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Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 5 of 8 Page 275 Page 277 5 APPEARANCES: 1 Deposition taken before MICHELLE PAYNE, Court 3 RICHARD WILLITS, ESQ. 2 Reporter and Notary Public in and for the State of 2290 10th AVenue North 3 Florida at Large, in the above cause. 4 Suite 404 4 os ; preebeiale hall 5 THE VIDEOGRAPHER: This is a continuation Appeared via telephone, 6 of the deposition of Alfredo Rodriguez. : 7 Today is Friday, August the 7th, the year BURMAN, CRITTON, LUTTIER & 8 2009, starting time approximately 1:15 p.m. 8 ET Le RrTTON £50 9 will the court reporter please swear in 9 515 North Flagier Drive 10 the witness? Suite 400 11 Thereupon, 10 West Palm Beach, Florida 33401 12 ALFREDO RODRIGUEZ, ‘i Atzomey for defray Epstels 13 having been first duly sworn or affirmed, was 12 14 examined and testified as follows: 13 ALSO PRESENT: 15 MR. CRITTON: Before we get started just = JOE LANGSAM, VIDEOGRAPHER 16 with regard to Ms. Ezell represents Jane Doe 15 ‘ 17 101 and 102, the alleged time of her 16 18 incidents as of least have been plead in the v7 a 19 complaint for 101 is ‘99 -- I'm sorry, '98 18 20 through 2002, with Jane Doe 102 the Spring 3 21 of -- Spring/Summer of 2003. Mr. Rodriguez 21 22 never even began employment until '04 and 22 23 ‘05. I think her questioning I think -- I 3; 24 can't say she doesn't have standing based on 25 the court order, but I would say it's Page 276 Page 278 1 CONTINUED INDEX OF EXAMINATION 1 completely irrelevant and immaterial and has 2 WITNESS DIRECT CROSS REDIRECT RECROSS 2 no probative value with regard to this i 3 particular witness based upon the two 4 ALFREDO RODRIGUEZ 4 clients at least that are in suit at this 5 point in time. a MRM 278 RAE? 6 MS, EZELL: As Mr. Critton well knows I é (By Mr. Willits) 334 453, 469 7 represent a number of other clients whose . 8 cases have not been filed and I believe we 7 Ay Mr citer) a8 _ 9 do have standing to ask questions, and I do ‘ (By Mr. Edwards) 419, 454, 468 10 intend to do that today. , 11 EXAMINATION 1, Cee hWtanRiCe) 1 12 BY MS. EZELL: 10 13 Q. Mr. Rodriguez, you stated last time that re CONTINUED INDEX OF EaqTEITS 14 there were guests at the house, frequent guests, 13. PLAINTIFFS PAGE 15 friends from Harvard. 34 3 Drawing oe 16 Do you remember that testimony? “4-Photographr 717 AYES; Ma an, io GPhone a 18 Q. And was there a lawyer from Harvard named |! 18 7 Photograph 331 19 Alan Dershowitz? BH ; le a ae 20 A. Yes, ma'am. 21 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. 21 Q. And are you familiar with the fact that Ezell.) 22 he's a famous author and famous lawyer? cas 23 A. Yes, ma'am. 24 24 Q. How often during the six months or so 25 that you were there was Mr. Dershowitz there? Kress Court Reporting, Inc, 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000317 GIUFFRE001006