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IN THE CIRCUIT COURT OF THE F1I-IEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
L.M.,
Plaintiff,
vs. CASE No.
502008CA02805IXXXXMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LOUELLA RABUYO
VOLUME I
October, 20, 2009
10:10 a.m.
515 N. Flagler Drive
Suite 200-P
West Palm Beach, Florida 33401
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, FL 33410
www.esquIresolutions.com
EFTA00181472
•
•
•
EFTA00181473
Louella Rabuyo - Volume I October 20, 2009
1 3
IN Tit CIRCUIT can or TM FIrrudem JUDICIAL CIRCUIT 1 APPEARANCES:
• IN AND FOR PALM BRACH COUN7y, FLORIDA
CIVIL D1VISLON
CUR Ito.9010000.0210,:xxXXXR As
Plaintiff,
2
3
4
On behalf of the Defendant.
ROBERT D. CRITTON. JR.. ESQUIRE
BURMAN CRITTON LUTTIER & COLEMAN. UP
303 Banyan Boulevard, Suite 400
.TRIIIRRY IIPSTRIN, 5 West Palm Beach. Florida 33401
Phone: 561.8422820
Defendant . 6
7 On behalf of Plaintiff L.M.:
B BRADLEY J. EDWARDS. ESQUIRE
DEPOSITIO1 or wuRLLA Ramiro CARA L. HOLMES, ESQUIRE
Viratelt I
9 ROTHSTEIN ROSENFELDT ADLER
Tuesday, October, 20. 2009 40t E. LEIS 0419 Boulevard. Suite 1650
10:10 - 1,10 pre 10 Fort Lauderdale. Florida 33394
Phone: 954.522.3456
11
515 N. Plagler Drive. Suite 200-P 11 On behalf of trosetappess
Wen Palm Beach, Florida 13401
13 BRUCE E. III IE
LAW OFFICE OF BRUCETIIIIIIII
Reported By: 14 250 S. Australian Avenue. Suite 1400
Teresa Whaler., RPR, PPR West Palm Beach, Florida 33401
Notary Public, State of Florida Is Phone: 561202.6360
Nest rain Beach Office Job 411001
16
17 On behalf of Dolenclantsclane Does 2 - 8:
le STUART S. MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, PA.
19 18205 Biscayne Boulevard. Suite 2219
Miami. Florida 33160
20 PhOole: 305.9312200
21 On behalf of Plaintiff In related Case No. 08-80811
22 JACK HILL. ESQUIRE IP/weary via speakerphone)
SEARCY. DENNEY, SCAFIOLA BARNHART e• SHIPLEY
23 2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
24 Phone: 561.686.6300
25
2 4
1 1 - - -
•
UNITED STATES DISTRICT COURT
SOU tHERN DISTRICT OF FLORIDA 2 INDEX
2
CASE No.08-CV-80119-CIV-MARRNJOHNSON 3 - - •
3 4
4 JANE DOE NO. 2,
5 5 WITNESS: DIRECT CROSS REDIRECT RECROSS
Plaintiff, 6
7 JEFFREY EPSTEIN. LOUELLA RABUTO
6 Defendant 7
9 Related Cases: 8 BY MR. EDWARDS: 5 190
03-80232. 08.80380. 98-60381, 08-80994. s BY MR. MERMELSTEile 135 208
10 08.60993, 08-80811. 08-80893. 09-80469,
09430591. 09.80656. 09-80802. 09-81092 10 BY MR. HILL: I%
il ..__f 11 BY MR. CARTON: 173
12
12
DEPOSITION OF LOUELLA RABUTO
13 VOLUME I 13 - • -
14 14 EXHIBITS
Tuesday, October 20.2009
Is 10:10 • 3:30 p.m. Is -- -
16 26
515 N. Flag's( Deno, Stale 200-P
17 17 NUMBER DESCRIPTION PAGE
West Palm Beach. Florida 33401 le DEFENDANTS EX. 1 COPIES. COMPOSITE PHOTOGRAPHS 103
18
19 19 DEFENDANTS EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
20 20 DEFENDANTS EX. 3 COPY OF PHOTOGRAPH 162
21 Reponed By:
Tenni Whalen, RPR. FPR 21
22 Notary Pubec. State of Fonda 22
Weal Palm Beath Office Job 1118991
23 23
Phase: 800.330.6952
561.659.4155 24
24 25
25
• • Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA00181474
Louella Rabuyo - Volume I October 20, 2009
5 7
1 PROCEEDINGS 1 0 How long have you been employed by
2 • • • 2 Mr. Epstein?
3 Deposition taken before Teresa Whalen. 3 A It will be five years this November 17th.
4 Registered Professional Reporter, Florida 4 0 So you started November 17th, 2004?
5 Professional Reporter, and Notary Public in and for 5 A Yes. sir.
6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein?
7 - - 7 A Through an agency.
Thereupon, 0 What agency?
9 (LOUELLA RABUYO) 9 A It's Regal Domestics.
10 having been first duly sworn or affirmed, was examined 10 0 And what was your position that you were hired
11 and testified as follows: 11 by Mr. Epstein tor?
12 THE WITNESS: I do. 12 A Housekeeper.
13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness
14 MR. EDWARDS: Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Are you familiar with
IS record what case this is being taken in? I noticed 15 that name?
16 it in L.M. versus Epstein. I don't know if anybody 16 A Yes.
17 cares to say who your clients are, what the case 17 0 And that person. I believe he represented that
18 style is or anything else for when she types it up. 18 he was also maybe a house manager. Is that correct?
19 MR. MERMELSTEIN: I don't have a problem with 19 A Correct.
20 that. Are we doing initials? 20 0 Would he have been, at some point in time,
21 MR. EDWARDS: Yeah. Initials. 21 your boss or your superior?
22 MR. MERMELSTEIN: Okay. 22 A Yes.
23 BY MR. EDWARDS: 23 0 That's somebody who you answered to,
24 0 All right. Will you state your name for the 24 Alfredo Rodriguez?
25 record. 25 A (Nodding head). Sometimes •-
6 8
A Louella Rabuyo. 1 You have to say yes or no. you
2 0 And what's your current address? 2 can't nod your head.
3 A 904 Summer Street, Lake Worth. 3 BY MR. EDWARDS:
4 0 All right. How long have you lived at 904 4 O Yes?
s Summer Street? 5 A Yes.
6 A About two years. 6 MR. CRITTON: No, no. She said sometimes.
7 0 Two years. Where did you live prior to 904 7 then you put yes In her mouth.
