Juan Patricio Alessi — Cross (Continued)
961 linesJUDGE NATHAN: Good morning, members of the jury. Right on time, as always. Thank you very much. We will begin with the cross examination of Mr. Alessi. Mr. Alessi, I remind you that you are under oath. Mr. Pagliuca, you may proceed.
MR. PAGLIUCA: Thank you, your Honor. JUAN PATRICIO ALESSI,
CROSS-EXAMINATION BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, let me start with, on direct examination, you testified that although your name is Juan, Mr. Epstein and Ms. Maxwell called you John; correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Now, isn't it true that during that time period, everyone called you John; right?
JUAN PATRICIO ALESSI: Yeah, basically. Yes.
MR. PAGLIUCA: And you preferred to be called John; right?
MR. PAGLIUCA: Okay. And, in fact, during that time when people would say to you, you're Juan, you would say, no, I'm not called Juan, I'm called John; right?
JUAN PATRICIO ALESSI: If they call me Juan, yes, I answered to Juan.
MR. PAGLIUCA: And John?
JUAN PATRICIO ALESSI: And John.
MR. PAGLIUCA: So there was no disrespect by anyone calling you John; correct?
JUAN PATRICIO ALESSI: No. John is the translation for Juan.
MR. PAGLIUCA: And Ms. Maxwell also speaks Spanish and would converse with you in Spanish, as well; correct?
JUAN PATRICIO ALESSI: Yes, she does.
MR. PAGLIUCA: So if she's speaking with you in Spanish, she would call you Juan; if she's speaking with you in English, she would call you John; correct?
JUAN PATRICIO ALESSI: Correct.
MR. PAGLIUCA: And absolutely no disrespect intended to you by calling you John or Juan; right?
MR. PAGLIUCA: And you didn't take it as a sign of disrespect; correct?
JUAN PATRICIO ALESSI: Absolutely not.
MR. PAGLIUCA: Mr. Alessi, yesterday at the end of your testimony, you told the jury that after you quit working for Mr. Epstein in 2002, you were having money problems. Do you remember that?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And you said that you made the biggest mistake of your life, that you went into Jeffrey Epstein's house one time and took a bundle of $100 bills that amounted to $6,300. Do you remember that testimony?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And then you looked at the jury and you said, I will tell the truth. Do you remember that, telling the jury that yesterday?
MR. PAGLIUCA: But you didn't tell the jury the truth yesterday, did you, Mr. Alessi?
JUAN PATRICIO ALESSI: I did tell the truth.
MR. PAGLIUCA: Well, isn't it true, isn't it true that you went into Mr. Epstein's house two times in 2003 and stole money twice from Mr. Epstein?
JUAN PATRICIO ALESSI: No, it was one time.
MR. PAGLIUCA: Isn't it true that the first time was in August or September of 2003 and you went in to steal a gun, but you couldn't find a gun?
JUAN PATRICIO ALESSI: That's not true.
MR. PAGLIUCA: Isn't it true that the second time that you went into Mr. Epstein's house -- well, when you couldn't find the gun, isn't it true that you looked around and took $1,900 in $100 bills from a white envelope, isn't that true?
JUAN PATRICIO ALESSI: That's not true.
MR. PAGLIUCA: Didn't you go back on October 5th, 2003 and steal $5,600 from Mr. Epstein?
JUAN PATRICIO ALESSI: No, that's not true.
MR. PAGLIUCA: And isn't it true that you stole the money to pay for your girlfriend's immigration papers?
JUAN PATRICIO ALESSI: It was not my girlfriend, sir.
MR. PAGLIUCA: Mr. Alessi, I'd like you to take a look -- if we can display for Mr. Alessi, please, 3504-6 -- 3501-080-001, page 11.
MS. COMEY: Your Honor, Ms. Drescher has explained the issue to me. 3501 is the series for nontestifying witnesses, so we did not print out copies of those. If I may ask the defense for a copy of this, please.
MR. PAGLIUCA: Certainly, your Honor.
MS. COMEY: Thank you.
MR. PAGLIUCA: Mr. Alessi, do you have that exhibit in front of you?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: I'd like you to go to page 11 of that exhibit.
JUAN PATRICIO ALESSI: I have only page 11 in front of me.
MR. PAGLIUCA: Do you recall that you were contacted by Officer Michael Dawson on October 15th, 2003?
JUAN PATRICIO ALESSI: I was not contacted by Michael Dawson. I went to the police on my own.
MR. PAGLIUCA: Do you remember when you went to the police, Mr. Dawson asked you questions about going into Mr. Epstein's house and you answered those questions?
JUAN PATRICIO ALESSI: I don't think he asked me questions. I did a statement to him of what I remembered.
MR. PAGLIUCA: And what you told him in 2003, first, was that you went in to steal a gun; correct?
JUAN PATRICIO ALESSI: I don't recall that.
MR. PAGLIUCA: You don't recall or you didn't say that?
JUAN PATRICIO ALESSI: I didn't recall.
MR. PAGLIUCA: So you might have said it, but now you just don't recall. Is that what you're saying?
MR. PAGLIUCA: And do you remember telling him that you couldn't find the gun?
MR. PAGLIUCA: Do you remember telling him that you went into Mr. Epstein's house twice, and the first time when you couldn't find the gun, you went into Mr. Epstein's briefcase and you stole $1,900 in $100 bills in a white envelope? Do you remember telling him that?
JUAN PATRICIO ALESSI: No, that's not true.
MR. PAGLIUCA: Do you remember telling him that or not?
MR. PAGLIUCA: Do you remember telling him that you went back on October 5th, 2003 at 5:00 a.m. in order to once again steal money?
JUAN PATRICIO ALESSI: I recall making a statement to him in request from Mr. Epstein that I should go to the police department and make that statement of what happened and why the reasons that I did. And I am trying to tell you that I did one time and that's what I think I told the police what happened.
MR. PAGLIUCA: My question simply, sir, is do you remember telling him that when you went back to the house on October 5th, 2003 at 5:00 a.m., that you went through the sliding glass door, opened Mr. Epstein's briefcase, and stole $5,600 in $100 bills? Do you remember telling him that?
JUAN PATRICIO ALESSI: I don't remember.
MR. PAGLIUCA: Do you remember telling him that you stole the money to pay for the girlfriend's immigration papers?
JUAN PATRICIO ALESSI: First of all, it was not my girlfriend. She was a friend. She came to live with me in my apartment, but we were not involved, and I was trying to help her with that.
MR. PAGLIUCA: So is it true that you stole the money for the immigration papers?
JUAN PATRICIO ALESSI: It's true that I stole $6,300 that I paid Mr. Epstein back.
MR. PAGLIUCA: That wasn't my question, sir. Is it true that you stole the money to pay for the immigration papers? Yes or no.
MR. PAGLIUCA: Now, you also testified under oath about stealing the money from Mr. Epstein. Do you recall that? Not before today, do you recall testifying previously about stealing the money from Mr. Epstein?
MR. PAGLIUCA: And do you recall testifying under oath, on September 8th, 2009, that you went to the house and got some money? Do you remember testifying to that under oath?
JUAN PATRICIO ALESSI: No, I don't remember that.
MR. PAGLIUCA: If we can show the witness, please, 3504-022. On this particular document, it's page 14. We're going to be looking at deposition transcript pages 133 through 135.
JUAN PATRICIO ALESSI: I cannot read this page.
MR. PAGLIUCA: It will come up for you on the screen, Mr. Alessi.
JUAN PATRICIO ALESSI: Is that my screen, because --
JUDGE NATHAN: They'll make it bigger, Mr. Alessi.
MR. PAGLIUCA: If we can go in this document, which is going to be page 14 of the document, and the page number I'd like to start with, the deposition page number is 133. If we can blow that up for the witness, please.
BY MR. PAGLIUCA:
MR. PAGLIUCA: At line 12, Mr. Alessi, do you recall giving the following testimony --
JUDGE NATHAN: I can't hear you.
MR. PAGLIUCA: I'm sorry, your Honor.
MR. PAGLIUCA: Do you recall giving the following testimony, Mr. Alessi: "A. That incident is, I went to the house and I got some money. "Q. What time of day did you go to the house? "A. Night. "Q. Was anybody home? "A. No. "Q. Where did you get the money? "A. Out of his bag. "Q. Out of his -- "A. Bag. "Q. Bag, briefcase, bag? "A. Briefcase. "Q. Briefcase? "A. Yeah." Did you give that testimony, Mr. Alessi?
JUAN PATRICIO ALESSI: I think I did.
MR. PAGLIUCA: Then at the bottom of page 134 on the same page, 14, line 25. "Q. Now, is that the only time that you took money out?" And we go to page 135, top of the page. "A. No." Do you see that, Mr. Alessi?
MR. PAGLIUCA: That was your testimony under oath on September 8th, 2009, that you went back more than once to steal money from Mr. Epstein; correct?
JUAN PATRICIO ALESSI: I guess it was. "Q. Out of his briefcase? "A. It was twice."
MR. PAGLIUCA: Do you see that testimony, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, I see it.
MR. PAGLIUCA: That's what you testified to under oath, September 8th, 2009; correct?
JUAN PATRICIO ALESSI: I guess I did. "Q. When was the other time? "A. Couple weeks before. "Q. What time of day was that? "A. At night. "Q. How much did you take out the first time? "A. It was a total of $6,300. "Q. That's for both times? "A. Yeah. "Q. Can you break them down? "A. I think one time was $1,500. Another time was the rest."
MR. PAGLIUCA: That was your testimony under oath, correct, Mr. Alessi?
JUAN PATRICIO ALESSI: Guess so.
MR. PAGLIUCA: Your Honor, I move for the admission of this testimony under Rule 801.
MS. COMEY: It's been read in already.
JUDGE NATHAN: It's read in the record and admitted.
MR. PAGLIUCA: Thank you.
