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Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 7 of 10 Depo Tr. at p. 40-41 (“I know she [Maxwell] went out and took pictures in the pool because later on I would see them at the desk or at the house. And nude - 99.9 percent of the time they were topless. They were European girls.”). Q. “Did they appear to be doing any sexual? A. Yes, ma’am. Q. And in these instances were there girls doing sexual things with other girls? A. Yes, ma’am. Q. And I’m still talking about the pictures on Ms. Maxwell’s computer. A. Yes, ma’am.” Upon leaving his employment, Rodriguez testified that Defendant threatened him that he should not tell anyone about what happened at the house: A. “Thave to say something. Mrs. Maxwell called me and told me not to ever discuss or contact her again in a threaten(ing) way. Q. When was this? A. Right after I left because I call one of the friends for a job and she told me this, but, you know, I feel intimidated and so I want to keep her out... Q. She made a telephone call to you and what precisely did she say? A. She said I forbid you that you’re going to be — that I will be sorry if I contact any of her friends again...She said something like don’t open your mouth or something like that. I’m a civil humble, I came as an immigrant to service people, and right now you feel a little -’m 55 and I’m afraid. First of all, I don’t have a job, but I’m glad this is on tape because I don’t want nothing to happen to me. This is the way they treat you, better do this and you shut up and don’t talk to nobody and— Q. When you say this is the way they treat, who specifically are you talking about when you say that word they? A. Maxwell. ” See McCawley Decl. at Exhibit 4, Alfredo Rodriguez July 29, 2009 Dep. Tr. at 169 — 172. In sum, at the core of this case are statements made by Ms. Giuffre that she was recruited, by Defendant, to be paid as a masseuse, yet was enticed or coerced into engaging in sexual acts with Epstein and Defendant for money. She has further explained that the recruitment of females through the offer of some legitimate position was the typical way in which Defendant and Epstein lured unsuspecting females to the house before converting the relationship into a sexual