COMEY: What do you understand Ms. Maxwell's desk to refer to?
JUAN PATRICIO ALESSI: The desk that she use all the time down on the first floor.
MS. COMEY: What room was that in?
JUAN PATRICIO ALESSI: That was in the garden room.
MS. COMEY: And the fourth bullet point, would you please read that for us?
JUAN PATRICIO ALESSI: JE and GM telephone directories placed to the right of the telephone.
MS. COMEY: Is that the same telephone directories that we were talking about earlier?
MS. COMEY: Let's turn now, please, to page 24. I want to look at the section titled stationery. Would you read this aloud for us, please?
JUAN PATRICIO ALESSI: The whole list?
MS. COMEY: Yes, please.
JUAN PATRICIO ALESSI: Three sizes of Jeffrey Epstein notepads. Two sizes of Ghislaine Maxwell and Lady Ghislaine notepads. Letterhead, stationery and envelopes. One pack from each of Mr. Epstein's residences and businesses. Mr. Epstein's personal stationery
(writing paper, notepads, envelopes, compliment slips). LC2Qmax5 - corrected Alessi - Direct Jeffrey Epstein and Ghislaine Maxwell cards and envelopes.
MS. COMEY: What was your understanding of what you were supposed to do with respect to stationery?
JUAN PATRICIO ALESSI: With respect to stationery, there was different sizes of pads for Mr. Epstein and Ms. Maxwell, and also there was engraving on those pages with her name and his name on top of it.
MS. COMEY: Let's turn now, please, to page 55. Could you explain to us what's on this page?
JUAN PATRICIO ALESSI: This was instructions for serving breakfast for Mr. Epstein and Ms. Maxwell, and breakfast for the guests.
MS. COMEY: Other than for Ms. Maxwell and Mr. Epstein, did you ever have special instructions for how to prepare breakfast for anyone else at the Palm Beach residence?
MS. COMEY: We can take that down. Thank you, Ms. Drescher. Mr. Alessi, during the time that you worked for Mr. Epstein, who else, if anyone, worked for Mr. Epstein, to your knowledge?
JUAN PATRICIO ALESSI: Can you repeat the question, please?
MS. COMEY: Who were the other of Mr. Epstein's employees that overlapped with you?
JUAN PATRICIO ALESSI: It was Emmy Tayler. She used to travel with them constantly.
MS. COMEY: What was her job, to your understanding? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: My understanding she was Ms. Maxwell's assistant.
MS. COMEY: Anyone else you remember?
JUAN PATRICIO ALESSI: There were a couple chefs. They were cam -- they came with him, they travel with him and Ms. Maxwell.
MS. COMEY: Let me pause you there. If there were chefs who traveled with Mr. Epstein and Ms. Maxwell, why would you need to prepare breakfast?
JUAN PATRICIO ALESSI: Sometimes I needed to prepare breakfast even when the chefs were there because they were -- had the privilege to sleep late, and I have to prepare breakfast at 5:00 in the morning for Mr. Epstein.
MS. COMEY: Other than chefs and Emmy Tayler, any other employees you remember?
JUAN PATRICIO ALESSI: Well, my wife worked for me during that time.
MS. COMEY: Were there any other assistants you remember working for Mr. Epstein or Ms. Maxwell?
JUAN PATRICIO ALESSI: At the very end, I saw Sarah Kellen at the very end of my stay there.
MS. COMEY: About how long before you left in December of 2002 do you remember Sarah Kellen starting to work for Mr. Epstein?
JUAN PATRICIO ALESSI: Couple weeks. I have very little interaction with Sarah.
MS. COMEY: Can we pull up what's already in evidence as Government Exhibit 327, Ms. Drescher? Do you recognize the person in this photograph, Mr. Alessi? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: That was Sarah Kellen.
MS. COMEY: What were Sarah's responsibilities during the brief time you overlapped?
JUAN PATRICIO ALESSI: I don't know her job responsibility, but she immediately took over the telephone, answering the phone, and I guess -- I think she did the scheduling of the massages.
MS. COMEY: You can take that down. Thank you. Do you know who Mr. Epstein's pilots were?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: Who were they?
JUAN PATRICIO ALESSI: It was Larry Visoski and David Rodgers.
MS. COMEY: Mr. Alessi, during the time that you worked for Mr. Epstein, how many, if any, young females do you remember seeing at Mr. Epstein's Palm Beach house?
JUAN PATRICIO ALESSI: I don't know what young you refer to, but underage you're talking?
MS. COMEY: Who appeared to be underage to you?
JUAN PATRICIO ALESSI: Who appeared to be, there were just two females.
MS. COMEY: Who appeared to be underage to you?
JUAN PATRICIO ALESSI: They appeared to be underage to me.
MS. COMEY: Without saying their names, do you know their names?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: I'd like to ask you to please turn in the binder next to you to Government Exhibit 12.
MS. COMEY: And, your Honor, I would ask that the jury LC2Qmax5 - corrected Alessi - Direct also be permitted to take out their binders and turn to Government Exhibit 12.
JUDGE NATHAN: Just a moment, jury. Any objection?
MR. PAGLIUCA: No, your Honor.
JUDGE NATHAN: The small binder or large binder?
MS. COMEY: I think it's the large binder.
JUDGE NATHAN: Large binder. GX-12, please.
BY MS. COMEY:
MS. COMEY: Do you have Government Exhibit 12 in front of you?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: Without saying the name out loud, I'd like you to look at the portion of this exhibit that says child's name. Is that the first and last name of one of the two underage females you remember seeing at Mr. Epstein's Palm Beach residence?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: I'm going to refer to her as Jane, and I would ask that you do the same, please. Okay?
JUAN PATRICIO ALESSI: Okay.
MS. COMEY: You can set that aside. Thank you. We won't need the binders again for the jurors for this witness. Mr. Alessi, other than Jane, what was the name of the second young female you remember seeing at Mr. Epstein's Palm Beach house?
JUAN PATRICIO ALESSI: Her name was Virginia Roberts. LC2Qmax5 - corrected Alessi - Direct
MS. COMEY: Who did you meet first, Jane or Virginia?
JUAN PATRICIO ALESSI: Jane.
MS. COMEY: How did you meet Jane?
JUAN PATRICIO ALESSI: I met Jane the first time when she came to the house in Palm Beach with her mother, and she was introduced her to Ms. Maxwell, and they stay with her mother talking in the living room.
MS. COMEY: When you first met Jane, about how old was she?
JUAN PATRICIO ALESSI: I don't know exactly how old she was, but she appeared to be young.
MS. COMEY: About how old did she appear to you?
JUAN PATRICIO ALESSI: I would say 14, 15.
MS. COMEY: Could you describe what Jane looked like when you first met her?
JUAN PATRICIO ALESSI: She was strikingly beautiful girl. Beautiful eyes. Long hair. Long brunette hair. Tall. Very pleasant.
MS. COMEY: About how many times do you remember seeing Jane at Mr. Epstein's Palm Beach house with her mother?
JUAN PATRICIO ALESSI: I remember at least three times she was there with her mother.
MS. COMEY: After those visits with her mother, do you remember seeing Jane at Mr. Epstein's home without her mother?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: Do you remember exactly how many times you saw her at Mr. Epstein's home without her mother? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: I don't remember exactly how many times, but it was four, five times after.
MS. COMEY: Who did you observe Jane spending time with when she came without her mother to the house?
JUAN PATRICIO ALESSI: Ms. Maxwell and Mr. Epstein.
MS. COMEY: To your knowledge, how did Jane get to Mr. Epstein's house when she would visit without her mother?
JUAN PATRICIO ALESSI: I was -- I was told to pick her up. Either Ms. Maxwell or Mr. Epstein instruct me to pick her up couple times.
MS. COMEY: I want to be clear here. Did Mr. Epstein instruct you to pick her up?
JUAN PATRICIO ALESSI: Either him or Ms. Maxwell.
MS. COMEY: You remember Ms. Maxwell instructing you to pick her up?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: And do you also remember Mr. Epstein instructing you --
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: -- to pick her up?
JUAN PATRICIO ALESSI: Yes, I do.
MS. COMEY: Where do you remember picking Jane up?
JUAN PATRICIO ALESSI: I remember picking Jane at the School of the Arts one time, only one time in West Palm Beach. That was the old Palm Beach Lakes High School, and they turn it into a School of the Arts, and I pick her up outside the school one time and brought her to Palm Beach.
MS. COMEY: Other than school, where else did you pick up Jane? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: I picked up Jane at her house that she live with her mother and siblings.
MS. COMEY: Why couldn't Jane drive herself?
JUAN PATRICIO ALESSI: I don't think she had the license.
MS. COMEY: Who else that you know of picked Jane up to bring her to Mr. Epstein's house?
JUAN PATRICIO ALESSI: My wife pick her up couple times.
MS. COMEY: When you picked Jane up, where in the car did she sit?
JUAN PATRICIO ALESSI: It was a rule that sit in the back of the car.
MS. COMEY: Who told you that rule?
JUAN PATRICIO ALESSI: The back seat. It was by Ms. Maxwell. Everybody should sit in the back.
MS. COMEY: Other than Jane, did you drive other people for Ms. Maxwell and Mr. Epstein?
JUAN PATRICIO ALESSI: Can you repeat the question, please?
MS. COMEY: Did you drive other people other than Jane for Ms. Maxwell and Mr. Epstein?
JUAN PATRICIO ALESSI: Oh absolutely, yes.
MS. COMEY: How many?
JUAN PATRICIO ALESSI: Dozens and dozens.
MS. COMEY: So do you have a clear memory of every single time you picked up a passenger?
JUAN PATRICIO ALESSI: Not a clear memory, no, but I remember driving to Miami to airports and homes to pick people up.
MS. COMEY: Other than Mr. Epstein's house, where else, to your LC2Qmax5 - corrected Alessi - Direct knowledge, would Jane go with Mr. Epstein and Ms. Maxwell?
MR. PAGLIUCA: Objection. Lack of foundation, your Honor.
JUDGE NATHAN: Sustained.
MS. COMEY: Did you ever see Jane with luggage?
JUAN PATRICIO ALESSI: Yes, I did.
MS. COMEY: After you -- where did you see Jane with luggage?
JUAN PATRICIO ALESSI: She came maybe twice with a small luggage, and they left with Mr. Epstein in their plane.
MS. COMEY: Let me break that down a little bit. Where did you see Jane with luggage on these approximately two occasions?
JUAN PATRICIO ALESSI: I saw her at the house in Palm Beach bringing the luggage.
