EFTA00181472

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