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that time. 
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A 
I was tidying the living room, then not 
really -- there was like part of the wall, so I saw one 
female there but not really, I saw it like this side 
(indicating), so... 
Q 
She was at the pool, or inside the house? 
A 
This side, not really frontal, but on the side 
I saw only -- I saw her side, not really like... 
: His question was, was she 
inside the house or out by the pool when you saw 
her from the side. 
THE WITNESS: The question -- they were in the 
pool. 
BY MR. 
• 
okay. So she was not wearing a bathing suit 
top, correct? 
A 
Yes. 
Q 
Was she wearing a bathing suit bottom? 
A 
I did not know. 
Q 
And how did you -- did you do anything in 
response to this? 
A 
No. I went to, what's this, to kitchen and I 
told Alfredo not to go to the pool. 
Q 
And this was the only time you ever remember 
seeing a girl who wasn't wearing a top at the pool? 
• 
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150 
A 
Yes. 
Q 
Were there frequently females at the pool to 
the house? 
A 
No. Not frequently. 
Q 
Not frequently. Sometimes? 
A 
Sometimes. 
Q 
Mr. Epstein would travel with some females, I 
think they would come on the plane with him to the 
house; is that correct? 
MR. CRITTON: Form. 
BY MR. 
Q 
You can answer. 
A 
I cannot remember if they -- let me see. I 
remember 
Because when Mr. Epstein arrives, most 
of the time I'm already off. 
Q 
Let me ask the question this way: Were there 
Females other than 
who would come with Mr. Epstein 
on the plane and stay at the house? 
MR. CRITTON: Form, predicate. 
BY MR. 
Q 
Stay overnight at the house? 
MR. CRITTON: Same. 
THE WITNESS: I did not know if they came with 
Mr. Epstein, I did not see. 
9 
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BY MR. 
O 
Okay. There were females who would stay 
overnight at the house, but you're not sure how they got 
to the house; is Lhilt. Lai: W say? 
A 
Yes. 
Q 
Did any of the females who came to the kitchen 
entrance to give a massage, did any of them stay 
overnight? 
A 
No, sir. 
Q 
Never, correct? 
A 
Yes, sir. 
MR. CRITTON: Did you say correct and she said 
yes? 
MR. 
: Yes. 
MR. CRITTON: Okay. Thank you. 
BY MR. 
• 
The girl at the pool who was topless, do you 
recall what her name was? 
A 
No. 
• 
Do you recall how she got to the house or, you 
know, what her purpose was in being there? 
A 
I cannot remember. 
O 
Was she a girl who had come to give 
Mr. Epstein a massage? 
MR. CRITTON: Form. 
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152 
THE WITNESS: No. 
BY MR. 
0 
The females who came to give Mr. Epstein a 
massage, did they ever use the pool? 
MR. CRITTON: Form, predicate. 
THE WITNESS: I did not see. 
BY MR. 
Q 
You don't know? 
A 
I don't know. 
• 
And again, this girl you saw topless was the 
only one you ever saw who was in any stage of undress in 
the pool area at the house; is that fair? 
A 
Yes. 
Q 
You mentioned in your testimony earlier that 
there was a back massager that was in Mr. Epstein's 
bedroom, correct? 
A 
In the massage room. 
• 
In the massage room. It was what, on the 
floor, on the massage table, where did you find it? 
A 
Sometimes on the, what's this, the table, 
sometimes on the floor. 
• 
So this would be a regular thing, you would go 
in the room to tidy up and you'd find this massager, 
correct? 
MR. CRITTON: Form. 
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THE WITNESS: Yes. 
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BY MR. 
Q 
You referred to it as a back massager, 
correct? 
A 
Yes. 
Q 
And did you do anything to this, did you put 
strike that. 
Did you put away this massager? 
A 
I return it to the drawer. 
Q 
Was that a drawer in the armoire? 
A 
No. In the bathroom. 
Q 
In the bathroom cabinet? 
A 
Yes. 
Q 
Were there other items in the drawer? 
A 
Lotions. 
• 
So thcoc were massage items --
MR. CRITTON: Form. 
BY MR. 
• 
-- that were in the drawer? 
MR. CRITTON: Sorry. Form. 
THE WITNESS: From Hodyworks, aroma massage 
therapy. 
BY MR. 
• 
So there was Bodyworks lotions and this back 
massager; is that correct, in the drawer? 
• 
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154 
A 
Yes. 
Q 
Anything else in the drawer? 
A 
That's all. And I put some, like, hand 
towels. 
Q 
In the drawer? 
A 
Yeah. On the side. 
Q 
Was there any -- was there just one drawer 
that was used for these massage materials, or was there 
more than one drawer? 
A 
There is only one drawer. 
Q 
Would you do anything to this massager before 
you put it in the drawer? 
