EFTA00181472

O9 - alga Condensed Transcript IN THE CIRCUIT COURT OF THE F1I-IEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION L.M., Plaintiff, vs. CASE No. 502008CA02805IXXXXMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF LOUELLA RABUYO VOLUME I October, 20, 2009 10:10 a.m. 515 N. Flagler Drive Suite 200-P West Palm Beach, Florida 33401 Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard ESQUIRE Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA00181472 • • • EFTA00181473 Louella Rabuyo - Volume I October 20, 2009 1 3 IN Tit CIRCUIT can or TM FIrrudem JUDICIAL CIRCUIT 1 APPEARANCES: • IN AND FOR PALM BRACH COUN7y, FLORIDA CIVIL D1VISLON CUR Ito.9010000.0210,:xxXXXR As Plaintiff, 2 3 4 On behalf of the Defendant. ROBERT D. CRITTON. JR.. ESQUIRE BURMAN CRITTON LUTTIER & COLEMAN. UP 303 Banyan Boulevard, Suite 400 .TRIIIRRY IIPSTRIN, 5 West Palm Beach. Florida 33401 Phone: 561.8422820 Defendant . 6 7 On behalf of Plaintiff L.M.: B BRADLEY J. EDWARDS. ESQUIRE DEPOSITIO1 or wuRLLA Ramiro CARA L. HOLMES, ESQUIRE Viratelt I 9 ROTHSTEIN ROSENFELDT ADLER Tuesday, October, 20. 2009 40t E. LEIS 0419 Boulevard. Suite 1650 10:10 - 1,10 pre 10 Fort Lauderdale. Florida 33394 Phone: 954.522.3456 11 515 N. Plagler Drive. Suite 200-P 11 On behalf of trosetappess Wen Palm Beach, Florida 13401 13 BRUCE E. III IE LAW OFFICE OF BRUCETIIIIIIII Reported By: 14 250 S. Australian Avenue. Suite 1400 Teresa Whaler., RPR, PPR West Palm Beach, Florida 33401 Notary Public, State of Florida Is Phone: 561202.6360 Nest rain Beach Office Job 411001 16 17 On behalf of Dolenclantsclane Does 2 - 8: le STUART S. MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, PA. 19 18205 Biscayne Boulevard. Suite 2219 Miami. Florida 33160 20 PhOole: 305.9312200 21 On behalf of Plaintiff In related Case No. 08-80811 22 JACK HILL. ESQUIRE IP/weary via speakerphone) SEARCY. DENNEY, SCAFIOLA BARNHART e• SHIPLEY 23 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 24 Phone: 561.686.6300 25 2 4 1 1 - - - • UNITED STATES DISTRICT COURT SOU tHERN DISTRICT OF FLORIDA 2 INDEX 2 CASE No.08-CV-80119-CIV-MARRNJOHNSON 3 - - • 3 4 4 JANE DOE NO. 2, 5 5 WITNESS: DIRECT CROSS REDIRECT RECROSS Plaintiff, 6 7 JEFFREY EPSTEIN. LOUELLA RABUTO 6 Defendant 7 9 Related Cases: 8 BY MR. EDWARDS: 5 190 03-80232. 08.80380. 98-60381, 08-80994. s BY MR. MERMELSTEile 135 208 10 08.60993, 08-80811. 08-80893. 09-80469, 09430591. 09.80656. 09-80802. 09-81092 10 BY MR. HILL: I% il ..__f 11 BY MR. CARTON: 173 12 12 DEPOSITION OF LOUELLA RABUTO 13 VOLUME I 13 - • - 14 14 EXHIBITS Tuesday, October 20.2009 Is 10:10 • 3:30 p.m. Is -- - 16 26 515 N. Flag's( Deno, Stale 200-P 17 17 NUMBER DESCRIPTION PAGE West Palm Beach. Florida 33401 le DEFENDANTS EX. 1 COPIES. COMPOSITE PHOTOGRAPHS 103 18 19 19 DEFENDANTS EX. 2 COMPOSITE PHONE MESSAGE BOOK 147 20 20 DEFENDANTS EX. 3 COPY OF PHOTOGRAPH 162 21 Reponed By: Tenni Whalen, RPR. FPR 21 22 Notary Pubec. State of Fonda 22 Weal Palm Beath Office Job 1118991 23 23 Phase: 800.330.6952 561.659.4155 24 24 25 25 • • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181474 Louella Rabuyo - Volume I October 20, 2009 5 7 1 PROCEEDINGS 1 0 How long have you been employed by 2 • • • 2 Mr. Epstein? 3 Deposition taken before Teresa Whalen. 3 A It will be five years this November 17th. 4 Registered Professional Reporter, Florida 4 0 So you started November 17th, 2004? 5 Professional Reporter, and Notary Public in and for 5 A Yes. sir. 6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein? 7 - - 7 A Through an agency. Thereupon, 0 What agency? 9 (LOUELLA RABUYO) 9 A It's Regal Domestics. 10 having been first duly sworn or affirmed, was examined 10 0 And what was your position that you were hired 11 and testified as follows: 11 by Mr. Epstein tor? 12 THE WITNESS: I do. 12 A Housekeeper. 13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness 14 MR. EDWARDS: Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Are you familiar with IS record what case this is being taken in? I noticed 15 that name? 16 it in L.M. versus Epstein. I don't know if anybody 16 A Yes. 17 cares to say who your clients are, what the case 17 0 And that person. I believe he represented that 18 style is or anything else for when she types it up. 18 he was also maybe a house manager. Is that correct? 19 MR. MERMELSTEIN: I don't have a problem with 19 A Correct. 20 that. Are we doing initials? 20 0 Would he have been, at some point in time, 21 MR. EDWARDS: Yeah. Initials. 21 your boss or your superior? 22 MR. MERMELSTEIN: Okay. 22 A Yes. 23 BY MR. EDWARDS: 23 0 That's somebody who you answered to, 24 0 All right. Will you state your name for the 24 Alfredo Rodriguez? 25 record. 25 A (Nodding head). Sometimes •- 6 8 A Louella Rabuyo. 1 You have to say yes or no. you 2 0 And what's your current address? 2 can't nod your head. 3 A 904 Summer Street, Lake Worth. 3 BY MR. EDWARDS: 4 0 All right. How long have you lived at 904 4 O Yes? s Summer Street? 5 A Yes. 6 A About two years. 6 MR. CRITTON: No, no. She said sometimes. 7 0 Two years. Where did you live prior to 904 7 then you put yes In her mouth. 8 Summer Street? 8 MR. EDWARDS: I didn't put anything in her 9 A In Palm Ridge Apartment, that's in Mango 9 mouth. I don't want the record — 10 Drive. 10 MR. CRITTON: Let me take it back. You said 11 0 How long did you five there? 11 yes, but she started to say something before she 12 A About a year. 12 was interrupted. 13 0 All right. Where did you live prior to that. 13 BY MR. EDWARDS: 14 the Palm Ridge Apartment? 14 0 That's fine. You can answer the question. 15 A In a townhouse in West Palm Beach. 15 then we'll Instruct you on the deposition. 16 Q Okay. How long did you live in the townhouse 16 MR. : Did you want to explain that 17 in West Palm Beach? 17 further? 18 A Less than a year. 18 THE WITNESS: Because we were supposed to work 19 0 Have you ever lived at Jeffrey Epstein's 19 together, but he was bossy, he was bossy. 20 location of 358 El Brillo Way? 20 BY MR. EDWARDS: 21 A No, sir. 21 O Okay. Have you ever had your deposition taken 22 0 Where are you currently employed? 22 beforeliko this? 23 A Mr. Epstein. 23 A No. 24 0 And what address do you report to work? 24 0 All right. Well, there is one court reporter, 25 A 358 El Brillo Way. 25 and it's very easy in casual conversation to nod your Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181475 Louella Rabuyo - Volume I October 20, 2009 9 11 1 head or shake your head. and she can't take that down. 1 that it's clean and appropriately, what's this... • 2 3 4 5 A All right. 0 It's also very easy to say uh-huh or huh.uh, but it kind of looks the same on paper, so you can't do that either. I'm going to wait until you finish your 2 3 4 0 And as I understand this properly, there is a main house and then there's also a staff house on the property: is that right? A Yes, sir. 6 answer, and you have to wad until I finish my question, 6 0 And when the guests would come over, would you 7 because if we talk over one another, then the cowl 7 stay in the main house, or would you go to the staff 8 reporter can't got it down. 8 house? 9 A Okay. Yes, sir. 9 MR. : Can we get a time frame to the 10 0 MI right. So if you don't understand the 10 question? 11 question, tell me you don't understand and ill try to it BY MR. EDWARDS: 12 ask a better question. 12 0 Over the last five years while you worked 13 A Yes. 13 there. 14 0 Okay. So you were Nred In November of 2004 14 A I usually stay in the staff house and do the 15 to be the housekeeper for Mr. Epstein? 15 laundry, then I go to the kitchen and then tidy the 16 A Yes. 16 kitchen. 17 0 And when you were hired, who exactly hired 17 0 You were hired in November of 2004. and what 18 you, who -- let me strike that. 18 were your hours that you worked there back in November 19 When you were hired to be the housekeeper for 19 of 2004 when you were hired? 20 Mr. Epstein, who did you interview with? 20 A Eight to five. 21 A Ms. Maxwell. 21 0 How many days a week? 22 0 Is that Ghislaine Maxwell or just 22 A Depends. 23 Leine Maxwell? 23 0 How would the schedule be relayed to you? 24 A Ghislaine Maxwell. 24 A When Mr. Epstein is there, then I'm supposed 25 0 And where did the Interview take place? 25 to report, but usually it's five days a week. 10 12 0 So am I correct In understanding that there • 1 2 3 4 A At 358 El Brilb Way. 0 And what did Ms. Maxwell and you speak about prior to your being hired as the housekeeper? A My duties. 2 3 4 was one schedule when Mr. Epstein was in town, and the schedule may be a little bit different if Mr. Epstein was out of town? 5 0 And what did she tell you your duties would 5 A Yes, sir. 6 be? 6 O All right. Toll me the differences when 7 A To tidy. to make beds. do laundry. 7 Mr. Epstein is in town versus when Mr. Epstein was not 8 0 Did she tell you what would take place in the ri in town. 9 house on a day-to-day basis? 9 A II he stays like three or four days, then I'm 10 A No. to supposed to be there, and then the house is to be 11 0 So going into that position, you had no idea 11 cleaned. And then when they do not come, then I can 12 who the guests would be or who the people coming in the 12 either go there, or I'm given free days off. 13 house would be, or what would generally go on? 13 0 Three days off? 14 A Can you simplify the question? 14 A No. A free day. 15 0 Sure. When you talked about with 15 0 Oh, okay. But typically back in 2004 when you 16 Ghislaine Maxwell at this interview, your duties being 16 were hired, you worked an average of about five days a 17 you would make the bed and tidy up, did she also tel 17 week; is that correct? 18 you that there would be a lot of guests, there would be 18 A Yes. 19 a few guests, did she talk to you about that at all? 19 0 All right. And I guess by the way that you're 20 A She mentioned that it there are guests, we 20 explaining it, if Mr. Epstein was in town for a longer 21 have to. like, you know, prepare the room, and, what's 21 period of time, you may work more than five days, and it 22 this, attend to the guests. 22 Mr. Epstein was not in town, you may work less than five 23 0 And what did you understand that to mean that 23 days? 24 you have to attend to the guests? 24 A Yes. 25 A You have to prepare the room and see to it 25 0 Okay. Did you ever talk to Mr. Epstein prior Toll Free: 866.709.8777 • 0 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181476 Louella Rabuyo - Volume I October 20, 2009 13 15 1 to being hired? 1 0 Did she tell what you would be paid at that 2 A No, sir. 2 time? 3 Q Where did this meeting, within the house where 3 A Not yet. 4 did the meeting with Ornstein° Maxwell take place? 4 0 Did you show up that Saturday? I guns that's 5 A In the living room. 5 November 17th of 2004? 6 0 Aside from teeing you that you were going to 6 A No, that's not. 7 be required to make the beds and just generally tidy up, 7 0 No. Was it prior to November 17th of 2004, or 8 did she specify anything else that you would be required atter? 9 to do? 9 A After. 10 A No. to 0 Okay. The interview that you first went to 11 0 Where had you worked prior to working for 11 was November 17th, 2004 with Ms. Maxwell; is that the 12 Mr. Epstein? 12 date that you gave us? 13 A I work as a certified nursing assistant. 13 A I cannot remember. 14 0 Where? 14 0 The only reason I'm using that date Is I 15 A At that time I was doing private duty. is believe the question I asked was when did you start 16 0 How long have you been a certified nursing 16 working for Mr. Epstein, and I thought the date that you 17 assistant? 17 gave me was November 17th, 2004. 18 A Since about ten years. 18 A Yes. 19 0 And what made you change professions from 19 0 Okay. And in the course of this whole thing, 20 being a certified nursing assistant to be a housekeeper 20 it sounds like you interviewed with ChIslaine Maxwell. 21 for Mr. Epstein? 21 there were other interviewees, you received a call and 22 A The agency called me that there is an 22 you were asked to try out on a Saturday? 23 interview; it I like. I go to, so that's how it started. 23 A Yes. 24 0 And when you went to the interview, obviously 24 0 And where does that Saturday fall in related 25 you're going to this very big house and you talked to 25 to November 17th, 2004? 14 16 1 Ornstein° Maxwell, right? i A When I accepted the job otter. 2 A Yes 2 0 Okay. And did they tel you at that time when 3 0 And did you decide right then that you liked 3 you accepted the job otter how much you were going to be 4 this and that you were going to change professions and 4 paid? s you were going to be his housekeeper? 5 A Yes. 6 A No. 6 0 What was that? 7 0 Okay. Then walk me through that, how did you 7 A II was 32,000 per annum. 8 go about eventually accepting the position? a 0 And has your salary increased over time? 9 A I didn't expect to be hired, because there 9 A Yes, sir. 10 were other interviewers (sic), interview people that to 0 And can you walk us through the increments of 11 were to be Interviewed. 11 increase in your salary? 12 a Okay. 12 A It was promised yearly increase. 13 A And then I receive a call from Ms. Maxwell if 13 0 By whom? 14 I like. I can do a try-out. 14 A Ms. Maxwell. 15 0 Okay. Did she tell you hew long this try-out is 0 Was that at the time when you were 16 period would last? 16 interviewed. or took the job? 17 A No. 17 A Yea. Sir. 18 0 And what did you tell her when she made that 18 O Did she promise you what your yearly increase 19 offer for you to by out? 19 would be? 20 A I told her that I am still taking care of this 20 A No. 21 patient, so she said if you like, you can come Saturday 21 0 And have you received a yearly increase every 22 and try it. 22 year? 23 0 Okay. And what did you tell her, did you 23 A I did. 24 accept that? 24 0 And what has that yearly increase been? 25 A Yes, I did. 25 A Up to 42. Toll Free: 866.709.8777 Facsimile: 561.394.2621 S Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181477 Louella Rabuyo - Volume I October 20, 2009 17 19 1 0 Today? 1 0 Okay. So lets talk about that. Back in • 2 3 4 5 A Yes. 0 So you're making $42,000 today, and that's the most that you've made over the five-year period you've worked for Mr. Epstein? 