8 Summer Street? 8 MR. EDWARDS: I didn't put anything in her
9 A In Palm Ridge Apartment, that's in Mango 9 mouth. I don't want the record —
10 Drive. 10 MR. CRITTON: Let me take it back. You said
11 0 How long did you five there? 11 yes, but she started to say something before she
12 A About a year. 12 was interrupted.
13 0 All right. Where did you live prior to that. 13 BY MR. EDWARDS:
14 the Palm Ridge Apartment? 14 0 That's fine. You can answer the question.
15 A In a townhouse in West Palm Beach. 15 then we'll Instruct you on the deposition.
16 Q Okay. How long did you live in the townhouse 16 MR. : Did you want to explain that
17 in West Palm Beach? 17 further?
18 A Less than a year. 18 THE WITNESS: Because we were supposed to work
19 0 Have you ever lived at Jeffrey Epstein's 19 together, but he was bossy, he was bossy.
20 location of 358 El Brillo Way? 20 BY MR. EDWARDS:
21 A No, sir. 21 O Okay. Have you ever had your deposition taken
22 0 Where are you currently employed? 22 beforeliko this?
23 A Mr. Epstein. 23 A No.
24 0 And what address do you report to work? 24 0 All right. Well, there is one court reporter,
25 A 358 El Brillo Way. 25 and it's very easy in casual conversation to nod your
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Palm Beach Gardens, FL 33410
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EFTA00181475
Louella Rabuyo - Volume I October 20, 2009
9 11
1 head or shake your head. and she can't take that down. 1 that it's clean and appropriately, what's this...
• 2
3
4
5
A All right.
0 It's also very easy to say uh-huh or huh.uh,
but it kind of looks the same on paper, so you can't do
that either. I'm going to wait until you finish your
2
3
4
0 And as I understand this properly, there is a
main house and then there's also a staff house on the
property: is that right?
A Yes, sir.
6 answer, and you have to wad until I finish my question, 6 0 And when the guests would come over, would you
7 because if we talk over one another, then the cowl 7 stay in the main house, or would you go to the staff
8 reporter can't got it down. 8 house?
9 A Okay. Yes, sir. 9 MR. : Can we get a time frame to the
10 0 MI right. So if you don't understand the 10 question?
11 question, tell me you don't understand and ill try to it BY MR. EDWARDS:
12 ask a better question. 12 0 Over the last five years while you worked
13 A Yes. 13 there.
14 0 Okay. So you were Nred In November of 2004 14 A I usually stay in the staff house and do the
15 to be the housekeeper for Mr. Epstein? 15 laundry, then I go to the kitchen and then tidy the
16 A Yes. 16 kitchen.
17 0 And when you were hired, who exactly hired 17 0 You were hired in November of 2004. and what
18 you, who -- let me strike that. 18 were your hours that you worked there back in November
19 When you were hired to be the housekeeper for 19 of 2004 when you were hired?
20 Mr. Epstein, who did you interview with? 20 A Eight to five.
21 A Ms. Maxwell. 21 0 How many days a week?
22 0 Is that Ghislaine Maxwell or just 22 A Depends.
23 Leine Maxwell? 23 0 How would the schedule be relayed to you?
24 A Ghislaine Maxwell. 24 A When Mr. Epstein is there, then I'm supposed
25 0 And where did the Interview take place? 25 to report, but usually it's five days a week.
10 12
0 So am I correct In understanding that there
• 1
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3
4
A At 358 El Brilb Way.
0 And what did Ms. Maxwell and you speak about
prior to your being hired as the housekeeper?
A My duties.
2
3
4
was one schedule when Mr. Epstein was in town, and the
schedule may be a little bit different if Mr. Epstein
was out of town?
5 0 And what did she tell you your duties would 5 A Yes, sir.
6 be? 6 O All right. Toll me the differences when
7 A To tidy. to make beds. do laundry. 7 Mr. Epstein is in town versus when Mr. Epstein was not
8 0 Did she tell you what would take place in the ri in town.
9 house on a day-to-day basis? 9 A II he stays like three or four days, then I'm
10 A No. to supposed to be there, and then the house is to be
11 0 So going into that position, you had no idea 11 cleaned. And then when they do not come, then I can
12 who the guests would be or who the people coming in the 12 either go there, or I'm given free days off.
13 house would be, or what would generally go on? 13 0 Three days off?
14 A Can you simplify the question? 14 A No. A free day.
15 0 Sure. When you talked about with 15 0 Oh, okay. But typically back in 2004 when you
16 Ghislaine Maxwell at this interview, your duties being 16 were hired, you worked an average of about five days a
17 you would make the bed and tidy up, did she also tel 17 week; is that correct?
18 you that there would be a lot of guests, there would be 18 A Yes.
19 a few guests, did she talk to you about that at all? 19 0 All right. And I guess by the way that you're
20 A She mentioned that it there are guests, we 20 explaining it, if Mr. Epstein was in town for a longer
21 have to. like, you know, prepare the room, and, what's 21 period of time, you may work more than five days, and it
22 this, attend to the guests. 22 Mr. Epstein was not in town, you may work less than five
23 0 And what did you understand that to mean that 23 days?
24 you have to attend to the guests? 24 A Yes.
25 A You have to prepare the room and see to it 25 0 Okay. Did you ever talk to Mr. Epstein prior
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Louella Rabuyo - Volume I October 20, 2009
13 15
1 to being hired? 1 0 Did she tell what you would be paid at that
2 A No, sir. 2 time?
3 Q Where did this meeting, within the house where 3 A Not yet.
4 did the meeting with Ornstein° Maxwell take place? 4 0 Did you show up that Saturday? I guns that's
5 A In the living room. 5 November 17th of 2004?
6 0 Aside from teeing you that you were going to 6 A No, that's not.
7 be required to make the beds and just generally tidy up, 7 0 No. Was it prior to November 17th of 2004, or
8 did she specify anything else that you would be required atter?
9 to do? 9 A After.
10 A No. to 0 Okay. The interview that you first went to
11 0 Where had you worked prior to working for 11 was November 17th, 2004 with Ms. Maxwell; is that the
12 Mr. Epstein? 12 date that you gave us?
13 A I work as a certified nursing assistant. 13 A I cannot remember.
14 0 Where? 14 0 The only reason I'm using that date Is I
15 A At that time I was doing private duty. is believe the question I asked was when did you start
16 0 How long have you been a certified nursing 16 working for Mr. Epstein, and I thought the date that you
17 assistant? 17 gave me was November 17th, 2004.