MS. COMEY: Mr. Epstein's house?
JUAN PATRICIO ALESSI: Mr. Epstein's house.
MS. COMEY: Do you know how Jane got to the airport?
JUAN PATRICIO ALESSI: Yes. I was introduced to be -- I was the driver also.
MS. COMEY: So did you drive Jane to the airport?
JUAN PATRICIO ALESSI: Jane with Mr. Epstein and Ms. Maxwell, Max, the little dog, and other guests.
MS. COMEY: And when you drove them to the airport, did you drive all the way up onto the tarmac?
JUAN PATRICIO ALESSI: All the way up to the plane.
MS. COMEY: Were you able to see Jane get on the plane?
MS. COMEY: And who did she get onto the plane with? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: Ms. Maxwell, Mr. Epstein. I don't remember I think it was Emmy Tayler, the chefs and Max.
MS. COMEY: Do you remember about what year you met Jane?
JUAN PATRICIO ALESSI: I think it was 1994, '94.
MS. COMEY: When Jane came over to Mr. Epstein's house, do you know if she ever went to the movies?
JUAN PATRICIO ALESSI: Yes, they went to the movies.
MS. COMEY: Who went to the movies?
JUAN PATRICIO ALESSI: Mr. Epstein, Ms. Maxwell, the guest and Emmy. Basically they went almost every night to the movies.
MS. COMEY: Did Jane sometimes go with them?
MS. COMEY: When Jane visited Mr. Epstein's house, were there ever other females around?
MS. COMEY: Who are the fe -- let me back up. Do you remember the name of every single female who was at Mr. Epstein's Palm Beach house when Jane came over?
MS. COMEY: Do you remember some of the names?
MS. COMEY: What are some of the names you remember?
JUAN PATRICIO ALESSI: Emmy Tayler, Gwendolyn Beck. I don't think I can recall anybody else.
MS. COMEY: When Jane would first arrive at Mr. Epstein's house, where LC2Qmax5 - corrected Alessi - Direct did you see her go?
JUAN PATRICIO ALESSI: She went through the kitchen, I will introduce her to Ms. Maxwell at her desk, and that's it. That's as far as I saw her going to. She talked to Ms. Maxwell. From then, I was -- that was not my job to see where they were.
MS. COMEY: During the time that you worked for Mr. Epstein, who, if anyone, would tell you about Mr. Epstein's upcoming travel plans?
JUAN PATRICIO ALESSI: Either Ms. Maxwell, sometimes the secretaries from the office. If I remember correctly, was Fiona secretary, also Kimberly, a secretary from New York, and sometimes the pilots told me, "We're on our way and we have to rush."
MS. COMEY: Other than Jane, what was the name of the other female who appeared to be underage that you remember seeing at Mr. Epstein's house?
JUAN PATRICIO ALESSI: The other young person that I saw there was Virginia Roberts.
MS. COMEY: How did you first come to see Virginia Roberts?
JUAN PATRICIO ALESSI: I saw Virginia Roberts at Mar-a-Lago one afternoon with Ms. Maxwell --
MS. COMEY: Let me stop you there. What were you doing at Mar-a-Lago with Ms. Maxwell?
JUAN PATRICIO ALESSI: She went to check the spa. She went to see the spa at Mar-a-Lago.
MS. COMEY: What had you and Ms. Maxwell been doing that day? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: That day we went from all the main expensive -- luxury spas and country clubs in Palm Beach County.
MS. COMEY: Did you go inside each those?
MS. COMEY: What were you doing?
JUAN PATRICIO ALESSI: I wait in the car like a driver.
MS. COMEY: What happened when you got to Mar-a-Lago that day with Ms. Maxwell?
JUAN PATRICIO ALESSI: I dropped Ms. Maxwell, I park in the spaces where I was supposed to park, wait in the car. I remember it was a very hot day, and we have a convertible. And Ms. Maxwell come out, got in the car and we were going up the ramp, small ramp going out of Mar-a-Lago --
MS. COMEY: As you were driving up that ramp, what did Ms. Maxwell say to you?
JUAN PATRICIO ALESSI: She told me to stop, "John, stop."
MS. COMEY: And after she told you to stop the car, did you stop the car?
JUAN PATRICIO ALESSI: I stopped the car, and she opened the door and she went towards this girl as she was coming down the ramp.
MS. COMEY: Let me break that down. After Ms. Maxwell told you to stop, what did you see Ms. Maxwell do?
JUAN PATRICIO ALESSI: She went to talk to this girl.
MS. COMEY: And where was this girl?
JUAN PATRICIO ALESSI: She was coming down the ramp from the main gate towards the LC2Qmax5 - corrected Alessi - Direct spa.
MS. COMEY: What did this girl look like?
JUAN PATRICIO ALESSI: She look -- she look young. She have blond hair, and she had a long white uniform, like a nurse's uniform.
MS. COMEY: What did you see Ms. Maxwell do after she got out of the car?
JUAN PATRICIO ALESSI: They talk briefly, and they went back to the spa.
MS. COMEY: Who talked?
JUAN PATRICIO ALESSI: Ms. Maxwell and Ms. Roberts.
MS. COMEY: Is that the girl?
MS. COMEY: And then where did you see Ms. Maxwell and the girl go?
JUAN PATRICIO ALESSI: They went inside the spa. And couple minutes later Ms. Maxwell come out, got in the car, and we left.
MS. COMEY: When was the next time you saw that girl from the Mar-a-Lago parking lot?
JUAN PATRICIO ALESSI: The next time I saw her was late that afternoon, around 5:00, 6:00 in the afternoon.
MS. COMEY: Where did you see her?
JUAN PATRICIO ALESSI: At the house in Palm Beach.
MS. COMEY: And when she arrived, where did she go?
JUAN PATRICIO ALESSI: She went -- I introduce her to Ms. Maxwell at her desk.
MS. COMEY: Did you learn her name?
MS. COMEY: At some point did you learn her name? LC2Qmax5 - corrected Alessi - Direct
MS. COMEY: The girl's name?
JUAN PATRICIO ALESSI: I didn't know her name -- her name or her last name.
MS. COMEY: Did you eventually learn her name? You told us her name. Yes?
JUAN PATRICIO ALESSI: Yes. Oh, eventually I learned her name.
MS. COMEY: Okay. What is her name?
JUAN PATRICIO ALESSI: It was Virginia Roberts.
MS. COMEY: I'd like to pull up, please, what's been marked for identification as Government Exhibits 113 and Government Exhibit 114, just for the witness, the Court and the parties, Ms. Drescher. Mr. Alessi, do you recognize these exhibits?
JUAN PATRICIO ALESSI: Yes, they are both pictures of Virginia.
MS. COMEY: Are these both fair and accurate depictions of Virginia Roberts?
MS. COMEY: Your Honor, the government offers these in evidence.
MR. PAGLIUCA: No objection.
JUDGE NATHAN: GX-113 and 114 are admitted. And you may publish.
MS. COMEY: Thank you, your Honor. (Government's Exhibits 113 and 114 received in evidence) LC2Qmax5 - corrected Alessi - Direct
MS. COMEY: Ms. Drescher, I'd ask you to publish these for the jury. After that first visit, about how often do you remember seeing Virginia at Mr. Epstein's Palm Beach home?
JUAN PATRICIO ALESSI: After the first time very often she came to the house while Mr. Epstein and Ms. Maxwell were at the Palm Beach house.
MS. COMEY: What was your understanding of why Virginia was at Mr. Epstein's house?
MR. PAGLIUCA: Objection. Lack of foundation.
JUDGE NATHAN: Sustained.
MS. COMEY: Did Ms. Maxwell ever tell you why Virginia was at the house?
MS. COMEY: About how old was Virginia when you saw her coming over to Mr. Epstein's Palm Beach home?
MR. PAGLIUCA: Objection. Lack of foundation.
JUDGE NATHAN: Sustained.
MS. COMEY: About how old did Virginia appear to you when you first met her?
JUAN PATRICIO ALESSI: Probably 14, 15.
MS. COMEY: Do you know how Virginia got to Mr. Epstein's Palm Beach home when she would visit?
JUAN PATRICIO ALESSI: When she visit the first time?
MS. COMEY: After the first time.
JUAN PATRICIO ALESSI: After the first time. She came with her boyfriend couple times, and I was told to pick her up couple times from her LC2Qmax5 - corrected Alessi - Direct house. She live with her boyfriend in Royal Palm Beach.
MS. COMEY: Who instructed you to pick Virginia up?
JUAN PATRICIO ALESSI: Either Mr. Epstein or Ms. Maxwell.
MS. COMEY: Let's break that down. Did Ms. Maxwell ever instruct you to pick up Virginia Roberts?
MS. COMEY: Did Mr. Epstein ever instruct you to pick up Virginia Roberts?
JUAN PATRICIO ALESSI: Yes, he did.
MS. COMEY: Who else, if anyone, did you see Virginia bring to Jeffrey Epstein's Palm Beach home?
JUAN PATRICIO ALESSI: On one occasion, she bring her boyfriend and he came to the kitchen. However, I was told by Ms. Maxwell to get him out of the kitchen, and he has to wait in the car.
MS. COMEY: What, if any, females do you remember Virginia bringing to Mr. Epstein's Palm Beach house?
JUAN PATRICIO ALESSI: At the end of my stay there, I saw her bringing two other girls. I even never saw their faces. They walk through the kitchen right away, and they went directly to Ms. Maxwell's desk.
MS. COMEY: When Virginia was at Mr. Epstein's Palm Beach home, who did you see her interact with?
JUAN PATRICIO ALESSI: Ms. Maxwell and Mr. Epstein.
MS. COMEY: Did you ever see Virginia at Mr. Epstein's Palm Beach house with luggage? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: Yes, I did.
MS. COMEY: About how many times?
JUAN PATRICIO ALESSI: Two, three times.
MS. COMEY: And on those times, did you then drive Virginia somewhere?
JUAN PATRICIO ALESSI: I drove from her house in Royal Palm Beach to the house in Palm Beach.
MS. COMEY: How about on the times she had luggage, do you know where she went from there with her luggage?
JUAN PATRICIO ALESSI: They went with Mr. Epstein and Ms. Maxwell to the plane.
MS. COMEY: How do you know that?
JUAN PATRICIO ALESSI: Because I brought them. I was the driver.
MS. COMEY: Did you drive right onto the tarmac?
JUAN PATRICIO ALESSI: Up to the tarmac.