2 3 4 5 November of 2004, you were to working 8:00 a.m. to 5:00 p.m. And when did that schedule change from 8:00 5:00? A When? When the house was renovated. 6 A Yes, sir. 6 0 When was that, do you remember the yew? 7 0 At the time when you — when we took 7 A 2006. B Alfredo Rodriguez's deposition, he described you as a 8 0 Okay. 9 very religious Catholic woman. Does that accurately 9 MR. CRITTON: I'm sony. '06? 10 describe you? 10 THE WITNESS: '06. 11 MR. CRITTON: Let me Just object to the loran. 11 BY MR. EDWARDS: 12 MR. : You can answer the question if 12 0 So from November 2004 through '06. I'm correct 13 you understood it. 13 in presuming that your schedule was an average of five 14 THE WITNESS: I am a Catholic and I go to 14 days a week from 8:00 a.m. to 5:00 p.m.? 15 mass. 15 A At that time I go nine o'clock, I go to the 16 BY MR. EDWARD$: 16 house at nine o'clock. 17 0 Is that something you go to regularly? 17 0 Starting in 2006? 18 A II I have time. I go regularly. 18 A Yes. 19 0 When do you normally go to mass? 19 0 So when your schedule changed from 8:00 to 20 A Sunday masses and weekdays. 20 5:00, in 2006 you started going to the house. 21 0 How many weekdays? 21 Jeffrey Epstein's house, at nine o'clock? 22 A If I can, every day. 22 A Yes, sir. 23 0 And in the five-year period that you've worked 23 0 And you would stay until what time? 24 for Mr. Epstein, have you tried to go every day if you 24 A Sometimes 5:00, sometimes later, 5:30. 25 could? 25 0 Would lhat depend on what needed to be done? 18 20 A Yes. • 1 2 3 4 A No. 0 In a typical week would you normally go on Sunday to mass? A Yes, sir. 2 3 4 C1 How have you received your money, has it been by check, by cash, in terms of payment from Mr. Epstein? A Its directly deposited to my bank. 5 0 And how many days during the week will you 5 0 Do you know who directly deposits your money? 6 also attend mass? 6 A Who? 7 A If the schedule permits, then I go, but if 7 0 Yeah. Whether it's Ghislaine Maxwell or a 8 not, then I don't go. corporation or Jeffrey Epstein, do you know who the 9 0 So is there a way that you could give me an 9 direct depositor is of your check? 10 average of how many times a week that you go during the 10 MR. CRITTON: Form. 11 week to mass? 11 THE WITNESS: Mr. Epstein. 12 A Mistime? 12 BY MR. EDWARDS: 13 0 Right. Yeah. I guess today, these days. 13 0 Okay. Over the five years that you have been 14 A I attend Sunday masses only. 14 working at Mr. Epstein's house, how many conversations 15 0 And back in 2004, when you first started with 15 have you had directly with Mr. Epstein? 16 Mr. Epstein? 16 A What's this, what year? 17 A I tried to go if I have the time, sir. 17 0 Well, in the last five years, how many 18 0 Was there ever a time that you went every day? 18 conversations have you had directly with Mr. Epstein? 19 A No. 19 MR. CRITTON: Form. 20 0 But your testimony is that if time permitted, 20 THE WITNESS: The past year it's just good 21 you tried to go every day? 21 morning, how are you, you're doing a good job. 22 A Yes. 22 BY MR. EDWARDS: 23 0 Is there a reason why now these days you only 23 0 Okay. How was it prior to that, did you talk 24 attend on Sundays? 24 to him more? 25 A Because my time schedule has changed. 25 A This time more. Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 ESQUIRE nn 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181478 Louella Rabuyo - Volume I October 20, 2009 21 23 O Now you talk to him more? 1 A Yes. 2 A Because I serve him breakfast, so... 2 O When did you talk to Lyn Fontanilla about 3 O And is that an additional responsibility that 3 == .7 4 you dickil have before? 4 A It was just through the conversation. 5 A Yes. 5 O What would cause you to be in a conversation 6 O In the five•year period that you've worked 6 with this person in New York? 7 there, can you name for me all of the other employees 7 MR. CRITTON: Form. 8 who have worked at the Jeffrey Epstein house? B THE WITNESS: She calls me, I call her. 9 A After Alfredo Rodriguez left, there was BY MR. EDWARDS: lo Jerome, the gardener, and now ifs Yanusz. 10 O You're friends? 12 O And those are the house managers? 11 A Yes. 12 A Yes. 12 O Do you still talk to her today? 13 O And then you work there? 13 A Yes. 14 A Right. 14 O And does she work for Mr. Epstein as well, to is O Aside from yourself, Jerome, and Janusz, was 15 your knowledge? 16 there anybody else that you can remember working at the 16 A She does. 17 house in the past five years in any position? 17 O And does Joie. her husband, also work for 19 A Yes. 18 Mr. Epstein as well? 19 O Who else? 19 A Yes, sir. 20 20 O Where do they work? 21 21 A In New York. 22 A Yes. 22 O At Mr. Epstein's house in New York? 23 O What does she do there? 23 A Yes, sir. 24 A She's the personal assistant. 24 O And have you talked with them about your 25 O Personal assistant to whom? 25 duties and has she talked to you about her duties? 22 24 1 A Mr. Epstein. 1 A Yes, sir. 2 O And as his personal assistant, what have you 2 O And your duties are similar to Lyn's duties in 3 observed her to do for him? 3 New York? 4 A Can you rephrase your question? 4 A No. Because that's a bigger house than... 5 O I can try. You said that she's his personal 5 O Palm Beach? 6 assistant. What does that mean, what does she do? 6 A Yes. sir. A Order things that I need, or, what s this. 7 O Is it your understanding that -- you know, 8 O So ifs your testimony that has a we're going to get into the past two years where 9 been, for the past five years that you've worked there, 9 Mr. Epstein has either been in jail or he's been on 10 has been somebody that you have observed to order things 10 house arrest in Palm Beach, so I'm going to ask you 11 that you need? 11 first for the first three years that you worked there 12 A If I need something, then I go to ask 12 and Mr. Epstein was traveling, was Mr. Epstein spending 13 O Okay. What other things have you seen 13 the majority of his time in Palm Beach or in New York or 14 do for Mr. Epstein? 14 elsewhere, if you know? 15 A I have not, that's the only thing I know. 15 A He comes -- we don't know the schedule, we 16 O Who told you that 16 receive a call, then we prepare. he's coming. 17 Mr. Epstein's personal assistant? 17 O You say we receive a call. Who receives the 18 A Coworker. 18 call? 19 O Who is that? 19 A Either Alfredo or Janusz. 20 A In New York. 20 O Depending on who the house manager is at the 21 O What's that person's name? 21 time? 22 A Lyn. 22 A Yes. 23 O Lyn who? 23 O And the call comes from whom, from Ghislaine 24 A Fontanilla. 24 or from Jeffrey Epstein? 25 O Is that Joio's wife? 25 A I don't know. Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181479 Louella Rabuyo - Volume I October 20, 2009 25 27 1 0 Okay. What's your understanding of Lyn's role MR. CRITTON: Form. • 2 3 4 5 in Jeffrey Epstein's life up in New York? A She's housekeeper, too. 0 And your understanding of Jojo's role? A A driver. 2 3 4 5 BY MR. EDWARDS: 0 You realize that? MR. BY MR. EDWARDS: Do you understand his question? 6 0 Does he also serve as a house manager, similar 6 0 Do you understand my question? 7 to the way Alfredo Rodriguez was in Palm Beach? 7 MR. Do you know that is what he's 8 A No. 8 asking you? 9 0 When you say a driver, who does he drive, if 9 THE WITNESS: Yes. 10 you know? 10 MR. : I think the question was do you 11 A Mr. Epstein. 11 know whether or not Mr. Epstein pled guilty to 12 0 All right. Mr. Epstein obviously hasn't been 12 crimes. 13 in New York for quite some time: isn't that your 13 Was that the question? 14 understanding? 14 MR. EDWARDS: Sure. 15 A Yes. 15 MR. CRITTON: That was not his question. 16 0 So Jojo's still employed up in New York as a 16 BY MR. EDWARDS: 17 driver for Mr. Epstein, right? 17 0 Okay. Well, do you realize that Mr. Epstein 18 A He also does housework, helps Lyn. 18 pled guilty to crimes? 19 0 Have you discussed with Lyn whether or not 19 A Plead guilty? From the news. 2o young girls visit the house in New York? 20 0 Okay. So when you say you saw the news, which 21 MR. CRITTON: Form. 21 is where this portion of our discussion began, are you 22 MR. la You can answer that. 22 referring to the news related to Mr. Epstein and the 23 BY MR. EDWARDS: 23 charges, the criminal charges or criminal investigation 24 0 He didn't like the form of my question so he's 24 surrounding him: is that the news you're talking about? 25 able to object. but you can still answer. 25 A Yes. 26 28 • 2 3 4 MR. la You can still answer if you understand the question. THE WITNESS: No. BY MR. EDWARDS: 1 2 3 4 0 Okay. So when that came out are we talking about 2005. 2006, something in that area? MR. CRITTON: Fenn. BY MR. EDWARDS: 5 0 You've never talked to Lyn about young girls 5 0 Is that the first tine you remember seeing the 6 being in the house in New York? 6 news on that subject? 7 A When the news carne up, so that's how we 7 MR. CRITTON: Form. 8 talked. 8 THE WITNESS: I cannot remember. 9 0 What do you mean, when the news came up? 9 BY MR. EDWARDS: 10 A Whenever there was something on the news on 10 0 All right. Whenever it was, you talked to Lyn 11 TV, then that's how we come to talk about it. 11 about that? 12 0 Okay. When you say something came on the 12 A No. I don't usually talk about it. She calls 13 news. you're talking about in terms of a criminal 13 and how are you doing, then oh, like that. 14 investigation of Mr. Epstein? 14 0 Okay. And what was the discussion as it 15 MR. CRITTON: Form. 15 related to girls in either the New York house or the 16 THE WITNESS: Criminal? 16 Palm Beach house between yourself and Lyn? 17 BY MR. EDWARDS: 17 MR. CRITTON: Form. 18 0 Well, you realize that Mr. Epstein went to 18 THE WITNESS: She talks to me when she read in 19 jail, right? 19 the news or she saw on the computer. 20 A Yes. 20 BY MR. EDWARDS: 21 0 And that was after pleading guilty to some 21 0 Okay. And does she tell you about young girls 22 crimes. You realize that, right? 22 being in the New York house? 23 MR. CRITTON: Form. 23 MR. CRITTON: Form. 24 BY MR. EDWARDS: 24 THE WITNESS: She did not. 25 0 I mean, that's why you go to jail. 25 • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutIons.com EFTA00181480 Louella Rabuyo - Volume I October 20, 2009 29 31 1 BY MR. EDWARDS: 1 O All right. And when is the first tine that 2 O Okay. Have you talked to Jojo about that? 2 you saw these girls come to the house? And by 'these 3 MR. CRITTON: Form. 3 girls," I'm talking about the girls that you were told 4 THE WITNESS: No. 4 were there to give massages. BY MR. EDWARDS: 5 MR. CRITTON: Form. 6 O In working there for five years, at least the 6 THE WITNESS: I cannot remember specifically 7 time period prior to Mr. Epstein going to jail. while 7 the day and the time. 8 you were there you recognized a lot of young girls in 8 BY MR. EDWARDS: 9 the house, right? 9 O These massages take place every day that 10 MR. CRITTON: Form, predicate. 10 Mr. Epstein's in town. right? It THE WITNESS: Young girls? 11 MR. CRITTON: Form, leading. 12 BY MR. EDWARDS: 12 THE WITNESS: Not always. 13 O Are you asking - 13 BY MR. EDWARDS: 14 A They are females. 14 O Okay. So if the testimony in this case by 15 O Where cad the females come from, did you know? 15 other witnesses has been that Mr. Epstein has these 16 A I don't know. 16 girls over at his house to give him a massage every day. 17 O Do you know why they were at the house? 17 then you would disagree with that testimony? 18 A For massage. le MR. CRITTON: Form, Improper question. 19 MR. CRITTON: Form. 19 THE WITNESS: Because there are times that I'm zo BY MR. EDWARDS: 20 not there in the house. 21 O When is the first time that you heard about 21 BY MR. EDWARDS: 22 females corning to Mr. Epstein's house for massages? 22 O Okay. Every day that you are there in the 23 A Maybe two weeks after I started working. 23 house and Mr. Epstein is also there, girls come over to 24 O All right. So if you started November 17th of 24 his house to give him massages. as you understand it? 25 2004, then sometime around early December of 2004, you 25 MR. CRITTON: Form, leading. 30 32 1 heard about young girls or girls ooming to Mr. Epstein's 1 BY MR. EDWARDS: 2 house for the purposes of giving him a massage? 2 O is that a fair statement? 3 MR. CRITTON: Form. 3 MR. CRITTON: Form, leading. 4 BY MR. EDWARDS: 4 MR. Also can we get a time frame? 5 O Is that light? You mean now. or prior? 6 A Young girls? They're females, and I was told 6 BY MR. EDWARDS: 7 they come to do massages. 7 O Between 2004 and the time that Mr. Epstein 8 O Who told you that? 8 went to jail in 2008. 9 A Alfredo. 9 MR. CRITTON: Same objection. 10 O Alfredo told you that the girls did massages? to MR. Do you understand the question? 11 A He told me when I started there that there are 11 THE WITNESS: No. 12 massages to be done, and then that's when I heard it 12 BY MR. EDWARDS: 13 first from him. 13 0 Okay. Between 2004 and the time that 14 O And then did you witness the girls come over 14 Mr. Epstein went to jail in 2008. on occasions where you 15 that you were told were there to give massages? 15 were in the house and Mr. Epstein was In town, Is it a 16 MR. CRITTON: Form. That she actually saw, is 16 fair statement that girls came over to give him a 17 that what you'ro let me just object to the form. 17 massage every day? 18 MR. EDWARDS: I said the word saw, so I mean, 18 MR. CRITTON: Form. 19 there's no. like, mixing words there. Yes, that 19 THE WITNESS: Between what year again? 20 she actually saw. 20 BY MR. EDWARDS: 21 MR. CRITTON: There's a distinction between 21 O When you started working and the time when 22 seeing the girls coming and seeing the massages. 22 Mr. Epstein went to jail. 23 BY MR. EDWARDS: 21 MR. CRITTON: Same objection. 24 O Did you see the girls come to the houso? 24 THE WITNESS: Yes. 25 A Sometimes. 25 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutions.com EFTA00181481 Louella Rabuyo - Volume I October 20, 2009 33 35 1 BY MR. EDWARDS: 1 what's this, to their appearances or to their what their 2 O All right. And when you were in the house and 2 attire is. 3 Mr. Epstein was also in town, would there be usually one 3 O All right. Haven't you made a comment to 4 massage per day, or two massages. or more? 4 Alfredo Rodriguez in the past that these girls that are 5 A Maybe three. 