18 A Since about ten years. 18 A Yes.
19 0 And what made you change professions from 19 0 Okay. And in the course of this whole thing,
20 being a certified nursing assistant to be a housekeeper 20 it sounds like you interviewed with ChIslaine Maxwell.
21 for Mr. Epstein? 21 there were other interviewees, you received a call and
22 A The agency called me that there is an 22 you were asked to try out on a Saturday?
23 interview; it I like. I go to, so that's how it started. 23 A Yes.
24 0 And when you went to the interview, obviously 24 0 And where does that Saturday fall in related
25 you're going to this very big house and you talked to 25 to November 17th, 2004?
14 16
1 Ornstein° Maxwell, right? i A When I accepted the job otter.
2 A Yes 2 0 Okay. And did they tel you at that time when
3 0 And did you decide right then that you liked 3 you accepted the job otter how much you were going to be
4 this and that you were going to change professions and 4 paid?
s you were going to be his housekeeper? 5 A Yes.
6 A No. 6 0 What was that?
7 0 Okay. Then walk me through that, how did you 7 A II was 32,000 per annum.
8 go about eventually accepting the position? a 0 And has your salary increased over time?
9 A I didn't expect to be hired, because there 9 A Yes, sir.
10 were other interviewers (sic), interview people that to 0 And can you walk us through the increments of
11 were to be Interviewed. 11 increase in your salary?
12 a Okay. 12 A It was promised yearly increase.
13 A And then I receive a call from Ms. Maxwell if 13 0 By whom?
14 I like. I can do a try-out. 14 A Ms. Maxwell.
15 0 Okay. Did she tell you hew long this try-out is 0 Was that at the time when you were
16 period would last? 16 interviewed. or took the job?
17 A No. 17 A Yea. Sir.
18 0 And what did you tell her when she made that 18 O Did she promise you what your yearly increase
19 offer for you to by out? 19 would be?
20 A I told her that I am still taking care of this 20 A No.
21 patient, so she said if you like, you can come Saturday 21 0 And have you received a yearly increase every
22 and try it. 22 year?
23 0 Okay. And what did you tell her, did you 23 A I did.
24 accept that? 24 0 And what has that yearly increase been?
25 A Yes, I did. 25 A Up to 42.
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EFTA00181477
Louella Rabuyo - Volume I October 20, 2009
17 19
1 0 Today? 1 0 Okay. So lets talk about that. Back in
• 2
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5
A Yes.
0 So you're making $42,000 today, and that's the
most that you've made over the five-year period you've
worked for Mr. Epstein?
2
3
4
5
November of 2004, you were to working 8:00 a.m. to
5:00 p.m. And when did that schedule change from 8:00
5:00?
A When? When the house was renovated.
6 A Yes, sir. 6 0 When was that, do you remember the yew?
7 0 At the time when you — when we took 7 A 2006.
B Alfredo Rodriguez's deposition, he described you as a 8 0 Okay.
9 very religious Catholic woman. Does that accurately 9 MR. CRITTON: I'm sony. '06?
10 describe you? 10 THE WITNESS: '06.
11 MR. CRITTON: Let me Just object to the loran. 11 BY MR. EDWARDS:
12 MR. : You can answer the question if 12 0 So from November 2004 through '06. I'm correct
13 you understood it. 13 in presuming that your schedule was an average of five
14 THE WITNESS: I am a Catholic and I go to 14 days a week from 8:00 a.m. to 5:00 p.m.?
15 mass. 15 A At that time I go nine o'clock, I go to the
16 BY MR. EDWARD$: 16 house at nine o'clock.
17 0 Is that something you go to regularly? 17 0 Starting in 2006?
18 A II I have time. I go regularly. 18 A Yes.
19 0 When do you normally go to mass? 19 0 So when your schedule changed from 8:00 to
20 A Sunday masses and weekdays. 20 5:00, in 2006 you started going to the house.
21 0 How many weekdays? 21 Jeffrey Epstein's house, at nine o'clock?
22 A If I can, every day. 22 A Yes, sir.
23 0 And in the five-year period that you've worked 23 0 And you would stay until what time?
24 for Mr. Epstein, have you tried to go every day if you 24 A Sometimes 5:00, sometimes later, 5:30.
25 could? 25 0 Would lhat depend on what needed to be done?
18 20
A Yes.
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4
A No.
0 In a typical week would you normally go on
Sunday to mass?
A Yes, sir.
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C1 How have you received your money, has it been
by check, by cash, in terms of payment from Mr. Epstein?
A Its directly deposited to my bank.
5 0 And how many days during the week will you 5 0 Do you know who directly deposits your money?
6 also attend mass? 6 A Who?
7 A If the schedule permits, then I go, but if 7 0 Yeah. Whether it's Ghislaine Maxwell or a
8 not, then I don't go. corporation or Jeffrey Epstein, do you know who the
9 0 So is there a way that you could give me an 9 direct depositor is of your check?
10 average of how many times a week that you go during the 10 MR. CRITTON: Form.
11 week to mass? 11 THE WITNESS: Mr. Epstein.
12 A Mistime? 12 BY MR. EDWARDS:
13 0 Right. Yeah. I guess today, these days. 13 0 Okay. Over the five years that you have been
14 A I attend Sunday masses only. 14 working at Mr. Epstein's house, how many conversations
15 0 And back in 2004, when you first started with 15 have you had directly with Mr. Epstein?
16 Mr. Epstein? 16 A What's this, what year?
17 A I tried to go if I have the time, sir. 17 0 Well, in the last five years, how many
18 0 Was there ever a time that you went every day? 18 conversations have you had directly with Mr. Epstein?
19 A No. 19 MR. CRITTON: Form.
20 0 But your testimony is that if time permitted, 20 THE WITNESS: The past year it's just good
21 you tried to go every day? 21 morning, how are you, you're doing a good job.
22 A Yes. 22 BY MR. EDWARDS:
23 0 Is there a reason why now these days you only 23 0 Okay. How was it prior to that, did you talk
24 attend on Sundays? 24 to him more?
25 A Because my time schedule has changed. 25 A This time more.
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EFTA00181478
Louella Rabuyo - Volume I October 20, 2009
21 23
O Now you talk to him more? 1 A Yes.
2 A Because I serve him breakfast, so... 2 O When did you talk to Lyn Fontanilla about
3 O And is that an additional responsibility that 3 == .7
4 you dickil have before? 4 A It was just through the conversation.
5 A Yes. 5 O What would cause you to be in a conversation
6 O In the five•year period that you've worked 6 with this person in New York?
7 there, can you name for me all of the other employees 7 MR. CRITTON: Form.
8 who have worked at the Jeffrey Epstein house? B THE WITNESS: She calls me, I call her.