MS. COMEY: Who did you see get on the plane?
JUAN PATRICIO ALESSI: Mr. Epstein, Ms. Maxwell, the chefs, Ms. Tayler, little Max, they went on the plane.
MS. COMEY: Did you also see Virginia go on the plane?
MS. COMEY: Do you remember approximately when you first met Virginia?
JUAN PATRICIO ALESSI: Not exactly, but I would say it's 2001.
MS. COMEY: We can take these exhibits down. Thank you, Ms. Drescher. Mr. Alessi, about how often did Mr. Epstein receive massages at the Palm Beach residence while you worked for him?
JUAN PATRICIO ALESSI: In the beginning, he receive around one. At the end of my stay, he received up to three massages per day. LC2Qmax5 - corrected Alessi - Direct
MS. COMEY: Was it the same person massaging Epstein at each appointment or a different person?
JUAN PATRICIO ALESSI: They were different persons.
MS. COMEY: Who scheduled Mr. Epstein's massages?
JUAN PATRICIO ALESSI: Ms. Maxwell, Mr. Epstein, or sometimes even the office people in New York, they would call me and ask me to schedule the massages.
MS. COMEY: When you scheduled the massages, what did you do?
JUAN PATRICIO ALESSI: I went to my office, and I had a Rolodex with all the massage therapists, and whoever they told me to call, I would call that person, and I will ask if they're available for this time. It was a different times of the day. And if they said yes, I would confirm with Ms. Maxwell or Mr. Epstein that she was coming.
MS. COMEY: And who do you remember telling you which person to call to come give Mr. Epstein a massage?
JUAN PATRICIO ALESSI: Either was Ms. Maxwell, Mr. Epstein, or the office.
MS. COMEY: Other than you, who else, if anyone, would call to schedule massages?
JUAN PATRICIO ALESSI: At the end, Ms. Kellen.
MS. COMEY: Now, you said that closer to the end, Mr. Epstein was getting three massages a day?
MS. COMEY: What time of day typically were those massages?
JUAN PATRICIO ALESSI: It was all different times of day. It was a massage in the LC2Qmax5 - corrected Alessi - Direct morning, a massage in the afternoon, and some of the massages after dinner, after the movies. They were scheduled to come after the movies, 10:00, 11:00 at night.
MS. COMEY: You mentioned the phone books that we saw in Government Exhibit 606. Do you remember that?
MS. COMEY: Did that have contact information for people to massage Mr. Epstein?
JUAN PATRICIO ALESSI: Yes, there was a page with the massages -- massage therapists for Palm Beach.
MS. COMEY: Was Jane's contact information in that book?
MS. COMEY: Jane.
JUAN PATRICIO ALESSI: No. Oh, excuse me. Can you repeat that?
MS. COMEY: The person we're referring to as Jane.
JUAN PATRICIO ALESSI: Yes. Yes, it was. It was her on the contact information.
MS. COMEY: I want to make sure the record is clear here. Do you remember looking earlier at Government Exhibit 12 and telling us that you recognized that name?
MS. COMEY: And we're calling that person Jane?
MS. COMEY: That person, do you remember seeing her true name in this directory?
JUAN PATRICIO ALESSI: Yes. LC2Qmax5 - corrected Alessi - Direct
MS. COMEY: About when do you remember first seeing this directory?
JUAN PATRICIO ALESSI: Probably 1995, '96.
MS. COMEY: Were there different versions of this directory?
JUAN PATRICIO ALESSI: Those directories were updated.
MS. COMEY: How often were they updated?
JUAN PATRICIO ALESSI: I think it was once a year or maybe twice a year.
MS. COMEY: When they were updated, what did you do with the old ones?
JUAN PATRICIO ALESSI: We just throw it away.
MS. COMEY: Did you look at different versions of the directory over the years you worked for Mr. Epstein?
MS. COMEY: And when you got an updated version, were there new contacts added?
MS. COMEY: Did you ever notice contacts being removed?
JUAN PATRICIO ALESSI: I don't recall being removed.
MS. COMEY: Who did you see using these directories?
JUAN PATRICIO ALESSI: Ms. Maxwell, Mr. Epstein.
MS. COMEY: Where were you supposed to keep copies of this directory?
JUAN PATRICIO ALESSI: We were supposed to keep the copies, one in the kitchen desk, it was a little tiny desk at the kitchen next to the telephone, it was at Ms. Maxwell's desk, Mr. Epstein's three desks he had in the house, Ms. Maxwell's each side of her night table or Mr. Epstein's night table.
MS. COMEY: Your Honor, may I approach the witness LC2Qmax5 - corrected Alessi - Direct with a physical exhibit?
JUDGE NATHAN: I'm sorry?
MS. COMEY: I have a physical exhibit that I would like to approach and give to the witness.
JUDGE NATHAN: Please identify it for the record.
MS. COMEY: Government Exhibit 52, which I will show to defense counsel before I bring it up.
JUDGE NATHAN: Marked for identification GX-52?
MS. COMEY: Yes. Thank you, your Honor.
JUDGE NATHAN: Before the witness, may I see it?
MS. COMEY: Yes, your Honor.
JUDGE NATHAN: Okay.
MS. COMEY: Thank you, your Honor. May I approach the witness?
JUDGE NATHAN: You may.
BY MS. COMEY:
MS. COMEY: Mr. Alessi, I've just handed you what is marked for identification as Government Exhibit 52. Would you please take a look at that, and then tell us if you recognize it?
JUAN PATRICIO ALESSI: Yes, I recognize it. The type of book, it was the same.
MS. COMEY: Hold on one second. What does this appear to be to you?
JUAN PATRICIO ALESSI: This appear to be the direct -- these were the directories of Ms. Maxwell and Mr. Epstein.
MS. COMEY: Did you review this directory last night?
JUAN PATRICIO ALESSI: Yes, I did. LC2Qmax5 - corrected Alessi - Direct
MS. COMEY: I want to ask you some questions about this directory. Starting with the cover, what do you recognize about the cover?
JUAN PATRICIO ALESSI: This was exactly the same cover of the directories that I saw.
MS. COMEY: Is it the same binding?
JUAN PATRICIO ALESSI: The same binding, binding.
MS. COMEY: Turning to the pages, what do you recognize about the layout on the pages?
JUAN PATRICIO ALESSI: It was exactly as the books that I recall.
MS. COMEY: Did you review every page of this exhibit last night?
MS. COMEY: When you reviewed this exhibit, did you see entries that you recognized from the book you saw when you worked for Mr. Epstein?
JUAN PATRICIO ALESSI: Yes, I did.
MS. COMEY: Do you remember about how many?
JUAN PATRICIO ALESSI: There were many, many, many, many names.
MS. COMEY: Were some of those entries for massage in Palm Beach?
MS. COMEY: Is there a difference in the size of the font in this book--
MS. COMEY: -- from the one that you remember?
JUAN PATRICIO ALESSI: Yes, these are much smaller font. My books, the books when I was there, they were a lot thicker, and the font was larger, LC2Qmax5 - corrected Alessi - Direct but the format was the same.
MS. COMEY: Format was the same. And are there some of the same contacts that you remember from when you worked for Mr. Epstein?
MS. COMEY: Based on your review of this book last night, do you think this is the same book that you saw when you were employed, or a later version from after you left working for Mr. Epstein?
MR. PAGLIUCA: Objection, your Honor. Lack of foundation.
JUDGE NATHAN: Overruled. You may answer.
JUAN PATRICIO ALESSI: Yes, it was the same book.
MS. COMEY: Hold on. Do you think this was a later version after you left?
JUAN PATRICIO ALESSI: This was a later version, yes, ma'am.
MR. PAGLIUCA: Objection.
JUDGE NATHAN: Just a second. I'm going to sustain. The jury will disregard the last answer. You may rephrase.
MS. COMEY: Mr. Alessi, based on your review of this book, do you believe that this is the same book you saw when you worked for Mr. Epstein or a later version from after you left?
JUAN PATRICIO ALESSI: This was a later version of book after I -- that it was printed probably after I left.
MS. COMEY: What makes you say that? LC2Qmax5 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: The books --
MR. PAGLIUCA: Your Honor, lack of foundation.
JUDGE NATHAN: The question right now -- and I'll take the objection after I hear the answer to this question. Go ahead.
MS. COMEY: What makes you say that?
MR. PAGLIUCA: I'm objecting to this question, your Honor.
JUDGE NATHAN: I am overruling that objection. Thank you.
MS. COMEY: What makes you say that this is a later version, Mr. Alessi?
JUAN PATRICIO ALESSI: It was a later version because the font is a lot smaller. The book is a lot thinner. Our books were about two inches thick.
MS. COMEY: Mr. Alessi, is your name in this book?
JUAN PATRICIO ALESSI: No, I didn't find it last night, and my name originally was in the information for Palm Beach information of the house, the house man in Palm Beach.
MS. COMEY: May I have a moment, your Honor?
JUDGE NATHAN: You may.
MS. COMEY: Ms. Drescher, can we please pull up what's been marked for identification as Government Exhibit 52A. Thank you, Ms. Drescher. Ms. Drescher reminds me that this is a sealed exhibit. LC2Qmax5 - corrected Alessi - Direct So, Mr. Alessi, would you please, with the Court's permission, look at the binder next to you and look at Government Exhibit 52A for identification. Do you recognize this?
MS. COMEY: Did you compare this exhibit to a page in the book that's marked for identification as Government Exhibit 52 earlier today?
JUAN PATRICIO ALESSI: Yes, I did.
MS. COMEY: And is Government Exhibit 52A a copy of that page from Government Exhibit 52?
MR. PAGLIUCA: Objection. Lack of foundation.
JUDGE NATHAN: Mr. Alessi, will you look through each page of the copy?
MS. COMEY: Your Honor, it's a single page.
JUDGE NATHAN: I'm sorry. What page?
MS. COMEY: It's marked for identification as Government Exhibit 52A. Oh, you want us to look through Government Exhibit 52?
JUDGE NATHAN: 52A is one page of 52?
MS. COMEY: Yes, your Honor.
JUDGE NATHAN: And what number page is it?
MS. COMEY: The pages are not numbered, your Honor.
MR. PAGLIUCA: Can we have a sidebar, your Honor?
JUDGE NATHAN: Actually, I'm going to break for the LC2Qmax5 - corrected Alessi - Direct afternoon. 15-minute break. Members of the jury, enjoy your break.
(Jury not present)
JUDGE NATHAN: Ms. Comey, may I have the book and a copy of 52A?