MR. PAGLIUCA: Now, Mr. Alessi, yesterday you told the jury that you stole the money because you were having --
JUDGE NATHAN: Pull up the microphone, please.
MR. PAGLIUCA: -- you stole the money because you were having financial problems. Do you remember that testimony?
MR. PAGLIUCA: Isn't it true that in 2003 when you stole the money, you owned a number of rental properties in Florida?
MR. PAGLIUCA: You owned 1515, number 1902 West Palm Beach. Do you recall that?
MR. PAGLIUCA: And that was a rental property that you purchased in 2001 for $105,000 for which Mr. Epstein gave you $20,000 for the down payment; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: You also owned the apartment next door, 1515 South Flagler Drive, number 1901, which is another property; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And you bought that in 2003 for $159,000; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: You also owned a multifamily residential property at Yarmouth Drive in Wellington, Florida that you bought in 2001 for a total of $310,000; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And when you left Mr. Epstein's employment in 2002, you were given a severance package of $50,000 for you and your wife; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: So when you went into Mr. Epstein's house twice in 2003 and stole at least $6,300, you owned properties valued at over a million dollars; correct?
JUAN PATRICIO ALESSI: I don't think it's correct.
MR. PAGLIUCA: Well --
JUAN PATRICIO ALESSI: Because I sold the properties at Tower 1515 in order to buy the property for the multifamily.
MR. PAGLIUCA: Let's look the 3504-022, going to be deposition page 145. Let's start at line 19. Do you have that in front of you, Mr. Alessi?
JUAN PATRICIO ALESSI: I cannot read.
MR. PAGLIUCA: 3500, page 17.
JUAN PATRICIO ALESSI: I cannot read it.
JUDGE NATHAN: They'll make it bigger in a moment. I'm sorry. Can you give me the cite again?
MR. PAGLIUCA: It's 3504-022, page 17 of 35, deposition page 145, line 19.
MR. PAGLIUCA: Do you have that, Mr. Alessi?
MR. PAGLIUCA: You were asked the question: "Q. Now, do you recall in December of 1997, you and your wife bought an apartment at 1902 115 South Flagler Drive; right?"
JUAN PATRICIO ALESSI: Yes. "Q. Purchase price was $105,000?" You answered: "A. Yes, sir." Do you see that? A. Yes, sir.
MR. PAGLIUCA: Then on the next page, 146, you were asked: "Q. Now, do you recall that in November, you and your wife bought apartment 1901?" Do you see that?
JUAN PATRICIO ALESSI: Yes. "Q. For a purchase price of $159,000?"
MR. PAGLIUCA: Do you see that?
MR. PAGLIUCA: And if we go down to line 18, after buying the lot, yes, we bought the lot years, years back. Then it says: "Q. Now in October 2001, do you remember buying a multifamily residential property at Yarmouth Drive in Wellington?" Answer at line 23: "A. I still have it." Do you see that?
MR. PAGLIUCA: Then the next question, line 24: "Q. Do you remember the purchase price being $310,000?" Do you see that?
MR. PAGLIUCA: And then if we go down --
JUDGE NATHAN: Mr. Alessi, could you reposition the mic as you're looking. Thank you.
MR. PAGLIUCA: We go down to page 147, which is in the left side there, if we go to line 9. "Q. Now, do you recall that in September of 2002 --
MR. PAGLIUCA: This is right at the same time that you were breaking into Mr. -- shortly, a year, a year before you broke into Mr. Epstein's house, September of 2002, you and your wife purchased a multifamily residential property at Sequoia Drive in West Palm Beach, that's correct, and the purchase price was $590,000. Do you remember that?
MS. COMEY: Your Honor, I'm going to object to this because I don't think any of this is inconsistent.
JUDGE NATHAN: Sustained. The answer earlier was that he had sold one of these properties before you add up to the amount you said, so it's not inconsistent. So I'm sustaining the objection.
MR. PAGLIUCA: I'm getting there, your Honor, because I don't think there was a sale of the property.
JUDGE NATHAN: You can get to that, but otherwise, so far, it's consistent.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, you owned all of these properties in 2003; correct?
MR. PAGLIUCA: With you one didn't you own?
JUAN PATRICIO ALESSI: I owned the house that I built in Royal Palm Beach and I sold the apartments at Tower 1515. And in all my life, I work very hard and save a lot of money, including the time that I work for Mr. Epstein. I did a lot of savings, sir.
MR. PAGLIUCA: The point is, Mr. Alessi, and you agree with me that you weren't poor when you went into Mr. Epstein's house in 2003 and stole the money; correct?
JUAN PATRICIO ALESSI: I was not poor, but it was -- the money was sequestered because I was going through a divorce and I had no access to the money.
MR. PAGLIUCA: Okay.
JUAN PATRICIO ALESSI: Or to sell the properties.
MR. PAGLIUCA: Now, Mr. Alessi, I'm going to turn to some testimony that you gave yesterday about Jane. Do you recall that?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Isn't it true -- well, yesterday you testified that you met Jane in 1994. Do you recall that testimony?
JUAN PATRICIO ALESSI: I recall the testimony, but I'm not sure if it was '94, '95, '93, '96. I cannot recall exactly the same date.
MR. PAGLIUCA: Isn't it true that you met Jane in 1998 or 2000?
JUAN PATRICIO ALESSI: Can you repeat the question.
MR. PAGLIUCA: Isn't it true that you met Jane in 1998 or 2000?
JUAN PATRICIO ALESSI: No, that's not true.
MR. PAGLIUCA: If we can show the witness 3504-030, page 20, deposition page 79, line 18.
JUDGE NATHAN: Just caution about not stating the real name of Jane.
MR. PAGLIUCA: I understand, your Honor. I completely blacked it out on all of my copies.
(Continued on next page)
JUDGE NATHAN: For the witness, too.
MR. PAGLIUCA: Understood.
JUDGE NATHAN: Thank you. What line am I looking at?
MR. PAGLIUCA: That's a good question, your Honor. I'm having trouble seeing it here. We're at page 19 and 20 of 3504-030.
JUDGE NATHAN: That's page 79 of the deposition?
MR. PAGLIUCA: Yes, your Honor, that's correct.
JUDGE NATHAN: That's the single page on the screen.
BY MR. PAGLIUCA:
MR. PAGLIUCA: If we go down to line 20, do you remember this question, Mr. Alessi: Do you know the year Nadia met --
JUAN PATRICIO ALESSI: You mentioned the name, sir.
MR. PAGLIUCA: I'm sorry.
MR. PAGLIUCA: I move to strike that, your Honor. I withdraw it.
JUDGE NATHAN: It will be struck. You are admonished to carefully abide by my ruling.
MS. COMEY: Your Honor, may we approach?
JUDGE NATHAN: You may.
(Continued on next page)
(At the sidebar)
MR. PAGLIUCA: I apologize, your Honor. It was completely unintentional. I apologize.
MS. COMEY: Your Honor, given that Mr. Pagliuca represented that he had prepared to cross-examine this witness on this testimony, I think we need to have a plan going forward for how to make sure this does not happen again because, clearly, Mr. Pagliuca had not prepared enough.
JUDGE NATHAN: The witness herself did the same thing. It happens. My perception was that it was an accident.
MR. PAGLIUCA: Completely.
JUDGE NATHAN: I agree, we need a plan, but --
MS. COMEY: Your Honor, I would propose that to the extent Mr. Pagliuca intends to use some sort of prior inconsistent statement, that he can discuss it with me before reading it into the record, and we can confer about how he should read it.
MR. PAGLIUCA: I understand how to read, your Honor. It won't happen again.
JUDGE NATHAN: All right. It won't happen again.
MR. PAGLIUCA: It will not.
JUDGE NATHAN: If it happens again, we're going to need a different approach.
MR. PAGLIUCA: I understand. It will not happen again.
(In open court)
MR. PAGLIUCA: May I resume, your Honor?
JUDGE NATHAN: Just a moment.
(Pause)
JUDGE NATHAN: You may.
MR. PAGLIUCA: Thank you.
BY MR. PAGLIUCA:
MR. PAGLIUCA: You were asked the question: "Q. Do you know what year Jane met Jeffrey Epstein and Glen Maxwell?" And your answer was: "I would say we left it in 2002. I would say '99 or 2000 maybe." Do you recall that question and answer?
JUAN PATRICIO ALESSI: I don't recall the question, but I imagine I made the mistake between the two girls that I met, Jane and I made -- I confuse the first girl with the second girl. The first girl that I met, underage, was Jane. And I think it was 1994, sir. The other girl that I met, it was 2002 or 2001, I'm not sure.
MR. PAGLIUCA: Okay. Well, let's continue, Mr. Alessi, because the questioner was Mr. Edwards. Do you recall Mr. Edwards being the person who questioned you?
JUAN PATRICIO ALESSI: It was one of the lawyers.
JUDGE NATHAN: Microphone.
MR. PAGLIUCA: The person who was questioning you in this deposition was Virginia Roberts' lawyer, Brad Edwards. Do you recall that?
JUAN PATRICIO ALESSI: I don't recall him, but it was one of the lawyers, he asked me questions.
MR. PAGLIUCA: And you were in Fort Lauderdale at an office when you were answering these questions?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Okay. And Mr. Edwards then says to you at line 22 --
JUDGE NATHAN: And I will caution --
MR. PAGLIUCA: Right.
MR. PAGLIUCA: -- "If Jane believes that the year was 1994 or 1995" -- and then you say, no. Do you see that?
JUAN PATRICIO ALESSI: Again, I think in this testimony, I mistake the two, I confused the two girls.
MR. PAGLIUCA: I understand that's what you're saying today, Mr. Alessi --
MR. PAGLIUCA: -- but in 2016, when you testified, you were specifically directed to the name Jane and what Jane, according to this lawyer, believed, and you answered no. Do you see that?
JUAN PATRICIO ALESSI: Could have been.
