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- Volume II 
October 20, 2009 
169 
MR. CRITTON: 
Form. 
THE WITNESS: 
Since I work? 
And then one 
year. 
BY MR. 
5 
Q 
You started 
work in 2005, right? 
6 
A 
Yes. 
7 
Q 
All right. 
And this happened up until 
the 
8 
time that Mr. Epstein went to jail where these young 
9 
ladies would come over? 
10 
MR. CRITTON: 
Form. 
11 
TMR WITNESS: Refnra ha wpnr rn jail'' 
12 
BY MR. 
13 
Q 
Yes, ma'am. 
14 
A 
Yes. 
15 
Q 
So we're talking about a period of years whore 
16 
this would happen, Light? 
17 
A 
Yes. 
18 
Q 
For the period of years that you were working 
19 
at Mr. Epstein's house where females would come to his 
20 
home for the purpose of providing him massages, you 
21 
don't remember the faces of any of them? 
22 
A 
You know, I just open the door and then I 
23 
cannot, I don't really, like, interact with them for a 
24 
long time. 
25 
But it is a true statement that you don't 
• 
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remember the faces of any of the females that would come 
to your boss's house, Jeffrey Epstein's house, over the 
period of years for the purposes of providing him 
massages? 
MR. CRITTON: Form. 
THE WITNESS: No. 
BY MR. 
Q 
It's true that you don't remember any of the 
faces? 
A 
If you show me picture, then 
Q 
No, ma'am. I'm asking you what you remember. 
A 
No. 
Q 
You don't remember any of their faces? 
A 
No. 
Q 
All right. Earlier you were asked about the 
folks that are at Mr. Epstein's house, and it sounds 
like one of those individuals is named Igor, the 
trainer? 
A 
Yes. 
Q 
All right. 
MR. 
BY MR. 
: Talking currently? 
Currently. 
: Thank you. 
Q 
When was the last time you saw Igor? 
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A 
Today. 
Q 
You saw him today? 
A 
Yes. 
Q 
When was Lhe time before that the last time 
that you saw him? 
A 
The last time? 
Q 
Yes, ma'am. You saw him today. When was the 
time before that that you saw him? 
A 
One week ago. 
Q 
All right. 
A 
Because T was on vacation. 
Q 
So you've been off for a week? 
A 
Yes, sir. 
Q 
So what day was it a week ago that you saw 
Igor the trainer? 
A 
• 
You and I both looked for a calendar but there 
isn't one up there. Today is Tuesday. You're talking 
this past Friday or the Friday before that? 
A 
I think 9th, October 9th. 
• 
So that was the last day that you worked up 
until Monday of this week? 
A 
Yen, Air. 
• 
And you worked October 9th and saw Igor, 
correct? 
•
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A 
Yes. 
Q 
And what is Igor's last name, do you know? 
A 
I don't know. 
Q 
Does Zinoviev sound familiar? 
A 
Because sometimes they called him Igor Z. 
Q 
Igor "Z," is that what you're saying? Yes? 
Igor then the letter "Z"? 
A 
Yes. 
• 
So you saw him October 9th, the last day that 
you worked. Where did you see him, at Mr. Epstein's 
house? 
A 
Yes, sir. 
Q 
Then you worked yesterday, right? 
A 
Yes. 
Q 
And you saw him? 
A 
No. 
Q 
When was the last time you saw him? You saw 
him today? 
A 
Today. 
Q 
Ah. Okay. And what was he doing today? 
A 
He was waiting to drive Mr. Epstein. 
• 
Okay. Do you have any understanding that 
Igor, Mr. Igor Z., left after you saw him on Friday 
October 9th and came back for you to see him at 
Mr. Epstein's house today? 
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A 
Can you rephrase the question? 
Q 
Sure. Do you know if he went anywhere in 
between the last time you saw him before today and 
October 9th? 
A 
Janusz told me he will be on vacation. 
Q 
He will be on vacation? When will he be on 
vacation. 
A 
The time that I will not be there. 
Q 
Oh. You were both on vacation? 
A 
Yes. 
Q 
So he's back now from what you believe to be 
his vacation? 
A 
Yes. 
Q 
No reason he can't show up for a deposition, 
right? 
MR. CRITTON: Form. 
THE WITNESS: I don't know. 
MR. 
: I don't know, either. Okay. 
That's all I have. Thank you. 
THE WITNESS: You're welcome. 
MR. CRITTON: Can I switch with you? 
CROSS ( 
SY MR. CRITTON: 
Q 
, my name is Bob Critton, I represent 
Mr. Epstein. I have a few follow-up questions based on 
• 
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174 
questions that have been asked to you. 
If I understood your earlier testimony --
well, let me ask you this: Do you have any personal 
knowledge that any female ever gave Mr. Epstein a 
massage; that is, were you ever present when a massage 
took place? 
