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Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 6 of 8 Page 279 f A. Two or three times. 1 2 Q. And did you have any knowledge of why he 2 3 was visiting there? 3 14 A. No, ma'am. 4 5 Q. You don't know whether or not he was a 5 6 lawyer -- acting as a lawyer or whether he was 6 7 there as a friend? 7 8 A. I believe as a friend. 8 9 Q. Were there also young ladies in the house 9 10 at the time he was there? 10 1% MR. CRITTON: Form. 11 12 THE WITNESS: Yes, ma'am. 12 13° BY MS, EZELL: 13 14 Q. And would those have included, for 14 15 instance, Sarah Kellen and Nadia Marcenacova? 15 16 A. Yes, ma'am. 16 17 Q. Were there other young ladies there when a7 18 Mr. Dershowitz was there? 18 19 MR. CRITTON: Form. 19 20 THE WITNESS: Yes, ma'am. 20 21. BY MS. EZELL: 21 22 Q. Do you have any idea who those young 22 23 women were? 23 24 A. No, ma'am. 24 25 Q. Were any of those the young women that 25 Page 280 Page 281 Q. Can you tell me where those were? A. One in the kitchen, and the one in the formal -- the main entrance. And there was one more added later on, but there is two when I was working there. Q. Could you just give me a rough sketch of the house of where the main entrance was and where the kitchen was? A. I'm not an architect but it's something like this. This is the kitchen, this is the main entrance. Q. Will you mark the kitchen with a K, please, and the main entrance with ME? This is the pool. The pool? Yes, ma'am. And in the upper left? In the terrace, yeah, there was a balcony her Od PrOrOPr And where were the staircases? A. This is one, the kitchen, one in the foyer, and the pool. Q. Okay. And would you just put an F where the foyer staircase began? And KS where the kitchen staircase began. Page 282 And you said that later another staircase was added? A. Yeah, we rehabilitated this, you know, but you asked me how many stairs there were, to answer your question there were three. Q. Three. So where was the third one? A. The pool, this leads to the pool. Through the outside master bedroom you could go downstairs to the pool. Q. Okay. A stairway then from the outside, from outside the master bedroom? A. Yes, ma'‘am. Q. Down to the pool? A, Yes, ma‘am. Q. One of your duties was to answer the door. Is that correct? 1 you have said came to give massages? 1 2 A. Yes, ma'am, 2 3 Q. And do you have any idea whether or not 8 4 Mr. Dershowitz was also receiving massages? 4 5 A. I don't know, Ma'am. 5 6 Q. I want to ask you to take this piece of 6 7 paper, please, and a pencil -- 7 8 MR. WILLITS: Can anybody hear me? 8 9 MS. EZELL: Yes. Can you hear me? 9 10 MR. WILLITS: I've heard nothing for 10 11 about a minute or so. ti 12 MR. CRITTON: Can you hear me now? 12 13 MR. WILLITS: Yes. 13 14 MS, EZELL: I'm asking questions, I'm 14 15 sorry. 15 16 MR. CRITTON: Why don't we go off the 16 “| i7 record for a second. 717 18 (Thereupon, a discussion was held off the 18 19 record.) 19 20 THE VIDEOGRAPHER: We're back on the 20 21 record, 21 22 BY MS. EZELL: ped 23 Q. Mr. Rodriguez, you indicated that there 23 24 were several staircases in the house? 24 A. Yes, ma'am, A. Yes, Wrra'arn, Q. Which door would you answer? A. Mainly the kitchen. Q. And why was that, why would people mainly come to the kitchen? A. I'll say it was for practicable reasons because not to go to the main -- it was shorter because the entrance was here, so this was the driveway and we used to take into the back door of Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000318 GIUFFRE001007