5 coming over to give massages are too young? 6 O Okay. So on a typical day when you were in 6 MR. CRITTON: Form. 7 town, you were in the house and Mr. Epstein was in town, 7 THE WITNESS: I cannot remember. 8 it's your testimony that he would have an average of BY MR. EDWARDS: 9 three massages a day? 9 O Isn't that something that you have believed? 10 A Not average. I'm I want to correct that. 10 MR. CRITTON: Form. 11 O Correct it. please. 1/ THE WITNESS: What you mean, believe? 12 A What's this, average? Can you... 12 BY MR. EDWARDS: 13 O Okay. I think I see what you're saying. 13 CI Isn't that something that you have thought in 14 Some days there would be two and some days 14 your head, these girls that are coming over to the house 15 there would be three, and you don't want to commit to an 15 that are supposedly giving Mr. Epstein massage aro too 16 average? 16 young? 17 A Yes. Because sometimes I'm not aware. I'm In 17 MR. CRITTON: Form. 18 the staff house. 18 THE WITNESS: At my age, these people are 19 O Okay. Al right. I understand what you're 19 young to me, so... 20 saying. 20 I'm past sixty, so they are young. 21 But the days when you are In the house and 21 BY MR. EDWARDS: 22 Mr. Epstein is there, you see days when there are two 22 O Well, haven't you also made the statement to 23 massages per day and some days when there are three 23 Mr. -- we'll come back to that statement. 24 massages per day? 24 When these girls would come in the house, you 25 A Yes. 25 said sometimes you would answer the door, right? 34 36 1 O All right. And these people that are coming MR. CRITTON: Forrn. 2 over that you were told by Alfredo Rodriguez are there 2 BY MR. EDWARDS: 3 to give Mr. Epstein a massage, isn't it typical that 3 O And you would see these -- 4 they would arrive by taxicab? 4 MR. CRITTON: Wait. Can I just... MR. CRITTON: Fenn, leading. 5 If you use the word *female: I'm not going to 6 THE WITNESS: I did not know about that. 6 object to most of your questions, as opposed to 7 BY MR. EDWARDS: 7 'girls.* because I don't know what you mean by O Do you know how any of these -- one more 8 that. So I'm going to keep objecting. 9 question before I ask the next one. 9 Whatever you want, I just... 10 Are they always female masseuses? 10 MR. EDWARDS: Yeah. I know. I'm just talking 11 A Yes. 11 about the girls that would come over to give 12 O And are you aware of how these female 12 massages. 13 masseuses would arrive to Mr. Epstein's house between 13 MR. CRITTON: If you want to cal them 14 the time you started working and the time he went to 14 females, I have no objection. If you call them 15 jail? 15 gins. I don't know what that means. Females. I 16 A No. Because I'm inside the house. 16 do. 17 O Okay. Can you describe these females for us? 17 MR. EDWARDS: Okay. 18 MR. CRITTON: Form. 18 MR. CRITTON: I'm not telling you how to do 19 THE WITNESS: I don't pay attention to their, 19 it. I'm just telling you — 20 what's this, because I just do my job, open the 20 MR. EDWARDS: No. no. I appreciate it. 21 door if rm what's this, I hear the doorbell 21 BY MR. EDWARDS: 22 rang. 22 O The females that would come over to give 23 BY MR. EDWARDS: 23 massages. often times you would answer the door when the 24 O Okay. 24 door rang? 25 A So I don't, like, really pay attention to, 25 A Sometimes. Toll Free: 866.709.8777 Facsimile: 561.394.2621 • 0 Suite 600 ESQUIRE sao Gaon, 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions. com EFTA00181482 Louella Rabuyo - Volume I October 20, 2009 37 39 1 O Okay. And sometimes who else would answer the that rotated, we're talking about fifty, a hundred, two 2 door? 2 hundred different females that you saw? 3 A Alfredo. 3 MR. CRITTON: Form. 4 O And what door would the females enter through? 4 THE WITNESS: I did not count. 5 A The kitchen door. 5 BY MR. EDWARDS: 6 O And is that the door that other guests would 6 0 You saw a lot of different female faces that 7 also enter through? 7 were supposedly there to give him a massage. nght? A Sometimes. 8 MR. CRITTON: Form, leading. 9 O Why was that door chosen as the door for the 9 THE WITNESS: Sometimes the same female comes 10 female masseuses to enter through, do you know? 10 11 A No, I don't. 11 BY MR. EDWARDS: 12 O What would happen, what would be the next step 12 0 And other times it would be different females? 13 as these females would enter through the kitchen door? 13 A Yes. 14 A I don't know, because I just let them and then 14 O All right. And can you approximate the age of 15 go finish my work. 15 these females that would come over to the house? 16 O Okay. And then would their next contact be 16 MR. CRITTON: Form. 17 with ==? 17 THE WITNESS: I did not ask their ago. 18 MR. CRITTON: Form. Is BY MR. EDWARDS: 19 THE WITNESS: If I see M. then yes. But I 19 0 You saw their face and you saw their 20 just let them stay in the kitchen and then go to 20 appearance. Would you be surprised if some of these 21 the staff house and continue the laundry. 21 females were thirteen years rid? 22 BY MR. EDWARDS: 22 MR. CRITTON: Form. You're asking her to 23 O Isn't it your understanding that these females 23 speculate and guess. 24 were on a schedule as to when to come over to give 24 THE WITNESS: I did nd see any thirteen years 25 Mr. Epstein a massage? 25 old. 38 40 MR. CAPTION: Form. 1 BY MR. EDWARDS: 2 THE WITNESS: No, I don't know. 2 0 Okay. Would you be surprised If some of these 3 BY MR. EDWARDS: 3 girls were fourteen years old? 4 Q Okay. Well, each time that the girls would 4 MR. CRITTON: Same objection. 5 come over to give Mr. Epstein a massage, he would be up 5 THE WITNESS: Fourteen? I don't know. 6 in his master bedroom already; is that correct? 6 BY MR. EDWARDS: 7 MR. CRITTON: Form. 7 0 Could they have been fifteen years old? 8 THE WITNESS: I don't know. a MR. CRITTON: Same objection. 9 BY MR. EDWARDS: 9 THE WITNESS: Maybe more than that. to 0 In the period of time between 2004 when you 10 BY MR. EDWARDS: 11 started working and when Mr. Epstein went to jail, can 11 0 Maybe more than that? 12 you approximate or estimate the number of these females 12 A Yeah. 13 that would come over to Mr. Epstein's house to allegedly 13 0 But maybe less than that? 14 give him a massage? MR. CRITTON: 15 A No. is THE WITNESS: I don't know. 16 0 Are we talking more than fifty, more than a 16 BY MR. EDWARD$: 17 hundred? 17 0 The truth is, you don't know how old these 18 MR. CRITTON: Form. 18 females were, but these females that were there to give 19 THE WITNESS: I did not count. 19 him a massage were young, in your mind? 20 BY MR. EDWARDS: 20 MR. CRITTON: Form. 21 0 But there were many different Os. right? 21 THE WITNESS: Some look young, but then they, 22 MR. CAUTION: Form. 22 what's this? 23 THE WITNESS: Many females. 23 BY MR. EDWARDS: 24 BY MR. EDWARDS: 24 0 You knew that something that was going on 25 0 It was not like there were only ten females 25 there was not right. isn't that true? Toll Free: 866309.8777 Facsimile: 561.394.2621 S Suite 600 ESQUIRE a Mania Galle tenpin 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIreSolutions.oum EFTA00181483 Louella Rabuyo - Volume I October 20, 2009 41 43 1 MR. CRITTON: Form, argumentative. 1 THE WITNESS: I did not find any sex toys. • 2 3 4 5 MR. EDWARDS: Jack, we're catching some music coming over. (Brief recess in proceedings.) BY MR. EDWARDS: 2 3 4 5 BY MR. EDWARDS: 0 You never, in your employment with Mr. Epstein, found sex toys in the room after these females left from giving him a massage? 6 0 As you saw these young females coming over to 6 A There was only this, like I thought it was for 7 Pk Epstein's house to give him a massage, you knew in 7 massage. That's it. that's what I saw. your heart of hearts that something was wrong? 8 0 Okay. Have you over - are you familiar with 9 MR. CRITTON: Form, argumentative. 9 the armoire that is in Mr. Epstein's room, bedroom? 10 THE WITNESS: I was told that there going to 10 A Yes. 11 do a massage. 11 0 And have you ever put items away in that 12 BY MR. EDWARDS: 12 armoire? 13 0 I realize you were told that. Okay. Isn't it 13 A No, slr. 14 true that each of these gins was then led upstairs to 14 0 If Alfredo Rodriguez testified that you and he 15 Mr. Epstein's bedroom; that was the routine, right? 15 had a conversation about the sex toys in Mr. Epstein's 16 MR. CRITTON: Form, predicate. 16 bedroom and your comment being it's not right -- 17 THE WITNESS: I don't know. When I'm there, 17 A No. sir. le then I -- most of the time I just go to the. what's 18 0 That's not something you would agree with? 19 this, to the staff house. 19 A We did not converse about sex toys. 20 BY MR. EDWARDS: 20 0 Have you talked to Mr. Epstein today about you 21 0 When the gifts would arrive -- when the 21 having your deposition today? 22 females would arrive, you would go to the staff house? 22 A No. sir. 23 MR. CRITTON: Form. 23 0 And this is your attorney who is hero next to 24 THE WITNESS: First sometimes I would offer 24 you? 25 them drinks, and then. what's this. 25 A Yes, sir. 42 44 0 And is that somebody that you paid to be your • 1 2 3 4 BY MR. EDWARD$: 0 All right. So did you talk to some of these females? A No. Just like you care for water or some 1 2 3 4 attorney? A No, sir. 0 That's somebody that Mr. Epstein has paid to 5 drinks. soda or something. 5 be your attorney? 6 0 All right. Did you ever discuss religion with 6 A Yes. 7 any of these females? 7 0 When you were hired, did you sign any A No, sir. 8 agreement of confidentiality that you wouldn't talk 9 O When those females would go upstairs, how long 9 about the matters that happened within the house? 10 would each typically stay upstairs with Mr. Epstein? 10 A Yes, sir. 11 MR. CRITTON: Form, predicate. 11 0 When did you sign that agreement? 12 THE WITNESS: I don't know, but I was told by 12 A When I received papers to sign for like my 13 Alfredo that it would take one hour. 13 evaluation, all the forms needed for employment, like 14 BY MR. EDWARDS: 14 tax forms. 15 0 All right. And when the females would leave, 15 Q Okay. And do you have a copy of that 16 wasn't one of your responsibilities to clean the room 16 agreement? 17 where the massage took place? 17 A Maybe in my house. 18 A Yes, sir, to tidy. 18 0 That's something that you think was provided 19 0 To tidy? 19 to you, or was the only copy kept with Mr. Epstein or 20 MR. CRITTON: Form. 20 Ms. Maxwell? 21 BY MR. EDWARDS: 21 A We were given duplicate, duplicate copy. 22 0 And in doing so, isn't it true that many times 22 Q Well, let me tell you that I represent three 23 after these females left, you found vibrators and sex 23 girls that in this case are L.M., E.W., and Jane Doe, 24 toys scattered on the floor and in the room? 24 who were three of the girls that you and I have been 25 MR. CRITTON: Form. 25 talking about as females that went to Mr. Epstein's Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA00181484 Louella Rabuyo - Volume I October 20, 2009 45 47 1 house to give him massages. Okay. Would it surprise 1 years old? 2 you to know that when they went to his house they were 2 MR. CRITTON: Form. 3 as young as thirteen, fourteen, and fifteen years old? 3 THE WITNESS: I do not know about that. 4 MR. CRITTON: Form. BY MR. EDWARDS: 5 THE WITNESS: I didn't know, sir. 5 0 Okay. And after this line of questioning 6 MR. CRITTON: Asked and answered. 6 related to things that happened in Mr. Epstein's bedroom 7 BY MR. EDWARDS: 7 that were actually not massages at all, does this help 8 0 Would it surprise you to know that once inside to refresh your recollection as to the sexual toys or 9 his bedroom, he instructed them each to get naked? 9 devices that you have found in his bedroom? 10 A I did not. 10 MR. CRITTON: Form. 11 MR. CRITTON: Let me just object to the form. 11 THE WITNESS: I only found one, that massage. 12 You're asking her to speculate on something she 12 I thought it was a massage thing. 13 knows nothing about. It serves no purpose. It's a 13 BY MR. EDWARDS: 14 groat argument, but it serves no purpose. 14 0 All fight. 15 MR. EDWARDS: I know you're not happy with the 15 A You know that thing, and then I thought it's 16 line of questioning, you do this every time in 16 for -- that thing I only see. 17 deposition. 17 MR. CRITTON: Just so the record is dear, I 18 MR. CRITTON: But it serves no purpose, it's 18 think we all agree that she took her hand and 19 never going to be admissible whether she's 19 like -• 20 surprised or not. It's like saying, you know, 20 MR. EDWARDS: She thought it was a back 21 would it -- well, never mind. 21 massager. 22 You know, would it surprise you that the 22 MR. CRITTON: Probably was a back massager. 23 Afghan election -- 23 MR. EDWARDS: Give me a break 24 MR. EDWARDS: Are you hying to make this line 24 MR. CRITTON: No. You want to argue sex toys, 25 of questioning go on longer? 25 she's saying back massager. Just let her testify 46 48 1 MR. CRITTON: No. But it's just painful. Ask 1 as distinct from argumentative. 2 her stuff that she knows. 2 MR. EDWARDS: I'm letting her testify. 3 MR. EDWARDS: I know it's painful. 3 MR. CRITTON: Okay. 4 MR. CRITTON: I could care less one way or the 4 BY MR. EDWARDS: other. It's just a waste of both our times. Brad. 5 0 The only thing that you found in his bedroom 6 MR. EDWARDS: You're getting paid for it. No 6 was In the shape of something that you believed to be a 7 defense attorney ever makes this argument on the 7 back massager, is that fair? record. A Yes, sir. Yes. 9 MR. CRITTON: You know what, I get paid by a 9 0 Okay. Who was the cleaning lady or 10 lot of people, and I don't need to do frivolous 10 housekeeper prior to you. do you know? 11. things in my mind, rd rather just go home. id A They have a cleaning crew. 12 THE WITNESS: I don't know. 12 0 Prior to you? 13 MR. EDWARDS: Okay. 13 A Yes. 14 MR. : Do you understand the question? la 0 To your knowledge, has anybody ever left the 15 THE WITNESS: Yeah. I do not know anything 15 house, meaning left the employment of Mr. Epstein 16 about that part. 16 because of anything that was taking place in the house/ 17 MR. CRITTON: From the last time I objected. 