A 
No, sir. 
Q 
So you've been asked a lot of questions about 
females coming to the house to give Mr Epstein a 
massage, right? You've been asked a lot of questions 
about that today? 
A 
Yes, sir. 
Q 
Okay. As to whether or not any female ever 
gave Mr. Epstein a massage, do you have any personal 
knowledge? 
A 
No, sir. 
Q 
All right 
You were asked a question by 
Mr. 
and others as how many faces of the females you 
remember who came to Mr. Epctoin'o houoo to give him a 
massage, do you remember any faces. Do you recall those 
questions? 
A 
Yes. 
• 
Okay. In fact, you're -- let me strike that. 
Would it be a correct statement that you're 
unaware of any females that came to his house that you 
0 
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175 
know actually gave him a massage? Is that correct? 
A 
Correct. 
Q 
You were shown a document marked Exhibit 2 
which was a bunch of message pads. Well, it was an 
exhibit, a composite exhibit that included a lot of 
message pads -- let me start again. 
Exhibit 2 has a lot of message pads, I'm 
sorry, a lot of papers. It looks like it has four 
"Important Message" and then there's a place to list who 
called, the date, and what the response should be; 
correct? 
A 
Yes. 
Q 
All right. You were asked earlier by 
Mr. 
whether you took phone calls for Mr. Epstein 
from any females who called about giving a massage. If 
I understood your testimony, no conversation that you 
ever -- well, let me strike that. 
If I understood your testimony, you never had 
a conversation with a female who called on the phone 
where the word "massage" was used? 
A 
NO, sir. 
Q 
Is that correct? 
A 
Correct. 
• 
All right. And when you were you responding 
to Mr. 
' questions about taking messages, did you 
• 
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just take -- that is, if a female called or a male 
called or whoever called and you happened to answer the 
phone, if they wanted to leave a message, did you fill 
out a message pad? 
A 
Correct. 
Q 
All right. So it didn't have to be a female 
who was giving a massage; it could have been a florist, 
it could have been a friend, it could have been anyone 
as far as ymn knnw7 
MR. 
: Object to form. 
MR. 
: Object to the form. 
THE WITNESS: Correct. 
BY MR. CRITTON: 
Q 
Well, did anyone ever say I'd like to come 
over and give Mr. Epstein a massage to you? 
A 
NO. 
MR. 
: I don't know if we talked about it 
yet, but is an objection by one good for all, or do 
we need to repeat everybody cloc'e objection? 
MR. 
I think it's good for all. 
: I'm fine with that. 
BY MR. CRITTON: 
Q 
If I understand your testimony, in the 
approximately three years that you worked at 
Mr. Epstein's house before June of '08, so it would have 
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177 
been the latter part of '05, '06, '07, and then '08 
through June, on the rare occasion you might answer a 
doorbell and someone might come in, that is, a female 
might come in who purportedly was to give Mr. -- let me 
strike that. 
As to any of the females that came to the door 
and punched the doorbell and you answered, do you know 
why they were there; that is, do you have any personal 
knowledge as to why they were there? 
A 
Sometimes. 
O 
Okay. And how would you know that? 
A 
Either Alfredo will tell me that this one is 
expected. 
Q 
Who was going to give a massage? He might say 
something like that, or just that the person is 
expected? 
A 
No. Is expected. 
• 
All right. And so if in fact -- let me strike 
that. 
During '04 -- I'm sorry. 
MR. CR1170M: What did she say, '05 when she 
started? 
MR. 
She started November of 2004, 
but then she just recently changed it to say she 
started 2005, so I don't know. 
. 
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Louella 
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October 20, 2009 
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178 
MR. CRITTON: That may have been me. 
BY MR. CRITTON: 
Q 
Did you start in 2004, November 2004? 
A 
Yes. November. 
Q 
When you started in November of 2004 and up 
through 2005, on how many occasions would you have 
answered the door where a female was coming that Alfredo 
said you can expect such and such? 
Does that make sense to you? 
MR. 
: Object to the form. 
BY MR. CRITTON: 
Q 
Do you want me to rephrase that? 
A 
Can you rephrase it? 
Q 
If I understood your testimony, your business 
is tidying, keeping the house tidy, laundry, 
straightening up, things of that nature? 
A 
Yes. 
Q 
All right. And that's most of your day when 
you're there? 
A 
Yes. 
• 
And when you're off, you don't know what goes 
on at the house? 
A 
No. 
Q 
Or for that matter any place else. If you're 
not there, you have no personal knowledge what goes on 
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179 
at the mall if you're not there, right? 
MR. 
: Form. 
THE WITNESS: Correct. 