A 
No. I just return it there. 
Q 
Did you ever clean it? 
A 
There was one time I clean it. 
Q 
One time you clean it. About how many times 
did this happen that you picked up the massager and put 
it in the drawer; did it happen many times? 
A 
Yes. 
Q 
So on this one occasion why did you clean it? 
A 
Because I thought it was, like, dirty, so I 
clean it. 
Q 
Explain to me how it was dirty. 
A 
There is -- the color is -- like you know 
when -- like there is stains or something, you know, 
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EFTA_00070870 
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- Volume II 
October 20, 2009 
155 
when something is not clean. So I very particular about 
cleanliness, so I... 
Q 
Did you believe that there was a sexual fluid 
on it and that's why you cleaned it? 
A 
No. 
MR. CRITTON: Form. 
THE WITNESS: No. 
8 
BY MR. 
9 
Q 
Mr. Rodriguez testified that you disliked the 
10 
task of putting away the massage items because you had 
11 
to clean them of sexual fluids and that was unpleasant. 
12 
Is that not true? 
13 
MR. CRITTON: Form. 
14 
THE WITNESS: Not true. 
15 
BY MR. 
16 
Q 
So Mr. Rodriguez would be lying about that, 
17 
correct? 
18 
A 
Yes. 
19 
Q 
The way I asked that question was sexual 
20 
fluids, and that may be an ambiguous term. What if I 
21 
used the term "body fluids," does that change your 
22 
answer at all? 
23 
A 
No. 
24 
Q 
It's the same, you never cleaned body fluids 
25 
off of a massager, correct? 
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EFTA 00070871 
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October 20, 2009 
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156 
A 
No. 
MR. CRITTON: Wait. You said 
when he said 
correct, you said no. Does that mean he's not 
correct? 
: Did you ever clean body fluids 
off of a massager? 
THE WITNESS: I don't know if it's fluid, 
BY MR. 
Q 
Did you ever clean body fluid off of any 
massager? 
MR. CRITTON: Form. 
THE WITNESS: No. 
MR. 
: I pass the torch. 
CROSS ( 
BY MR. 
Q 
I'm the mysterious voice that was on the phone 
before, and now you get the privilege of seeing me in 
person. I'm teasing, the privilege is mine. I won't be 
very long with you, I promise. 
I want to follow up on this line of 
questioning, though. The single time of the many 
instances in which you put back what you believed to be 
some kind of massage implement into the bathroom drawer, 
you only cleaned it one time? 
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October 20, 2009 
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157 
A 
One time. 
Q 
All right. And you said that it appearnl rn 
you to be stained? 
A 
Yes. 
Q 
Did you have any idea of what it was that 
caused the implement which you believed to be a massager 
to become stained? 
A 
No, sir. 
Q 
So when you were asked questions about whether 
it was bodily fluid or not, you had no idea what it was 
that you were cleaning off that item that you believed 
to be a back massager? 
A 
Correct. 
Q 
Okay. How did you clean the item that one 
time that you believed to be a back massager? 
A 
I use a paper towel, wet the paper towel and 
wipe it. 
Q 
All right. Where was the item stained? 
A 
On the tip of the massager. 
Q 
All right. And if someone has asked you this 
and I missed it, I apologize. Describe Lot us what the 
item looked like that you believed to be a back 
massager. 
A 
It's an elongated piece with a thing --
Q 
Elongated what? 
• 
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October 20, 2009 
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158 
A 
Elongated thing, and then on the tip is like a 
round part. So I thought it's used for massaging. 
Q 
Did this implement have any kind of electrical 
power, did it have a cord, did it have batteries, did it 
move; do you know? 
A 
I don't know. 
• 
And the area that it was stained was where, 
ma'am? 
A 
On the tip of the, what's this. 
• 
Can you describe for us what the stain looked 
like? 
A 
It looks like it's dirty, like brown thing. 
• 
Was there any kind of material other than --
did it look like it was some kind of dried liquid on 
there? 
MR. CRITTON: Form. 
THE WITNESS: I really don't know. I just, 
what's this, dirty, so I just clean it. Because I 
thought it was lotion because he have lotion there 
for... 
BY MR. 
Q 
And it's a true statement you never complained 
to anybody about your responsibilities for having to put 
back an item which you believed to be a back massager 
into the cabinet drawer in the bathroom? 
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- Volume II 
Ocnober 20, 203; 
159 
A 
No, sir. 
: Hold on. I think your question 
was, was it a true statement that. 
BY MR. 
Q 
That you never complained to anybody? 
: Did you ever complain? 
THE WITNESS: I never complain, because 
8 
my job to, so... 
9 
BY MR. 
10 
Q 
Was it always the same item, did you put it 
11 
back these many many times but only cleaned it once? 