MR. PAGLIUCA: Okay. And then the question from Mr. Edwards is: You don't remember that way? And then you say, at the next page, page 80, lines 1 and 2, you say: That is not true. I don't think it was that early. Do you remember giving that testimony under oath?
JUAN PATRICIO ALESSI: I don't remember, but I could have been confused again.
MR. PAGLIUCA: And then the question is: Okay, but you remember going and picking her up from the school? And the answer is: Yes. Correct?
MR. PAGLIUCA: And then you're asked another question, and then you say: I would -- I would say it's 1999, '98 maybe. Correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And then you're asked some specific questions about Jane and whether Jane is driving or not?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And then you say: I never saw Jane driving a car. Right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And those were all questions and answers about Jane, correct?
JUAN PATRICIO ALESSI: I'm not sure those are all the questions about Jane.
MR. PAGLIUCA: Yesterday you also testified that Jane would go to see Epstein without her mother. Do you recall that?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: If we can go to 3304-22, which is a different exhibit. 3504-22. Your Honor, I neglected to move for the admission of that prior inconsistent testimony. I will do so now.
JUDGE NATHAN: It was read into the record and admitted.
MR. PAGLIUCA: Thank you.
JUDGE NATHAN: If it's read into the record, it's admitted.
MR. PAGLIUCA: No need to move for admission?
JUDGE NATHAN: Correct.
MR. PAGLIUCA: Thank you.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, we're at 3504-22. Do you see that?
JUAN PATRICIO ALESSI: Yes. Not legible.
JUDGE NATHAN: Needs to be bigger, please.
MR. PAGLIUCA: Can we enlarge, please.
MR. PAGLIUCA: At page 26 of this exhibit, deposition page 183, lines 9 through 13 -- are you there, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MS. COMEY: Your Honor, before Mr. Pagliuca reads this into the record, I don't believe it's inconsistent with any testimony that's been given.
JUDGE NATHAN: I need to see earlier portions of the transcript.
MR. PAGLIUCA: Your Honor, are you talking about yesterday's testimony?
JUDGE NATHAN: Well, I think it's two things. It's yesterday's testimony -- and give me the line. And then I need to have context for who is being spoken about in the depo.
MR. PAGLIUCA: Sure. Yesterday's testimony, we're talking about page 835, 836, 837, which was where this was referenced. And for purposes of this transcript, I think if the Court starts at line 6, you will get the context of the question. If you go to the page before, 182, you start at line 15, that will give you the complete context. If we can blow up for the Court and the witness 182, beginning at line 15.
JUDGE NATHAN: Just a minute.
(Pause)
JUDGE NATHAN: Transcript 835, line 19?
MR. PAGLIUCA: 19 through 20; 836, lines 1 and 2; and 836, I think, line 5.
JUDGE NATHAN: Can you go back to the line in the deposition, please? Now I have 182.
MR. PAGLIUCA: Yes, your Honor.
MS. COMEY: Your Honor, I just want to make sure that your Honor has also reviewed page 835 --
JUDGE NATHAN: Yes, I have the testimony in mind. Now I need to see what you're contending is inconsistent.
MR. PAGLIUCA: Right. I'm at lines 10 through 12, your Honor.
JUDGE NATHAN: Of what page? I have page 182.
MR. PAGLIUCA: It's 183, lines 9 through 12. 182 is for context.
(Pause)
JUDGE NATHAN: Sustained.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, do you recall that the lawyer for Jane, a lawyer for Jane, contacted you in July of 2020, two thousand twenty?
MR. PAGLIUCA: Do you recall that in July of 2020, you authored a declaration, which is a sworn statement, under oath, declaration of Juan P. Alessi?
JUAN PATRICIO ALESSI: I don't know. I don't know what you talking about. At 2020?
MR. PAGLIUCA: Yes.
MR. PAGLIUCA: Can we show the witness Defendant's Exhibit JA-1, please.
MS. COMEY: Your Honor, I do not have a copy of this.
JUDGE NATHAN: You will be provided one before we show the witness.
MS. COMEY: Thank you, your Honor.
MR. PAGLIUCA: Does the witness have JA-1?
JUDGE NATHAN: Not yet. Ms. Comey, are you ready?
MS. COMEY: Yes, thank you, your Honor.
JUDGE NATHAN: Go ahead.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Do you see JA-1, Mr. Alessi?
JUDGE NATHAN: Mr. Alessi, could you reposition the mic, please. Thank you.
JUAN PATRICIO ALESSI: Yes, I am reading. I can't remember where this was done. Where?
MR. PAGLIUCA: Mr. Alessi, I'm just going to ask you a couple of questions. First, is that your signature?
JUAN PATRICIO ALESSI: Yes, it is.
MR. PAGLIUCA: It's dated July 9, 2020; is that correct?
JUAN PATRICIO ALESSI: That's correct.
MS. COMEY: Your Honor, before this is read, I would make the same objection. I don't believe this is inconsistent.
JUDGE NATHAN: Which paragraph are you focused on?
MR. PAGLIUCA: Your Honor, I was going to move for the introduction of the entire exhibit.
JUDGE NATHAN: So paragraph 1, sustained. Paragraph 2, sustained. You want to focus me?
MR. PAGLIUCA: Paragraphs 3 and 4, your Honor, are the inconsistencies.
JUDGE NATHAN: Okay. Just a moment.
(Pause)
JUDGE NATHAN: Sustained.
MR. PAGLIUCA: May we be heard on this, your Honor?
JUDGE NATHAN: Yes.
(Continued on next page)
(At the sidebar)
JUDGE NATHAN: Let's just set the stage. The testimony yesterday said "multiple occasions with her mother, some occasions without the mother; in those instances, he would pick her up and drive her."
MR. PAGLIUCA: Okay.
JUDGE NATHAN: You agree that is the testimony?
MR. PAGLIUCA: Generally, yes. On line 9, we have: "I personally observed Jane along with her mother on three occasions, not multiple occasions."
JUDGE NATHAN: "Three" is not "multiple"?
MR. PAGLIUCA: Not in my view, your Honor. It is inconsistent with "multiple." At Mr. Epstein's --
JUDGE NATHAN: I don't understand --
MR. PAGLIUCA: It is more than one.
JUDGE NATHAN: So is "multiple."
MR. PAGLIUCA: Yes, I understand.
JUDGE NATHAN: I mean, unless we're speaking a different language.
MR. PAGLIUCA: We may be, but this is quantifying the number. It's not multiple, it's three. "At Mr. Epstein's home in Palm Beach. I don't recall the year," which is also inconsistent with his testimony yesterday.
JUDGE NATHAN: Well, he said he doesn't recall exactly the year, and you impeached on the earlier one.
MR. PAGLIUCA: Yesterday, he said it was 1994, and this is impeaching that testimony as well.
MS. COMEY: Your Honor, if I may on that point, I believe the testimony was 1994 or 1995 yesterday, and then today on cross-examination I think he expanded it to between 1993 and 1996. I think it's clear in the record that he's not sure exactly what year it was.
JUDGE NATHAN: Yes, I agree with that.
MR. PAGLIUCA: Respectfully, I disagree, your Honor. "During those occasions, I observed Mr. Epstein and Ms. Maxwell and her mother talking." We're limiting it to those occasions, and it's not expanding on any of those occasions. Yesterday he testified to multiple occasions, more than three, many more than three. Paragraph 4: "In addition to seeing Jane at Mr. Epstein's home, I was also instructed on one occasion by Mr. Epstein to pick Ms. Jane up from what I presume was her home address in West Palm Beach." He discussed yesterday more than one occasion being instructed to pick her up at West Palm Beach.
JUDGE NATHAN: You can ask him if he recalls saying one occasion.
MS. COMEY: Your Honor, if I may, the fact that he remembers one occasion does not preclude that there were other occasions. He's just saying in the declaration --
JUDGE NATHAN: I agree, and I presume that will be the testimony.
MS. COMEY: But then, your Honor, it's not inconsistent. I just don't see the basis to put this in front of the jury if it's not inconsistent on its face. There's just not a basis.
JUDGE NATHAN: Well, on this one, I think he said multiple occasions, this says one. He can explain the difference, and the jury will decide. So I'll permit you to ask about that one.
MR. PAGLIUCA: Thank you.
(Continued on next page)
(In open court)
MR. PAGLIUCA: Thank you, your Honor.
JUDGE NATHAN: Okay.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, do you recall in 2020, in this declaration, saying, I was also instructed on one occasion by Mr. Epstein to pick Ms. Jane up from what I presumed was her home address in West Palm Beach, Florida and drive her to Mr. Epstein's home? Do you recall that statement in your under-oath declaration?
JUAN PATRICIO ALESSI: First of all, I would like to know where this declaration was taken place. I think this -- if I remember correctly, this was sent to me by mail. By somebody. I don't recall making this declaration with anybody.
MR. PAGLIUCA: Well, Mr. Alessi, we've established that that's your signature on July 9 --
JUAN PATRICIO ALESSI: Yeah, it is my signature, but I don't recall being in a place and declare this.
MR. PAGLIUCA: Okay. Are you denying making the declaration?
MS. COMEY: Your Honor, I think there may be some confusion about terminology here.
JUDGE NATHAN: Yes. I think the question is not, were you deposed, but, did you sign this statement?
JUAN PATRICIO ALESSI: Yes. It definitely is my signature.
MR. PAGLIUCA: And is that what you said, you were instructed by Mr. Epstein on one occasion to pick Ms. Jane up from what I presume was her home address in West Palm Beach, Florida and drive her to Mr. Epstein's house, is that correct?
JUAN PATRICIO ALESSI: That's correct. It might have been more than one occasion, too.
MR. PAGLIUCA: That's not what you said in this declaration, correct?
JUAN PATRICIO ALESSI: No, in this declaration it says once.
MR. PAGLIUCA: Right. Mr. Alessi, I want to talk a little bit now about the renovations to the Palm Beach house, okay?
