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Louella Rabuyo - Volume I 57 intentionally exposes the genitals in a lewd or 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 of age commits lewd or lascivious exhibition. An offender eighteen years of age or older who commits a lewd or lascivious exhibition commits a felony of the second degree. Have you seen that crime committed in Mr. Epstein's house? A_ No, sir. MR. CRITTON: Form. BY MR. EDWARDS: Q_ Are you aware of the allegations by multiple female girls that allege that these are the crimes that were taking place behind closed doors when they were just minor females; are you aware of those allegations? MR. CRITTON: Form. MR. REINHART: Do you understand the question? MR. CRITTON: Asked and answered. MR. REINHART: Do you understand the question? MR. CRITTON: And argumentative. THE WITNESS: From the news, | heard that from the news. 58 BY MR. EDWARDS: Q_ And are you also aware that many of these girls did not know one another that were these female masseuses, are you aware of that? MR. CRITTON: Form. THE WITNESS: | don't know. BY MR. EDWARDS: Q Okay. When these girls that would come -- Where these females that would come over where you were told they were giving massages would come over, how many would come over at any time, meaning would they come over with twenty at time, or one at a time? MR. CRITTON: Form. THE WITNESS: Sometimes one at a time. BY MR. EDWARDS: Q_ And given the number of these females that are making these allegations, doesn't it cause you to believe the allegations that there are so many of them and their stories are so strikingly similar as to what's taking place in Mr. Epstein's bedroom? MR. CRITTON: Form, predicate, speculation, argumentative. THE WITNESS: | don't know what's happening in the bedroom, | did not see anything that cause me alarm. ESQUIRE an Alexander Gallo Company Case 1:15-cv-07433-LAP Document 1328-13 Filed 01/05/24 Page 5 of 9 October 20, 2009 59 BY MR. EDWARDS: Q_ Have you ever worked for anyone that had this many young females come over to his house every day? A No, sir. Q_ Have you ever heard anybody say that these girls are making this up or that this did not happen, these sexual acts did not happen in Mr. Epstein's bedroom? MR. CRITTON: Form, argumentative. BY MR. EDWARDS: Q_ By that | mean Mr. Epstein, Ghislaine Maxwell? A_ No, sir. No. Q_Did Sarah Kellen ever say any of these girls were making this up? A_ No, sir. MR. CRITTON: Form. BY MR. EDWARDS: Q_ So these girls are making these allegations, you work in Mr. Epstein's house? A Yes. Q_ And you've never heard anybody deny these allegations, have you? MR. CRITTON: Form, argumentative. THE WITNESS: | do my job, we don't, like, talk. 60 BY MR. EDWARDS: Q_Sois that a no, you've never heard anybody deny that? MR. CRITTON: Form. THE WITNESS: No, sir. BY MR. EDWARDS: Q_ When was the last time you talked to Ghislaine Maxwell? ‘A answer the phone when she... Q = Okay. When you first started working there back in November of 2004, she was the person who you interviewed with, right? A Yes, sir. Q_ Was she somebody who you would regularly see at the house during that period of time? A Not regular. Q_ How often would you see her in the house back in the late 2004, when you were hired, through 2005? A Three times. Q_ Three times a week? A_ No. During the period of that | was there. Q = Okay. During the entire five-year period you were there you only saw Ghislaine Maxwell three times? A_ Not five years. Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com GIUFFRE004402