MS. COMEY: Of course, your Honor. Your Honor, if I may clarify.
JUDGE NATHAN: I just want to make sure the witness is clear. Okay. All right, go ahead.
MS. COMEY: Thank you, your Honor. I just wanted to clarify that last line of questioning. The witness this morning looked at Government Exhibit 52A and compared it against Government Exhibit 52. He essentially did this homework before getting on the stand and he did that for --
JUDGE NATHAN: Sometimes you have to show your work.
MS. COMEY: Absolutely, your Honor. I just wanted to clarify that he could testify that he has just this morning taken this exhibit and the other sub-marked exhibits that I expect to introduce and compared them against Government Exhibit 52 to confirm that they're copies. But happy to go through the process on the stand as well, your Honor.
MR. PAGLIUCA: I think the problem from my perspective, your Honor --
JUDGE NATHAN: Could you pull up the microphone? LC2Qmax5 - corrected Alessi - Direct
MR. PAGLIUCA: Yes. First of all, we're talking about copies. All of this is copies. And this witness has no personal knowledge about whether the copy he's being shown is a copy from this book or from some other book, number one.
JUDGE NATHAN: Well, just on that, so if he could -- if he's directed to a page in the book and then directed to the exhibit, the A exhibit, he could look and compare and indicate whether he sees any differences.
MR. PAGLIUCA: Sure. He could say this looks like a copy from this book. I agree with that.
JUDGE NATHAN: Right. So, Ms. Comey, you will do that.
MS. COMEY: Yes, your Honor.
JUDGE NATHAN: Do you have way to direct him to the relevant page?
MS. COMEY: Your Honor, during the break, I'm happy to take the exhibit, and I will figure out a way to direct him to the relevant page during our break.
JUDGE NATHAN: Okay.
MR. PAGLIUCA: I guess, the other -- I'm not sure how we're doing this, but it seems to me that foundationally there should be a discussion about the admission of 52 before we're doing these comparatives in front of the jury.
JUDGE NATHAN: I think that's fair enough. Why not do it that way, Ms. Comey? LC2Qmax5 - corrected Alessi - Direct
MS. COMEY: I'm sorry, your Honor, I didn't hear the proposal.
JUDGE NATHAN: Why not do it that way?
MS. COMEY: I didn't hear Mr. Pagliuca's proposal.
JUDGE NATHAN: Why not deal with the admission, the offer of 52 -- I mean, we don't need testimony on the subpages --
MS. COMEY: Your Honor, we're not offering the entirety of 52. As I believe we mentioned to your Honor in briefing, we're trying to narrow what we're offering from this exhibit, and so we picked five pages that are particularly relevant to the facts that are at issue in this case, and we would only propose to show the jury those five pages, which is why we're going through this process.
MR. PAGLIUCA: I don't have a problem with that, your Honor, but I think what I would say is they would offer 52 and, in essence, it's a redacted version of 52 that's going to the jury. So the record will be clear that 52, if the Court is going to allow it, is authenticated and admitted, and that it's a redacted version of 52 is what's going to the jury.
JUDGE NATHAN: That sounds exactly right.
MS. COMEY: That's fine, your Honor.
JUDGE NATHAN: So it's 52A through what?
MS. COMEY: It's 52A, D, E, F, G and H.
JUDGE NATHAN: So you will -- to the extent you have more testimony to elicit for authentication, you're done, I presume LC2Qmax5 - corrected Alessi - Direct you want to inquire, I'll allow that, and then I'll make my ruling. If 52 is admitted, I'll indicate that it's admitted in redacted form, and for those purposes, Mr. Pagliuca, you'd like the witness to compare each of the A, D, E, F, G, H pages to those in the book.
MR. PAGLIUCA: I think the answer to that question is depending on whether the Court admits it or not, then we don't need to make a copy. If the Court is not going to admit it, then we don't get to the 52. If the Court does admit it, I do not need an on-the-record comparison because we've dealt with, I think, the issue. I accept that the government is going to say, and I agree, that they, they, the government, have copied those pages. That was not the problem of my objection. It was the rest of this format of how this was being done. So I think if it's admitted, they say: Here's 52. Is that a copy of a page out of the book? Yes. Okay, fine. And we move on. Because the actual substance has been admitted, we don't have to deal with -- copies are the same.
JUDGE NATHAN: How about this: If I sustain the objection, that's the end of it. If I overrule the objection, 52 will be admitted in redacted form, and then you can stipulate to the government's 52A, D, E, F, G and H being true and correct photocopies of five pages from 52. Is that reasonable? LC2Qmax5 - corrected Alessi - Direct
MR. PAGLIUCA: That's fine.
JUDGE NATHAN: So you don't -- we don't need the witness to verify the copies.
MR. PAGLIUCA: I agree.
MS. COMEY: Thank you, your Honor.
JUDGE NATHAN: I will give you the book back, and we'll take a short break.
MS. COMEY: Thank you, your Honor.
(Recess)
(Continued on next page)
JUDGE NATHAN: So I want to ask, there was an objection to a question on foundation. The question was, is this -- do you know if this is the same book or a later book. I wanted to hear the answer to that. But looking at it, I don't know what his basis for knowledge is for saying that it's the later book. So you can inquire into that or I'll -- yes?
MR. PAGLIUCA: Well, I guess if he left in 2002 and the book is after 2002, I don't think there can be a basis for knowledge.
JUDGE NATHAN: Well, I'll allow the question to be asked. And if there's not, then I will agree with you and I'll strike the testimony.
MR. PAGLIUCA: Okay.
MS. COMEY: Understood, your Honor.
JUDGE NATHAN: So that's one. And then two, I just want to make sure I understand, because the letter indicated this witness, sort of a new person to authenticate, as opposed to the original witness who you indicated would authenticate; correct?
MS. COMEY: Yes, your Honor. That other witness we believe could also authenticate it, but --
JUDGE NATHAN: Right. So it seems to me when you're finished here and after the voir dire, I can sustain the objection, overrule the objection, or reserve until I hear additional. Any reason not to do it that way?
MS. COMEY: No, your Honor. I think our position is clear that we think it should come in at this time, but understood.
MR. PAGLIUCA: I think that's entirely appropriate. I guess the question is are you conditionally admitting it or not.
JUDGE NATHAN: The reason I ask, do you need -- is there more to do with it now or can we simply reserve and move on till the other witness?
MS. COMEY: I think it's fine to reserve, your Honor.
JUDGE NATHAN: Okay. So if that's what I do, I won't conditionally admit and we'll take it from there.
MR. PAGLIUCA: Okay.
JUDGE NATHAN: Anything to take up before we bring the witness back?
MR. PAGLIUCA: Not from me, your Honor.
MS. COMEY: Your Honor, I apologize if I was not clear, but we do want to admit this through this witness. And I do have questions for him about this exhibit, so we are seeking to admit it. I apologize. My colleagues let me know that I was not clear.
JUDGE NATHAN: It wasn't that you weren't clear. That's an opposite answer of the one you just gave.
MS. COMEY: I apologize, your Honor. I misunderstood the question.
JUDGE NATHAN: Well, I think -- you may move it. And I will tell you whether I'm -- presuming -- I'm going to hear the voir dire. You'll move it. I'll either overrule -- there will be an objection. I'll either overrule the objection, sustain the objection, or reserve.
MS. COMEY: Understood.
JUDGE NATHAN: The other option I sort of reserve sub A is conditionally admit it pending further testimony. But I may not do that. I'm not sure.
MS. COMEY: Understood, your Honor. Thank you.
MR. PAGLIUCA: To the extent it matters, I would be opposed to conditionally admitting the exhibit, your Honor.
JUDGE NATHAN: I want to just get in my head the question. The question I have in mind that drew the foundation objection was, Mr. Alessi, based on your review of this book, do you believe this is the same book that you saw when you worked for Mr. Epstein or a later version after you left? And he said, This was a later version of the book after I left, that it was printed probably after I left. And then the objection came after that, lack of foundation. The question was, What makes you say this is a later version, Mr. Alessi, which was what I thought would elicit -- be responsive to the foundation objection. And he said, The book is a lot thinner. Our books were about two inches thick. So you'll return to that. I agree, based on that answer, which I had assumed would provide a foundation.
MS. COMEY: Yes, your Honor.
JUDGE NATHAN: But it didn't. So unless there's further foundation, I'll sustain the lack of foundation objection and I'll tell the jury to disregard Mr. Alessi's testimony that it was a later version of the book. Okay, Mr. Pagliuca?
MR. PAGLIUCA: Yes, your Honor. That's appropriate.
JUDGE NATHAN: Okay. We'll bring in the witness. The witness while we're getting the jury, please. Thank you.
(Witness present)
(Jury present)
JUDGE NATHAN: You may be seated. Thank you so much, members of the jury. All right. Ms. Comey, you may continue your direct of Mr. Alessi. Mr. Alessi, I remind you, you are under oath. Go ahead.
MS. COMEY: Thank you, your Honor.
BY MS. COMEY:
MS. COMEY: Good afternoon, Mr. Alessi.
JUAN PATRICIO ALESSI: Good afternoon.
MS. COMEY: I want to return to talking about the booklet. And in particular, I want to ask you some questions about the booklet that you saw during your employment for Mr. Epstein. So remind us, between what years did you work for Mr. Epstein?
JUAN PATRICIO ALESSI: Around 1990 to 2002.
MS. COMEY: During that time, how often were new booklets printed? Or, excuse me, directories, directories is what I wanted to talk about. How often were new directories --
JUAN PATRICIO ALESSI: I think they were printed twice a year.
MS. COMEY: Did each directory have the names of current employees in it?
MS. COMEY: So when an employee left, was that employee's name still in the next version of the directory?
JUAN PATRICIO ALESSI: No, because -- and the new directory you show me, my name is not --
MS. COMEY: That's not my question, Mr. Alessi. That's not my question. My question is just in your experience looking at the different versions of directories that you saw, did the directories remove the names of employees who had left?
MS. COMEY: Okay. And did they add the names of any new employees who had come?
MS. COMEY: I want to talk about Government Exhibit 52, the same exhibit you reviewed last night.
MS. COMEY: Is your name in that book?
JUAN PATRICIO ALESSI: No, my name is not in the book.
MS. COMEY: Is your wife's name in that book?
MS. COMEY: Is Sarah Kellen's name in that book?
JUAN PATRICIO ALESSI: Excuse me?
MS. COMEY: Is Sarah Kellen, is her name in the book?