MR. PAGLIUCA: If we can show the witness what's been admitted as Government Exhibit 297, please.
MS. COMEY: Your Honor, could this be published to the parties and the public as well?
JUDGE NATHAN: It's admitted, so GX 297 may be published.
MR. PAGLIUCA: Thank you, your Honor.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, you talked about this exhibit yesterday. Do you recall that?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: First, I would like to zoom in on the lower right corner of the exhibit, and highlight that, please.
MR. PAGLIUCA: Do you see the date here 4/4/94, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: We can zoom out.
MR. PAGLIUCA: These are architectural drawings of the El Brillo Way house, correct?
MR. PAGLIUCA: If we can go to Government Exhibit 298, and also zoom in on the lower right corner.
MR. PAGLIUCA: The date is a little hard to read here, but do you see that there's a 24, and then a 94 is there as well, Mr. Alessi?
MR. PAGLIUCA: If we can go to Government Exhibit 299, and zoom in on the same section.
MR. PAGLIUCA: We have a date 3/23/94. Do you see that, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: We can zoom out. Let's go back to 297, please. We can zoom in, please, on the writing, the small writing, that you can't read, through the lower right quarter of this document. Right there. Go ahead, zoom in there.
MR. PAGLIUCA: These are instructions for the contractor as part of the renovation. Do you see that, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: We're installing new doors and frames, in this note. Do you see that?
MR. PAGLIUCA: And then we're giving instructions to the subcontractor here as well. Do you see that? In item 6.
JUAN PATRICIO ALESSI: AC subcontractor shall... Yes, sir, I see it.
MR. PAGLIUCA: We can take that down and go back to the notes to the left of that, please, and blow those up.
MR. PAGLIUCA: Do you see that the bathrooms are being redone with marble tile, the floors are being done, countertops are being done, the baths are being done, we're installing new molding in the guestrooms? Do you see those general notes, Mr. Alessi?
MR. PAGLIUCA: If we can take that down and go back to the notes to the left of those notes.
MR. PAGLIUCA: We're removing windows, we're cutting masonry down to floor level, installing new doors, modifying, replacing windows. Do you see that, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: So this was a major renovation, correct, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And the architects, if we can go to page 297, on the upper right, look at who the architects were, you remember these folks from New York, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And they would fly down to Palm Beach and supervise the major construction, correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And you were in the construction business years ago, Mr. Alessi, right?
MR. PAGLIUCA: And you know that you need these kind of construction drawings before you can begin construction, correct?
JUAN PATRICIO ALESSI: Of course.
MR. PAGLIUCA: So the architects finish these construction drawings in 1994, and the construction begins sometime after they finish these drawings, right?
JUAN PATRICIO ALESSI: I think so yes.
MR. PAGLIUCA: So in 1994, when the construction starts, nobody's living in this residence, correct?
JUAN PATRICIO ALESSI: No, sir. It was a large part -- during the construction, Mr. Epstein and Ms. Maxwell live at the residence.
MR. PAGLIUCA: You had, during your time on El Brillo Way, had regular access to the house, meaning complete access, you could go anywhere --
JUAN PATRICIO ALESSI: I live at the house.
MR. PAGLIUCA: -- you want, correct?
MR. PAGLIUCA: And --
JUDGE NATHAN: Could you pull up the microphone, Mr. Alessi. Thank you.
JUAN PATRICIO ALESSI: Keep forgetting. I'm sorry.
BY MR. PAGLIUCA:
MR. PAGLIUCA: There was no part of the house that you were denied access to, correct?
JUAN PATRICIO ALESSI: There was no part, no.
MR. PAGLIUCA: So you could go wherever you wanted, whenever you wanted, in the house, correct?
MR. PAGLIUCA: And there was a difference between when Mr. Epstein was going to be in the house and when he wasn't there, correct?
JUAN PATRICIO ALESSI: Can you repeat the question and also --
MR. PAGLIUCA: Sure.
JUAN PATRICIO ALESSI: Difference? What you mean, difference?
MR. PAGLIUCA: When Mr. Epstein was going to be in the residence --
MR. PAGLIUCA: -- he wanted you and your wife there, correct?
JUAN PATRICIO ALESSI: Only us. He didn't want -- no contractors at the house.
MR. PAGLIUCA: Right. And so when he was there, you had to be there pretty much 24 hours a day, correct?
JUAN PATRICIO ALESSI: Yes. It was slavery.
MR. PAGLIUCA: And you needed to be there at 5:00 a.m. and work all day and go to bed whenever you were able to; is that right?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: When Mr. Epstein wasn't there, you had the apartment on the other side of the bridge that you and your wife would go to, correct?
JUAN PATRICIO ALESSI: To sleep, yes.
MR. PAGLIUCA: To sleep. And then you would come back during the day and work during the day when Mr. Epstein wasn't there, right?
MR. PAGLIUCA: And there were lots of other workers who came to the house on a regular basis; is that right?
JUAN PATRICIO ALESSI: When Mr. Epstein was not at the residence, they will come and I will be there.
MR. PAGLIUCA: Right. And you would have different kinds of workers? You would have -- the pest control people would come, correct, the people that took care of bugs and things, they would come?
JUAN PATRICIO ALESSI: Yeah, there were all kinds of contractors, subcontractors.
MR. PAGLIUCA: Landscaper kind of people, right?
JUAN PATRICIO ALESSI: Excuse me?
MR. PAGLIUCA: Landscapers?
JUAN PATRICIO ALESSI: Yes. They were outside, not inside the house.
MR. PAGLIUCA: And there were people inside as well, right? There were people that dealt with air conditioning and heating and furnace and cleaning, right?
JUAN PATRICIO ALESSI: Of course.
MR. PAGLIUCA: And those people came and went under your supervision at the time, correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: I think you testified that there were many properties that Mr. Epstein owned, right?
MR. PAGLIUCA: And you had been to those properties, correct?
JUAN PATRICIO ALESSI: Briefly, yes.
MR. PAGLIUCA: And all of those properties required substantial daily maintenance and care, correct?
JUAN PATRICIO ALESSI: I imagine so.
MR. PAGLIUCA: Okay, just like the Palm Beach property required, correct?
JUAN PATRICIO ALESSI: Of course.
MR. PAGLIUCA: Okay. So that was why there was a plan to do regular scheduled checklists for maintenance and things, correct?
JUAN PATRICIO ALESSI: I guess so.
MR. PAGLIUCA: Mr. Epstein was your boss, correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: When Mr. Epstein was in Palm Beach, you would go to Mr. Epstein for direction, correct?
JUAN PATRICIO ALESSI: No. I will go directly to Ms. Maxwell. She was my immediate superior. I will go to her first.
MR. PAGLIUCA: Do you recall that -- let's talk about Mr. Epstein for a little bit. Mr. Epstein wanted his properties to be run like five-star hotels, correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And Mr. Epstein liked having guests, right?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: Mr. Epstein liked having people that he thought were important in the house, correct?
MS. COMEY: Foundation.
JUDGE NATHAN: Overruled.
JUAN PATRICIO ALESSI: I guess so.
MR. PAGLIUCA: Well, he had pictures of famous people in the house that he was meeting with, right?
MR. PAGLIUCA: And he brought famous people to the house, and you saw them there, right?
MR. PAGLIUCA: And Mr. Epstein would have lots of meetings with lots of famous people there, right?
MR. PAGLIUCA: And he liked to show off the properties, correct?
JUAN PATRICIO ALESSI: I don't know if he likes it or not, I don't know.
MR. PAGLIUCA: But he did it, right?
JUAN PATRICIO ALESSI: To show off the properties?
MR. PAGLIUCA: Yes. He had all the people there, and they were at the pool, and they would --
JUAN PATRICIO ALESSI: Sir, I don't know anything about the other properties.
MR. PAGLIUCA: No, your property, the Palm Beach property.
JUAN PATRICIO ALESSI: Yeah, they were there sometimes, they were a guest and they stay there. So I don't know if he liked to show off that property or not.
MR. PAGLIUCA: Okay. He also liked to be in control of things, didn't he, Mr. Epstein?
JUAN PATRICIO ALESSI: He had a very little contact with me in the later years.
MR. PAGLIUCA: Well, isn't it true, Mr. Alessi, that if Mr. Epstein was at the house, you would never go to Ms. Maxwell and you would go directly to him, or he would come to you? Isn't that true?
JUAN PATRICIO ALESSI: That is not true.
MR. PAGLIUCA: If we can show the witness 3504-030. At that transcript, page 6, deposition page 23.
MR. PAGLIUCA: Do you have that, Mr. Alessi?
JUAN PATRICIO ALESSI: Page 23, yes, sir.
MS. COMEY: Your Honor, may I have a moment to review this?
JUDGE NATHAN: Yes. Can you give me the lines?
MR. PAGLIUCA: Yes, your Honor. Page 23, line 6 through 8.
MS. COMEY: Your Honor, I would object. This is not inconsistent.
MR. PAGLIUCA: Excuse me?
JUDGE NATHAN: Overruled. You may read it.
BY MR. PAGLIUCA:
MR. PAGLIUCA: The question was: Who was in charge of the Palm Beach house? Your answer was: I was. And then the next question is: All right. Who was your direct supervisor? You said: Mr. Epstein. He would deal with me directly or, if he was not available, Ms. Maxwell. Do you see that?
MR. PAGLIUCA: Those were the questions and answers under oath that you gave, correct?
JUAN PATRICIO ALESSI: Could have been, yes.
MR. PAGLIUCA: Are you denying it, Mr. Alessi?
JUAN PATRICIO ALESSI: I am not denying it.
MR. PAGLIUCA: Okay. And then at line 18 of the same transcript --
JUDGE NATHAN: Just a moment.
(Pause)
JUDGE NATHAN: Okay.