9 A After Alfredo Rodriguez left, there was BY MR. EDWARDS:
lo Jerome, the gardener, and now ifs Yanusz. 10 O You're friends?
12 O And those are the house managers? 11 A Yes.
12 A Yes. 12 O Do you still talk to her today?
13 O And then you work there? 13 A Yes.
14 A Right. 14 O And does she work for Mr. Epstein as well, to
is O Aside from yourself, Jerome, and Janusz, was 15 your knowledge?
16 there anybody else that you can remember working at the 16 A She does.
17 house in the past five years in any position? 17 O And does Joie. her husband, also work for
19 A Yes. 18 Mr. Epstein as well?
19 O Who else? 19 A Yes, sir.
20 20 O Where do they work?
21 21 A In New York.
22 A Yes. 22 O At Mr. Epstein's house in New York?
23 O What does she do there? 23 A Yes, sir.
24 A She's the personal assistant. 24 O And have you talked with them about your
25 O Personal assistant to whom? 25 duties and has she talked to you about her duties?
22 24
1 A Mr. Epstein. 1 A Yes, sir.
2 O And as his personal assistant, what have you 2 O And your duties are similar to Lyn's duties in
3 observed her to do for him? 3 New York?
4 A Can you rephrase your question? 4 A No. Because that's a bigger house than...
5 O I can try. You said that she's his personal 5 O Palm Beach?
6 assistant. What does that mean, what does she do? 6 A Yes. sir.
A Order things that I need, or, what s this. 7 O Is it your understanding that -- you know,
8 O So ifs your testimony that has a we're going to get into the past two years where
9 been, for the past five years that you've worked there, 9 Mr. Epstein has either been in jail or he's been on
10 has been somebody that you have observed to order things 10 house arrest in Palm Beach, so I'm going to ask you
11 that you need? 11 first for the first three years that you worked there
12 A If I need something, then I go to ask 12 and Mr. Epstein was traveling, was Mr. Epstein spending
13 O Okay. What other things have you seen 13 the majority of his time in Palm Beach or in New York or
14 do for Mr. Epstein? 14 elsewhere, if you know?
15 A I have not, that's the only thing I know. 15 A He comes -- we don't know the schedule, we
16 O Who told you that 16 receive a call, then we prepare. he's coming.
17 Mr. Epstein's personal assistant? 17 O You say we receive a call. Who receives the
18 A Coworker. 18 call?
19 O Who is that? 19 A Either Alfredo or Janusz.
20 A In New York. 20 O Depending on who the house manager is at the
21 O What's that person's name? 21 time?
22 A Lyn. 22 A Yes.
23 O Lyn who? 23 O And the call comes from whom, from Ghislaine
24 A Fontanilla. 24 or from Jeffrey Epstein?
25 O Is that Joio's wife? 25 A I don't know.
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Louella Rabuyo - Volume I October 20, 2009
25 27
1 0 Okay. What's your understanding of Lyn's role MR. CRITTON: Form.
• 2
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5
in Jeffrey Epstein's life up in New York?
A She's housekeeper, too.
0 And your understanding of Jojo's role?
A A driver.
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5
BY MR. EDWARDS:
0 You realize that?
MR.
BY MR. EDWARDS:
Do you understand his question?
6 0 Does he also serve as a house manager, similar 6 0 Do you understand my question?
7 to the way Alfredo Rodriguez was in Palm Beach? 7 MR. Do you know that is what he's
8 A No. 8 asking you?
9 0 When you say a driver, who does he drive, if 9 THE WITNESS: Yes.
10 you know? 10 MR. : I think the question was do you
11 A Mr. Epstein. 11 know whether or not Mr. Epstein pled guilty to
12 0 All right. Mr. Epstein obviously hasn't been 12 crimes.
13 in New York for quite some time: isn't that your 13 Was that the question?
14 understanding? 14 MR. EDWARDS: Sure.
15 A Yes. 15 MR. CRITTON: That was not his question.
16 0 So Jojo's still employed up in New York as a 16 BY MR. EDWARDS:
17 driver for Mr. Epstein, right? 17 0 Okay. Well, do you realize that Mr. Epstein
18 A He also does housework, helps Lyn. 18 pled guilty to crimes?
19 0 Have you discussed with Lyn whether or not 19 A Plead guilty? From the news.
2o young girls visit the house in New York? 20 0 Okay. So when you say you saw the news, which
21 MR. CRITTON: Form. 21 is where this portion of our discussion began, are you
22 MR. la You can answer that. 22 referring to the news related to Mr. Epstein and the
23 BY MR. EDWARDS: 23 charges, the criminal charges or criminal investigation
24 0 He didn't like the form of my question so he's 24 surrounding him: is that the news you're talking about?
25 able to object. but you can still answer. 25 A Yes.
26 28
• 2
3
4
MR. la
THE WITNESS: No.
BY MR. EDWARDS:
You can still answer if you
understand the question.
1
2
3
4
0 Okay. So when that came out are we talking
about 2005. 2006, something in that area?
MR. CRITTON: Fenn.
BY MR. EDWARDS:
5 0 You've never talked to Lyn about young girls 5 0 Is that the first tine you remember seeing the
6 being in the house in New York? 6 news on that subject?
7 A When the news carne up, so that's how we 7 MR. CRITTON: Form.
8 talked. 8 THE WITNESS: I cannot remember.
9 0 What do you mean, when the news came up? 9 BY MR. EDWARDS:
10 A Whenever there was something on the news on 10 0 All right. Whenever it was, you talked to Lyn
11 TV, then that's how we come to talk about it. 11 about that?
12 0 Okay. When you say something came on the 12 A No. I don't usually talk about it. She calls
13 news. you're talking about in terms of a criminal 13 and how are you doing, then oh, like that.
14 investigation of Mr. Epstein? 14 0 Okay. And what was the discussion as it
15 MR. CRITTON: Form. 15 related to girls in either the New York house or the
16 THE WITNESS: Criminal? 16 Palm Beach house between yourself and Lyn?
17 BY MR. EDWARDS: 17 MR. CRITTON: Form.
18 0 Well, you realize that Mr. Epstein went to 18 THE WITNESS: She talks to me when she read in
19 jail, right? 19 the news or she saw on the computer.
20 A Yes. 20 BY MR. EDWARDS:
21 0 And that was after pleading guilty to some 21 0 Okay. And does she tell you about young girls
22 crimes. You realize that, right? 22 being in the New York house?
