EFTA00181472.pdf

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