BY MR. PAGLIUCA:
MR. PAGLIUCA: You answered: But if Mr. Epstein was at the house, I would never go to Ms. Maxwell, I would go to him directly or he would come to me. Do you see that, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And that was your testimony under oath about who the boss was, correct?
JUAN PATRICIO ALESSI: Well, the boss of what I understand was Mr. Epstein he was the owner.
MR. PAGLIUCA: Mr. Alessi, the question I asked you was: That's what you testified about who the boss was? Isn't that what I asked you?
JUDGE NATHAN: I direct the witness: Can you give the answer and then you can explain. Go ahead.
JUAN PATRICIO ALESSI: I could have said this statement at that time.
MR. PAGLIUCA: Okay. Thank you, Mr. Alessi. It's also true, isn't it, Mr. Alessi, that you understood that whatever Ms. Maxwell was telling you, it was coming from Mr. Epstein, correct?
JUAN PATRICIO ALESSI: I don't know the answer. I don't know if it was from him or from herself.
MR. PAGLIUCA: You're aware that this book that we talked about, the household manual -- we talked about that yesterday, correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Now, that was -- Mr. Epstein hired a countess. Do you recall that?
MR. PAGLIUCA: And the countess put together the manual, correct?
JUAN PATRICIO ALESSI: I don't know if she got it or not. I don't know if she was the author of the manual.
MR. PAGLIUCA: If we can go to 3504-030 page 6, line 24. 3504-030, 6, deposition page 23, lines -- page 24, lines 9 through 16.
MS. COMEY: Your Honor, I object. I don't believe it's inconsistent.
JUDGE NATHAN: Sustained.
BY MR. PAGLIUCA:
MR. PAGLIUCA: You didn't agree with the manual, correct, Mr. Alessi?
JUAN PATRICIO ALESSI: Yes, I did not.
MR. PAGLIUCA: And you didn't follow it?
JUAN PATRICIO ALESSI: I did not -- I did my chores, I did my work. I did not follow the manual. I don't think I never did the checkmarks on the manual.
MR. PAGLIUCA: Okay. But you knew that they hired the countess to write the book and write the ideas of how the house should be, correct?
JUAN PATRICIO ALESSI: I don't know that, sir.
MR. PAGLIUCA: We can go to 3504-022. Page 25 of that exhibit.
MS. COMEY: I'm sorry, I didn't hear you.
MR. PAGLIUCA: 3504-022, page 25.
MS. COMEY: Thank you.
JUDGE NATHAN: Page and line?
MR. PAGLIUCA: Yes, I'm getting there, your Honor. Page 179, lines 25 through 18 --
MS. COMEY: Your Honor, which lines is Mr. Pagliuca proposing to read?
JUDGE NATHAN: I think he said 25 through -- something.
MS. COMEY: I would ask the whole answer be read, the whole question and the whole answer, if Mr. Pagliuca wants to introduce this.
JUDGE NATHAN: Okay. Go ahead.
MS. COMEY: Just for the record, I believe the question would begin on line 17 at page 179, and the answer would end on line 6 of page 180. I think that's the full question and answer.
JUDGE NATHAN: Okay. Go ahead.
MR. PAGLIUCA: I'm sorry, your Honor, I'm on the wrong page. I will come back to this.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, I want to now talk a little bit about --
MR. PAGLIUCA: Well, would this be a good time for a break, your Honor?
JUDGE NATHAN: Let me just check.
(Pause)
JUDGE NATHAN: Okay, yes, we can break. We'll take our mid-morning break. About 15 minutes, members of the jury. Thank you.
(Continued on next page)
(Jury not present)
JUDGE NATHAN: Mr. Alessi, you may step down for the break. Everyone may be seated. While we're waiting, I'll just note that Ms. Williams has asked someone from A/V to come talk to the government during the break, so hopefully we can figure that out.
MS. COMEY: Thank you, your Honor.
JUDGE NATHAN: Matters to take up?
MS. COMEY: Not from the government, your Honor.
MR. PAGLIUCA: No, your Honor.
JUDGE NATHAN: We'll meet again in ten. You'll let me know if there are any issues. Thank you.
(Recess)
JUDGE NATHAN: Matters to take up?
MS. COMEY: Not from the government, your Honor.
JUDGE NATHAN: Mr. Pagliuca, anything?
MR. PAGLIUCA: No, your Honor.
JUDGE NATHAN: We can bring the witness back to the stand and Ms. Williams will bring in the jury.
(Continued on next page)
(Jury present)
JUDGE NATHAN: Thank you, everyone. Thank you, members of the jury. Mr. Pagliuca, you may continue with your cross examination of Mr. Alessi. Mr. Alessi, I remind you, you are under oath.
MR. PAGLIUCA: Thank you, your Honor.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi I want to talk now about you meeting Virginia Roberts. Okay?
JUAN PATRICIO ALESSI: Okay, sir.
MR. PAGLIUCA: Do you recall that you met Ms. Roberts for the first time at Mar-a-Lago; correct?
MR. PAGLIUCA: And you went, Ms. Maxwell, Ghislaine went into Mar-a-Lago for a treatment. Do you recall that?
JUAN PATRICIO ALESSI: I don't know if she was going to get a treatment, but if that's why she went inside, yes.
MR. PAGLIUCA: Let me just ask the question. Do you recall that she went into Mar-a-Lago for some form of treatment? Do you recall that?
JUAN PATRICIO ALESSI: I don't recall that.
MR. PAGLIUCA: If we can show the witness 3504-030, page 48, deposition transcript page 190, lines 13 through 25, and page 191, lines 2 through 6.
MR. PAGLIUCA: Have you had the opportunity to review that, Mr. Alessi?
JUAN PATRICIO ALESSI: Can you repeat the number.
MR. PAGLIUCA: Sure. Page 190 beginning at line 15.
JUAN PATRICIO ALESSI: Okay. Sir, I cannot see the number of the page. Okay, now I do. Yes, sir.
MR. PAGLIUCA: Does that refresh your memory, Mr. Alessi, that, as you understood it, Ms. Maxwell went into Mar-a-Lago for some form of treatment?
JUAN PATRICIO ALESSI: No, I think she was looking for -- because we -- I don't know if she went in for a treatment or not.
MR. PAGLIUCA: Isn't it true that you testified, as I understand it, Ms. Maxwell went into Mar-a-Lago for some form of treatment, correct, and you said yes. Do you see that?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And that was your testimony under oath; correct?
MR. PAGLIUCA: And then the question was: "Q. So you were waiting outside for about an hour?" Do you see that, line 22?
MR. PAGLIUCA: And you said, "Right." Do you see that?
MR. PAGLIUCA: And that was your testimony under oath; correct?
JUAN PATRICIO ALESSI: I guess so.
MR. PAGLIUCA: And then the question was: "Q. And then Ms. Maxwell came out after she had her treatment?" Do you see that?
JUAN PATRICIO ALESSI: Okay.
MR. PAGLIUCA: And you said, "Right." Do you see that?
JUAN PATRICIO ALESSI: Uh-huh.
MR. PAGLIUCA: Is that a yes?
MR. PAGLIUCA: Okay. And that's when you saw her talking to a person who you later came to find out was Virginia Roberts?
MS. COMEY: Objection, your Honor. It was misread.
JUDGE NATHAN: I'm sorry?
MS. COMEY: I believe that counsel just inserted two extra words in what he's reading from the deposition.
MR. PAGLIUCA: I will reread it, your Honor.
JUDGE NATHAN: Okay. "Q. You saw her talking to a person who you later came to find out was Virginia Roberts?"
MR. PAGLIUCA: Did I read that correctly?
MS. COMEY: I believe you did. Thank you.
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And you said, "That's right." Do you see that?
JUAN PATRICIO ALESSI: Yeah.
MR. PAGLIUCA: And do you recall that it was very hot out, do you recall that?
JUAN PATRICIO ALESSI: I recall that very much.
MR. PAGLIUCA: And you met -- well, this event occurred in 2002. Do you recall that, Mr. Alessi?
JUAN PATRICIO ALESSI: Excuse me? Can you repeat the question.
MR. PAGLIUCA: What we're talking about here, going to Mar-a-Lago and meeting Ms. Roberts occurred in 2002. Do you recall that?
JUAN PATRICIO ALESSI: I'm not sure if it was 2002 or 2001.
MR. PAGLIUCA: Okay. If I could direct the witness's attention to 3504-030, page 24, let's just see if we can refresh your memory, Mr. Alessi. Will you look at page 95, lines 17 through 21.
MS. COMEY: Your Honor, I would object to reading that in isolation. I would ask that the whole series of questions and answers before that be read.
JUDGE NATHAN: Okay.
MR. PAGLIUCA: I'm happy to read it all, your Honor.
MS. COMEY: Your Honor, I would ask that it begin on page 94 at line 19 is where I believe the exchange begins.
MR. PAGLIUCA: Your Honor, I think, appropriately, if Ms. Comey wants to redirect this witness's attention on --
JUDGE NATHAN: Well, then I'll sustain the objection or you could read the whole thing.
MR. PAGLIUCA: I guess it will save time if we read the whole thing.
JUDGE NATHAN: Okay.
BY MR. PAGLIUCA:
MR. PAGLIUCA: So let's start at page 94 and I will read. You're being asked a series of questions again by Mr. Edwards who is Virginia Roberts' lawyer. Do you recall that?
JUAN PATRICIO ALESSI: I don't recall him, but I imagine so.
MR. PAGLIUCA: Do you recall saying, beginning at line 21 on page 94 --
MS. COMEY: Your Honor, I ask that it begin on line 19 of page 94 with the question.
JUDGE NATHAN: Okay. Go ahead.
MR. PAGLIUCA: Okay. 19, okay. "Q. What year do you believe that you went to Mar-a-Lago to pick Virginia up? "A. I think it was 2000 and I think it was the summer of 2002." Do you see that?