23 MR. CRITTON: Form. 23 MR. CRITTON: Form.
24 BY MR. EDWARDS: 24 THE WITNESS: She did not.
25 0 I mean, that's why you go to jail. 25
•
Condensed Transcript
IN THE CIRCUIT COURT OF THE F1I-IEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
L.M.,
Plaintiff,
vs. CASE No.
502008CA02805IXXXXMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LOUELLA RABUYO
VOLUME I
October, 20, 2009
10:10 a.m.
515 N. Flagler Drive
Suite 200-P
West Palm Beach, Florida 33401
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, FL 33410
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EFTA00181472
•
•
•
EFTA00181473
Louella Rabuyo - Volume I October 20, 2009
1 3
IN Tit CIRCUIT can or TM FIrrudem JUDICIAL CIRCUIT 1 APPEARANCES:
• IN AND FOR PALM BRACH COUN7y, FLORIDA
CIVIL D1VISLON
CUR Ito.9010000.0210,:xxXXXR As
Plaintiff,
2
3
4
On behalf of the Defendant.
ROBERT D. CRITTON. JR.. ESQUIRE
BURMAN CRITTON LUTTIER & COLEMAN. UP
303 Banyan Boulevard, Suite 400
.TRIIIRRY IIPSTRIN, 5 West Palm Beach. Florida 33401
Phone: 561.8422820
Defendant . 6
7 On behalf of Plaintiff L.M.:
B BRADLEY J. EDWARDS. ESQUIRE
DEPOSITIO1 or wuRLLA Ramiro CARA L. HOLMES, ESQUIRE
Viratelt I
9 ROTHSTEIN ROSENFELDT ADLER
Tuesday, October, 20. 2009 40t E. LEIS 0419 Boulevard. Suite 1650
10:10 - 1,10 pre 10 Fort Lauderdale. Florida 33394
Phone: 954.522.3456
11
515 N. Plagler Drive. Suite 200-P 11 On behalf of trosetappess
Wen Palm Beach, Florida 13401
13 BRUCE E. III IE
LAW OFFICE OF BRUCETIIIIIIII
Reported By: 14 250 S. Australian Avenue. Suite 1400
Teresa Whaler., RPR, PPR West Palm Beach, Florida 33401
Notary Public, State of Florida Is Phone: 561202.6360
Nest rain Beach Office Job 411001
16
17 On behalf of Dolenclantsclane Does 2 - 8:
le STUART S. MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, PA.
19 18205 Biscayne Boulevard. Suite 2219
Miami. Florida 33160
20 PhOole: 305.9312200
21 On behalf of Plaintiff In related Case No. 08-80811
22 JACK HILL. ESQUIRE IP/weary via speakerphone)
SEARCY. DENNEY, SCAFIOLA BARNHART e• SHIPLEY
23 2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
24 Phone: 561.686.6300
25
2 4
1 1 - - -
•
UNITED STATES DISTRICT COURT
SOU tHERN DISTRICT OF FLORIDA 2 INDEX
2
CASE No.08-CV-80119-CIV-MARRNJOHNSON 3 - - •
3 4
4 JANE DOE NO. 2,
5 5 WITNESS: DIRECT CROSS REDIRECT RECROSS
Plaintiff, 6
7 JEFFREY EPSTEIN. LOUELLA RABUTO
6 Defendant 7
9 Related Cases: 8 BY MR. EDWARDS: 5 190
03-80232. 08.80380. 98-60381, 08-80994. s BY MR. MERMELSTEile 135 208
10 08.60993, 08-80811. 08-80893. 09-80469,
09430591. 09.80656. 09-80802. 09-81092 10 BY MR. HILL: I%
il ..__f 11 BY MR. CARTON: 173
12
12
DEPOSITION OF LOUELLA RABUTO
13 VOLUME I 13 - • -
14 14 EXHIBITS
Tuesday, October 20.2009
Is 10:10 • 3:30 p.m. Is -- -
16 26
515 N. Flag's( Deno, Stale 200-P
17 17 NUMBER DESCRIPTION PAGE
West Palm Beach. Florida 33401 le DEFENDANTS EX. 1 COPIES. COMPOSITE PHOTOGRAPHS 103
18
19 19 DEFENDANTS EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
20 20 DEFENDANTS EX. 3 COPY OF PHOTOGRAPH 162
21 Reponed By:
Tenni Whalen, RPR. FPR 21
22 Notary Pubec. State of Fonda 22
Weal Palm Beath Office Job 1118991
23 23
Phase: 800.330.6952
561.659.4155 24
24 25
25
• • Toll Free: 866.709.8777
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Louella Rabuyo - Volume I October 20, 2009
5 7
1 PROCEEDINGS 1 0 How long have you been employed by
2 • • • 2 Mr. Epstein?
3 Deposition taken before Teresa Whalen. 3 A It will be five years this November 17th.
4 Registered Professional Reporter, Florida 4 0 So you started November 17th, 2004?
5 Professional Reporter, and Notary Public in and for 5 A Yes. sir.
6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein?
7 - - 7 A Through an agency.
Thereupon, 0 What agency?
9 (LOUELLA RABUYO) 9 A It's Regal Domestics.
10 having been first duly sworn or affirmed, was examined 10 0 And what was your position that you were hired
11 and testified as follows: 11 by Mr. Epstein tor?
12 THE WITNESS: I do. 12 A Housekeeper.
13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness
14 MR. EDWARDS: Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Are you familiar with
IS record what case this is being taken in? I noticed 15 that name?
16 it in L.M. versus Epstein. I don't know if anybody 16 A Yes.
17 cares to say who your clients are, what the case 17 0 And that person. I believe he represented that
18 style is or anything else for when she types it up. 18 he was also maybe a house manager. Is that correct?
19 MR. MERMELSTEIN: I don't have a problem with 19 A Correct.
20 that. Are we doing initials? 20 0 Would he have been, at some point in time,
21 MR. EDWARDS: Yeah. Initials. 21 your boss or your superior?
22 MR. MERMELSTEIN: Okay. 22 A Yes.
23 BY MR. EDWARDS: 23 0 That's somebody who you answered to,
24 0 All right. Will you state your name for the 24 Alfredo Rodriguez?
25 record. 25 A (Nodding head). Sometimes •-
6 8
A Louella Rabuyo. 1 You have to say yes or no. you
2 0 And what's your current address? 2 can't nod your head.
3 A 904 Summer Street, Lake Worth. 3 BY MR. EDWARDS:
4 0 All right. How long have you lived at 904 4 O Yes?
s Summer Street? 5 A Yes.
6 A About two years. 6 MR. CRITTON: No, no. She said sometimes.
7 0 Two years. Where did you live prior to 904 7 then you put yes In her mouth.