17 A No, sir. 18 can you just made that, I want that two pages 18 0 Have you ever thought of leaving the 19 marked so I can get that somehow separate and 19 employment of Mr. Epstein because of what was happening 20 apart. 20 in the house? 21 THE COURT REPORTER: Okay. 21 MR. CRITTON: Form. 22 BY MR. EDWARDS: 22 THE WITNESS: No, sir. 23 0 Would it come as a surprise to you that 23 BY MR. EDWARDS: 24 Mr. Epstein used sexual devices such as vibrators on 24 0 Have you ever prayed for Mr. Epstein 25 each of my clients when they were fourteen or fifteen 25 because of what was happening Toll Free: 866.709.8777 Facsimile: 561.394.2621 O Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA00181485 Louella Rabuyo - Volume I October 20, 2009 49 51 1 A I pray for my co-employees and for my, what's 1 THE WITNESS: Yes. I do not know what's • 2 3 4 5 this, employers. 0 Have you ever prayed for him related to these females that come over to the house? MR. CRITTON: Form. 2 3 4 5 happening inside. MR. BY MR. EDWARDS: Okay. 0 Okay. And have you ever asked what is going 6 THE WITNESS: I just lift his name to God. 6 on inside? 7 that's it. 7 A No. sir. 8 BY MR. EDWARDS: 8 0 Is that something that you have chosen just 9 0 Have you ever prayed for the females that come 9 not to find out about? 10 over to his house? 10 MR. CRITTON: Form. 11 A I prayed for everyone. 11 THE WITNESS: I was told that he's going to 12 0 Do you know what Mr. Epstein does for a 12 have a massage. 13 living? 13 BY MR. EDWARDS: 14 A I was told that he's an investor. 14 0 Is that something that you believe? 15 0 Who told you that? 15 A That's what I was told, and what's this. 16 A Coworkers. 16 0 You're aware of the allegations against 17 0 Which coworkers? 17 Mr. Epstein that each of these girls that was coming 18 A Lyn and Jojo. 18 over to his house — each of those females that was 19 0 Did Lyn and Jojo -- 19 coming over to his house was engaging in sexual activity 20 A And Alfredo. 20 with Mr. Epstein. right? 21 0 And Alfredo. 21 MR. CRITTON: Form. 22 Dkl Lyn and Jojo ever tell you about 22 THE WITNESS: Could you read the question 23 Mr. Epstein getting females over to the house in 23 back? 24 New York for massages? 24 (A portion of the record was read by the 25 MR. CRITTON: Form. 25 reporter.) 50 52 1 THE WITNESS: They have visitors, that's what 1 MR. CRITTON: Form. • 2 3 4 I was told. BY MR. EDWARDS: 0 Were you ever told that he gets massages by 2 3 4 MR. Western? : Did you understand the THE WITNESS: Yes. s females similar to the manner in West Palm Beach? 5 MR. : Yos, you understand the 6 MR. CRITTON: Form. 6 question? 7 THE WITNESS: Yes. THE WITNESS: Yes. 8 BY MR. EDWARDS: MR. : And I think the question was 9 0 And who told you that? 9 are you aware of the allegations. 10 A Lyn. 10 BY MR. EDWARDS: 11 0 And did she say with what frequency — 11 0 Are you aware of the allegations? 12 A No, sir. 12 A Through TV news. 13 0 -- he has females come over? 13 0 Have you talked to anybody else about these 14 A No, sir. 14 allegations being made against your employer? 15 0 You didn't continue the conversation after she 15 A With Janusz. 16 told you this? 16 0 When did you talk to Janusz about the 17 A No. I just listen, and then she talks and 17 allegations being made against your employer? 18 then that's it. We don't realty, like, oh, no. 18 A There is the scenario whenever I -- what's 19 0 SO is it your testimony that you don't know 19 this — I heard the news, its oh, the boss is on the 20 what happens in the bedroom behind closed doors with 20 news. And that's it, to be honest. 21 Mr. Epstein and these females? 21 0 And what would Janusz comment back to you, it 22 A No, sir. 22 anything? 23 MR. a One second. I want to make 23 A Oh, he's in the news. So we did not really, 24 sure you understand the question. 24 like, talk about... 25 MR. CRITTON: Form. 25 0 But It's one thing when your boss is on the • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181486 Loue 1 la Rabuyo - Volume I October 20, 2009 53 55 1 news and it's for accolades or for awards, its another 1 like pry on other personal activities. 2 thing when your boss is on the news related to 2 Q Crimes are being committed against these girls 3 allegations that he is engaging in sexual activity with 3 on a daily basis while you're working. And 4 minor females. Wouldn't you agree with that? 4 hypothetically let's say you knew about it, would you 5 MR. CRITTON: Form, argumentative. 5 report it? 6 THE WITNESS: Of course there's a difference, 6 A If I knew about it, of course. 7 7 0 Sure. Like if you walked in on rt, then would BY MR. EDWARDS: 8 you report il? O So did you talk to Janusz about the fact that 9 MR. CRITTON: Form. 10 there are allegations that he is engaging in sex with 10 MR. : When you say 'it.' do you mean 11 these minor females that are coming over to the house 11 a crime? 12 and you're told that they're giving massages? 12 BY MR. EDWARDS: 13 MR. CRITTON: Form, compound. 13 0 Yeah. If you walked in on a crime? 14 THE WITNESS: Not really. Like we don't 14 A A crime? Of course. If it's a crime, I will. 15 really discuss-discuss. We just oh, he's in the 15 0 Okay. going to ask you'd you've ever 16 news, and then that's it, and I go to work because 16 witnessed certain acts. First I'm going to read to you 17 we're so busy. so... 17 directly from the Florida Statutes related to a crime 18 BY MR. EDWARDS: 18 cad lewd and lascivious molestation. Okay. 19 O Do you talk to your family or anybody else 19 A All right. 20 about -- 20 0 Florida Statute 794.021. 21 A No. 21 MR. : Do you have a copy that she can 22 O Let me finish my question. 22 read along with you perhaps? 23 -- about the fact that many minor females have 23 MR. EDWARDS: I don't have a copy, but I'll 24 Staged that they have come over to Mr. Epstein's house 24 hand it to her as soon as I've read it. 25 and engaged in sexual activity with him in his bedroom 25 MR. : Thank you. 54 56 1 while they were under the age of eighteen? 1 BY MR. EDWARDS: 2 MR. CRITTON: Form. 2 0 It reads as follows: 3 THE WITNESS: No. 3 A person who intentionally touches in a lewd 4 BY MR. EDWARDS: 4 and lascivious manner the breasts, genitals, 5 0 Are you aware now that your employer, 5 genital area, or buttocks, or the clothing covering 6 Mr. Epstein, Is a registered sex offender? 6 them of a person less than sixteen years of age. or 7 A I heard about it. 7 forces or entices a person under sixteen years of 8 0 Does that bother you? age to so touch the perpetrator, commits lewd or 9 A Sometimes. but I don't know if the allegations 9 lascivious molestation. An offender eighteen years 10 IS true, so... 10 of age or older who commits lewd or lascivious 11 0 Because you don't know what's going on behind 11 molestation against a victim twelve years of age or 12 dosed doors, right, you have no idea? 12 older but less than sixteen years of age commits a 13 MR. CRITTON: Form, argumentative. 13 felony of the second degree. 14 BY MR. EDWARDS: 14 Have you ever observed -- if you want to see 15 0 l hear you. 15 the law, you can. Have you ever observed that crime 16 Have you ever asked your employer if the 16 committed in his house? 17 allegations being made against him are true or if they 17 A No, sir. 18 are not true related to his sexual activities with 18 MR. CRITTON: Form. 19 underage females? 19 What statute was that? 20 A No. 20 MR. EDWARDS: It's 794.021, subsection live. 21 0 Isn't that something that you, as a religious 21 MR. CRITTON: Thank you. 22 person, would want to know, whether that's true that 22 BY MR. EDWARDS: 23 that's what's going on in the bedroom every day while 23 0 Subsection seven of that same statute, lewd 24 you're at work? 24 and lascivious exhibition, indicates: 25 A Sir. I go there to work, not to. what's this, 25 A person who intentionally masturbates. Toll Free: 866.709.8777 Facsimile: 561.394.2621 S Suite 600 ESQUIRE ae AlaiefittGalloCesp•ay 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA00181487 Louella Rabuyo - Volume I October 20, 2009 57 59 1 intentionally exposes the genitals in a lewd or 1 BY MR. EDWARDS: • 2 3 4 5 lascivious manner, or intentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim in the presence of a victim who Is less than sixteen years 2 3 4 5 0 Have you ever worked for anyone that had this many young females come over to his house every day? A No, sir. 0 Have you ever heard anybody say that these 6 of age commits lewd or lascivious exhibition. An 6 girls are making this up Of that this did not happen, 7 offender eighteen years of age or older who 7 these sexual acts did not happen in Mr. Epstein's commits a lewd or lascivious exhibition commits a bedroom? 9 felony of the second degree. 9 MR. CRITTON: Form, argumentative. 10 Have you seen that crime committed in lo BY MR. EDWARDS: 11 Mr. Epstein's house? 11 0 By that I mean Mr. Epstein, Ghislaine Maxwell? 12 A No. sir. 12 A No. sir. No. 13 MR. CRITTON Form. 13 0 Did ever say any of these girls 14 BY MR. EDWARDS: 14 were making this up? 15 0 Are you aware of the allegations by multiple 15 A No, sir. 16 female girls that allege that these are the crimes that 16 MR. CRITTON: Form. 17 were taking place behind closed doors when they were 17 BY MR. EDWARDS: 18 just minor females; are you aware of those allegations? 18 0 So these girls are making these allegations, 19 MR. CRITTON: Form. 19 you work in Mr. Epstein's house? 20 MR. : Do you understand the question? 20 A Yes. 21 MR. CRITTON: Asked and answered. 21 0 And you've never heard anybody deny these 22 MR. : Do you understand the question? 22 allegations, have you? 23 MR. CRITTON: And argumentative. 23 MR. CRITTON: Form argumentative. 24 THE WITNESS: From the news, I heard that from 24 THE WITNESS: I do my job, we don't, like. 25 the news. 25 talk. 58 60 1 BY MR. EDWARDS: 1 BY MR. EDWARDS: • 2 3 4 0 And are you also aware that many or these girls did not know one another that were these female masseuses. are you aware of that? 2 3 4 0 So is that a no, you've never heard anybody deny that? MR. CRITTON: Form. 5 MR. CRITTON: Form. 5 THE WITNESS: No, sir. 6 THE WITNESS: I don't know. 6 BY MR. EDWARDS: 7 BY MR. EDWARDS: 7 0 When was the last time you talked to 8 0 Okay. When these girls that would come -- Ghistaine Maxwell? 9 Where these females that would come over where 9 A I answer the phone when she... io you were told they were giving massages would come over. 10 0 Okay. When you first started working there 11 how many would come over at any time. meaning would they 11 back in November of 2004, she was the person who you 12 come over with twenty at time, or one at a time? 12 interviewed with, right? 13 MR. CRITTON: Form. 13 A Yes. sir. 14 THE WITNESS: Sometimes one at a time. 14 0 Was she somebody who you would regularly see 15 BY MR. EDWARDS: 15 at the house during that period of time? 16 0 And given the number of these females that are 16 A Not regular. 17 making these allegations. doesn't it Cause you to 17 0 How often would you see her in the house back 18 believe the allegations that there are so many of them 18 in the late 2004. when you wore hired, through 2005? 19 and their stories are so strikingly similar as to what's 19 A Three tines. 20 taking place in Mr. Epstein's bedroom? 20 0 Three times a week? 21 MR. CRITTON: Form, predicate, speculation. 21 A No. During the period of that I was there. 22 argumentative. 22 0 Okay. During the entire five-year period you 21 THE WITNESS: I don't know what's happening in 23 were there you only saw Ghislaine Maxwell three times? 24 the oectroomard not see anything that cause me 24 A Not live years. 25 alarm. 25 0 Okay. From the end of 2004 through 2005 you Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 ESQUIRE i• A I • ride. Gallo C•apny 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esguiresolutfons.com EFTA00181488 Louella Rabuyo - Volume I October 20, 2009 61 63 1 saw her three times? 1 MR. CRITTON: But if you just asked her. Say 2 A Yes. sir. 2 did you ever have a discussion with her about it. 3 0 During - 3 If she says yes, then well find out what it is. 4 A Maybe more or less three times. 4 If she didn't have one, why ask the question? 5 0 During 2006 how often did you see hero 5 Go ahead. 6 A 2006? He was in New York, so I saw her. 6 THE WITNESS: There was no discussion. 7 0 You worked for Jeffrey Epstein but you worked MR. a There's no question pending. a in New York? I'm sorry. Wait for Mr. Edwards to ask his question and answer 9 A I saw Ms. Maxwell in New York. 9 the question if you understand it. 10 O I think I understand. Primarily, though, you 10 BY MR. EDWARDS: 11 were still working at the 358 El Brillo location? 11 O How long were you at Ghislaine Maxwell's house 12 A Yes. 12 this time that you visited her in 2006? 13 O However, at some point in time that year you 13 MR. CRITTON: Form. 14 took a trip to the New York house and you saw her there? 14 THE WITNESS: I cannot remember, because I 15 A In her house. 15 16 O In Ghislaine Maxwell's house? 16 BY MR. EDWARDS: 17 A Yes. 17 O Back and forth? is O What was the occasion for you to go see her up 18 A Yes. 19 there? 19 O From West Palm Beach to New York? 20 A Lyn was having I think surgery. 20 A Yes. 21 O And when was that? 21 O Why were you up in Ghislaine Maxwell's house 22 A I cannot recall the month, but it's I think 22 in New York? 23 2006. 23 A I help over there when she has a party. 24 O So this is after the criminal investigation 24 O Okay. And then after the party you would 25 into Mr. Epstein, or before, if you remember? 25 return to West Palm Beach? 62 64 1 MR. CRITTON: Form, predicate. 1 A Yes. 2 THE WITNESS: 2006? After. 2 0 While you were up there, during any of the 3 BY MR. EDWARDS: 3 times that you were up there, did you have any 4 0 Okay. And while you were up there with 4 conversations with Ghistaine Maxwell? 5 Ghislaine Maxwell, did you talk to her about the 5 A I think once. But it was oh, and what's this, 6 criminal Investigation of Mr. Epstein? 