JUAN PATRICIO ALESSI: Yes, sir.
MS. COMEY: Your Honor, I believe that the understanding was that the remainder of that exchange would then be read.
MR. PAGLIUCA: I'm going to keep reading it. I'm just asking questions along the way, your Honor.
BY MR. PAGLIUCA:
MR. PAGLIUCA: And you say, "Okay." Is that right, on line 23?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And then the next question -- well, after that, it's okay, and then you say summer, because I remember that day that I was sweating like hell in the car waiting for Ms. Maxwell to come out of the massage; right? Do you see that?
JUAN PATRICIO ALESSI: Yes, sir. "Q. Okay. So what month of summer do you remember it being? "A. I think it was June, July, maybe 2001. "Q. 2000 and what? "A. 2001. "Q. June, July 2001, that's when you believe that it was? "A. Yes. "Q. Okay. And do you remember the month? "A. No, sorry. Sorry. Not 2001. We left in December 31st. It was 2000, the year that I was working for Jeffrey when I met Virginia. "Q. Your recollection as you sit here today? "A. It was 2002."
MR. PAGLIUCA: Did I read that correctly?
JUAN PATRICIO ALESSI: You were reading correctly.
MR. PAGLIUCA: And that was your answer; right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And then the next question is: "Q. Is that it was June or July 2002? "A. 2002. "Q. When you met Virginia Roberts at Mar-a-Lago? "A. My recollection."
MR. PAGLIUCA: Correct?
MR. PAGLIUCA: And you thought that Virginia Roberts was a massage therapist; correct?
JUAN PATRICIO ALESSI: I have -- I have no idea what she was.
MR. PAGLIUCA: When you saw her for the first time, she had a white uniform on. Do you remember that?
MR. PAGLIUCA: And she was at the spa; right?
JUAN PATRICIO ALESSI: No, she was coming from the front gate of Mar-a-Lago down the ramp, and I was -- we were driving the car up the ramp with Ms. Maxwell in the car and she says to me, stop. I stopped the car, Ms. Maxwell walk across where she was coming to, she talked to this girl that I didn't know her name or what she was doing there, she talked to her and they went back to the spa.
MR. PAGLIUCA: And that's when Ms. Maxwell had her treatment; right?
JUAN PATRICIO ALESSI: I don't know what she had. I don't -- I never see the treatments.
MR. PAGLIUCA: So if we can take a look at 3504-22, page 30, deposition page 199.
JUDGE NATHAN: What line?
MR. PAGLIUCA: Line 22 through 25.
JUDGE NATHAN: Okay.
MR. PAGLIUCA: There was a question: "Q. And did you consider her, at least from your viewpoint, that she was one of the individuals that came to give massages? "A. She was supposed to be a massage therapist." Do you remember giving that testimony under oath?
JUAN PATRICIO ALESSI: I do not remember.
MR. PAGLIUCA: Did you give that testimony under oath?
JUAN PATRICIO ALESSI: I think it was under oath, yes.
MR. PAGLIUCA: Part of what -- one of the things that Mr. Epstein asked you to do was to go to clubs and spas to hire licensed massage therapists; is that correct?
JUAN PATRICIO ALESSI: That is incorrect.
MR. PAGLIUCA: If we can go to 3504-22, page 34, deposition page 213, lines 7 through 19.
MS. COMEY: Your Honor, I would just ask that the full question preceding this answer and the entire answer be read.
JUDGE NATHAN: Okay. Go ahead.
MR. PAGLIUCA: I will, your Honor. I'm trying to figure out exactly what Ms. Comey is requesting here.
MS. COMEY: From page 213, line 5, through page 213, line 22, please. I think that is the full exchange.
MR. PAGLIUCA: Okay. That's fine. Line 2. "Q. And one of those things that you had to do with her was take her to different spas? "A. Yes. "Q. And there she would recruit young women to come to massage? "A. Because she was English and she didn't know the area too much as well as I know. So she says, John, make a list of all the massage, the spas in the area from Jupiter to Boca Raton, and we went to all this main spas. And then we went to the schools for massage therapists and all the massage parlors and massages, the small massage. So I make a list from the telephone book and we would go from one to the other one. I would wait in the car and she goes in. And sometimes it took a couple of minutes and walk out with cards, business cards, and that she did the recruiting." Do you see these questions and answers? A. Yes, sir.
MS. COMEY: Your Honor, I would ask that the remainder of the answer be read, please.
JUDGE NATHAN: Go ahead. "A. From then she would pick up the girls and that was the end of it. I never did any recruiting and I never really saw him doing that. Him, right?" A. Hold on. Can you repeat the question.
MR. PAGLIUCA: There is no question. I was just reading your answer, Mr. Alessi.
JUAN PATRICIO ALESSI: Yes. Sometimes she took a couple minutes and walk out with business cards and that she did, I imagine that she was doing the recruiting.
JUDGE NATHAN: Okay. He read it. Thank you. Next question.
MR. PAGLIUCA: And the business cards are from places like The Breakers; right?
JUAN PATRICIO ALESSI: I don't know, sir. I never saw the business cards. They were -- she come out with in her hands. I didn't ask it to give it to me. I was never -- they were never given to me. But we went to from the most exclusive spas and country clubs from -- in the country of Palm Beach and I was the driver.
MR. PAGLIUCA: Well, you kept a Rolodex, Mr. Alessi; correct?
JUAN PATRICIO ALESSI: True.
MR. PAGLIUCA: And the Rolodex you had kept cards in it from the spas; right?
JUAN PATRICIO ALESSI: No. It had cards from the names of the repeat woman who came to the house and massage therapists.
MR. PAGLIUCA: If we can show the witness 3504-030, page 8, deposition page 30, lines 5 through 7.
MS. COMEY: Your Honor, I don't believe this is inconsistent.
JUDGE NATHAN: Sustained.
MR. PAGLIUCA: Do you recall, Mr. Alessi, that you got referrals from other people for massage therapists?
JUAN PATRICIO ALESSI: No, sir.
MR. PAGLIUCA: If we can look at 3504-030, page 47.
JUDGE NATHAN: Page and line.
MR. PAGLIUCA: Yes. Let's start with page 187, line 10.
MS. COMEY: Your Honor, I'm not sure this is inconsistent. It appears to refer to a different part of the testimony.
JUDGE NATHAN: Can I see the earlier testimony.
MR. PAGLIUCA: I'm referring to his testimony right now, your Honor.
JUDGE NATHAN: But what you want to read refers in the line to earlier testimony. I need to see that.
MR. PAGLIUCA: I think we're talking about page 47 of this document, at 88, lines 4 through 6.
JUDGE NATHAN: Do you know what page number of the transcript?
MR. PAGLIUCA: 188, lines 4 through 6.
MS. COMEY: Your Honor, that's after the portion.
JUDGE NATHAN: Agreed. If you don't have it, move on and come back to it.
MR. PAGLIUCA: Okay.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, you would call The Breakers or Mar-a-Lago or Boca Raton resort and find someone to give Jeffrey Epstein a massage; correct?
JUAN PATRICIO ALESSI: Can you repeat the question, sir.
MR. PAGLIUCA: Yes. You would call The Breakers or Mar-a-Lago or Boca Raton resort and find someone to give Jeffrey Epstein a massage?
JUAN PATRICIO ALESSI: Never.
MR. PAGLIUCA: If we can go to page 47 of the transcript, deposition page 187. May I inquire, your Honor?
JUDGE NATHAN: I don't see it yet.
MS. COMEY: Can we get clarification on which lines, please.
MR. PAGLIUCA: Starting 187, line 21 for context, and going into the next page.
MS. COMEY: Your Honor, I don't believe this is inconsistent.
JUDGE NATHAN: Let me read it.
MR. PAGLIUCA: Through page 188, line 15, your Honor.
JUDGE NATHAN: I have to admit, the difficulty is I don't understand the grammar of the question you asked.
MR. PAGLIUCA: My question to Mr. Alessi is that he would get phone numbers and call people for Mr. Epstein and he said no.
JUDGE NATHAN: That was the question?
MR. PAGLIUCA: Yes. Well, that is the question.
JUDGE NATHAN: You can ask that question, because the question you asked was, you would call The Breakers, et cetera, and find someone to give Epstein a massage.
MR. PAGLIUCA: Okay, your Honor.
JUDGE NATHAN: So you can ask that question, your question. Go ahead.
MR. PAGLIUCA: Thank you, your Honor.
BY MR. PAGLIUCA:
MR. PAGLIUCA: Mr. Alessi, you got numbers for massage therapists to call for Mr. Epstein; isn't that correct?
JUAN PATRICIO ALESSI: Yes, I had a list of massage therapists, repeat massage therapists, and I never call anybody with that -- they told me who to call. I never made a call suggesting to get a massage therapist to come to the house, never.
MR. PAGLIUCA: May I, your Honor, from line 24 --
MS. COMEY: Your Honor, I don't believe any of the testimony --
JUDGE NATHAN: Just say objection.
MS. COMEY: Objection, your Honor.
JUDGE NATHAN: I'll allow it.
MR. PAGLIUCA: Thank you.
MS. COMEY: Your Honor, may I just ask which lines Mr. Pagliuca is going to read, because I just want to make sure we have the full context.
JUDGE NATHAN: Okay.
MR. PAGLIUCA: I'm going to read from line 24, your Honor.
JUDGE NATHAN: Through?
MR. PAGLIUCA: 188, line 24.
JUDGE NATHAN: Okay.
MR. PAGLIUCA: Thank you.
BY MR. PAGLIUCA:
MR. PAGLIUCA: The question under oath, again, Mr. Alessi, was: "Q. But, for example, one of Mr. Epstein's friends would say, 'I got a good massage from this person, I recommend her to you.'" And then you said: "A. Yes, he would give me the number." Do you see that at page 188, line 3?
JUAN PATRICIO ALESSI: Who you talking about?