8 Summer Street? 8 MR. EDWARDS: I didn't put anything in her
9 A In Palm Ridge Apartment, that's in Mango 9 mouth. I don't want the record —
10 Drive. 10 MR. CRITTON: Let me take it back. You said
11 0 How long did you five there? 11 yes, but she started to say something before she
12 A About a year. 12 was interrupted.
13 0 All right. Where did you live prior to that. 13 BY MR. EDWARDS:
14 the Palm Ridge Apartment? 14 0 That's fine. You can answer the question.
15 A In a townhouse in West Palm Beach. 15 then we'll Instruct you on the deposition.
16 Q Okay. How long did you live in the townhouse 16 MR. : Did you want to explain that
17 in West Palm Beach? 17 further?
18 A Less than a year. 18 THE WITNESS: Because we were supposed to work
19 0 Have you ever lived at Jeffrey Epstein's 19 together, but he was bossy, he was bossy.
20 location of 358 El Brillo Way? 20 BY MR. EDWARDS:
21 A No, sir. 21 O Okay. Have you ever had your deposition taken
22 0 Where are you currently employed? 22 beforeliko this?
23 A Mr. Epstein. 23 A No.
24 0 And what address do you report to work? 24 0 All right. Well, there is one court reporter,
25 A 358 El Brillo Way. 25 and it's very easy in casual conversation to nod your
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Louella Rabuyo - Volume I October 20, 2009
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1 head or shake your head. and she can't take that down. 1 that it's clean and appropriately, what's this...
• 2
3
4
5
A All right.
0 It's also very easy to say uh-huh or huh.uh,
but it kind of looks the same on paper, so you can't do
that either. I'm going to wait until you finish your
2
3
4
0 And as I understand this properly, there is a
main house and then there's also a staff house on the
property: is that right?
A Yes, sir.
6 answer, and you have to wad until I finish my question, 6 0 And when the guests would come over, would you
7 because if we talk over one another, then the cowl 7 stay in the main house, or would you go to the staff
8 reporter can't got it down. 8 house?
9 A Okay. Yes, sir. 9 MR. : Can we get a time frame to the
10 0 MI right. So if you don't understand the 10 question?
11 question, tell me you don't understand and ill try to it BY MR. EDWARDS:
12 ask a better question. 12 0 Over the last five years while you worked
13 A Yes. 13 there.
14 0 Okay. So you were Nred In November of 2004 14 A I usually stay in the staff house and do the
15 to be the housekeeper for Mr. Epstein? 15 laundry, then I go to the kitchen and then tidy the
16 A Yes. 16 kitchen.
17 0 And when you were hired, who exactly hired 17 0 You were hired in November of 2004. and what
18 you, who -- let me strike that. 18 were your hours that you worked there back in November
19 When you were hired to be the housekeeper for 19 of 2004 when you were hired?
20 Mr. Epstein, who did you interview with? 20 A Eight to five.
21 A Ms. Maxwell. 21 0 How many days a week?
22 0 Is that Ghislaine Maxwell or just 22 A Depends.
23 Leine Maxwell? 23 0 How would the schedule be relayed to you?
24 A Ghislaine Maxwell. 24 A When Mr. Epstein is there, then I'm supposed
25 0 And where did the Interview take place? 25 to report, but usually it's five days a week.
10 12
0 So am I correct In understanding that there
• 1
2
3
4
A At 358 El Brilb Way.
0 And what did Ms. Maxwell and you speak about
prior to your being hired as the housekeeper?
A My duties.
2
3
4
was one schedule when Mr. Epstein was in town, and the
schedule may be a little bit different if Mr. Epstein
was out of town?
5 0 And what did she tell you your duties would 5 A Yes, sir.
6 be? 6 O All right. Toll me the differences when
7 A To tidy. to make beds. do laundry. 7 Mr. Epstein is in town versus when Mr. Epstein was not
8 0 Did she tell you what would take place in the ri in town.
9 house on a day-to-day basis? 9 A II he stays like three or four days, then I'm
10 A No. to supposed to be there, and then the house is to be
11 0 So going into that position, you had no idea 11 cleaned. And then when they do not come, then I can
12 who the guests would be or who the people coming in the 12 either go there, or I'm given free days off.
13 house would be, or what would generally go on? 13 0 Three days off?
14 A Can you simplify the question? 14 A No. A free day.
15 0 Sure. When you talked about with 15 0 Oh, okay. But typically back in 2004 when you
16 Ghislaine Maxwell at this interview, your duties being 16 were hired, you worked an average of about five days a
17 you would make the bed and tidy up, did she also tel 17 week; is that correct?
18 you that there would be a lot of guests, there would be 18 A Yes.
19 a few guests, did she talk to you about that at all? 19 0 All right. And I guess by the way that you're
20 A She mentioned that it there are guests, we 20 explaining it, if Mr. Epstein was in town for a longer
21 have to. like, you know, prepare the room, and, what's 21 period of time, you may work more than five days, and it
22 this, attend to the guests. 22 Mr. Epstein was not in town, you may work less than five
23 0 And what did you understand that to mean that 23 days?
24 you have to attend to the guests? 24 A Yes.
25 A You have to prepare the room and see to it 25 0 Okay. Did you ever talk to Mr. Epstein prior
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1 to being hired? 1 0 Did she tell what you would be paid at that
2 A No, sir. 2 time?
3 Q Where did this meeting, within the house where 3 A Not yet.
4 did the meeting with Ornstein° Maxwell take place? 4 0 Did you show up that Saturday? I guns that's
5 A In the living room. 5 November 17th of 2004?
6 0 Aside from teeing you that you were going to 6 A No, that's not.
7 be required to make the beds and just generally tidy up, 7 0 No. Was it prior to November 17th of 2004, or
8 did she specify anything else that you would be required atter?
9 to do? 9 A After.
10 A No. to 0 Okay. The interview that you first went to
11 0 Where had you worked prior to working for 11 was November 17th, 2004 with Ms. Maxwell; is that the
12 Mr. Epstein? 12 date that you gave us?
13 A I work as a certified nursing assistant. 13 A I cannot remember.
14 0 Where? 14 0 The only reason I'm using that date Is I
15 A At that time I was doing private duty. is believe the question I asked was when did you start
16 0 How long have you been a certified nursing 16 working for Mr. Epstein, and I thought the date that you
17 assistant? 17 gave me was November 17th, 2004.
18 A Since about ten years. 18 A Yes.
19 0 And what made you change professions from 19 0 Okay. And in the course of this whole thing,
20 being a certified nursing assistant to be a housekeeper 20 it sounds like you interviewed with ChIslaine Maxwell.