MS. COMEY: Do you want to go ahead and take a look at that book, please, and tell me if you see Sarah Kellen's name in it?
JUDGE NATHAN: Just a moment. He's looking at the binder.
MS. COMEY: Oh, no. May I approach, your Honor?
JUDGE NATHAN: You may.
MR. PAGLIUCA: Your Honor, I'm going to object to this process. He answered no, and this is essentially a leading question to change the answer.
JUDGE NATHAN: I'll sustain the leading objection. But otherwise, I'll allow it. Well, I'll permit the question that you asked. So I'll allow the question, which is, is Sarah Kellen's name in the book?
MS. COMEY: I think I'm asking him to look in the exhibit.
MR. PAGLIUCA: And that's my objection, your Honor.
JUDGE NATHAN: I understand. I'm going to overrule the objection. Go ahead.
MS. COMEY: Would you please look through the exhibit and let us know if you see Sarah Kellen's name in the exhibit?
JUAN PATRICIO ALESSI: Can you repeat the name?
MS. COMEY: Sarah Kellen.
JUDGE NATHAN: Actually, do you know what? I'll ask you to pause, Mr. Alessi. I'll sustain the objection. I think it's lost the thread on authentication at this point. You'll go to the question that I asked you to.
MS. COMEY: Your Honor, I'm sorry. Now I'm confused.
JUDGE NATHAN: The earlier foundation objection that I asked you to return to.
MS. COMEY: Yes, your Honor. May I have a moment?
JUDGE NATHAN: You may.
(Counsel conferred)
BY MS. COMEY:
MS. COMEY: So Mr. Alessi --
MS. COMEY: -- how do you know that this Government Exhibit 52 is a later version of the directory that you saw when you worked for Mr. Epstein?
JUAN PATRICIO ALESSI: I think this is a later version. In the back page of the front cover it says 2004-2005.
MR. PAGLIUCA: Your Honor, I object. Now he's just reading from the book.
JUDGE NATHAN: Sustained. The jury will disregard that answer.
MS. COMEY: Your Honor, may I be heard on this issue?
JUDGE NATHAN: You may.
(Continued on next page)
(At sidebar)
JUDGE NATHAN: All you're doing at this point is asking him to look at the exhibit and read from it. It's not in evidence. He didn't seem to have a basis that he recalled, as far as I can tell for why he thinks it's a different version. So I'm not going to permit him to read from the document.
MS. COMEY: Yes, your Honor. All I was going to say is his view of that is based on his observation of the exhibit. I did not intend him to have him read the document not in evidence. My question is based on his observations of this exhibit. What makes him believe that it's a later version and the contents of this exhibit is part of how he forms that answer.
JUDGE NATHAN: The content, other than the date or anything else?
MS. COMEY: I think at this point it's the fact that his name and his wife's name were not in the exhibit and that there is the date on there.
JUDGE NATHAN: I think you can ask -- without -- putting the document aside, he already answered that. You think this is a later version. What is your basis for saying that?
MS. COMEY: Your Honor, I think his basis would be --
JUDGE NATHAN: I know what you think his basis --
MS. COMEY: I just don't want to -- I apologize, your Honor. I just don't want to elicit something that your Honor does not want me to elicit. I think what he will say is something referring to the content of the exhibit. I don't want to elicit that if your Honor has ruled that I cannot.
JUDGE NATHAN: Fair enough. I mean, it sounds like he gave two responses to the question, right. One is, I saw the date and it's a later date; the other is my name has been removed, my name's not in it, my wife's name is not in it. He hasn't provided that testimony, so I don't know -- it's a logical inference which you may be making. I don't know it's a logical inference that he would make.
MS. COMEY: Your Honor, at this point I'll rest on the logical inference that I think the Court can make based on the record before it. I'll move on.
JUDGE NATHAN: So what I'm going to do is sustain the foundation objection at this point. I'll tell the jury to disregard the testimony that he believes it to be a later version of the book from his time. I'll allow the voir dire, and we'll take it from there.
MS. COMEY: Yes, your Honor.
MR. PAGLIUCA: Thank you, your Honor.
MS. COMEY: Your Honor, I apologize.
(Counsel conferred)
MS. COMEY: Your Honor, I think Ms. Moe would like to be heard on this issue. I apologize.
MS. MOE: I'm sorry, your Honor. Just to frame the issue, I recognize we've been clarifying the record about time periods. Our view on authentication for this exhibit is this witness is not authenticating it as a document from a particular time period. I recognize we've been asking questions about that. The question before the Court is whether this witness can authenticate this exhibit as a document belonging to Maxwell and Epstein or a document that he recognizes based on his observations of the book. So we just wanted to frame the question in terms of our perspective.
JUDGE NATHAN: That's fine. I didn't ask the question if it was a later book. Ms. Comey did. There was an objection. We thought we were on foundation. That's where we are. I'm now ruling, sustaining that objection, telling the jury to disregard that testimony. Then it's the defense's turn to voir dire, you'll seek admission, I'll rule. I may admit it, I may not admit it, I may reserve until we hear the testimony of employee one.
(Continued on next page)
(In open court)
JUDGE NATHAN: I am sustaining the earlier objection to foundation. I will instruct the jury to disregard prior testimony that the witness indicated that this book is a later version of the directory that he's familiar with. Okay.
MS. COMEY: Your Honor, the government offers Exhibit 52 in redacted form.
JUDGE NATHAN: You may inquire.
MR. PAGLIUCA: Thank you, your Honor. VOIR DIRE EXAMINATION
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, as I understand it, the first time you've looked at Exhibit 52 is last night; is that correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Okay. So 19 years after you left Mr. Epstein's employment is the first time you've seen Exhibit 52; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: Okay. And as you sit here today, 19 years later, you have no idea where Exhibit 52 has been for the last 19 -- well, has been for however long that's been in existence; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: Okay. The books that you remember from the 2000 time frame, I think you testified, were approximately two inches thick; is that correct?
MR. PAGLIUCA: Okay. So two inches, I don't know if you can see this far, but that's about two inches; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And the Exhibit 52 is maybe a quarter of an inch, is that a fair statement?
JUAN PATRICIO ALESSI: It's fair.
MR. PAGLIUCA: Okay. The books that you were talking about, as I understand it, came from New York; is that right?
MR. PAGLIUCA: Okay. And you don't have any idea whether that book -- well, whether Exhibit 52 -- let's just call it Exhibit 52, came from New York or not; correct? You don't know whether Exhibit 52 came from New York, came from Palm Beach, came from California, came from anywhere? I mean, you have no personal knowledge about where Exhibit 52 was created; correct?
JUAN PATRICIO ALESSI: Excuse me. This is Exhibit 52?
MR. PAGLIUCA: Yes, that's correct.
JUAN PATRICIO ALESSI: Yeah, I have no idea.
MR. PAGLIUCA: Okay. There are -- when you held that up, I can see a bunch of different Post-It notes in Exhibit 52. Do you see that?
MR. PAGLIUCA: Okay. You have no idea where those Post-It notes came from; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: Okay. Whenever you saw whatever books you saw in the 2000s, they didn't have Post-It notes on them; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: Okay. When you looked through Exhibit 52 last night, 19 years after you left Mr. Epstein's employment, did you notice that there was handwriting in Exhibit 52?
MR. PAGLIUCA: That's not your handwriting; correct?
MR. PAGLIUCA: And there were dates in Exhibit 52 that were handwritten not by you; correct?
JUAN PATRICIO ALESSI: Absolutely.
MR. PAGLIUCA: And you can't recognize the handwriting that's contained in Exhibit 52; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: There were parts of Exhibit 52 that were circled or there were boxes put around different things; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: You didn't put those boxes or circles around anything; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: And you don't know who, if anybody, put those boxes or circles around the things in Exhibit 52; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: Now, you testified that from your observation and memory, the books that you saw in Palm Beach that came from New York, the type was much larger; correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And so that's different in what you're looking at in Exhibit 52; correct?
MR. PAGLIUCA: And as you sit here today, you can't tell us, for example, whether someone took a book from Mr. Epstein's house, took it to Kinko's, had it printed much smaller and shrunk down, took out pages, added pages, did whatever they did to it, and then rebound it. You can't -- you don't know whether that happened or not; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: You were not charged with -- you were not tasked or directed by anyone to maintain these books in Palm Beach? Do you understand my question, which may be a little complicated. It wasn't your job to take the books, put them in a folder, and put them in a drawer somewhere and keep them to record them for history, right?
JUAN PATRICIO ALESSI: Not that I remember.
MR. PAGLIUCA: Okay. In fact, every time there was a new book that came out, the old books were destroyed, as I understand it; is that right?
JUAN PATRICIO ALESSI: It was tossed in the garbage, yes.
MR. PAGLIUCA: Okay. Tossed in the garbage. And so there was no practice, as you understood it, to keep any of these books for the future; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: Also in Exhibit 52 there are different -- there are arrows that are pointed to some of the names. You don't need to look at them. I'm asking you about your memory, okay? When you looked at it last night, did you see some of the entries had arrows pointing to them, right?
MR. PAGLIUCA: And you didn't put those in there, right?
JUAN PATRICIO ALESSI: Absolutely, no.
MR. PAGLIUCA: And you don't know how they got there; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: The bottom line here, Mr. Alessi, you don't have any personal knowledge about first how or when Exhibit 52 was created; correct?
JUAN PATRICIO ALESSI: Correct. No knowledge.
MR. PAGLIUCA: You have no personal knowledge how or in what fashion Exhibit 52 has been kept for the last 19 years; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: You have no personal knowledge about whether or not someone took a book from Palm Beach, took out pages, photocopied it, put it back together, put those sticky notes on it, and made the markings on there; correct?
MS. COMEY: Objection, your Honor.
JUDGE NATHAN: Sustained.
MR. PAGLIUCA: I can break it down, your Honor.
JUDGE NATHAN: No, no, no. I assume the objection is asked and answered.
MS. COMEY: Correct, your Honor.
MR. PAGLIUCA: Without a grounds, I'm unaware of what the --
JUDGE NATHAN: He said he didn't understand the grounds.
MR. PAGLIUCA: That's all.
JUDGE NATHAN: Making a gesture as if we could read each other's minds. Fair enough. I'm sustaining. Asked and answered.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, as you sit here today, you have no personal knowledge about whether or not Exhibit 52 was ever touched by Mr. Epstein; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: And you have no personal knowledge about whether Exhibit 52 was ever touched by Ms. Maxwell; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: I think that's all, your Honor.