BY MR. CRITTON: 
Q 
All right. On approximately how many 
occasions would you have ever answered the door during 
the '04, '05 time period where a female came in and you 
left them alone in the kitchen or offered them something 
to drink? Are we talking three or four times, are we 
talking five or ten times, or more or less? 
MR. 
Form. 
THE WITNESS: That specific time? 
BY MR. CRITTON: 
Q 
Yeah. During '04 and '05 from the time you 
started in '04 through the end of '05. 
A 
I cannot remember how many times. 
• 
Okay. Was it often or rarely that you were 
the one who actually let someone in the house? 
A 
Rarely. 
Q 
All right. And did you ever see a female 
coming, and i'm not talking 
or 
, did you ever 
see a female coming down the stairs into the kitchen 
ever? 
A 
Yes. 
Q 
On how many occasions, your best recollection? 
• 
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MR. 
she worked there? 
180 
What time frame? The whole time 
BY MR. CRITTON: 
Q 
'04, '05, '06. 
A 
Rarely. Maybe. 
Q 
Let me rephrase my question. 
During the period '04 and '05, through the end 
of '05; that is, November of '04 through the end of '05, 
approximately how many times did you see someone, a 
female, who would come from upstairs downstairs? And 
I'm not talking about 
or 
or someone there 
who was there regularly. 
A 
Maybe three times. 
Q 
Okay. And on the three times that you saw 
someone come down the stairs, you saw them where, in the 
kitchen? 
A 
Yes. 
Q 
Did anyone ever look upset? 
A 
No. 
Q 
Did anyone look like they were crying? 
A 
No. 
Q 
Did anyone look distraught? 
A 
No. 
Q 
Did any those people cry for help? 
A 
No, sir. 
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181 
• 
During the entire time that you've been 
working for Mr. Epstein, from November of '04 through 
'05 did you ever hear a female cry for help? 
A 
No. 
Q 
Did you ever hear them yell out for help? 
A 
No, sir. 
• 
Did you ever hear someone scream for help? 
A 
No. 
Q 
Did anyone ever ask you to call the police? 
A 
No, sir. 
Q 
Did anyone ever tell you that they were 
molested? 
A 
No, sir. 
Q 
Did anyone ever tell you that they were 
abused? 
A 
No, cir. 
Q 
Did anyone tell you that they had received any 
type of physical harm? 
A 
No. 
Q 
Okay. Did anyone appear to have, at least 
from your observations of their facial features, to have 
been in any way emotionally upset or distraught? 
A 
No. 
Q 
Okay. You were asked a number of guest- nr 
about what you observed or -- let me strike that. 
• 
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182 
You were asked a number of questions by 
Mr. 
about what was taken from the house by the 
police. Do you remember those questions? 
A 
Correct, I remember. 
Q 
Were you present when the police took certain 
items from Mr. Epstein's home? 
A 
No sir. 
Q 
Do you know what the police have in their 
possession? 
A 
No. 
Q 
Did anyone ever tell you what the police took 
from the house, other than I think you said Janusz said 
they took computers? 
A 
I cannot remember he said computers. I 
remember pictures. 
Q 
Okay. That's what Janusz told you? 
A 
Yes. 
Q 
But you have no personal knowledge? 
A 
No, sir. 
Q 
That's correct? 
A 
Correct. 
Q 
All right. You talked about a photograph of 
what you described as an approximately four-year-old 
girl and it looked like the back portion of a swimsuit 
or some bottoms she had on was being pulled down a 
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- VOlume II 
October 20, 200) 
183 
little bit? 
A 
Correct. 
0 
Is that Mr. Epstein's Goddaughter? 
MR. 
: 
Object to Lhe form. 
BY MR. CRITTON: 
Q 
Strike that. 
Do you know whether or not that's a picture or 
Mr. Epstein's Goddaughter? 
9 
MR. 
: Form. 
10 
THE WITNESS: I was told that. 
11 
BY MR. CRITTON: 
12 
Q 
By whom? 
13 
A 
By Lyn. 
14 
Q 
Lyn up in New York? 
15 
A 
Yes. 
16 
Q 
All right- You were asked about what you 
17 
described as a back massager. Do you recall that 
18 
earlier? Mr. 
asked you and I think Mr. 
19 
In fact, I think all the other lawyers asked you that 
20 
question. 
21 
A 
Yes. 
22 
Q 
Is the item that you describe as a back 
23 
massager, have you seen that like -- let me strike that. 
24 
Do you know what Brookstone is? 
25 
A 
Yes. 
• 
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184 
Q 
Is the item that you saw similar to something 
that you've seen at Brookstone? 
MR. 
: Objection to form. 
THE WITNESS: Yes, sir. 
BY MR. CRITTON: 
Q 
You were asked a number of questions about 
Ms. Maxwell. Do you recall that series of questions? 
A 
Yes. 
