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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 19 of 27 A: I don’t know sir.” Ex. U at 426-27. 43. Mr. Rodriguez’s testimony contained nothing inculpatory of me and, inasmuch as it concerned the period 2005 and later, it has absolutely no bearing on Ms. Giuffre’s allegations about me, since Ms. Giuffre left Mr. Epstein’s orbit in 2002. 44. Mr. Cassell also refers to Mr. Epstein’s “little black book” of contacts and phone numbers, which Alfredo Rodriguez had stolen. Mr. Cassell claims that “[Rodriguez] appeared to have circled the name of Alan Dershowitz as someone who had information about Epstein[’s] criminal activities.” Cassell Decl., § 21(m). Of course, what Mr. Rodriguez did or didn’t write or circle in Mr. Epstein’s address book is probative of nothing. In fact, however, the address book contained the circled names of many celebrities and other individuals, including Donald Trump, Flavio Briatore, and Courtney Love, among others.® Even the late Elie Wiesel’s name and redacted phone number was in the “black book.” And yet, Mr. Cassell seems to have falsely assumed that, among those individuals whose names were in the book circled, only I was a possible accomplice of Mr. Epstein: Q: Donald Trump was a friend of Jeffrey Epstein; is that not correct? A: I really don't -- my understanding is yes, but I -- I don’t have a lot of information about Trump. Q: It’s true also, is it not, that Mr. Trump was a frequent visitor to Mr. Epstein’s residence? A: I -- I know that he visited frequent. I -- I don’t have a lot of information about Trump. Q: And his name is circled in this book; is it not? 8 Including Peter Soros, Joseph and Florina Rueda, Alberto Pinto, Valda Veira Cotrin, Evan Anderson, Michelle Campos, Eric Gany, Cindy Lopez, Timothy Newcombe, Douglas Schoettle, Caroline Stark, Larry Visoski, Tom and Pat Sawyers, Lynn Fontanella, Christophe Gaie, Bill Maronet, Mike Pazulo, Alan Stopek, and Bruce King. 19