JUDGE NATHAN: Okay. Counsel, I'm going to reserve, as discussed, pending additional testimony.
MS. COMEY: Thank you, your Honor. May I resume direct?
JUDGE NATHAN: You may.
BY MS. COMEY:
MR. PAGLIUCA: Mr. Alessi, I want to talk some more about the massages that Jeffrey Epstein received at his Palm Beach house.
MR. PAGLIUCA: Did you see the people who came to the house to give Mr. Epstein massages during your employment?
MR. PAGLIUCA: About what percentage of those people were female?
JUAN PATRICIO ALESSI: I would say 98 percent they were female.
MR. PAGLIUCA: And when those females would come to Mr. Epstein's Palm Beach house to give him massages, which entry would they take -- would they use to get into the house?
JUAN PATRICIO ALESSI: If they were there for the first time, they will go through the front entrance, front door.
MR. PAGLIUCA: Go ahead.
JUAN PATRICIO ALESSI: And if they were repeat visits, they will come through the kitchen always.
MR. PAGLIUCA: And when a female came through the kitchen and was there to massage Jeffrey Epstein, where did they go from there based on your observations?
JUAN PATRICIO ALESSI: Based on my observation, they will stay in the kitchen, I will let Mr. Epstein know, Ms. Maxwell, that this person is here for a massage. And they will tell me, Okay. Set it up upstairs in his bathroom, Mr. Epstein's bathroom, or by the pool, in different locations of the house.
MR. PAGLIUCA: Where did Mr. Epstein receive the majority of his massages?
JUAN PATRICIO ALESSI: His bathroom.
MR. PAGLIUCA: And is that the bathroom attached to the master bedroom that we were talking about earlier?
MR. PAGLIUCA: What, if any, massage tables were in Jeffrey Epstein's Palm Beach house when you worked for him?
JUAN PATRICIO ALESSI: We have a massage table in every guest room, and Mr. Epstein room.
MR. PAGLIUCA: Where in Mr. Epstein's room was the massage table?
JUAN PATRICIO ALESSI: It was on his bathroom.
MR. PAGLIUCA: The same bathroom where you said he received the majority of his massages?
MR. PAGLIUCA: While you worked for Mr. Epstein, when someone called Mr. Epstein's Palm Beach house, how would employees keep track of any messages left for Mr. Epstein?
JUAN PATRICIO ALESSI: Most of the times I will answer the phone. And I will ask who the -- they want to talk to, and they will tell me, Is Mr. Epstein at the house? I will say, Yes. He's busy. You want to leave a message? And I will write it down in a -- in a message sheet. It was this booklet. I think they have three or four messages in each booklet, and they have a carbon copy.
MR. PAGLIUCA: Let me ask you some questions about that. Where would you write phone messages down for Mr. Epstein when you worked for him?
JUAN PATRICIO ALESSI: Usually at the kitchen desk.
MR. PAGLIUCA: And into what type of book? You mentioned a book.
JUAN PATRICIO ALESSI: It was a book with three or four pull-out pages. And it had a copy, carbon copy on each page.
MR. PAGLIUCA: So after you wrote down a message for Mr. Epstein, what did you do?
JUAN PATRICIO ALESSI: If it was a message for Mr. Epstein and if he was in the house, I will leave it in the -- his desk or in the kitchen table.
MR. PAGLIUCA: And once you --
JUDGE NATHAN: I'm sorry, can I just ask, can we collect 52?
MS. COMEY: Oh, yes, your Honor. May I approach?
JUDGE NATHAN: You may. Thank you.
MR. PAGLIUCA: Once you removed the message you had written for Mr. Epstein, what would be left in the book?
JUAN PATRICIO ALESSI: The carbon copy of the -- of the message.
MR. PAGLIUCA: Would it be an exact copy of the message you had written down?
MR. PAGLIUCA: And what was the practice when you worked for Mr. Epstein of how you would take messages?
JUAN PATRICIO ALESSI: I will answer the phone, I will listen who is calling. And if the message was for Mr. Epstein, and if he wants to take the call, he usually answer his calls, he has his number. And if he was there, he will answer his calls. If he was not there, I will take a message. Who's calling? I will ask for the telephone number, the name, and I will write it down in the -- in the -- in the message book.
MR. PAGLIUCA: And when would you write it in the message book?
JUAN PATRICIO ALESSI: Soon while I was talking on the phone.
MR. PAGLIUCA: As you're talking on the phone receiving the information, you were writing down that information into the book?
MR. PAGLIUCA: Other than you, who else took messages in message books for Mr. Epstein?
JUAN PATRICIO ALESSI: Occasionally, my wife and occasionally he will preliminary injunction Taylor.
MR. PAGLIUCA: When a message book was full, what would happen to it?
JUAN PATRICIO ALESSI: We have a closet, utility closet in my office, in my little office. And it was a bunch of books, new books, and the old ones were kept there.
MR. PAGLIUCA: Were the old books kept off of the staff room that we were talking about earlier?
MS. COMEY: Your Honor, I'd ask permission now to approach the witness with what's been marked for identification as Government Exhibit 2.
JUDGE NATHAN: Okay.
MS. COMEY: And I'll show it to counsel first.
JUDGE NATHAN: Thank you.
MR. PAGLIUCA: Mr. Alessi, I've just handed you what is marked for identification as Government Exhibit 2. Would you take a look at that and tell us if you recognize it?
JUAN PATRICIO ALESSI: Yes, I do.
MR. PAGLIUCA: What do you recognize it to be?
JUAN PATRICIO ALESSI: This was the booklet that it was -- that would take messages on it. These are the carbon copies.
MR. PAGLIUCA: Okay. Do you recognize any of the handwriting in those books?
MR. PAGLIUCA: Could you just -- without reading the content of any messages, just tell us whose handwriting you recognize?
JUAN PATRICIO ALESSI: The first one, the second one, the fourth one in the first page are mine.
MR. PAGLIUCA: On the first page, three of the messages are in your handwriting?
MR. PAGLIUCA: Let's go to the second page please.
JUAN PATRICIO ALESSI: The second page, I recognize the first one as being my wife. The second one is mine, the third one is mine, the four one is mine. In the -- in the next page, for some reason this messages were not taken or put --
MR. PAGLIUCA: My question for you, Mr. Alessi, is just whether you recognize the handwriting, okay?
JUAN PATRICIO ALESSI: Yes. Okay. The first one is my wife. The second one, I don't know, this is not my writing. The third one is my writing. The four one is not my writing. And the last one is my writing.
MR. PAGLIUCA: And what about the next page?
JUAN PATRICIO ALESSI: Next page is my writing, my writing, my writing, my writing.
MR. PAGLIUCA: And the next page?
JUAN PATRICIO ALESSI: This is my wife's writing, the next one is my writing, my wife's writing, and my writing.
MR. PAGLIUCA: How about the next page?
JUAN PATRICIO ALESSI: This is my wife's writing, my, my wife's writing, and my writing.
MR. PAGLIUCA: And the next page?
JUAN PATRICIO ALESSI: Mine, mine, this one I don't recognize it, and this one is blank.
MR. PAGLIUCA: The next page?
JUAN PATRICIO ALESSI: This one is mine. This one is -- I don't recognize this. This -- I don't recognize this, this, and the last one I don't recognize.
MR. PAGLIUCA: And how about the next page?
JUAN PATRICIO ALESSI: The first one, I don't recognize it. The second one is blank. The third I don't recognize it. The four one I don't recognize it.
MR. PAGLIUCA: And can you just flip through the rest of the pages and tell us if you recognize any of the handwriting in the rest. Just look at them silently and tell me, yes or no, whether you recognize any of the handwriting in the rest of the book?
MR. PAGLIUCA: Now, the portions of handwriting that you do recognize, Mr. Alessi --
MR. PAGLIUCA: -- are those messages that you took using the same process you just described for us?
JUAN PATRICIO ALESSI: Yes, I did.
MR. PAGLIUCA: So at the same time that you were taking information from a phone call for Mr. Epstein --
MR. PAGLIUCA: -- you were writing it down simultaneously?
JUAN PATRICIO ALESSI: Right.
MR. PAGLIUCA: And was that part of your job for Mr. Epstein?
JUAN PATRICIO ALESSI: Yes, it was.
MR. PAGLIUCA: Was that a part of the practice of running Mr. Epstein's Palm Beach residence?
JUAN PATRICIO ALESSI: Yes, it was.
MR. PAGLIUCA: Okay. You can set that aside and I'll come retrieve it. Thank you, Mr. Alessi.
MS. COMEY: One moment. I'm sorry. If I may have a moment, your Honor.
JUDGE NATHAN: You may.
(Counsel conferred)
MS. COMEY: May I come get the exhibit, your Honor?
JUDGE NATHAN: Yes. Thank you.
MS. COMEY: Your Honor, at this time the government would offer certain excerpts from Government Exhibit 2, which are marked for identification as Government Exhibits 2A through 2W. And we'd ask that other than 2A, they be received under seal.
MR. PAGLIUCA: Well, your Honor, can I ask a few questions about this exhibit with the witness?
JUDGE NATHAN: Yes.
MR. PAGLIUCA: Thank you. VOIR DIRE EXAMINATION
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, again, you left in -- at the end of 2002; is that right?
MR. PAGLIUCA: And if I'm looking at this exhibit correctly, the dated -- the date range goes beyond 2002. And you would have -- you would not have taken any message after 2002; correct?
MR. PAGLIUCA: And you would not have any personal knowledge about any of the information conveyed to whoever is operating anything down in this book after 2002; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And I don't believe you've identified any handwriting other than yours and your wife's handwriting in the beginning of this book; is that correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And there are a number of pages in this book that don't have dates reflected in the message pad. Do you know that or not?
JUAN PATRICIO ALESSI: Probably.
MR. PAGLIUCA: Okay. I'm actually old enough to have used message pad books in the past. And as I recall -- and you tell me if this is any different -- oftentimes there are five, six different message pads being used at any particular point in time. And someone may write a message in one pad, and then may go to another pad. And so there can be conflicting dates in different message pads at the same time. Was that the practice or not at Mr. Epstein's house?
MS. COMEY: Objection, your Honor.
JUDGE NATHAN: Grounds.
MS. COMEY: Form, your Honor.
JUDGE NATHAN: Overruled. You may answer.
MR. PAGLIUCA: Did you understand my question?
JUAN PATRICIO ALESSI: Yes, I did. No, it was only one pad, and it was usually situated at the kitchen -- kitchen desk.