Q 
What was your relationship with Ms. Maxwell; 
did you get along well with her, did you find her 
difficult, easy going? 
A 
I have a good relationship with Ms. Maxwell. 
Q 
Okay. Did she always treat you with respect? 
A 
Yes. 
Q 
And I think you told us that she's the one who 
actually hired you? 
A 
Correct. 
Q 
Was Alfredo Rodriguez the person responsible 
for hiring you, or was it Ms. Maxwell? 
A 
Ms. Maxwell. 
• 
And when you started, you first said that you 
thought -- well, let me strike that. 
in your earlier testimony you said that 
Mr. Rodriguez was your boss, and then you said well, 
really we work side by side. 
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185 
So my question to you is was Mr. Rodriguez 
your boss, or were you co-equals in the house and you 
each had your own job? 
A 
We have our own job. He told me he is my 
supervisor. 
• 
Okay. 
A 
But Ms. Maxwell told us we have to work like, 
you know, work together for the house. 
Q 
For the good of the house? 
A 
Yes. 
• 
So if he needed help you'd help him, if you 
needed help he was supposed to help you? 
A 
Correct. 
• 
Did Ms. Maxwell ever tell you that 
Mr. Rodriguez was your boss, or only Mr. Rodriguez? 
A 
Mr. Rodriguez tell me. 
Q 
okay. was Mr. Rodriguez -- let me strike 
that. 
Mr. Rodriguez was working at the house when 
you started? 
A 
Correct. 
Q 
And he continued for how long after you 
started? That is, you started sometime in mid November 
of '04, how many more months did he work? 
A 
I think up to February. 
• 
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186 
Q 
February of '05? 
A 
'05. 
Q 
And did he resign, or was he terminated? 
A 
He was terminated. 
Q 
Do you know why he was terminated? 
A 
One reason I know is one time he did not bu•: 
any food when Mr. Epstein came, the refrigerator was 
empty. 
Q 
Was that his job, to make certain there was 
food in the house when Mr. Epstein came to town? 
A 
It was his job. 
Q 
All right. Did you consider Mr. Rodriguez an 
honest person? 
MR. 
: Object to the form. 
MR. 
: Form. 
THE WITNESS: NO. 
BY MR. CRITTON: 
Q 
Why not? 
MR. 
Object to the form. 
THE WITNESS: Because he used my name. He had 
almost a fist fight with a gardener. 
BY MR. CRITTON: 
Q 
Was that Jerome? 
A 
Jerome. And he used my name that I am a 
witness of the time that Jerome comes to work. So 
0 
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- Volume II 
October 20, 2009 
187 
Jerome talked to me, and I told Alfredo not to use my 
name, because I don't keep tab of people's time coming 
in and out. 
I told Alfredo, if you ask me if Jerome is 
here, I say he's here; if he's not, he's not. But I 
6 
don't tell you he came this time and that time. So I 
7 
was upset too with Alfredo, because I said that's a lie, 
8 
don't use my name. 
9 
Q 
All right. Now, you were asked some 
10 
questions, a number of questions as to what 
11 
Mr. Rodriguez testified at his deposition that he said, 
12 
Mr. Rodriguez, that you were disgusted with cleaning sex 
13 
toys. Do you remember that question? 
14 
A 
Yes. I remember. 
15 
Q 
And I think your testimony is you never had 
16 
that conversation with Mr. Rodriguez; is that correct? 
17 
A 
No, sir. 
18 
Q 
So I think you --
19 
: Hold on. I think you said your 
20 
testimony is, she said no, sir. Can we be clear 
21 
what the question and answer was? 
22 
BY MR. CRITTON: 
23 
Q 
Did you ever tell Mr. Rodriguez that you were 
24 
disgusted with cleaning sex toys? 
25 
A 
No. 
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- Volume II 
October 20, 2009 
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188 
Q 
All right. And if he said that, was he lying? 
MR. 
: Form. 
THE WITNESS: He is. He was. 
BY MR. CRITTON: 
Q 
If I asked you to assume Mr. Rodriguez said 
that you were upset because there were pictures of 
partially-clothed or naked women near a picture of the 
Pope, I ask you to assume that he said that, would that 
be true? 
A 
That's a lie. 
Q 
All right. Was there a picture of the Pope in 
Mr. Epstein's house? 
A 
Yes. 
Q 
All right. Was that near any picture of any 
individual in some state of undress? 
A 
No. 
Q 
Did Mr. Rodriguez ever lie to you? 
MR. 
: Object to the form. 
MR. 
: Form. 
THE WITNESS: Using my name was a lie. 
BY MR. CRITTON: 
Q 
Okay. Did he ever ask you to lie tor him? 
A 
One time. 
Q 
What happened? 
A 
Mr. Epstein was not in his house, he's away, 
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