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Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 37 of 38 DMIDMNAHBWNHRFPOWODIA UY AWNHE Page 334 G Maxwell - Confidential addresses affiliated with Jeffrey Epstein from your computer? MR. PAGLIUCA: Objection to the form and foundation. A. Jalready said, I didn't have a computer there, so I don't know where this came from, I have no idea. Q. I'm going to read to you some testimony from Alfredo Rodriguez's deposition and it's on page 370 and I want to ask you a question about it, if it's true or false? MR. PAGLIUCA: I'm going to object unless you show the witness the document. MS. McCAWLEY: I will pass it. We are not going to mark it. We will skip it. Q. Did you ever tell Alfredo Rodriguez that he better watch out and better keep his mouth shut with respect to what occurred at Mr. Epstein's home? MR. PAGLIUCA: Objection to the form and foundation. A. It doesn't sound like anything I DIDO BWNFPWOOANDOAWNE Page 336 G Maxwell - Confidential reference to this case with any, anything you just mentioned, I never threatened anyone. Q. Have you ever directed anyone to call any witnesses relevant to this case and threaten them not to testify? MR. PAGLIUCA: Objection to the form and foundation. A. Inever done such a thing. Q. Did Jeffrey Epstein or you ever ask any female, regardless of age, to carry Jeffrey's baby for him? MR. PAGLIUCA: Objection to the form and foundation. Q. Or anything along those lines? MR. PAGLIUCA: Objection to the form and foundation. A. Can you repeat the question, please? Q. Did you or Jeffrey Epstein ever ask any female, regardless of age, to carry Jeffrey Epstein's baby for him? MR. PAGLIUCA: Objection to the form and foundation. A. Are you asking -- Page 335 G Maxwell - Confidential would say. Q. Did you ever threaten Alfredo Rodriguez in any way if he were to disclose information he learned from his employment with Jeffrey Epstein? MR. PAGLIUCA: Objection to the form and foundation. A. I'm happy to answer. No, I never threatened him in any way. Q. Were you concerned that he was going to disclose that Jeffrey Epstein was trafficking underage girls? MR. PAGLIUCA: Objection to the form and foundation. A. First of all, there are so many things wrong with that question, but I have no knowledge of what you are talking about. Q. Have you ever contacted or instructed anyone to contact any witness in this case for the purposes of threatening them not to testify in this case? MR. PAGLIUCA: Objection to the form and foundation. A. Ihave never called anybody with Page 337 G Maxwell - Confidential Q. To become pregnant, did you or Jeffrey Epstein ever ask any female to become pregnant and carry Jeffrey Epstein's baby for you or for Jeffrey? MR. PAGLIUCA: Objection to form and foundation. A. You need to be very specific. I have no idea what you are talking about. That's completely rubbish. Q. Did you or Jeffrey Epstein ask any female to become pregnant and carry his baby for either him or you? MR. PAGLIUCA: Objection to the form and foundation. Go ahead. A. Ican't testify to anything Jeffrey did or didn't do when I am not present, but I have never asked anybody to carry a baby for me. Q. Or anything along those lines? MR. PAGLIUCA: Object to the form and foundation. Q. I want to make sure we are talking about the same thing, not physically carry a baby, I mean become pregnant with a baby? 85 (Pages 334 to 337) MAGNA® LEGAL SERVICES