MR. PAGLIUCA: And that would have been your desk; is that correct?
JUAN PATRICIO ALESSI: No, that was the kitchen -- the desk -- that was the desk for anybody to use.
MR. PAGLIUCA: I see. So one message pad at the kitchen desk, and anybody could answer the phone and write down a message; is that correct?
MR. PAGLIUCA: Okay. And then at some point, this message book was put into a closet, would that have been the practice?
MR. PAGLIUCA: And then you don't know what happened to it after that?
MR. PAGLIUCA: Your Honor, I have no objection to the messages that were identified by Mr. Alessi as to his handwriting or his wife's handwriting. I think those have been authenticated. I object to the remainder as being hearsay.
JUDGE NATHAN: Can you specify as to 2A through 2W?
MR. PAGLIUCA: Yes. I'll have to go back to that exhibit, your Honor.
JUDGE NATHAN: Okay. Maybe Ms. Comey can --
MR. PAGLIUCA: Sure. So 2A, your Honor, I don't object to. That's a cover page.
JUDGE NATHAN: Okay.
MR. PAGLIUCA: I think 2 -- I don't have a 2B in my book.
MS. COMEY: I apologize, your Honor. I don't think we're offering 2B, so we'll just do 2C through 2W.
MR. PAGLIUCA: Okay. So 2C, your Honor, I object to.
(Counsel conferred)
MR. PAGLIUCA: Ms. Moe has helped speed up the process. Ms. Moe. I'm sorry, Ms. Comey has helped speed up the process here, your Honor. As I understand it, none of these exhibits being offered were written by Mr. Alessi or his wife and have not been authenticated, and so I object to all of those exhibits.
JUDGE NATHAN: Ms. Comey, can I see the book?
MS. COMEY: Yes, your Honor. May I approach?
JUDGE NATHAN: Yes. Do you have anything further, Ms. Comey?
MS. COMEY: I'm sorry, your Honor?
JUDGE NATHAN: Do you have anything further?
MS. COMEY: I'm happy to argue at sidebar, if your Honor would like to hear argument.
JUDGE NATHAN: I was wondering if you had anything further with the witness.
MS. COMEY: No, your Honor.
JUDGE NATHAN: I'm overruling the objection to -- so you're not seeking 2A, just 2C --
MS. COMEY: I am seeking 2A, I'm not seeking 2B. Just C through W.
JUDGE NATHAN: All right. 2A on consent is admitted. And I am overruling the objection as to 2C through 2W based on the testimony of the witness.
MS. COMEY: Thank you, your Honor. These are sealed exhibits. I would ask that we please go through them with the jurors in their binders.
JUDGE NATHAN: So are they all sealed?
MS. COMEY: Yes, your Honor, I apologize. We are offering all of these under seal, consistent with prior applications.
JUDGE NATHAN: I presume 2A is not under seal.
MS. COMEY: No, 2A is not under seal. Thank you for clarifying, your Honor.
JUDGE NATHAN: 2C through 2W.
MS. COMEY: We are moving under seal.
JUDGE NATHAN: Under seal.
MS. COMEY: And it's both to protect witnesses who you've authorized to testify under pseudonym, and to protect personal information of third parties who have names, phone numbers, and contact information in the other exhibits.
JUDGE NATHAN: Do you have any objection to the sealing request?
MR. PAGLIUCA: No, the sealing I have no objection to, your Honor.
JUDGE NATHAN: All right. So 2A is admitted. And then 2C through 2W is admitted under seal for the reasons indicated by Ms. Comey. (Government's Exhibits 2A, 2C through 2W received in evidence)
MS. COMEY: Thank you, your Honor. Ms. Drescher, would you please pull up 2A and publish it for the jury. Thank you. I'm told that the remaining exhibits are in a different set of binders that are not with the jury right now. So we'll publish the remaining exhibits at a later time and I'll move on to another topic. So we can take this down.
JUDGE NATHAN: Okay.
BY MS. COMEY:
MS. COMEY: Mr. Alessi, what, if any, supplies were you instructed to buy for Mr. Epstein to use during his massages?
JUAN PATRICIO ALESSI: I don't recall buying any oils or perfumes or whatever for the massages because they were purchased by Ms. Maxwell.
MR. PAGLIUCA: Your Honor, I'm going to object to the narrative. I'm going to object to foundation.
JUDGE NATHAN: Okay.
MS. COMEY: If you didn't buy them, where did they come from?
MR. PAGLIUCA: Objection. Foundation, your Honor.
JUDGE NATHAN: Sustained.
MS. COMEY: Did Ms. Maxwell ever give you supplies for Mr. Epstein's massages?
MS. COMEY: What did she give you?
JUAN PATRICIO ALESSI: All types of exotic oils, most of where they were from other countries.
MS. COMEY: Where did you put them after Ms. Maxwell gave them to you?
JUAN PATRICIO ALESSI: They were put in the dress -- on top of the dresser of Mr. Epstein's bathroom.
MS. COMEY: Were you ever present in the massage room when Mr. Epstein received his massages?
JUAN PATRICIO ALESSI: Never.
MS. COMEY: Was the door ever open when Mr. Epstein received a massage in his master bedroom and bathroom?
JUAN PATRICIO ALESSI: Never.
MS. COMEY: Did you ever go into the massage room after Mr. Epstein's massage appointments?
JUAN PATRICIO ALESSI: Yes, usually I will go up --
MS. COMEY: Let me ask you a follow-up question. Why? Why did you go into Mr. Epstein's --
JUAN PATRICIO ALESSI: To clean up and retrieve the -- the massage table.
MS. COMEY: Where was the massage table kept?
JUAN PATRICIO ALESSI: In Mr. Epstein's closet.
MS. COMEY: Where was that closet?
JUAN PATRICIO ALESSI: In Mr. Epstein's bathroom.
MS. COMEY: What do you remember finding after -- when cleaning up after Mr. Epstein's massages in that room?
MR. PAGLIUCA: Object to the time frame, your Honor.
JUDGE NATHAN: Okay.
MS. COMEY: Between the periods of 1994 and 2002, what are some of the things you remember finding after Mr. Epstein's massages?
MR. PAGLIUCA: Your Honor, I still object to this time frame. It's too broad as framed.
JUDGE NATHAN: All right. Ms. Comey, you can ask if there's continuity or you can go through the dates.
BY MS. COMEY:
MS. COMEY: Mr. Alessi, are there some things that you remember seeing after just about every one of Mr. Epstein's massages?
JUAN PATRICIO ALESSI: Not after every one.
MS. COMEY: After the massages, would you clean up towels?
MS. COMEY: And would you clean up towels after all of his massages?
JUAN PATRICIO ALESSI: Not all of his massages. Not all of his massages, no.
MS. COMEY: About how many?
JUAN PATRICIO ALESSI: Depends who the massage therapist was.
MS. COMEY: Can you explain?
JUAN PATRICIO ALESSI: If the massage therapist was a repeat massage and they usually were people who always come back to the house, they will bring the towels for me to the laundry room.
MS. COMEY: And how about if it was a new person?
JUAN PATRICIO ALESSI: I will have to go out and bring the towels down.
MS. COMEY: What else did you do after the majority of Mr. Epstein's massages?
JUAN PATRICIO ALESSI: I will put the table away, I will put the -- take all the towels out, and I will clean the table, and I will put the oils away, higher up.
MS. COMEY: Are there any incidents that stand out in your mind where you found something unexpected when cleaning up after a massage?
MS. COMEY: Can you tell us about that?
MR. PAGLIUCA: Objection, your Honor. I think we need to be specific as to time frame here.
JUDGE NATHAN: Why don't you start with the first incident.
MS. COMEY: About when was the first time?
JUAN PATRICIO ALESSI: Excuse me?
MS. COMEY: Did there ever come a time where you found something other than towels and oils in Mr. Epstein's massage room?
MS. COMEY: About when was that?
JUAN PATRICIO ALESSI: 1995, '96, '97, '98.
MS. COMEY: What do you remember finding?
JUAN PATRICIO ALESSI: I remember finding a large dildo.
MS. COMEY: What did it look like?
JUAN PATRICIO ALESSI: It looked like a huge man's penis with two heads.
MS. COMEY: What did you do with the dildo?
JUAN PATRICIO ALESSI: The dildo, I use to put my gloves on, put them in the sink, run it under water, and put the dildo in Ms. Maxwell's closet in a basket.
MS. COMEY: I want to be clear here. Where did you find the dildo after the massage?
JUAN PATRICIO ALESSI: Usually at the table, at the massage table or at his bed.
MS. COMEY: And the massage table, where was that?
JUAN PATRICIO ALESSI: The massage table was -- it was left there in the room. It was in his -- in Mr. Epstein's bathroom.
MS. COMEY: If that's where you found it, why would you put it in Ms. Maxwell's bathroom?
JUAN PATRICIO ALESSI: That's the place what I was told -- it was kept all the time.
MS. COMEY: How do you know that?
JUAN PATRICIO ALESSI: Because I knew everything that happen in that house.
MS. COMEY: Can you describe the basket in Ms. Maxwell's bathroom where you put the dildo after Mr. Epstein's massages?
JUAN PATRICIO ALESSI: Yes. It was like a wicker basket, the size of a garbage can, pretty large, and it had a cover on it.
MS. COMEY: What else do you remember seeing in that basket?
JUAN PATRICIO ALESSI: I saw pornographic tapes, tapes, and I saw a custom, a black vinyl or leather black, I remember it was black, custom.
MS. COMEY: Do you mean costume?
JUAN PATRICIO ALESSI: Costume, sorry.
MS. COMEY: About how many times do you remember seeing that dildo after one of Mr. Epstein's massages?
JUAN PATRICIO ALESSI: At least four, five times.
MS. COMEY: Are there any other items that stand out in your mind that you saw after one of Mr. Epstein's massages?
JUAN PATRICIO ALESSI: Yes, it was also a massage, a large massager that you put them under your neck and it vibrates. And it also was a very large massager and it would vibrate the head. I think it was for the back.
(Continued on next page) LC2Qmax7 - corrected Alessi - Direct
BY MS. COMEY:
MS. COMEY: I want to break that down. Were there two different kinds of massagers?
MS. COMEY: What did the first one look like?
JUAN PATRICIO ALESSI: The first one looked like a pillow, the form of a pillow, and the other one looked like an arm with -- at the end of the arm, there was this rubber vibrator ball.
MS. COMEY: So the second one with the ball at the end of the long arm, did it vibrate?