12 
A 
Yes. 
13 
Q 
And you've never seen it in use, you had no 
14 
idea how it operates, if it operates at all? 
15 
A 
No. 
16 
Q 
I want to talk to you about the folks, the 
17 
ladies, the young girls, the young ladies, the women, 
18 
however you want to describe them, and ask you if you 
19 
can sit here today, close your eyes, and remember the 
20 
face of any of the folks that would come over and give 
2i 
your boss, Jeffrey Epstein, massages? 
22 
A 
If I remember? 
23 
Q 
As you sit here today, if I asked you to close 
24 
your eyes, can you bring up in your mind's eye the faces 
25 
of any of the young ladies that would come over to 
• 
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October 20, 2009 
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160 
Epstein's house and give him massages? 
MR. CRITTON: Form. 
BY MR. 
Q 
Do you understand the question? 
A 
Yes. 
Q 
Okay. 
A 
If you'll show me a picture then. 
• 
No, ma'am. What I'm asking you to do, as an 
employee of Jeffrey Epstein's for many many years, and 
for many many years these ladies, young ladies, these 
females would come to his house and give him massages, 
do you remember the faces of any of them? 
A 
Maybe one or two. 
Q 
All right. Earlier you testified that 
sometimes the same girl would come back, the same young 
lady would come back more than one time? 
A 
Yes. 
• 
How many young ladies can you recall making 
multiple visits to Jeffrey Epstein's house for the 
purpose of giving him massages? 
A 
Maybe two. 
Q 
Maybe two? 
A 
Yes. 
Q 
And you can recall certainly their faces? 
MR. CRITTON: Form. 
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161 
THE WITNESS: Yes. 
BY MR. 
Q 
Okay. So far there are at least two young 
ladies who you can close your eyes and remember their 
faces, right? 
A 
Yes. 
Q 
Are there more than two young ladies that you 
can close your eyes and remember their faces? 
A 
No. Maybe two. 
Q 
Just two? 
A 
Two. 
Q 
Do you recall the names of any of these young 
ladies 
A 
No, sir. 
Q 
-- who would come over? 
A 
No. 
Q 
The name 
doesn't ring a bell 
to you at all? 
A 
Excuse me? 
A 
No, sir. 
MR. 
: 
Let me show you a photograph and 
see if you --
MR. CRITTON: Are you going to mark that 
Exhibit 3? 
• 
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October 20, 2009 
162 
(Plaintiff's Exhibit No. 3 was marked for 
identification.) 
BY MR. CRITTON: 
Q 
Pursuant to Mr. Critton's suggestion, we 
5 
marked that as Plaintiff's Exhibit 3, and ask you to 
6 
take a look at that photograph and tell me if you 
7 
recognize this individual depicted on Plaintiff's 3. 
8 
A 
I'm not sure. 
9 
Q 
All right. Earlier you were shown a binder 
10 
with a bunch of photographs in it? 
11 
A 
Yes. 
12 
Some of those photographs were of young 
13 
ladies, yes? 
14 
A 
I don't know their age. 
15 
Q 
Well, I didn't --
16 
: Listen to the question. He's 
17 
just asking it you saw a binder with pictures of 
18 
young ladies in it. 
19 
THE WITNESS: Yes. 
20 
BY MR. 
21 
Q 
Okay. And many of those young ladies you were 
22 
able to say without any kind of doubt that you did not 
23 
recognize them, right? 
24 
A 
Yes. 
25 
You don't have that same degree of certainty 
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163 
for the young lady pictured in photograph Plaintiff's 
Exhibit 3? 
A 
That's right. 
Q 
You don't know whether you've seen her or not? 
A 
No. Yes. 
: Hold on. She said no, yes. 
THE WITNESS: I'm not so sure if I've seen 
her, but you know, the face seems familiar. 
BY MR. 
Q 
You don't know how you would have met this 
young lady anywhere else other than Jeffrey Epstein's 
house, do you? 
MR. CRITTON: Form, speculation. 
THE WITNESS: What was the question again? 
BY MR. 
Q 
Sure. We were talking earlier about your 
being unsure whether you had met this particular young 
lady pictured in Plaintiff's 3, and my question is you 
wouldn't have seen her someplace other than 
Jeffrey Epstein's house, right? 
A 
I'm not. sure. 
Q 
Okay. But she is someone who very well may be 
familiar to you? 
A 
Yes. 
Q 
Okay. Describe for me the two young ladies 
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EFTA_00070879 
EFTA01247602

Louella 
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October 20, 2009 
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164 
that you can remember when you close your eyes as being 
one of the young ladies that would come over to 
Epstein's house and give him massages. What do they 
look like? Let's start with number one, what did she 
look like? 