MR. PAGLIUCA: I'm reading your answer, Mr. Alessi, to the question. In answer to the question: "Q. One of Mr. Epstein's friends would say to you, 'I got a good massage from this person. I recommend her to you.'" And your answer was: "A. Yes, he would give me the number." Correct?
JUAN PATRICIO ALESSI: Can I answer the question?
MR. PAGLIUCA: Did you say that, Mr. Alessi, did you answer that question under oath in 2016 in that fashion?
JUAN PATRICIO ALESSI: I might have answered and I didn't understand the question. I had never had the authority to call, myself, or to look for a massage therapist. I always complaint with the questions from Mr. Epstein and Ms. Maxwell or the office secretaries to get. And they would call me, they says, John, get an appointment at 10 o'clock tonight for Jeffrey or get an appointment -- or Ms. Maxwell come to me and says, get Jodi or whatever name to come. That was my job, sir. I went to the phone, called that person. I never call anybody for them.
MR. PAGLIUCA: May I continue, your Honor?
JUDGE NATHAN: Yes, and I permitted it, so you just read. We don't need to continue with the back and forth.
MR. PAGLIUCA: Yes, your Honor.
MR. PAGLIUCA: Beginning again at line 4, Mr. Alessi: "Q. And most of the people, I take it, were from these spas or clubs, is that right, most of the massage people?" Do you see that question, Mr. Alessi?
MR. PAGLIUCA: And your answer was, "Yes." Correct?
JUAN PATRICIO ALESSI: Yes. And it's yes today. "Q. Okay. And do you know, did they have what I'll call regular day jobs at the spas and then they would come into Mr. Epstein's after?" And then your answer was: "A. I think so." Right? A. I think so, too.
MR. PAGLIUCA: And then the next question was: "Q. Okay. And why do you think so? "A. Because they were working at The Breakers, and sometimes I have to get in touch with these people. I used to call -- have to call The Breakers or Mar-a-Lago, all the clubs. There be clubs, even in Boca Raton, and Boca Raton Resort and Hotel, they have a great spa. I had to call these people, can you come in at 10:00 tonight. "Q. You would know they were working there because you would talk to them there?" "A. Yes. Correct."
JUAN PATRICIO ALESSI: It might be correct, but I never did contact these people like you says, I contact the person who I was told to call.
MR. PAGLIUCA: Mr. Alessi, you answered those questions in 2016 under oath the way I read them; correct?
JUAN PATRICIO ALESSI: I can't recall.
MR. PAGLIUCA: Okay. Mr. Alessi, do you recall that there were times that Mr. Epstein would come to the Palm Beach house without Ms. Maxwell?
JUAN PATRICIO ALESSI: Yes, he did.
MR. PAGLIUCA: And there were times that he would bring other women to the house, to the Palm Beach house; correct?
JUAN PATRICIO ALESSI: Yes, he did.
MR. PAGLIUCA: And he would tell you before he got there to remove any of the pictures of Ms. Maxwell in the house; correct?
JUAN PATRICIO ALESSI: Yes, he did sometimes.
MR. PAGLIUCA: And you understood the reason for that, for removing the pictures was Mr. Epstein was interested in the other women; correct?
JUAN PATRICIO ALESSI: I have no idea about that answer, sir. I don't know if it was interested, in love with her, or just going to be with them. I have no idea or presentations.
MR. PAGLIUCA: But you would remove the pictures; correct?
JUAN PATRICIO ALESSI: I did what he told me to do all the time.
MR. PAGLIUCA: Which was remove the pictures; is that right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And that happened regularly, didn't it, Mr. Alessi?
JUAN PATRICIO ALESSI: No, sir. It might have happened maybe -- in the time I worked for Mr. Epstein, probably three, four times.
MR. PAGLIUCA: And you never told Ms. Maxwell about removing the pictures for the other women to show up with Mr. Epstein; correct?
JUAN PATRICIO ALESSI: It was not necessary, sir.
MR. PAGLIUCA: Well, Mr. Epstein told you not to tell her; correct?
JUAN PATRICIO ALESSI: No, sir.
MR. PAGLIUCA: Well, you knew it was a secret between you and Mr. Epstein you were taking pictures down?
JUAN PATRICIO ALESSI: It was not a secret, sir. It was a mandate.
MR. PAGLIUCA: A mandate from Mr. Epstein?
JUAN PATRICIO ALESSI: Absolutely.
MR. PAGLIUCA: And a secret between you and Mr. Epstein about the other women coming; correct?
JUAN PATRICIO ALESSI: A secret from me and Mr. Epstein? He have no secrets with me, sir. He never share anything of his personal life with me.
MR. PAGLIUCA: It was a secret between you and Mr. Epstein that was kept from Ms. Maxwell; correct?
JUAN PATRICIO ALESSI: Sir, he never told me, this is a secret, don't tell Ghislaine about this. He never suggest it, imply, or told me about that.
MR. PAGLIUCA: Why did you think you were taking her pictures down, Mr. Alessi?
JUAN PATRICIO ALESSI: I have no idea, sir.
MR. PAGLIUCA: Towards the end of your stay with Mr. Epstein, working for Mr. Epstein, that was about the same time that you met Virginia Roberts; correct?
JUAN PATRICIO ALESSI: I'm not clear about these dates. I have difficult to remember exactly what years or what you're talking about, what years or what timeframe. I left at the end of the year at 2002, sir.
MR. PAGLIUCA: And that's the same time that you -- around the same time that you recall meeting Ms. Roberts; is that right?
JUAN PATRICIO ALESSI: Probably was 2002, probably was 2001. I'm not sure.
MR. PAGLIUCA: Okay. And that's around the same time that there were more massages happening, right around when you were leaving; correct?
JUAN PATRICIO ALESSI: It gradually went from one massage to around three massages a day.
MR. PAGLIUCA: Now, when you were working for Mr. Epstein between let's say 1994 and 2002, there were a number of other foreign people who came to Mr. Epstein's house; correct?
JUAN PATRICIO ALESSI: Another -- what is it?
MR. PAGLIUCA: Foreign people.
JUAN PATRICIO ALESSI: Foreign. Yes. Yes.
MR. PAGLIUCA: And there were many people that worked for Mr. Epstein that had accents, do you recall that, different accents?
JUAN PATRICIO ALESSI: Yes, sir, there were Butler -- I mean chefs, friends with English accents, French accents, Italian accents.
MR. PAGLIUCA: Lots of different accents?
JUAN PATRICIO ALESSI: Lots of different accents.
MR. PAGLIUCA: Okay. And do you remember, for example, any tailor who worked for Mr. Epstein who had a British accent; correct?
JUAN PATRICIO ALESSI: Yes, I remember her very clearly, sir.
MR. PAGLIUCA: And she would answer the phone in around 2002 timeframe when you were there at the house; correct?
JUAN PATRICIO ALESSI: I not sure if she came at 2002, sir. I think it was a little later. I'm not sure. I'm not sure if it was 2002.
MR. PAGLIUCA: You're not sure, but you know that she came and you know that she would answer the phones at the house; correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And she had a British accent; right?
JUAN PATRICIO ALESSI: Yes, she was English.
MR. PAGLIUCA: Do you recall meeting Shelly Lewis?
JUAN PATRICIO ALESSI: I recall the name, sir. I don't recall the person.
MR. PAGLIUCA: Do you recall Ms. Lewis was also a citizen of the United Kingdom?
JUAN PATRICIO ALESSI: Could have been.
MR. PAGLIUCA: And she had a British accent, as well; right?
JUAN PATRICIO ALESSI: I don't recall her, sir.
MR. PAGLIUCA: Do you remember meeting Frances Hardinge?
MR. PAGLIUCA: And she was from --
JUAN PATRICIO ALESSI: South Africa.
MR. PAGLIUCA: South Africa, and had a South African accent; correct?
JUAN PATRICIO ALESSI: Yes. She came a couple times.
MR. PAGLIUCA: And that accent, to some people, can sound like a British accent, as well; right?
JUAN PATRICIO ALESSI: It is, but it's different.
MR. PAGLIUCA: A little bit.
JUAN PATRICIO ALESSI: A little bit.
MR. PAGLIUCA: Do you remember Mandy Ellison from South Africa, also?
JUAN PATRICIO ALESSI: Yes, she was a lawyer for Mr. Epstein.
MR. PAGLIUCA: And she had a South African accent?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Do you remember Eva Andersson?
JUAN PATRICIO ALESSI: Yes, I do.
MR. PAGLIUCA: And she was Mr. Epstein's girlfriend; right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And she stayed friends with Mr. Epstein for many years?
JUAN PATRICIO ALESSI: For many years, sir.
MR. PAGLIUCA: And she came to the house regularly; correct?
JUAN PATRICIO ALESSI: Very regular with the husband and the kids.
MR. PAGLIUCA: Right, Mr. Dubin and the children?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And she had -- she was from Sweden. Do you recall that?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And she had a Swedish accent; right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Do you remember a woman named Grace who had a British accent?
JUAN PATRICIO ALESSI: Grace?
MR. PAGLIUCA: Grace.
JUAN PATRICIO ALESSI: No, I don't remember Grace, sir.
MR. PAGLIUCA: Do you remember a woman from Norway, Selena?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And she had an accent, northern European accent; correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And those people would be at the house and when they were there, they would talk to people, guests, other people; correct?
JUAN PATRICIO ALESSI: They were guests, sir.
MR. PAGLIUCA: Right. And you observed them talking to people; right?
JUAN PATRICIO ALESSI: I would say yes, I observe them, but not in the same room, sir. I was not allowed to be in the same room where Mr. Epstein and their guests were conversating.
MR. PAGLIUCA: Mr. Alessi, on behalf of Mr. Epstein, you went looking for people to give massages; correct?
JUAN PATRICIO ALESSI: Never, sir.
MR. PAGLIUCA: You drove the car to Mar-a-Lago, to The Breakers?