MS. COMEY: About how often do you remember finding these massagers in Mr. Epstein's room after one of Mr. Epstein's massages?
JUAN PATRICIO ALESSI: Not too often.
MS. COMEY: About how many times?
JUAN PATRICIO ALESSI: Probably three, four times.
MS. COMEY: What did you do with the massagers after you found them?
JUAN PATRICIO ALESSI: Those massagers were kept at the top of his dresser with the rest of the oils and fragrances for the massage.
MS. COMEY: At the top of whose dresser?
JUAN PATRICIO ALESSI: Mr. Epstein's dresser.
MS. COMEY: In whose room?
JUAN PATRICIO ALESSI: Mr. Epstein's bathroom.
MS. COMEY: Attached to the master bedroom?
JUAN PATRICIO ALESSI: Yes, Mr. Epstein's bathroom. LC2Qmax7 - corrected Alessi - Direct
MS. COMEY: Forgive me. I don't think I asked. Where do you remember finding these massagers after Mr. Epstein's massages?
JUAN PATRICIO ALESSI: I would find by the sink or in the couch -- there was a couch in the bathroom -- or on top of the table or at his bed.
MS. COMEY: When you say the table, what do you mean?
JUAN PATRICIO ALESSI: The massage table.
MS. COMEY: What, if any, photographs do you remember seeing in Mr. Epstein's Palm Beach house while you worked for him?
JUAN PATRICIO ALESSI: It was a lot of photographs with important people from -- or Ms. Maxwell with Mr. Epstein. I remember seeing many important people photographed with them.
MS. COMEY: Who are some of the important people you remember seeing in photographs with Ms. Maximum and Mr. Epstein in the Palm Beach residence?
JUAN PATRICIO ALESSI: I think there was a photograph with Mr. Trump. Photographs with -- if I remember, I think there was a photograph with the Pope. I think there was a photograph with Fidel Castro.
MS. COMEY: What, if any, photographs do you remember seeing that contained females who were topless?
JUAN PATRICIO ALESSI: There were many photographs with females topless. Usually they were kept at Ms. Maxwell's desk.
MS. COMEY: Remind us where that desk was.
JUAN PATRICIO ALESSI: The desk was at the garden room behind the pantry.
MS. COMEY: Based on your observations of those photographs, where do they appear to have been taken? LC2Qmax7 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: They appear to have been taken --
MS. COMEY: Could you say that again, please? Where did they appear to have been taken?
JUAN PATRICIO ALESSI: By the pool side.
MS. COMEY: In the Palm Beach residence?
MS. COMEY: Last question on the photos, Mr. Alessi. Who, if anyone, do you remember using a camera to take pictures around Mr. Epstein's Palm Beach house during the years you worked for him?
JUAN PATRICIO ALESSI: I don't remember seeing anybody else but Ms. Maxwell.
MS. COMEY: The only person you remember seeing was who?
JUAN PATRICIO ALESSI: Ms. Maxwell.
MS. COMEY: I want to circle back to something I asked you at the beginning of your testimony. Could you clarify for us what year did you move from New Jersey to Florida?
JUAN PATRICIO ALESSI: I moved from New Jersey to Florida in October 1984.
MS. COMEY: 1984?
MS. COMEY: Thank you. About when did you stop working for Mr. Epstein?
JUAN PATRICIO ALESSI: I stopped working for him December, at the end of December of 2002.
MS. COMEY: Why did you stop working for Mr. Epstein then?
JUAN PATRICIO ALESSI: I was sick. I was ill. I had a lot of pain. I come up LC2Qmax7 - corrected Alessi - Direct with a disease that I was bleeding profusely.
MS. COMEY: Mr. Alessi, you don't need to go into the details, but suffice it to say --
JUAN PATRICIO ALESSI: I was sick and I was also very, very tired of the job.
MS. COMEY: What, if any, agreement were you required to sign when leaving Mr. Epstein's employment?
JUAN PATRICIO ALESSI: I sign an agreement of separation agreement with Mr. Epstein.
MS. COMEY: What was your understanding of what you were required do under that agreement?
JUAN PATRICIO ALESSI: I was required not to talk to anybody about his life or Ms. Maxwell. It was a stipulated for the two of them to be completely private from --
MS. COMEY: After you stopped working for Mr. Epstein, did you see Ms. Maxwell in person again between then and today?
MS. COMEY: After you stopped working for Mr. Epstein, how many times, if any, did you go back to Mr. Epstein's house?
JUAN PATRICIO ALESSI: I went back one time.
MS. COMEY: About when was that?
JUAN PATRICIO ALESSI: I think it was 2004.
MS. COMEY: Why did you go back to Mr. Epstein's house?
JUAN PATRICIO ALESSI: I was -- I was -- I will tell the truth. I was having a tremendous pressure in my marriage. I move out of my house, but somehow I got involved with another woman, not romantically LC2Qmax7 - corrected Alessi - Direct but involved, and she -- and we have -- I was having a lot of financial problems without a job. And I move out of my house, out of my -- my family, and I commit the greatest mistake I ever done in my life.
MS. COMEY: What did you do, Mr. Alessi?
JUAN PATRICIO ALESSI: I went back to the house, and I took some money out.
MS. COMEY: How did you get into the house?
JUAN PATRICIO ALESSI: Through a sliding door.
MS. COMEY: How could you get in?
JUAN PATRICIO ALESSI: Through the sliding door. It was open. It was easily opened.
MS. COMEY: Once you got into the house, where did you go?
JUAN PATRICIO ALESSI: I went to this -- I went directly to where this luggage bag was situated.
MS. COMEY: Where was that?
JUAN PATRICIO ALESSI: By Mr. Epstein's desk.
MS. COMEY: Which desk?
JUAN PATRICIO ALESSI: The lake room.
MS. COMEY: What did you do when you went to Mr. Epstein's desk in the lake room?
JUAN PATRICIO ALESSI: I took a band of a hundred dollar bills.
MS. COMEY: About how much money did you take?
JUAN PATRICIO ALESSI: I took -- it was $6,300.
MS. COMEY: After you broke into Mr. Epstein's home and stole that money, who, if anyone, contacted you? LC2Qmax7 - corrected Alessi - Direct
JUAN PATRICIO ALESSI: Only Mr. Epstein.
MS. COMEY: What happened after he contacted you?
JUAN PATRICIO ALESSI: He says, "We need to talk." And should I elaborate on that? And he --
MS. COMEY: After he said, "We need to talk," did you meet with Mr. Epstein?
JUAN PATRICIO ALESSI: Yes, I met with Mr. Epstein.
MS. COMEY: And then what happened?
JUAN PATRICIO ALESSI: We talk for about a half hour about family, talk about his mother. And he says --
MR. PAGLIUCA: Your Honor, I'm going to object to this as being hearsay. This is outside of the --
JUDGE NATHAN: Sustained.
MS. COMEY: Your Honor, I'm not offering this for the truth.
JUDGE NATHAN: Then just ask about what happened next.
MS. COMEY: Mr. Alessi, did Mr. Epstein confront you about stealing the money?
JUAN PATRICIO ALESSI: Yes, he did.
MS. COMEY: How did he do that?
JUAN PATRICIO ALESSI: He show me a picture.
MS. COMEY: What was the picture?
JUAN PATRICIO ALESSI: It was a very small picture, it was showing my face.
MS. COMEY: Where did it appear?
JUAN PATRICIO ALESSI: Inside the house. LC2Qmax7 - corrected Alessi - Direct
MS. COMEY: After he showed you the picture, what happened next?
JUAN PATRICIO ALESSI: We discuss it for an hour -- for awhile, and he -- he says to me, "John" --
MR. PAGLIUCA: Objection, your Honor. Hearsay.
JUDGE NATHAN: Sustained.
MS. COMEY: Did you come to an agreement with Mr. Epstein?
JUAN PATRICIO ALESSI: Yes, I did.
MS. COMEY: What was the agreement?
JUAN PATRICIO ALESSI: The agreement was that it was going to be considered as a loan from Mr. Epstein to me; that he will not press charges because of the kind of employee I had been, and the amount of care that was given --
MS. COMEY: Mr. Alessi, what did you have to do under the agreement? Under the agreement with Mr. Epstein, what did you have to do?
JUAN PATRICIO ALESSI: I have to pay it back.
MS. COMEY: Did you pay him the money back?
JUAN PATRICIO ALESSI: Absolutely.
MS. COMEY: How much money did you pay him back?
JUAN PATRICIO ALESSI: I pay it with a money order, and I have the receipt.
MS. COMEY: Was it the full amount?
JUAN PATRICIO ALESSI: $6,300.
MS. COMEY: Were you interviewed by the police about this incident?
JUAN PATRICIO ALESSI: Yes, by his request --
MS. COMEY: Just yes or no. Were you interviewed by the police?
JUAN PATRICIO ALESSI: Yes. LC2Qmax7 - corrected Alessi - Direct
MS. COMEY: Were you arrested or charged with a crime?
MS. COMEY: After that incident, did you ever see Mr. Epstein in person again?
JUAN PATRICIO ALESSI: Never.
MS. COMEY: May I have a moment, your Honor?
JUDGE NATHAN: You may.
(Pause)
MS. COMEY: Nothing further, your Honor.
JUDGE NATHAN: I'll leave it to you, Mr. Pagliuca. Do you want to start or do you want --
MR. PAGLIUCA: I think it would be better if we start tomorrow.
JUDGE NATHAN: That's fine. We only have ten minutes. Members of the jury, we'll send you home for the evening. Same schedule tomorrow. We'll start promptly at 9:30. Thank you for your diligence. We'll see you in the morning.
(Jury not present)
JUDGE NATHAN: Mr. Alessi, you may step down.
MR. PAGLIUCA: Your Honor, I don't recall whether the Court's practice is to admonish the witness when he's on cross-examination or not.
MS. COMEY: We have no intention of having any substantive communications with the witness other than LC2Qmax7 - corrected Alessi - Direct logistics to get him to where he's staying.
JUDGE NATHAN: I usually just make sure everybody is on the same page, and we are. Thank you. Everyone may be seated.
(Witness not present)
JUDGE NATHAN: Are there matters to take up?
MR. PAGLIUCA: Not from the defense, your Honor.
MS. COMEY: None from the government, your Honor.
JUDGE NATHAN: So we will meet at 8:45. Please confer on any anticipated issues so that we can address them before we have the jury. And I'll see you in the morning. Thank you.
(Adjourned to December 3, 2021 at 8:45 a.m.)