6 it was just oh, I'm sorry about the bad news. That's 7 A No. sir. 7 it. 8 0 At any point in lime when you were up there. a 0 You said that? 9 did she say to you or you overheard -- let me ask you 9 A Because we have only, like, short 10 this way: Did she say to you that the allegations are 10 conversation, we just don't really, like, talk-talk. 11 false -- 11 0 When you're saying that a statement was made 12 MR. CRITTON: Form. 12 I'm sorry about the bad news, who made the statement to 13 BY MR. EDWARDS: 13 whom: she made it to you, Of you made it to her7 14 that are being made against him? 14 A She made it. But that was I really cannot 15 MR. CRITTON: Form. There's no predicate that 15 remember how it was how, but it was. like, I'm sorry 16 a discussion ever took place about anything. 16 about the news. 17 THE WITNESS: There was no discussion about 17 0 Okay. What news was she referring to when she 18 that. s said to you I'm sorry to hear about the bad news? 19 MR. EDWARDS: Mr. Craton. If you could just 19 A She not say anything. I just I do not say 20 object to the form. Obviously this witnesses just 20 anything about what the bad news is. 21 takes your words and she's going to recite them to 21 0 Okay. I guess what I'm asking is did you have 22 me. If you want to say lack of predicate, okay, 22 a death in the family or something happen to you 23 fine. But to say no discussion look place and then 23 personally? Or why would she say this to you, it you 24 she says no discussion took place, we're leading 24 know? 25 the witness here, It's obvious. 25 A No. Toll Free: 866.709.8777 Facsimile: 561.394.2621 S Suite 600 ESQUIRE so Meuse,' Calle Cajon 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esqulresolutlons.com EFTA00181489 Louella Rabuyo - Volume I October 20, 2009 65 67 1 O You have no idea why she said that statement? 1 0 What did she say when you answered the phone? • 2 3 4 5 A I think that it was about the news that was going on about Mr. Epstein. MR. CRITTON: Move to strike as speculation. BY MR. EDWARDS: 2 3 4 5 A Oh, she was happy. I was happy to hear her voice. And then she said oh, she was also happy to she was so nice on tho phone. 0 What did she say? 6 0 And did she elaborate on the news about 6 A Oh, nice talking to you, Leucite. 7 Mr. Epstein? 7 0 Then did she ask to speak to somebody else? 8 A No. sir. 8 A To Mr. Epstein. 9 O During that conversation where she makes a 9 0 Aside from the telephone call one month ago, 10 statement that she's sorry about the news. did she ever 10 how many times has she called the house in the last 11 tell you that the allegations being made against him are 11 year? 12 false or unfounded or untrue? 12 A That was my only, what's this, my the time 13 MR. CRITTON: Form. 13 that I was answer the phone and it was Ms. Maxwell. 14 THE WITNESS: Our conversation was then. 14 0 Do you know why she called Mr. Epstein? 15 BY MR. EDWARDS: 15 A I do not know, sir. 16 0 So the answer is no? 16 0 Have you ever seen scheduling logs, either on 17 A No. 17 a computer or on paper, with girls' names on it and 18 0 What is your understanding of le numbers? 19 Ghislaine Maxwells role in Jeffrey Epstein's life back 19 A No. No, sir. 20 In 2004 and 2005 and 2006? 20 0 Have you ever seen the names of these females 21 MR. CRITTON: Fenn. 21 that are alleged to have been masseuses written on 22 THE WITNESS: She told me he was his boylnend 22 anything? 23 (Stet. 23 A Yes, sir. 24 BY MR. EDWARDS: 24 0 What have you seen them written on? 25 0 Ghislaine Maxwell told you that 25 A I just saw names, and that's it. 66 68 • 1 2 3 4 Jeffrey Epstein was her boyfriend? A When I was hired. 0 And then over the next year and a half when Jeffrey Epstein was in West Palm Beach. you only saw 1 2 3 4 O Just the names. or the telephone numbers as well? MR. CRITTON: Form. THE WITNESS: I cannot remember. 5 Ghislaine Maxwell at the house approximately three 5 BY MR. EDWARDS: 6 times? 6 O Where did you see this? 7 A Yes, sir. 7 A We have like butlers pantry and there's a 8 0 Did you still believe that Ghislaine Maxwell 8 telephone there. 9 and Jeffrey Epstein were boyfriend and girlfriend? O Is this in the staff house or the main house? 10 MR. CRITTON: Form. 10 A No. The main house. 11 THE WITNESS: At that time or what time? 11 O And do you know who wrote the names? 12 BY MR. EDWARDS: 12 A No, sir. 13 0 Yeah. Back then in 2004, 2005. 13 O How do you know that these were the names of 14 A Yes. la the females that were alleged to have been masseuses? 15 0 All right. Is it your understandng that they 15 A Because there is time. 16 am still boyfriend and girlfriend today? 16 O What do you mean, there Is time? 17 A I don't know. 17 A Sometimes name and then the time, that's it. 18 0 Ghislaine Maxwell and Jeffrey Epstein, do they 18 O What does the time indicate? 19 still talk to one another today? 19 A I cannot remember. 20 A I do not know, sir. 20 O The lime to you you know, I'm watching what 21 0 What is the last time that you talked to 21 you're doing, but the court reporter is not able to draw 22 Ghislaine Maxwell? 22 a picture of it. So I guess what I'm asking is you're 23 A She called the house and I answered the phone. 23 saying there is on the left-hand side there is a 24 0 How long ago? 24 name. and on the right-hand side corresponding to that 25 A About a month ago. 25 name there is a time written down? Is that what you • 0 Toll Free: 866.709.8777 Facsimile; 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com EFTA00181490 Louella Rabuyo - Volume I October 20, 2009 69 71 1 indicated? 1 BY MR. EDWARDS: 2 A Yes. 2 O -- and you would answer the phone? 3 0 And that lime is indicative of the appointment 3 A Again, can you... 4 line when that female was supposed to be al 4 O What would they say? Hi, this is Mary, I'd 5 Mr. Epstein's house? 5 like to come work, is there a time available for me. 6 MR. CRITTON: Form. 6 I'm making this up. What would they say? • THE WITNESS: I realty don't know if that's 7 MR. CRITTON: Form. • the one that indicate who is coming, I just see 8 BY MR. EDWARDS: 9 names there and then limo. 9 O II you know. 10 BY MR. EDWARDS: 10 A They just say the, what's this. The female 11 0 Describe for me what this book looks like, or 11 wiU just -- tell Mr. Epstein I called. 12 what this piece of paper looks like. 12 O Okay. Just tell him I called? 13 A Someplace there are like white paper wo write 13 A Uh-huh. 14 the names. if I hear if somebody receives a call, and 14 O And you would write down the name of the 15 then we write the name of the person and the time. 15 person and the time the person called? 16 0 It sounds like you've answered the phone for 16 A Yes, sir. 1? when one of these females has called? 17 MR. When you get to a convenient 18 A Sometimes. 18 breaking point. 19 MR. CRITTON: Form. 19 MR. EDWARDS: Let's break. 20 BY MR. EDWARDS: 20 (Brief recess in proceedings.) 21 0 How many times in the last five years have you 21 MR. II may be obvious to us in the 22 answered the telephone when one of these females has 22 room, but it may not be apparent in the cold record 23 called? 23 that English is not Ms. Rabuyo's first language. 24 MR. CRITTON: Form. 24 So that's why I've interrupted a couple of times 25 THE WITNESS: I cannot remember. 25 and asked her if she understands the question, 70 72 1 BY MR. EDWARDS: 1 because it's apparent to me sometimes that her 2 0 All right. I asked this question that way 2 English isn't as eloquent as Mr. Edwards. 3 because you said sometimes we take the message. 3 BY MR. EDWARD$: 4 A Yes. 4 0 What is your first language. Ms. Rabuyo? 5 0 And when you say we, you're including A Visayan and Tagalog. 6 yourself? 6 0 Do you feel comfortable with taking this 7 A Yes. 7 deposition in English; meaning do you understand my 8 0 Okay. And when the female would call to 8 questions and are you giving me answers that aro 9 schedule I mean, when the female could call, what 9 truthful and accurate? 10 exactly would she say where you would write down a name 10 A Sometimes I have to ask you to rephrase 11 and a time? 11 because, you know. 12 A I don't know N I just receive a call and 12 0 Okay. And when you've asked me to rephrase 13 then I get the message and write the name and the time. 13 and I've rephrased the question. have you understood it 14 0 Okay. It's just a message from whom? 14 and given me an answer that you feel is accurate? 15 A For Mr. Epstein. 15 A Yes. 16 0 And who is the call that the calls that 16 0 Okay. Did you ever talk to the police? 17 you're referring to, who are they, who is calling? 17 A No. 18 A They are female voices. 18 0 Have you ever talked to the FBI? 19 0 And are they asking to come over to give a 19 A No. 20 massage, to work, to .- 20 0 Were you ever asked to talk to the State 21 A To work. 21 Attorney's Office? 22 0 And what is the language that the females 22 A No. 23 would typically use when they would call •- 23 0 Were you ever asked to talk to the United 24 MR. CRITTON: Form. 24 States Attorney's Office? 25 25 A No. Toll Free: 866.709.8777 Facsimile: 561.394.2621 0 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutions.com EFTA00181491 Louella Rabuyo - Volume I October 20, 2009 73 75 1 O Did you ever talk to any law enforcement type 1 A Yes. • 2 3 4 5 related to the Jeffrey Epstein criminal investigation? A No, sir. O Did you remain employed from November 2004 through today continuously with Jeffrey Epstein? 2 3 4 5 A Where? In jail. 0 How do you know that? A Through Janusz or, what's this, through the 6 A Yes, sir. 6 news. 7 O Was it discussed as to how your employment 7 0 So you did you work at his house during the 8 would be altered, if at all, while Mr. Epstein was going 8 time period -- 9 to be either -- while Mr. Epstein was going to be in 9 A Yes. 10 tall or away from the house? 10 0 Wait until I finish. 11 A No, sir. 11 A Sorry. 12 O Did you know, did you have any prior warning 12 Q Did you work at his house during time period 13 before Mr. Epstein pled guilty and went to jail? 13 when Mr. Epstein was in jail' 14 A No, sir. 14 A I did. 15 Q All right. So it was just one day he's there 15 0 Did you see Mr. Epstein during that year time 16 and the next day he's not, as far as you knew? 16 period? 17 A Janusz, we discuss it with Janusz, he received 17 A No. 18 a call, and then oh. Mr. Epstein is coming so is how I 18 0 What was your schedule during that year time 19 know. 19 period that Mr. Epstein was in jail? 20 O I'm sorry. Maybe we miscommunicated there. 20 A Flexible. No. Wait. The time that he was in 21 You're saying that Janusz received a call that 21 jail? 22 Mr. Epstein was coming to the house? 22 0 Right. June 30th, 2008 through sometime in 23 A Your first question was? 23 July, 2009. 24 O Were you made aware of the date or time period 24 MR Do you understand the question? 25 that Mr. Epstein would be going to court to plead guilty 25 THE WITNESS Yes. 74 76 Okay. Go ahead and answer it • 1 2 3 4 to crimes and then going to jail so that he would no longer be at the house, were you made aware that that was going to take place? A Not directly. 1 2 3 4 MR. then THE WITNESS: I usually come nine o'clock. BY MR. EDWARDS: 5 0 Okay. Indirectly then, did you know that that And you would leave? 6 was taking place? 6 A At 5:00 or 5:30. A No. Janusz and I talked, so... 7 Q And who else would be in the house during that 8 0 And what did Janusz tell you about Mr. Epstein 8 year time period from June 2008 through July 2009? 9 going to court and after court he would be in jail and 9 A Only Janusz and me; and the gardener, he 10 no longer at the house? 10 passed away. 11 A We really don't know when he's going there to 11 0 Who? 12 jail or Is going to court. It's just a discussion like 12 A The gardener. 13 oh, he's going to court or something, but the date and 13 0 Jerome? 14 the time, no. 14 A Jerome. 15 Q rm not concerned with the date and the time. 15 0 And you said he said passed away? 16 I guess what I'm getting at just is were you told that 16 A Yes. 17 there was going to be a time period he was going to be 17 Q When was that? 18 in jail? le A I remember right we came from New York, I 19 A No. 19 cannot remember, but I remember when we came from 20 0 All right. There was a period ol time that 20 New York, we attended his not burial, the ceremony in 21 was just over a year where Mr. Epstein was not in the 21 church. 22 house, that being from June 30th. 2008 through sometime 22 0 Do you know how he passed away? 23 in July of 2009; correct? 23 A Janusz told me that he has a bean attack or 24 A Yes. 24 something. 25 Q And do you know where he was during that time? 25 0 Okay. But it wasn't on the property while he • 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutIons.com EFTA00181492 Louella Rabuyo - Volume I October 20, 2009 77 79 I was working? 1 O Was it somebody from New York? 2 A No. 2 A What, you mean when he was jail? 3 0 During that year time period that Mr. Epstein 3 O When he was in jail. 4 was in jail, what did you do on a day-to-day basis when 4 A Story. 5 you were there from 9:00 to 5:00? 5 O It was Story? 6 A I dean the house, I made inventory of the 6 A It was Story. 7 linens, and what's this, staled inventorying, making an 7 O This is Story Cowles? Do you know the last 8 inventory of the silverwares. 8 name? 9 0 Okay. Did you talk to during 9 A I don't know his last name. 10 that time period he was in jail? 10 o And when you say she came with a person, you 11 A Yes. 11 mean she came to the house with a person named Story? 12 0 And went to visit him in jail numerous 12 A Yes. 13 times; are you aware of that? 13 O And do you know if that person named Story 14 MR. CRITTON: Form. la flew in with MI from elsewhere? 15 THE WITNESS: No, sir. 15 A I don't know. 16 BY MR. EDWARDS: 16 O And did Story stay at the house with 17 18 Ci And did stay in the house during the time period where Mr. Epstein was In jail? 17 ==.? 18 A No, sir. 19 A Yes. 19 O AM right. So this is during the day he came 20 0 Permanently, or did she fly in town and fly 20 over. Story came over and visited with 21 back somewhere else? 21 A Visited? I think so. 22 A (Nodding head.) 22 Q Okay. Do you know the purpose for Mr. Cowles, 23 MR. You have to say yes or no. 23 or Story as you referred to him, meeting with 24 THE WITNESS: Yes. 24 at the house during the year time period 25 MR. Yes she flew in, or yes she 25 when Mr. Epstein was in jail? 78 80 1 stayed permanently? 1 A No. 2 THE WITNESS: Not for a longer period. 