A 
The picture that he showed me, what's her 
name, Haley or something? I recognize that one. 
Q 
Let me ask you, the two young ladies that you 
can imagine that you can see in your mind's eye that 
provided Epstein massages when you were working there, 
were those young ladies both in the binder that was 
shown to you earlier that was Plaintiff's Exhibit No. 1, 
or are we talking about different ladies? 
A 
I remember that lady there. 
MR. 
: Just so that you're clear, I 
don't know that she said that the first time. 
THE WITNESS: Not this one. 
: Not that one? 
THE WITNESS: Not that one. 
MR. 
: She said that. 
BY MR. 
Q 
She said that. 
Which one is this, so we're clear? 
MR. 
: And for the court reporter.
MR. CRITTON: What did she refer to? 
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165 
MR. 
: No, no, no. Let's get the exhibit 
number rather than provide names. 
: This should be 1-N from my 
uuLes, "N" as in Nancy. 
5 
BY MR. 
6 
Q 
So you recognize 1-N there? 
7 
A 
I recognize one, that's the one that... 
Q 
So you recognize this one lady, 1-N? 
9 
A 
No. I did not say I recognize her. 
10 
Q 
You don't recognize her. Okay. So why don't 
11 
we gn hark thrnugh the hnnklet and ycal ran tell me whn 
12 
it is that you recognize as the young lady who would 
13 
come over and give Epstein massages? 
14 
MR. CRITTON: Object to the form. I think it 
15 
misstates her testimony. It was 1-F. 
16 
THE WITNESS: This elle. 
What's her -- I 
17 
remember this one, but I don't know if she gives 
18 
massage. 
19 
Let's get a number for that 
20 
one. 
21 
MR. 
: 1-F. 
22 
: I'm showing you what has 1 
21 
next en ir, right? 
24 
THE WITNESS: Yes. 
25 
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BY MR. 
Q 
And you remember this person as someone who 
would come over and give Mr. Epstein massages? 
MR. CRITTON: Form. 
THE WITNESS: I don't know if she give 
massage, but I saw her in the house. 
BY MR. 
Q 
Okay. When I started the line of questioning 
a few minutes ago, I asked you to close your eyes and 
imagine the faces of any of the young ladies that would 
come to Epstein's house and give him massages. You said 
that you can recall two such young ladies, right? 
A 
Yes. 
Q 
All right. And so you don't remember whether 
this lady in 1-F provided massages to Epstein, correct? 
A 
Correct. 
• 
So this 1-F lady isn't one of the two that you 
can close your eyes and see as one of the young ladies 
who would come over to provide massages, right? 
MR. CRITTON: Form. 
THE WITNESS: So I can only picture maybe one. 
1 thought this 
BY MR. 
Q 
I'm sorry. I cut you off, that was rude, I 
apologize. 
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A 
Okay. Your question was if I can recall two 
persons? 
Q 
That was your testimony, yes, ma'am. 
A 
I remember this one. 
Q 
You remember this one, pointing to 1-F, you 
6 
remember this young lady? 
7 
A 
Yes. 
8 
But you don't know whether this young lady 
provided massages to Mr. Epstein, correct? 
10 
A 
Correct. 
11 
0 
And I guess back to my original line of 
12 
questioning, I asked you whether about young ladies you 
13 
can close your eyes and recall their faces as being 
14 
girls, young ladies, excuse me, who would provide 
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Epstein massages. Remember that? 
16 
MR. CRITTON: Form. 
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BY MR. 
18 
Q 
And you said that there were two such young 
19 
ladies that you recall in your mind picturing their 
20 
faces as young ladies who would come over and give 
21 
M . Epstein massages? Thac's what you testified to, 
22 
right? 
23 
MR. CRITTON: Form. 
24 
THE WITNESS: I get confused, because there 
25 
are -- some visitors come or female come, and 
• 
0 
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October 20, 2009 
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then -- so I get confused, so I can't remember 
this, and I'm telling you that I don't know if she 
gives massages. 
BY MR. 
Q 
Let me give you chance to answer it again. 
Okay. If you close your eyes and think back, are you 
able to see in your mind's eye the faces of any of the 
young ladies that would come over to your boss, 
Jeffrey Epstein, for the purpose of giving him massages? 
MR. CRITTON: Form. 
THE WITNESS: No. 
BY MR. 
Q 
And how many years are we talking about where 
these women would come, excuse me, these females would 
come to Mr. Epstein's house for the purpose of providing 
him massages, how many years are we talking about? 
MR. CRITTON: Form. 
: When she worked there. 
BY MR. 
Q 
When you worked there. 
A 
If you show me pictures, then --
: No. Listen and answer the 
question you're being asked. How many years do you 
remember females coming to give massages to 
Mr. Epstein during the time you worked there? 
0 
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