21 for Mr. Epstein? 21 there were other interviewees, you received a call and
22 A The agency called me that there is an 22 you were asked to try out on a Saturday?
23 interview; it I like. I go to, so that's how it started. 23 A Yes.
24 0 And when you went to the interview, obviously 24 0 And where does that Saturday fall in related
25 you're going to this very big house and you talked to 25 to November 17th, 2004?
14 16
1 Ornstein° Maxwell, right? i A When I accepted the job otter.
2 A Yes 2 0 Okay. And did they tel you at that time when
3 0 And did you decide right then that you liked 3 you accepted the job otter how much you were going to be
4 this and that you were going to change professions and 4 paid?
s you were going to be his housekeeper? 5 A Yes.
6 A No. 6 0 What was that?
7 0 Okay. Then walk me through that, how did you 7 A II was 32,000 per annum.
8 go about eventually accepting the position? a 0 And has your salary increased over time?
9 A I didn't expect to be hired, because there 9 A Yes, sir.
10 were other interviewers (sic), interview people that to 0 And can you walk us through the increments of
11 were to be Interviewed. 11 increase in your salary?
12 a Okay. 12 A It was promised yearly increase.
13 A And then I receive a call from Ms. Maxwell if 13 0 By whom?
14 I like. I can do a try-out. 14 A Ms. Maxwell.
15 0 Okay. Did she tell you hew long this try-out is 0 Was that at the time when you were
16 period would last? 16 interviewed. or took the job?
17 A No. 17 A Yea. Sir.
18 0 And what did you tell her when she made that 18 O Did she promise you what your yearly increase
19 offer for you to by out? 19 would be?
20 A I told her that I am still taking care of this 20 A No.
21 patient, so she said if you like, you can come Saturday 21 0 And have you received a yearly increase every
22 and try it. 22 year?
23 0 Okay. And what did you tell her, did you 23 A I did.
24 accept that? 24 0 And what has that yearly increase been?
25 A Yes, I did. 25 A Up to 42.
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Louella Rabuyo - Volume I October 20, 2009
17 19
1 0 Today? 1 0 Okay. So lets talk about that. Back in
• 2
3
4
5
A Yes.
0 So you're making $42,000 today, and that's the
most that you've made over the five-year period you've
worked for Mr. Epstein?
2
3
4
5
November of 2004, you were to working 8:00 a.m. to
5:00 p.m. And when did that schedule change from 8:00
5:00?
A When? When the house was renovated.
6 A Yes, sir. 6 0 When was that, do you remember the yew?
7 0 At the time when you — when we took 7 A 2006.
B Alfredo Rodriguez's deposition, he described you as a 8 0 Okay.
9 very religious Catholic woman. Does that accurately 9 MR. CRITTON: I'm sony. '06?
10 describe you? 10 THE WITNESS: '06.
11 MR. CRITTON: Let me Just object to the loran. 11 BY MR. EDWARDS:
12 MR. : You can answer the question if 12 0 So from November 2004 through '06. I'm correct
13 you understood it. 13 in presuming that your schedule was an average of five
14 THE WITNESS: I am a Catholic and I go to 14 days a week from 8:00 a.m. to 5:00 p.m.?
15 mass. 15 A At that time I go nine o'clock, I go to the
16 BY MR. EDWARD$: 16 house at nine o'clock.
17 0 Is that something you go to regularly? 17 0 Starting in 2006?
18 A II I have time. I go regularly. 18 A Yes.
19 0 When do you normally go to mass? 19 0 So when your schedule changed from 8:00 to
20 A Sunday masses and weekdays. 20 5:00, in 2006 you started going to the house.
21 0 How many weekdays? 21 Jeffrey Epstein's house, at nine o'clock?
22 A If I can, every day. 22 A Yes, sir.
23 0 And in the five-year period that you've worked 23 0 And you would stay until what time?
24 for Mr. Epstein, have you tried to go every day if you 24 A Sometimes 5:00, sometimes later, 5:30.
25 could? 25 0 Would lhat depend on what needed to be done?
18 20
A Yes.
• 1
2
3
4
A No.
0 In a typical week would you normally go on
Sunday to mass?
A Yes, sir.
2
3
4
C1 How have you received your money, has it been
by check, by cash, in terms of payment from Mr. Epstein?
A Its directly deposited to my bank.
5 0 And how many days during the week will you 5 0 Do you know who directly deposits your money?
6 also attend mass? 6 A Who?
7 A If the schedule permits, then I go, but if 7 0 Yeah. Whether it's Ghislaine Maxwell or a
8 not, then I don't go. corporation or Jeffrey Epstein, do you know who the
9 0 So is there a way that you could give me an 9 direct depositor is of your check?
10 average of how many times a week that you go during the 10 MR. CRITTON: Form.
11 week to mass? 11 THE WITNESS: Mr. Epstein.
12 A Mistime? 12 BY MR. EDWARDS:
13 0 Right. Yeah. I guess today, these days. 13 0 Okay. Over the five years that you have been
14 A I attend Sunday masses only. 14 working at Mr. Epstein's house, how many conversations
15 0 And back in 2004, when you first started with 15 have you had directly with Mr. Epstein?
16 Mr. Epstein? 16 A What's this, what year?
17 A I tried to go if I have the time, sir. 17 0 Well, in the last five years, how many
18 0 Was there ever a time that you went every day? 18 conversations have you had directly with Mr. Epstein?
19 A No. 19 MR. CRITTON: Form.
20 0 But your testimony is that if time permitted, 20 THE WITNESS: The past year it's just good
21 you tried to go every day? 21 morning, how are you, you're doing a good job.
22 A Yes. 22 BY MR. EDWARDS:
23 0 Is there a reason why now these days you only 23 0 Okay. How was it prior to that, did you talk
24 attend on Sundays? 24 to him more?
25 A Because my time schedule has changed. 25 A This time more.
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Louella Rabuyo - Volume I October 20, 2009
21 23
O Now you talk to him more? 1 A Yes.
2 A Because I serve him breakfast, so... 2 O When did you talk to Lyn Fontanilla about
3 O And is that an additional responsibility that 3 == .7
4 you dickil have before? 4 A It was just through the conversation.
5 A Yes. 5 O What would cause you to be in a conversation
6 O In the five•year period that you've worked 6 with this person in New York?
7 there, can you name for me all of the other employees 7 MR. CRITTON: Form.
8 who have worked at the Jeffrey Epstein house? B THE WITNESS: She calls me, I call her.