2 Q What did you watch them do together, if 3 BY MR. EDWARDS: 3 anything? 4 0 Okay. Who would she fly into town with, if 4 A Do the computer. 5 anyone? 5 O All right. How many computers were there In 6 A Alone. I don't know, because she just come to 6 the house during the year time period Mr. Epstein was in 7 the house and that's how she's there. I didn't know who 7 jail? 8 she came with. 8 A They have their own personal computers. 9 O Did she come to the house alone, she being 9 O Who is 'they'? 10 10 A If you're asking about and Story? 11 : Again, we're talking during the 11 O Right. They brought laptops with them, you're 12 time period when Mr. Epstein is in Jail? 12 saying? 13 THE WITNESS: Yes. 13 A Yes. 14 MR.-: Thank you. 14 O Okay. For the period of time between 15 THE WITNESS: So one time she came with male 15 November 2004 through June of 2008, when — sorry. 16 friend. 16 Were you working at the house when the police 17 BY MR. EDWARDS: 17 executed a search warrant on the house? 18 O With a male friend? 18 A No. 19 A Yes. 19 Q You wore not working at the house? 20 O Do you know his name? 20 A I wasn't. 21 A I forgot it. 21 O Were you aware of a search warrant being 22 O Was it [ger? 22 executed on the house? 23 A No. 23 A No. 24 O Was 4 Story? 24 O Did you know that a search warrant was ever 25 A No. 25 executed on the house at 358 El Brillo Way? Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE • A It taader Oak COMPRI 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquireSolutions.corn EFTA00181493 Louella Rabuyo - Volume I October 20, 2009 81 83 1 A When I came back to report, that's how I 0 So are we talking about the day the police • 2 3 4 5 learned. 0 Elaborate on that for me. What do you mean, when you came back to report that's how I learned? A I reported in the afternoon, and then that's 2 3 4 went to Jeffrey Epstein's house you did not go in the morning, but you went after lunch and the police had already left? A Oh. No. When I went there nobody was there, 6 how I learned that the police came. 6 no policemen were around. 7 0 All right. And when were you - you're now 7 0 Who was at the house then? a saying you came back to report and you learned that the 8 A Janusz, and Douglas, the architect. 9 police had already come to the house, right? 9 O Sc nettle? 10 A Yes, sir. 10 A Yes. 11 0 Pro{ to that occasion, when was the previous 11 0 And did you have a discussion with them? 12 time that you were at the house? 12 A No. 13 A The day before. 13 0 How did you know the police had been to the 14 0 Okay. And the day before you left your shift 14 house? 15 at roughly five o'clock? 15 A Janusz told me. 16 A I cannot remember. I usually leave 5:00 or 16 0 When? 17 5:30. 17 A When I arrive. la 0 But sometime late in the afternoon? 113 0 That's what I was asking you when I said did 19 A Yes. 19 you have a discussion with them, meaning Janusz and 20 0 And as of that time, the day before the search 20 Douglas. 21 warrant was issued, you had seen no police officers in 21 A Okay. Being because them with Janusz only. 22 or around the house? 22 0 What did he say? 23 A No. 23 A He said the police came and, what's this, took 24 0 And then the next day you reported to the job 24 away some stuff. 25 at what time? 25 0 Did he say what they took? 82 84 • 1 2 3 4 A The next day? O The next day. A I report in the afternoon. 0 Was there a reason why you reported in the 2 3 4 A He said pictures. 0 Did he tell you which pictures? A No, sir. 0 Aside from pictures, what else did the police 5 afternoon? 5 take, as Janusz told you? 6 A Ms. Maxwell called me. 6 A He did not elaborate. 7 Q When did she call you? 7 Q MI right. Prior to the police going to the A During that day, she sad Louella. you can 8 house and taking pictures, do you remember seeing 9 report in the afternoon. 9 pictures around Mr. Epstein's house? 10 0 She called you early in the morning? 10 A Yes. 11 A Not early. 11 0 Do you remember seeing pictures of naked or 12 0 Normally you would report to the house between 12 nude females around Mr. Epstein's house? 13 eight and nine o'clock, right? 13 A Not around, in his closet. 14 A Yes, sir. 14 0 In Mr. Epstein's closet you would see -- 15 0 So in order for you not to arrive al the 15 describe what you would see related to females in 16 house, she had to have called you before eight or 16 pictures. 17 nine o'clock, right? 17 A Some have topless. 18 A Yes. 18 0 Is this a big closet? 19 0 Okay. So approximately what time does 19 A No. Not really big, its just this big, not 20 Ms. Maxwell call you to tell you you can report to the 20 so big. 21 house later on that day? 21 0 Okay. Were these pictures that could be seen 22 A I cannot remember really the time. 22 by — strike that. 23 0 Okay. What time did you actually report to 23 Do you know of any other pictures of females 24 the house? 24 that were confiscated by the police that did not come 25 A After lunch, about -- maybe after lunch. 25 from Mr. Epstein's closet? Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 ESQUIRE .....". 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA00181494 Louella Rabuyo - Volume I October 20, 2009 85 87 1 MR. CRITTON: Form. 1 MR. CRITTON: Form. 2 THE WITNESS: Nude picture? 2 BY MR. EDWARDS: 3 BY MR. EDWARDS: 3 0 You were able to tell me the approximate age 4 0 Any other pictures that were taken by the 4 of the child in the photograph, but you're unable to 5 police that were not taken from his closet. tell me the approximate age -- 6 MR. CRITTON: Form. 6 A It was just a guess for four, because I could 7 THE WITNESS: One. 7 hardly, like, tell the age. It was just maybe four, 8 BY MR. EDWARDS: 8 because... 9 0 Where was that picture? 9 0 Okay. Was there anything else in the house 10 A The hallway leading to the master bedroom. 10 that you were told was taken by the police? 11 0 And what was that picture of? 11 A No, sir. 12 A It's like advertisement, small child. 12 0 Prior to the day when the police came to the 13 0 A small child. When you Say 'small Child: 13 house, how many computers did Mr. Epstein have in his 14 what age range are you talking about? 14 house? 15 A Maybe four. 15 MR. CRITTON: Form, predicate. 16 0 What is that child in that picture who is 16 THE WITNESS: One -- three. 17 maybe four doing? 17 BY MR. EDWARDS: 18 A I cannot really, like -- I don't know what's 18 O Where were those three computers located? 19 this, but I think the underwear was (indicating), like 19 A In the cabana, in ono of the desks, and one in 20 pulled down. zo the little office. 21 MR. CRITTON: Just for the record, she's 21 0 And after the police came to the house do you 22 pointing to her rear-end, derriere. 22 remember seeing those computers any more? 23 BY MR. EDWARDS: 23 A No. I really did not focus on what was 24 0 So in this picture that was taken by the 24 missing, only the picture that was big, and in the 25 police or confiscated by the police, it was in the 25 bedroom. 86 88 1 hallway and it was of a child roughly lour years old 1 0 Okay. But you're aware, as you told me. that 2 that was puling down her underwear and exposing her 2 there were these computers -- 3 buttock area: is that fairly accurate? 3 A Yes. 4 A Yes. Not really lull, just like slightly. 4 0 Let me finish. 5 that's what I remember. 5 A Sony. 6 0 Okay. Are there any other photographs that 6 0 You where aware, as you told me, that there 7 were confiscated by the police, to your knowledge? 7 were these computers that you described as being three 8 A No. 8 computers in Mr. Epstein's house, right? 9 0 So how many photographs had you seen prior to 9 A Yes, sir. 10 the police going into Mr. Epstein's house in 10 0 And do you know whether those were taken out 11 Mr. Epstein's closet? 11 of Mr. Epstein's house by Mr. Epstein or somebody 12 MR. CRITTON: Form. 12 associated with Mr. Epstein. or by the police? 13 THE WITNESS: Less than ten. 13 A I'm not aware. 14 BY MR. EDWARDS: 14 0 So to the best of your knowledge, the police 15 0 Okay. So there were less than ton photographs 15 took less than ten photographs from Mr. Epstein's house, 16 In Mr. Epstein's closet that you remember? 16 and that should be all of the evidence or objects that 17 A Yes. 17 were taken by the police from Mr. Epstein's house, to 18 0 And what were those photographs of, these less 18 your knowledge? 19 than ten? 19 MR. CRITTON: Form, predicate. 20 A Half nude women. 20 THE WITNESS: I dont know. 21 0 Do you know the ages of those women? 21 BY MR. EDWARDS: 22 A No, sir. 22 0 I'm only asking what you do know. 23 0 Do you know the approximate ages of those 23 To your knowledge, what you described to me 24 women in those photographs? 24 as -- I just want to know a list of all the things that 25 A No. 25 you know were taken by the police. And you've described Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE as Attander Campaay 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutI0nS.00M EFTA00181495 Louella Rabuyo - Volume I October 20, 2009 89 91 1 to me I believe one photograph of this four-year-old 1 A Yes. • 2 3 4 5 child as well as less than ten photographs that wore previously in Mr. Epstein's closet. A Yes. MR. CRITTON: Form. 2 3 4 0 So you know what bedrooms need to be tidied up and look like someone slept there? A Yes. 0 And does it appear that I= slept in the 6 BY MR. EDWARDS: 6 same bedroom as Mr. Epstoin, or some other bedroom? 7 O Is there anything else that you know was taken 7 A Sometimes the other bedroom is also, like, 8 by the police? 8 slept in. 9 A No. 9 0 Okay. So sometimes 10 0 Since Mr. Epstein has been out of Oil, I 10 A Sometimes one bed is the master, and sometimes 11 guess this Is since July of 2009, what has your schedule 11 the other. what's this, is slept in. 12 been? 12 0 What is your understanding of the relationship 13 A My sdieduM has ctanged. 13 between and Mr. Epstein? 14 0 To what? 14 A Relationship? 15 A From 6:00 to 3:30. 15 0 Yeah. What is your understanding of 16 0 6:00 a.m.? 16 role in Mr. Epstein's life? 17 A Yes. sir. 17 MR. CAUTION: Form. 18 0 And why the schedule change? THE WITNESS: She did not tel me that. She's 19 A Because I was chosen to give breakfast. 19 his girlfriend, so she stays there, so... 20 0 To whom? 20 BY MR. EDWARDS: 21 A Mr. Epstein. 21 0 She didn't tell you, or she did? 22 0 By whom? 22 A She did not. 23 A Because it was Janusz was there usually gives 23 0 She did not tell you. 24 the breakfast, but there was a change, it was me. 24 How long has been around Mr. Epstein, to 25 0 Okay. You don't know why that change 25 the best of your memory? 90 92 1 occurred? 1 A Since a few months I started working there. • 2 3 4 A No. 0 Well, do you know why that change occurred? A Because so that somebody because Janusz has 2 3 4 0 Okay. So that's late 2005 you're talking about, or 2004? Sorry. A 2005, I think. 5 to stay later, so... MR. CRITTON: 2005? 6 0 Every morning now you serve breakfast to 6 MR. EDWARD$: She said 2005. 7 Mr. Epstein? 7 MR. CRITTON: Okay. A Yes, sir. 8 BY MR. EDWARDS: 9 0 So that's why you're required to be there at 9 0 And what was your understanding back then why 10 6:00 a.m. Is that what time he eats? 10 she was at the house with Mr. Epstein? 11 A 6:30. 11 A Understanding? I thought she is his 12 0 Tell me since Mr. Epstein has been out of jail 12 girlfriend. 13 and back at the house, what other people have frequently 13 0 Ghislaine Maxwell, when she hired you or 14 visited and/or stayed at house? 14 interviewed you, told you that she, Ghislaine, was 15 A Who? 15 Mr. Epstein's girtfriend, right? 16 0 Who. 16 A Yes. 17 A =, =, Story. 17 0 And Mena month or two after you began 18 0 And where does Mr. Epstein sleep in the house 18 working at Mr. Epstein's house is also around the 19 since he's been out of jail? 19 house and you believed that she was Mr. Epstein's 20 A Where? In the master bedroom. 20 girlfriend? 21 0 All right. And where does MI sleep? 21 A I want to — before I did not know that, she 22 A I'm not aware if -- I did not see if they 22 was just a visitor. 23 sleep together or... 23 0 Okay. When was it that you started, you wore 24 0 Well, you tidy up the house the following day, 24 led to believe, or based on your observations you 25 correct? 25 believed that was a girlfriend of Mr. Epstein? Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE az Aleasskr Gallo Cantor 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181496 Louella Rabuyo - Volume I October 20, 2009 93 95 A 2006. No. Wait. When he was in jail. 1 A Yes. 2 O All right. When Mr. Epstein was in jail 2 O Have you ever been told that was 3 between June 2008 and July of 2009 is the first time 3 purchased from her family by Mr. Epstein? 4 that you began to believe that was a girlfriend of 4 A No. 5 Mr. Epstein? 5 O Have you ever been told that serves as a 6 A Yes. That's just my own, but she did not tell 6 lesbian sex slave for Jeffrey Epstein? 7 me that she's the girlfriend. 7 A No. 8 O Did anybody tell you that? 8 O Since Mr. Epstein has been out of jail, you 9 A No. 9 indicated that the frequent visitors are M, 10 a Prior to that period of time when Mr. Epstein 10 and Story; right? 11 was in jail, what was your understanding as to 11 A Yes, sir. 12 relationship to Mr. Epstein or role in Mr. Epsteires 12 O And does Story stay at the house? 13 life? 13 A No. 14 A A friend. 14 O How often is Story at the house? 15 O What did she do when she was at the house 15 A Often. Like they come in the morning, they 16 prior to Mr. Epstein going to jail, MI, what did 16 stay a few hours, then leave. 17 do? 17 O Who is -they'? 18 A What did she do? 18 and Story. 19 O What did do around the house prior to 19 O And is that on a daily basis? 20 Mr. Epstein going to jail? 20 A Not always. 21 A Go shopping. 21 O Do you know if or Story -- do you know 22 O Anything else? 22 if is staying at Mr. Epstein's house now? 23 A That's what I know only. 23 A No. 24 O Do you remember a person named 24 O You don't know, or she's not? 25 25 A No, she's not. 94 96 1 A Adrian? 1 O Do you know where she is staying? 2 O Yes. 2 A Not now. no. 3 A I remember a name Adriana, but the family 3 O Do you know If she's staying with Story? 4 name, no. 4 A I don't know. 5 a And what cid Adriana do at Mr. Epstein's 5 O Do you know if Story is boyfriend? 