JUAN PATRICIO ALESSI: I drove Ms. Maxwell to a different massage places.
MR. PAGLIUCA: Okay. But you were there; correct?
JUAN PATRICIO ALESSI: I was the driver, sir.
MR. PAGLIUCA: And you knew what was happening, that people were looking for professional masseuses; correct?
JUAN PATRICIO ALESSI: They were people looking for professional -- I don't understand your question, sir.
MR. PAGLIUCA: Right. The point of being at The Breakers was to find a professional masseuse for Mr. Epstein; correct?
JUAN PATRICIO ALESSI: I imagine so.
MR. PAGLIUCA: Okay. Now, that doesn't make you guilty of sex trafficking, does it, Mr. Alessi?
MS. COMEY: Objection.
JUDGE NATHAN: Sustained.
MR. PAGLIUCA: At Mr. Epstein's direction, you called people and scheduled massages; correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And at Mr. Epstein's direction, you answered phones at the house; correct?
JUAN PATRICIO ALESSI: It was one of my duties. If he didn't pick up the phone or Ms. Maxwell didn't pick up the phone, it was one of my duties if I was at the house at the moment.
MR. PAGLIUCA: Right. So you answered the phones at the house at Mr. Epstein's direction; correct?
JUAN PATRICIO ALESSI: Not all of it.
MR. PAGLIUCA: And you would speak to females who you knew were going to give Mr. Epstein massages; right?
JUAN PATRICIO ALESSI: When I would call these girls or these women to ask for a massage at the time they was requested by Mr. Epstein or Ms. Maxwell.
MR. PAGLIUCA: Okay. And you would do that?
JUAN PATRICIO ALESSI: Of course.
MR. PAGLIUCA: Okay. And you would sometimes arrange for transportation for people to come to the house; correct?
JUAN PATRICIO ALESSI: I did not arrange. They arrange.
MR. PAGLIUCA: Well, you would call cabs; right?
JUAN PATRICIO ALESSI: If they asked me to call a cab, I will call a cab.
MR. PAGLIUCA: And you would set up the room for a massage; right?
JUAN PATRICIO ALESSI: If they told me in which room they want a massage or which place they want a massage, I will set up the massage table.
MR. PAGLIUCA: You would pay the masseuses when they were done; correct?
JUAN PATRICIO ALESSI: Some of them, yes, sir.
MR. PAGLIUCA: And the process that you went through for paying the masseuses was, generally, you would pay them by check; is that right?
JUAN PATRICIO ALESSI: Most of the times I would pay them by check. If they request cash, I will go to my petty cash box and find if I had enough. If I had $100 or $200, I will pay in cash, otherwise it was a process of making them sign a piece of paper and make a receipt, make the check, send a copy of the check back to the office in New York, and that's how they kept the records.
MR. PAGLIUCA: Okay. So the process would be someone would give a massage and sometimes they would come down and say to you, okay, I was there for an hour and you would pay them a check for $100; right?
JUAN PATRICIO ALESSI: Yes. The massage, when I was working with Mr. Epstein, it was $100 flat. I didn't have to tip or no tips. It was $100. And it was on repeat girls that came to the house and they will have -- they didn't want to get paid that night and they -- I just kept -- they kept a record on it for the amount of times they were there. So if it was five massage, it was $500 check, $600 check, $200 checks.
MR. PAGLIUCA: Let's just break it down so we're clear. You would either pay them when they were leaving or they could run a tab; right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And so they would come to you and say, I did five massages last week, so I need $500; right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And then you would write a check for $500?
JUAN PATRICIO ALESSI: Exactly.
MR. PAGLIUCA: And that was the process that you went through through 2002 when you worked for Mr. Epstein; is that right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: And to your knowledge, you never observed -- first of all, no one forced anyone to come to the house; correct?
JUAN PATRICIO ALESSI: No, they were not forced to come to the house.
MR. PAGLIUCA: People came to the house because they wanted to come to the house to give a massage; right?
MS. COMEY: Objection.
JUDGE NATHAN: Sustained.
MR. PAGLIUCA: No one complained to you about having to come to the house; correct?
JUAN PATRICIO ALESSI: No, sir.
MR. PAGLIUCA: And no one came into the house, that you observed, looked afraid or hurt or screaming or anything that would show you that they were in any kind of distress; correct?
JUAN PATRICIO ALESSI: No, sir, never.
MR. PAGLIUCA: And during the entire time you were there, people would come, they would give their massage, and then they would get paid and leave, and no one complained to you about anything; correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And the entire time that you were there, after people came, gave massages, got paid and left, sometimes you would go clean the room; correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: You never saw any signs that anyone was hurt or injured during any of these massages; correct?
JUAN PATRICIO ALESSI: No, sir.
MR. PAGLIUCA: And no one complained to you that they had ever been forced to do anything against their will; correct?
JUAN PATRICIO ALESSI: No, they never did, but I wish they would have done because I would have done something to stop it.
MR. PAGLIUCA: But no one did; correct?
JUAN PATRICIO ALESSI: No one did.
MR. PAGLIUCA: And you were asked some questions about photographs and Ms. Maxwell taking photographs. Do you recall that?
JUAN PATRICIO ALESSI: Yes, Ms. Maxwell.
MR. PAGLIUCA: Ms. Maxwell took a lot of photographs of many different things; is that correct?
JUAN PATRICIO ALESSI: That's correct.
MR. PAGLIUCA: And she was very artistic about the kinds of photographs that she took; correct?
JUAN PATRICIO ALESSI: She was a good photographer and she had a fantastic setup for cameras and lenses. I don't know anything about photography.
MR. PAGLIUCA: But she would take pictures of her dog, for example?
JUAN PATRICIO ALESSI: She took pictures of everything.
MR. PAGLIUCA: Everything. And that was a hobby of hers; correct?
JUAN PATRICIO ALESSI: I would say so.
MR. PAGLIUCA: It's also true, Mr. Alessi, that during the time you were there, it was your view that, other than Jane, you had no knowledge of anyone at the house being under the age of probably 20; correct?
JUAN PATRICIO ALESSI: I will answer that question, did I find out about those two individuals being underage, Jane and Virginia, after they were in the house for couple days. I don't recall anybody else. I was not -- I was not asked for their age to any individuals that came to the house.
MR. PAGLIUCA: Let's break it down a little bit here, Mr. Alessi. There are a number of women that were there that have been described as European women. Do you recall that?
MR. PAGLIUCA: And in your view, they were over 20 years old --
JUAN PATRICIO ALESSI: In my view, yes.
MR. PAGLIUCA: And you, during your time there, saw maybe between 50 and 100 people. So over the 10 years or the 11 years that you were there, there were maybe 50 or 100 people that were hired to give massages. Do you recall that?
JUAN PATRICIO ALESSI: Not all those people were massage therapists.
MR. PAGLIUCA: That wasn't my question, Mr. Alessi. You recall that during your time there, there would be between about 50 and 100 people that were hired to give massages. Do you recall that?
JUAN PATRICIO ALESSI: Sir, I repeat it again, I don't know if they were called to give massages. They were at the house as guests. That's all I know.
MR. PAGLIUCA: Okay. Between 50 and 100 people?
JUAN PATRICIO ALESSI: Probably more.
MR. PAGLIUCA: And in your view, they all appeared to be over the age of 20; correct?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: In your view, they could have been 18, 19, 20, or 25; right?
JUAN PATRICIO ALESSI: Yes, sir.
MR. PAGLIUCA: Isn't it true that when you were working for Mr. Epstein, you didn't have any doubt that the girls that provided him with massages were not of the proper age; correct?
JUAN PATRICIO ALESSI: Can you repeat the question.
MR. PAGLIUCA: When you were working for Mr. Epstein, you didn't have any doubt that the girls who provided him with massages were not of proper age; correct?
MS. COMEY: Your Honor, I'm going to object to form.
JUDGE NATHAN: Sustained. Can you clarify.
MR. PAGLIUCA: I'm trying to be precise with this question for impeachment purposes, your Honor. So I will ask a different question.
JUDGE NATHAN: Still has to be clear.
MR. PAGLIUCA: Yes. I will ask a different question.
BY MR. PAGLIUCA:
MR. PAGLIUCA: You believed, when you were working for Mr. Epstein, that the people who provided Mr. Epstein with massages were of age; correct?
JUAN PATRICIO ALESSI: I believe -- I believe so, yes.
MR. PAGLIUCA: If I could have a moment, your Honor.
JUDGE NATHAN: You may.
MR. PAGLIUCA: One final question, Mr. Alessi. When you were there, you don't recall meeting anyone named Carolyn; correct?
JUAN PATRICIO ALESSI: Karen?
MR. PAGLIUCA: Carolyn.
JUAN PATRICIO ALESSI: Carolyn. Probably.
MR. PAGLIUCA: You do or you don't?
JUAN PATRICIO ALESSI: Sir, I saw hundreds of guests at the house. I don't recall their name.
MR. PAGLIUCA: Thank you. No other questions, your Honor.
MS. COMEY: No redirect, your Honor.
JUDGE NATHAN: Okay. Mr. Alessi, you may step down. You are excused. Thank you. You're finished, yes.
JUAN PATRICIO ALESSI: Thank you.
JUDGE NATHAN: Government may call its next witness.
MS. COMEY: Government calls Gregory Parkinson.
JUDGE NATHAN: Gregory Parkinson may come forward. GREGORY PARKINSON, called as a witness by the Government, having been duly sworn, testified as follows:
JUDGE NATHAN: Mr. Parkinson, you may remove your mask and please state and spell your name for the record.
JUAN PATRICIO ALESSI: My name is Gregory Parkinson, G-r-e-g-o-r-y P-a-r-k-i-n-s-o-n.
JUDGE NATHAN: Ms. Comey, you may proceed.
MS. COMEY: Thank you, your Honor.