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WOON AN AWNr WOON DANDAWNE 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 18-2868, Document 283, 08/09/2019, 2628241, Page381 of 883 Page 70 in cash as opposed to check? MR. CRITTON: Form. THE WITNESS: I was told to pay them cash, sir. BY MR. MERMELSTEIN: Q. Simply you were told and didn't ask why? A. No. Q. Do you recall telling the detective who interviewed you for the police that you thought of yourself as a human ATM machine? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. MERMELSTEIN: Q. You recall saying that? MR, CRITTON: Form. THE WITNESS: Because I always had cash RRR ER eee AIDMHAWNRFOWMNAUHAWNHE in my pocket. BY MR. MERMELSTEIN: Q. And why was there always cash in your 19 pocket? 20 A. That was part of my job to have, you 21 know, for emergencies or paying somebody cash. 22 Q. Okay. What kind of emergencies? 23 A. It's hard to say. I was supposed to put 24 cash on each Mercedes Benz on each ashtray. The | 25 Page 71 idea behind this is you get stranded nobody accept credit card or check you have cash. Q. How much did you leave in the ashtray? A. 300. Q. And did you ever have to replenish that money? A. Yes. Q. Because the Mercedes was stranded? A. No, because when Mr. Epstein will leave I have to collect that money because I will send the | 10 cars to the car wash so to avoid that money being 11 stolen we used to keep track, you know, when to 12 retrieve that money and then when he's coming put } 13 WAN ANDWNH Page 72 A. Not him, I will drive anybody else but he would rather eat at home. Q. So you would drive house guests to restaurants? A. Yes. Q. And when you did that you would -- didn't you stay with the car or did you eat with them? A. No, I will stay with the car. Q. So who did you tip? A. If you want to park in front of the restaurant you got to tip the valet otherwise you're taking one of the spots. Sometimes I used to take -- I'm sorry. Aviation, you know, you need to go to aviation and help those guys move your cars around, you need -- they carry luggage, so I used to tip those too. Q. That would be when you picked up or dropped off Mr. Epstein. Correct? A. Yes. MR. MERMELSTEIN: We'll mark this as an exhibit, composite exhibit. (Composite Exhibit 1 was marked for Identification.) MR. CRITTON: Just out of curiosity, on depositions are we going to use instead of Page 73 doing plaintiff and defendant designations do you just want to run them one, two, three, four? MR. MERMELSTEIN: That's fine with me as long as we remember where we left off. MR. CRITTON: Well, are we going to do it consecutive with all of the depositions? I'm okay with that if someone can keep track of that. MR. EDWARDS: I've had that go wrong before, especially when we have some parties who aren't here, such as Mr. Garcia, he's going to join depositions, we have to start at 27 or whatever. MR. CRITTON: For each deposition one through whatever without necessarily giving it back there again. 14 Q. So you use cash for that purpose and you 15 also use cash to pay the masseuses. Correct? 16 A. Yes. Q. Did you use cash for any other purpose? 18 A. Car wash for the guy who used to came to 19 the house and wash all the cars. Tipping 20 sometimes for getting a good spot in the 21 restaurant you have to have cash, something like 22 that. 23 Q. Okay. Would you drive Mr. Epstein to a 24 restaurant? 25 BY MR, MERMELSTEIN: Q. Mr. Rodriguez, I've marked as Exhibit 1 a composite document which includes four per page of what appear to be message slips. First of all let me ask you, let me direct your attention to the first page of this exhibit. And the upper left message has initials at the bottom. Is that correct? 19 (Pages 70 to 73) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000265