6 house, if anything? 6 A Yes. A Alfredo told me that Adriana is a personal 7 O And Is that the relationship between Story and 8 assistant. 8 M. they're boyfriend and girlfriend, as you 9 O Similar to 9 understand it? 10 A Yes. 10 A Yes. 11 O Was there anything that you observed that 11 O And do you know how it is that they met? 12 would distinguish from Adriana in terms of 12 A I don't know. 13 the role that they played in Mr. Epstein's life? 13 O Do you know how long they've been boyfriend 14 A Not really. 14 and girlfriend? 15 O Is that somebody who you believe scheduled 15 A No. 16 Mr. Epstein for massages with the females, Adriana? 16 O Do you know, have you witnessed Story talking 17 A I don't know. 17 with Mr. Epstein at Mr. Epstein's house? 18 O And were you ever told that by anybody that 18 A Yes. 19 was also involved in sex acts with minor females 19 O And where do those conversations take place? 20 at Mr. Epstein's house? 20 A In the breakfast room. 21 A No. 21 O And when those conversations are taking place 22 MR. CRITTON: Form. 22 in the breakfast room between Story and Mr. Epstein, is 23 BY MR. EDWARDS: 23 also there? 24 O Am I the first person that has said that in 24 A There are times when she's there, there is 25 your presence? 25 times that she's not there. Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE as Me. tat Gallo Gapsay 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181497 Louella Rabuyo - Volume I October 20, 2009 97 99 1 0 All right. So there are times that Story 1 mean do you know if she flies in from New York or flies • 2 3 4 5 talks directly with Mr. Epstein in the breakfast room and ills just two of them? A Yes. 0 All tight. And there are times when Story 2 3 4 5 in from LA. or where she fives down the street In Palm Beach? A No. She said she comes from New York. 0 What does she do when she's in Palm Beach? 6 talks with Mr. Epstein in the breakfast room and 6 A Go to the beach. 7 is also there? 7 O Did you know her prior to -- had you seen her A Yes. a prior to Mr. Epstein going to jail? 9 0 Are there times when is also involved in 9 A No, sir. to conversations where Story and Mr. Epstein are talking 10 0 Other than are there any other 11 with one another in the breakfast room? 11 visitors that you have witnessed or observed? 12 A Yes. 12 A Sultan. 13 0 Are there times when all four of them, that 13 0 Who is that? 14 meaning Story. and Mr. Epstein, are all 14 A Sultan. 15 conversing together in the breakfast room? 15 O S-U-L-T-A-N? 16 A Yes. 16 A Yes. 17 0 Have you overheard the conversations? 17 O Is that a female? 18 A No. 18 A A male. 19 0 Do you know or have you been made aware of 19 0 Do you know what Sultan does? 20 them talking about the allegations concerning 20 A No, sir. 21 Mr. Epstein and female masseuses? 21 O Do you know why he's ever at the house? 22 A No, sir. 22 A No. 23 0 Since Mr. Epstein has been out of jail in July 23 O How often is Sultan there? 24 of 2009. have you seen any females coming over to give 24 A I saw him two times. 25 Mr. Epstein a massage? 25 Q And is that somebody that you saw pnor to 98 100 1 A No. sir. 1 Mr. Epstein going to jail? • 2 3 4 0 Do you know why that is? A I don't know, sir. 0 Does M, have you seen keeping a 2 3 4 A No, sir. 0 So the first time you saw him was sometime after Mr. Epstein got out of jail? 5 schedule of females or masseuses? A Yes, sir. 6 A No, sir. 6 0 Any other visitors that you've seen since 7 0 Since July of 2009. has Jeffrey Epstein spent 7 Mr. Epstein's been out of jail in July? 8 every night at the Palm Beach house, to your knowledge? 8 A M. 9 MR. CRITTON: Form, predicate. 9 0 And who is-? 10 THE WITNESS: I leave at 3:30, so... 10 A She's also a friend. 11 BY MR. EDWARDS: 11 0 A friend of whom? 12 0 When you arrive every morning at 6:00 a.m., 12 A Mr. Epstein. 13 has Mr. Epstein been there every day? 13 0 And where does she come from? 14 A Yes, sir. 14 A I did not ask her, I did not know. 15 Q Aside from M, M, and Story, have there 15 0 All right. Is It somebody that a driver has 16 been any other visitors that are regular visitors of 16 to go pick up from the airport, or she flew from 17 Mr. Epstein since he's been out of jail? 17 somewhere? 18 A Some female friends. 18 A Yes. Janusz. 19 0 Who would those people be? 19 0 Janusz picks these people up from the airport? 20 A Difficult names. M. 20 A Yes, sir. 21 0 who? 21 MR. CRITTON: Form. 22 A I don't know their... 22 BY MR. EDWARDS: 23 0 Do you know where she comes from? 23 0 And when I say "these people,' I'm talking 24 A No. 24 about M, Sultan, and all are driven by 25 0 And I don't mean her country of origin. I 25 Janusz to the house? • 43 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181498 Louella Rabuyo - Volume I October 20, 2009 101 103 MR. CRITTON: Form. 1 massage from any of these females? 2 THE WITNESS: I did not see Janusz drive, but 2 MR. CRITTON: Form. 3 what's this. 3 THE WITNESS: I do not know. 4 BY MR. EDWARDS: 4 BY MR. EDWARDS: 5 0 But that's what you understand? 5 0 I'm just going to ask you if you can identify 6 A Yes. 6 any of these people in this book. If you can. okay. if 7 MR. CRITTON: Form, speculation. 7 you cannot, it's line. 8 BY MR. EDWARDS: 8 MR. CRITTON: I want to mark those, please. 9 0 My other visitors? 9 MR. EDWARDS: Well. if she can Identify them to A That's all I can remember. 10 I'll mark them. 11 0 Do you know how old is? 11 MR. CRITTON: No, no. I want thorn identified. 12 A She, veliars this. 12 because it she can't identify them that's 13 0 Excuse me? 13 significant to me as well. So can we mark those as 14 A I don't know her age, but she looks like, 14 a composite? 15 what's this. 15 MR. EDWARDS: I can mark them as a composite. 16 0 Did you say -what's this*? 16 and we can either copy them here as black and white 17 A What? 17 or whatever. 18 0 I'm sorry. We're just I think 18 MR. CRITTON: That's line. 19 miscommunicating here. 19 (Plaintiff's Exhibit No. 1 was marked for 20 A Okay. zo identification.) 21 O I was asking the age of the person that you've 21 BY MR. EDWARDS: 22 described as M. 22 0 Do you know who this Is, have you ever seen 23 A I did not ask her age. 23 her before? 24 Q How do you know the names of Sultan. 24 A No. 25 and MI? 25 MR. CRITTON: And we'll call this Exhibit 1-A. 102 104 1 A What's this? Janusz. 1 MR. EDWARDS: And then the next page will be 2 0 Okay. Any other visitors aside from those 2 3 three people that you have just listed, and the frequent MR. CRITTON: Yeah. 4 visitors: M. an 4 BY MR. EDWARDS: A Mats all I can remember. 5 0 What was your response? 6 0 Has Ghislaine Maxwell come to visit since 6 A No. 7 Mr. Epstein's been out of jail? 7 Q Never seen her before? 8 A No, sir. 8 A No. 9 0 Do you know if they frequentty talk with one MR. CRITTON: Can you tell us who they are? 10 another? 10 MR. EDWARDS: Can I tell you? 11 A I don't know, sir. 1.1 MR. CRITTON: Yes. 12 0 Do you know what the relationship is or has 12 MR. EDWARDS: No. 13 been between Ghislaine Maxwell and Mr. Epstein? 13 MR. CRITTON: Okay. 14 A No. 14 MR. EDWARDS: She may be able to tell you. 15 MR. CRITTON: Form. 15 BY MR. EDWARDS: 16 BY MR. EDWARDS: 16 0 Have you ever seen her before? 17 0 In the five years or so that you've worked at 17 MR. CRITTON: That's 1-B. 18 Mr. Epstein's house, what other persons besides 18 BY MR. EDWARDS: 19 Mr. Epstein have received massages from these females, 19 o This is 1•B. 20 from these female masseuses? 20 A No. 21 MR. CRITTON: Form. 21 0 That's not somebody that you recognize as 22 THE WITNESS: I don't know. 22 anybody working on Mr. Epstein's staff, pointing at 23 BY MR. EDWARDS: 23 picture 1-B? 24 0 Do you know of any other visitors who have 24 A No. 25 frequented Mr. Epstein's house that have also received a 25 0 Okay. 1-C, is that somebody that you Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.eSquiretiOlUtiOnS.COm EFTA00181499 Louella Rabuyo - Volume I October 20, 2009 105 107 1 recognize 1 A I cannot remember. • 2 3 4 5 A No. 0 -- as anybody who has ever been to Mr. Epstein's house in the past five years? A No. 2 3 4 s MR. CRITTON: This is 1-I now? MR. EDWARDS: This is H. THE WITNESS: I cannot remember. BY MR. EDWARDS: 6 0 1-D, do you know who that is? 6 0 By that I mean you've been able to tell me no. A No. 7 no, no, no. no. When you say I don't remember, does 8 0 You don't remember seeing her come t0 8 that mean maybe you have? 9 Mr. Epstein's house? 9 A Maybe, because the eyes. 10 A No. 10 0 Okay. So that's somebody who may look 11 0 1-E, do you know who that is? 11 familiar to you but you don't know why? 12 A No. 12 A Yes. 13 0 In the live years that you worked there, you 13 0 Okay. Is that somebody you remember seeing at 14 never remember seeing her come to Mr. Epstein's house? 14 Mr. Epstein's house: I mean, is that where the 15 A No. 15 Familiarity comes from? 16 0 Do you know who this is? 16 A Maybe. 17 A I remember this. 17 0 Okay. Do you recognize that person? 18 0 You remember her? 18 A That's= 19 MR. CRITTON: Are you talking 1•F? 19 0 And that's the person that you've been 20 BY MR. EDWARDS: 20 describing as- throughout this deposition? When 21 Cr Let's make sure we're right. 1-F. 21 you've talked about = that's the person you're 22 A Yes. 22 talking about? 23 0 All right. When do you remember seeing her? 23 A Yes. 24 A I cannot remember the dates, you know, but I 24 MR. What number are we on now? 25 remember seeing her. 25 MR. CRITTON: 'J." 106 108 1 0 Do you remember her name? 1 MR. MERMELSTEIN: • 2 3 4 A No. 0 Does the name as to who this person is? refresh your recollection 2 3 4 MR. EDWARDS: =Is BY MR. EDWARDS: 'J.* 0 Do you know who that is, have you ever seen 5 A M? 5 that person? 6 0 You remember a In& 6 A Yes. 7 A remember a name but I don't know if 7 0 Where have you seen him? 8 that's =I. 8 A In the house. 9 0 Okay. And where do you think that you saw 9 MR. CRITTON: This is "Ks now? 10 this person? 10 BY MR. EDWARDS: 13. A In the house. 11 0 This is 1-K. 12 0 Do you know yaw she was there? 12 What have you seen him doing in the house? 13 A No. 13 A He came with his family. 14 0 Is that one of the people that was giving a 14 0 Every time that he's been In the house he's Is massage, or is that somebody else? 15 come with his family? 16 A I do not know. I do not know. 16 A No. no, no. He came with his family to spend 17 MR. CRITTON: I'm sorry. 17 a week. 18 THE WITNESS: No. I do not see this. 18 0 Okay. And did his family come to the house as 19 BY MR. EDWARDS: 19 well? 20 0 1-G, that's not somebody you remember seeing? 20 A Yes. They stay there. 21 A No. 21 0 They stayed at the house? 22 0 1-H. do you remember seeing that person? 22 A This Is Mr. Dershowitz? 23 A No. 23 0 Right. And how many times have you seen 24 0 This is a hard picture to decipher maybe. but 24 Mr. Dershowitz at the house in the time period that you 25 do you remember seeing that face? And that's 1-I. 25 were there? • Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA00181500 Louella Rabuyo - Volume I October 20, 2009 109 111 1 A Two times. in the house? 2 0 And one of the times he was with his family? 2 A I cannot remember. 3 A Yes. 3 0 Do you know if Mr. Dershowitz has ever been in 4 0 And the other time Is it safe to presume then 4 the house when the females would come to the house to 5 that he was alone? 5 give Mr. Epstein a massage? 6 A Yes. 6 A I told you, I do not know. 7 0 During the time that he was with his family. 7 0 You don't remember that? 8 do you remember if Mr. Epstein received any massages 8 A I don't remember that. 9 from females? 9 O Okay. Do you know it Mr. Dershowitz has 10 A No. 10 received a massage while staying at Mr. Epstein's house? 11 0 You don't remember, or he did not? 11 A No. 12 A Oh, he was there when Mr. Epstein was not in 12 0 You don't know? 13 the house. 13 A I don't know. 14 0 Mr. Dershowitz and his family were in the 14 0 Do you know who that is? 15 house when Mr. Epstein was not in the house? 15 MR. CRITTON: Lot's get a letter now, or this 16 A Yes. They spend a week there. 16 is going to be a mess. 17 0 And Mr. Epstein was not in South Florida, you 17 MR. EDWARDS: Not really. they're all in 18 mean, not in Palm Beach? la order. 19 A No. 19 MR. CRITTON: For the record, yoU're going how 20 MR. CRITTON: mars coned? 20 about this person, and nobody is going to know who 21 BY MR. EDWARDS: 21 you're talking about. This is 'L' 22 0 That's correct, my statement is correct? 22 MR. EDWARDS: Yeah. 23 A Correct. 23 BY MR. EDWARDS: 24 MR. : So no, he was not in the house? 24 0 Who is 1-L? 25 THE WITNESS: He was not in the house. 25 A 1-L? 110 112 1 BY MR. EDWARDS: 1 0 Who is this? 2 0 So Mr. Dershowitz and his family were 2 A Oh. That's Ms. Maxwell. 3 occupying the house in Palm Beach. and during that 3 0 That's Ghislaine Maxwell? 4 period of time Mr. Epstein was not staying at the 4 A Yes, sir. 5 Palm Beach house? 5 O That's somebody who you know? 6 A No. 6 A Yes, sir. 7 O That's correct? 7 0 And you've seen her at the house before? a A I think he was in jail. 8 A Yes. 9 0 Oh, okay. This is a tine period when 9 0 All right. And that's the same Ms. Maxwell 10 Mr. Epstein was in jail? 10 that hired you into the position, correct? 11 A (Nodding head). 11 A Yes. 12 0 That Mr. Dershowitz was at the house? 12 0 Do you remember seeing this person? 13 A Yes. 13 A That's Igor. 14 0 Okay. Other than that time period -- there 14 MR. CRITTON: 'M.' 15 was another time period when Mr. Dershowitz was at the 15 BY MR. EDWARDS: 16 house and he was not with his family? 16 0 This is 1-M. 17 A Yes. 1? And how do you know Igor? 18 0 And how long ago was that? 18 A He's now in the house. 19 A Oh. I cannot remember when. 19 0 He's now in the house? 20 0 MI right. Was it before Mr. Epstein went to 20 A Yes. 21 jail? 21 0 But when we listed the people. I wanted you to 22 A I think after. 22 list for me all of the people -- 23 0 So you think again Mr. Epstein was not in the 23 A I forgot. I'm sorry. I forget Igor. 24 house. To the best of your memory, has Mr. Dershowitz 24 0 Is there anybody else that you think you 25 been in the house at the same tine Mr. Epstein has been 25 forgot? Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 ivww.eSquireS0lutions.com EFTA00181501 Louella Rabuyo - Volume I October 20, 2009 113 115 1 A I think this is the only one I forgot. 1 A Because he aged. • 2 3 5 O And what is his role in Mr. Epstein's life, if you know? A He's a driver and he is trainer. O Trainer? 2 3 4 5 MR. CRITTON: He aged? THE WITNESS: He aged. MR. CRITTON: Okay. And this is 'P.' 6 A (Nodding head). 6 BY MR. EDWARDS: 7 O What do you mean by that? 7 O This is 'P.' A Because I saw him tolling Mr. Epstein, one 8 And this is, just so that you know, a fairly 9 more lap. 9 recent photograph of him, and you haven't seen him In 10 O One more lap where? 10 how long? 11 A In the swimming pool. And he said he's a 11 A Alter he left Mr. Epstein's employ. 12 trainer. 12 O So it's been numerous years since you've seen 13 O Who said he's a trainer? 13 this person? 14 A Igor. 14 A Yes. 15 O Igor told you that he's a trainer? 15 O So in fairness to you, that may be the reason 16 A Yes. 16 why you didn't recognize this panicular person? 17 O Okay. Do you know who that is? 17 A Yes. 18 A No. 18 O Okay. And if any of these preViOuS 19 O Never seen her before? 19 photographs were taken recently and you hadn't seen the 20 A Never. 20 person for five years, then that would be a possibility 21 O Affright. 21 as to why you don't recognize that person anymore? 22 MR. CRITTON: That's 'N.' 22 MR. CRITTON: Form. 23 BY MR. EDWARDS: 23 (Telephone ringing.) 24 O That's 'N.' 24 MR. EDWARDS: Jack? 25 Do you ever remember a girl named Mi coming 25 MR. CRITTON: Jack? 114 116 MR. HILL: Hey, guys. I got cut off. Sorry. • 1 2 3 to the house? A M? I heard =. O But you never remember seeing somebody in the house that somebody referred to as Ilat? 2 3 4 BY MR. EDWARDS: O This is 'P.' That was Alfredo Rodriguez, you've seen him in the house? 5 A No. I don't know their names if they come, I 5 A Yes. 6 don't know their names. 6 O How many months was Alfredo Rodriguez working 7 O But the name in this photograph, which is 11,' 7 there overlapping your employment? a you don't remember seeing her? 8 A I started November, December. and then — 9 A No, sir. 9 about three months. 10 O Do you know who that is? 10 O Okay. Do you know who that is? 11 A Yes, sir. 11 A Oh. You got that from my Facebook? 12 O Who is that? 12 a Do you know who that is? 13 A My employer. 13 A That's me. 14 O And that is Mr. Epstein? 14 O Okay. You recognize that. 15 A Mr. Epstein. 15 MR. CRITTON: That was 'O.' 16 O All right. So Mr. Epstein is 'Or 16 THE WITNESS: Thank you. 17 A Correct. 17 MR. : You made the book. 18 MR. CRITTON: Right. 18 THE WITNESS: My niece made it for me. 19 BY MR. EDWARDS: 19 MR. CRITTON: Next is 'R.' 20 O Do you know who that is? 20 BY MR. EDWARDS: 21 A I don't know. 21 O Do you know who this person is who is labeled 22 O Do you remember Alfredo Rodriguez? 22 1•R? 23 A Oh. That's Alfredo? Oh. yes. 23 A No. 24 O Now that you look at the photograph, does it 24 O Never seen that person before? 25 look like Alfredo Rodriguez? 25 A No. Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181502 Louella Rabuyo - Volume I October 20, 2009 117 119 1 0 Has Mr. Epstein had anyone in the house that 1 0 Okay. Other than on the news, anybody around 2 you remember by the name of Martin? 2 the house ever say that? 3 A No. 3 A President Clinton? No. Lyn and Jojo. 4 0 Have you ever been on Mr. Epstein's planes? 4 0 Lyn and Jojo. What did they say? 5 A No. 5 A Oh, not him. It's Kerry, Senator Kerry, they 6 0 Do you know this person who we are labeling 6 have a picture. 7 1-S? 7 0 Senator Keny? 8 A No. A Yes. Clinton? Let me see. Oh, no. 9 0 You've never seen that person before? 9 0 So Lyn and Jojo, at some point in time, told 10 A Never. 10 you that Senator Clinton (sic) was at the New York 11. Do you know the name Leslie Wexner? 11 house? 12 A I heard that one. 12 MR. CRITTON: No. Senator Kern'. 13 0 When did you hear about Leslie Wexner? 13 BY MR. EDWARDS: 14 A In the news, it was in the news. 14 0 Senator Kerry. Sony. 15 0 Other than in the news, you have no idea who 15 A I remember when I was in New York she showed 16 Leslie Wexner is? 16 me a picture of them with Senator Kerry or Clinton. 17 A No. 17 don't know. you know. 18 0 Have you seen that person before? 18 0 So either Kerry or Clinton was in a picture 19 MR. CRITTON: This is 1-T. 19 With Who? 20 BY MR. EDWARDS: 20 A With Lyn and Jojo. 21 0 1-T. 21 0 And this picture was purportedly taken at the 22 A This is the Duke of, what's this? 22 New York house of Mr. Epstein? 23 0 Prince Andrew. Have you ever seen 23 MR. CRITTON: Form. 24 Prince Andrew in Mr. Epstein's house? 24 THE WITNESS: I don't know if its in the 25 A No. 25 house. but they showed me a picture. 118 120 1 MR. CRITTON: Next one is 'U.' 1 BY MR. EDWARDS: 2 BY MR. EDWARDS: 2 0 Okay. 3 0 1-U, have you ever seen this person? 3 MR. This is 'W.' 4 A No. No, sir. 4 BY MR. EDWARDS: 5 0 That's not somebody you recognize as ever 5 0 1-W, have you ever seen this person? 6 being at Mr. Epstein's house? 6 A No. 7 A No. 7 0 No? 8 0 Do you know who this is? A No. 9 A President Clinton. 9 0 Do you know anybody by the name of 10 0 Have you ever seen President Clinton in the 10 Cecelia Stein? 11 house? 11 A Cecelia Stein? I heard about it. 12 A No. 12 0 How have you heard about her? 13 MR. CRITTON: That wasill? 13 A Cecelia Stein. I know Cecelia that works in 14 MR. EDWARDS: That's ' 14 the office. 15 MR. CRITTON: 1 is Clinton. 15 0 Works in what office? 16 MR. EDWARDS: was Clinton. 16 A New York. 17 BY MR. EDWARDS: 17 0 You think she still works in that office? 18 0 Have you ever seen him at the house? 18 A I don't know. 19 A No. 19 0 When was the last time you remember her 20 0 Have you ever seen him at all in person, 20 working in that office? 21 Mr. Clinton? 21 A I don't know. I just heard her name. 22 A No. 22 0 Okay. Through whom? 23 0 Have you ever heard that Mr. Clinton was ever 23 A Sometimes I think when I was in New York I 24 at Mr. Epstein's house? 24 answer a phone call, so that's... 25 A On the news. 25 0 You remember a time -- did you ever hear of Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE .m"..“_ 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181503 Louella Rabuyo - Volume I October 20, 2009 121 123 1 her being relocated to some other location? 1 0 Do you know it he's a business associate or • 2 3 4 5 A No. MR. CRITTON: We are at 1-X now. BY MR. EDWARDS: 0 So 1-X is==? 2 3 4 5 partner of Mr. Epstein? A No. 0 Had you seen him prior to this time that you recently saw him after Mr. Epstein was out of jail? 6 A Yes, sir. 6 MR. CRITTON: Form. 7 0 And you recognize =='? 7 THE WITNESS: I cannot remember. a A Yes. BY MR. EDWARDS: 9 0 Okay. Do you know who that is? 9 0 Okay. Do you think that the first time that 10 A I saw him on magazines. 10 you ever saw this person was recently. when Mr. Epstein 11 0 David Copperfield, do you know who that is? 11 got out of jail? 12 A Oh, yes. 12 A Yes. 13 0 And have you seen him at Mr. Epstein's house 13 0 Okay. 14 oven 14 MR. CRITTON: So this is AA. 15 A No, 15 BY MR. EDWARDS: 16 0 Do you know Mr. Epstein to be friends with 16 0 Do you know who this is? 17 David Copperfiekl? 17 A No. 18 A No. 18 0 Have you ever seen him before? 19 0 If Alfredo Rodriguez remembers him performing 19 A No. 20 magic in Mr. Epstein's living room, you weren't at the 20 0 All right. 21 house al that time? 21 A He's an actor? 22 MR. CRITTON: Form. 22 0 Have you ever heard of the name Todd Meister? 23 THE WITNESS: No. Because I did not see him. 23 A No. 24 BY MR. EDWARDS: 24 0 That's not somebody you've ever taken a 25 0 Okay. Do you over remember anyone performing 25 message for that's called? 122 124 1 a magic show in Mr. Epstein's living room? 1 A No. • 2 3 4 A No. MR. EDWARDS: What are we at? MR. CRITTON: 2 3 4 0 Okay. The next one is BB. Do you know who that is? A That's Story. 5 BY MR. EDWARDS: 0 Story Cowles? 6 0 Do you know this? 6 A Yes. I don't know his family name, but Story. 7 A Yes. What's his name. 7 0 When is the first time that you remember 0 Jean Luc Brunel. Do you know who that is? 8 seeing Story? 9 A Yes. 9 A First time? Mr. Epstein was in jail. 10 0 How do you know him? 10 0 Okay. And was that as a result of him being 11 A He comes to the house. 11 at the house with MI, Story and Ms. Kellen? 12 0 He comes to the house. When you say The comes 12 A No. I don't think so. He came without MI, 13 to the house.' you've worked since November of 2004, 13 he came first without =. 14 five years; when has he come to the house? 14 0 And did he knock on the door? 15 A He came after Mr. Epstein got out of jail. 15 A Yes. 16 0 And what did he do there? 16 0 Or does he have a key? 17 A He talked to Mr. Epstein, had breakfast. 17 A I think he knows the combination. 18 0 How long did he stay? 18 0 There is a combination to one of the doors to 19 A About a day. 19 get access to the house? 20 0 Okay. So he stayed overnight at the house? 20 A Yes. 21 A Yes. 21 0 And Story Cowles is one of the people who has 22 0 And was he accompanied by any females? 22 the combination? 23 A No. 23 A Yes. 24 0 Do you know what he does for a living? 24 0 Who are the other people that have the 25 A No. 25 combination to get in Mr. Epstein's house? • 0 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com EFTA00181504 Louella Rabuyo - Volume I October 20, 2009 125 127 1 A Me. 1 A No. 2 O Excuse me? 2 0 They weren't boyfriend and girlfriend yet? 3 A Me. 3 A No. 4 O Okay. 4 0 Do you know Mien that evolved into a boyfriend 5 A Janusz. 5 and girlfriend relationship? 6 O Okay. 6 A I don't know. 7 A Igor. 7 MR. EDWARDS: All right. 8 O Okay. MR. CRITTON: Are you done? 9 9 MR. EDWARDS: Probably. 10 Q Who is that? 10 MR. MM Do you need a second? Do you 11 A =. 11 need a break? 12 O And when Story came to Mr. Epstein's house 12 MR. MERMELSTEIN: Can we take a break? 13 without M, how long ago was that, do you remember? 13 (Brief recess in proceedings.) 14 MR. CRITTON: Form. la MR. EDWARDS: Jack, do you have questions. 15 THE WITNESS: How long ago? 15 too? 16 BY MR. EDWARDS: 16 THE WITNESS: I'm trying to get a photograph 17 O Yes. Was Mr. Epstein in jail, was it before 17 of somebody over Mere. I don't know if Esquire is 18 he went to jail? 18 going to be able to print it, if they've got a 19 A Oh. The other day he came without M. 19 color copier, or if I've just got to fun it over. 20 O But the other day is not the first time you've 20 How much longer do you-all plan on going, do 21 seen Story, right? 21 you know? 22 A Yes. 22 MR. CRITTON: About another fifteen minutes. 23 O The other day was the first time you've seen 23 I don't know. How long have you got, about 24 Story? 24 ten? 25 A No, no, no, no. I said he came without M. 25 MR. MERMELSTEIN: About ten, fifteen. 126 128 1 O Right. This whole back and forth started with 1 MR. CRITTON: I may have ten minutes worth of 2 me asking you when is the first time that you ever saw 2 questions. 3 Story. And I thought you responded by telling me that 3 MR. EDWARDS: Well be another thirty minutes 4 he came to the house for the first time without M. 4 at least. 5 I don't want to put words in your mouth, we'll start 5 MR. HILL: 1 might just get in the car and 6 over. 6 shoot over there. 7 A Okay. 7 MR. EDWARDS: I think we're taking a break 8 O When is the first time you saw Story? 8 tight now anyway. 9 A When Mr. Epstein was in jail. 9 MR. CRITTON: Well, if we're going to take a 10 O Do you know why he came to the house? 10 break, then I want to do a lunch break. I've got 11 A No. 11 some stuff I have to do. If we're only going to be 12 O Do you know who he talked to when he was 12 fifteen or twenty minutes. that's fine. But if 13 there? 13 we're going to go another half hour, let's take a 14 14 lunch break. 15 O And what did he talk to about? 15 MR. EDWARDS: It's going to take a while. 16 A I do not know. 16 MR. CRITTON: So let's take a lunch break. 17 O Did he talk to MI about Jeffrey being in 17 (Brief recess in proceedings.) 18 jail? 18 (Continued to Volume II.) 19 MR. CRITTON: Form. She said she didn't know. 19 20 THE WITNESS: I did not hear anything. 20 21 BY MR. EDWARDS: 21 22 O Where did they talk? 22 23 A In the kitchen. 23 24 O At the time were Story and Ml boyfriend and 24 25 girlfriend. did you know? 25 Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 ESQUIRE .Afl.4.OsH“nnn 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com EFTA00181505 Louella Rabuyo - Volume I October 20, 2009 129 1 STATE OF FLORIDA • 2 3 4 5 COUNTY OF PALM BEACH I. the undersigned authority. certify that 6 LOUELLA RABUTO personally appeared before me on the 20th 7 d October. 2009. and was duly sworn. 8 9 Dated this 30th day of October, 2(109. 10 11 12 13 14 Teresa Whalen, RPR, FPR is Notary Public - State of Florida My Commission Expires: 4/25/11 16 My Commission No.: DD 644533 17 Job a 118991 18 19 20 21 22 23 24 25 130 • 1 CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 I. Teresa Whalen. Registered Professional Reporter and Notary Public in and for the State of 6 Flonda at Large, do hereby certify that the aforementioned witness was by me first duly sworn to 7 testify the whole truth: that I was authonzed to and did report said deposition in stenotype: and that the foregoing pages are a true and correct transcription of my shorthand notes of said 9 deposition. 10 I further certify that said deposition was taken at the time and place hereinabove sot forth 11 and that the taking of said Opposition was commenced and completed as hereinabove set out. 12 I further certify that I am not attorney or 13 counsel of any of the parties. nor am I a relative or employee of any attorney or counsel of party connected 14 with the action, nor am I financially interested in the action. 15 The foregoing Certification of this transcript 16 does rot apply to any reproduction of the same by any means unless under the drect control and/or direction 17 of the certifying reporter. 18 19 Dated this 30th day of October, 2009. 20 21 22 Teresa Whalen, APP. FPR 23 Jai 8 118991 24 25 Toll Free: 866.709.8777 • Facsimile: 561.394.2621 Suite 600 ESQUIRE .....m." 4440 PGA Boulevard Palm Beach Gardens, FL 33410 wvnv.esquIresolutions.com EFTA00181506 S • • EFTA00181507 EFTA00181508 WORD INDEX RABUYO, LOUELLA • . • S • • EFTA00181509