9 A After Alfredo Rodriguez left, there was BY MR. EDWARDS:
lo Jerome, the gardener, and now ifs Yanusz. 10 O You're friends?
12 O And those are the house managers? 11 A Yes.
12 A Yes. 12 O Do you still talk to her today?
13 O And then you work there? 13 A Yes.
14 A Right. 14 O And does she work for Mr. Epstein as well, to
is O Aside from yourself, Jerome, and Janusz, was 15 your knowledge?
16 there anybody else that you can remember working at the 16 A She does.
17 house in the past five years in any position? 17 O And does Joie. her husband, also work for
19 A Yes. 18 Mr. Epstein as well?
19 O Who else? 19 A Yes, sir.
20 20 O Where do they work?
21 21 A In New York.
22 A Yes. 22 O At Mr. Epstein's house in New York?
23 O What does she do there? 23 A Yes, sir.
24 A She's the personal assistant. 24 O And have you talked with them about your
25 O Personal assistant to whom? 25 duties and has she talked to you about her duties?
22 24
1 A Mr. Epstein. 1 A Yes, sir.
2 O And as his personal assistant, what have you 2 O And your duties are similar to Lyn's duties in
3 observed her to do for him? 3 New York?
4 A Can you rephrase your question? 4 A No. Because that's a bigger house than...
5 O I can try. You said that she's his personal 5 O Palm Beach?
6 assistant. What does that mean, what does she do? 6 A Yes. sir.
A Order things that I need, or, what s this. 7 O Is it your understanding that -- you know,
8 O So ifs your testimony that has a we're going to get into the past two years where
9 been, for the past five years that you've worked there, 9 Mr. Epstein has either been in jail or he's been on
10 has been somebody that you have observed to order things 10 house arrest in Palm Beach, so I'm going to ask you
11 that you need? 11 first for the first three years that you worked there
12 A If I need something, then I go to ask 12 and Mr. Epstein was traveling, was Mr. Epstein spending
13 O Okay. What other things have you seen 13 the majority of his time in Palm Beach or in New York or
14 do for Mr. Epstein? 14 elsewhere, if you know?
15 A I have not, that's the only thing I know. 15 A He comes -- we don't know the schedule, we
16 O Who told you that 16 receive a call, then we prepare. he's coming.
17 Mr. Epstein's personal assistant? 17 O You say we receive a call. Who receives the
18 A Coworker. 18 call?
19 O Who is that? 19 A Either Alfredo or Janusz.
20 A In New York. 20 O Depending on who the house manager is at the
21 O What's that person's name? 21 time?
22 A Lyn. 22 A Yes.
23 O Lyn who? 23 O And the call comes from whom, from Ghislaine
24 A Fontanilla. 24 or from Jeffrey Epstein?
25 O Is that Joio's wife? 25 A I don't know.
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25 27
1 0 Okay. What's your understanding of Lyn's role MR. CRITTON: Form.
• 2
3
4
5
in Jeffrey Epstein's life up in New York?
A She's housekeeper, too.
0 And your understanding of Jojo's role?
A A driver.
2
3
4
5
BY MR. EDWARDS:
0 You realize that?
MR.
BY MR. EDWARDS:
Do you understand his question?
6 0 Does he also serve as a house manager, similar 6 0 Do you understand my question?
7 to the way Alfredo Rodriguez was in Palm Beach? 7 MR. Do you know that is what he's
8 A No. 8 asking you?
9 0 When you say a driver, who does he drive, if 9 THE WITNESS: Yes.
10 you know? 10 MR. : I think the question was do you
11 A Mr. Epstein. 11 know whether or not Mr. Epstein pled guilty to
12 0 All right. Mr. Epstein obviously hasn't been 12 crimes.
13 in New York for quite some time: isn't that your 13 Was that the question?
14 understanding? 14 MR. EDWARDS: Sure.
15 A Yes. 15 MR. CRITTON: That was not his question.
16 0 So Jojo's still employed up in New York as a 16 BY MR. EDWARDS:
17 driver for Mr. Epstein, right? 17 0 Okay. Well, do you realize that Mr. Epstein
18 A He also does housework, helps Lyn. 18 pled guilty to crimes?
19 0 Have you discussed with Lyn whether or not 19 A Plead guilty? From the news.
2o young girls visit the house in New York? 20 0 Okay. So when you say you saw the news, which
21 MR. CRITTON: Form. 21 is where this portion of our discussion began, are you
22 MR. la You can answer that. 22 referring to the news related to Mr. Epstein and the
23 BY MR. EDWARDS: 23 charges, the criminal charges or criminal investigation
24 0 He didn't like the form of my question so he's 24 surrounding him: is that the news you're talking about?
25 able to object. but you can still answer. 25 A Yes.
26 28
• 2
3
4
MR. la
THE WITNESS: No.
BY MR. EDWARDS:
You can still answer if you
understand the question.
1
2
3
4
0 Okay. So when that came out are we talking
about 2005. 2006, something in that area?
MR. CRITTON: Fenn.
BY MR. EDWARDS:
5 0 You've never talked to Lyn about young girls 5 0 Is that the first tine you remember seeing the
6 being in the house in New York? 6 news on that subject?
7 A When the news carne up, so that's how we 7 MR. CRITTON: Form.
8 talked. 8 THE WITNESS: I cannot remember.
9 0 What do you mean, when the news came up? 9 BY MR. EDWARDS:
10 A Whenever there was something on the news on 10 0 All right. Whenever it was, you talked to Lyn
11 TV, then that's how we come to talk about it. 11 about that?
12 0 Okay. When you say something came on the 12 A No. I don't usually talk about it. She calls
13 news. you're talking about in terms of a criminal 13 and how are you doing, then oh, like that.
14 investigation of Mr. Epstein? 14 0 Okay. And what was the discussion as it
15 MR. CRITTON: Form. 15 related to girls in either the New York house or the
16 THE WITNESS: Criminal? 16 Palm Beach house between yourself and Lyn?
17 BY MR. EDWARDS: 17 MR. CRITTON: Form.
18 0 Well, you realize that Mr. Epstein went to 18 THE WITNESS: She talks to me when she read in
19 jail, right? 19 the news or she saw on the computer.
20 A Yes. 20 BY MR. EDWARDS:
21 0 And that was after pleading guilty to some 21 0 Okay. And does she tell you about young girls
22 crimes. You realize that, right? 22 being in the New York house?
23 MR. CRITTON: Form. 23 MR. CRITTON: Form.
24 BY MR. EDWARDS: 24 THE WITNESS: She did not.
25 0 I mean, that's why you go to jail. 25
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