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Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 18 of 21 Mr. Bradley Edwards, counsel in this case. According to the Criminal Complaint filed against Mr. Rodriguez in 2009, Mr. Rodriguez approached one of the lawyers and offered to sell the lawyer evidence against Mr. Epstein. United States v. Rodriguez, United States District Court for the Southern District of Florida, Case No. 9:09-mj-08308-LRJ, EFC No. 3, 93-7. Mr. Rodriguez “explained that he had compiled lists of additional victims in the case and their contact information” Jd. [6. A sting operation was set up by the FBI during which the 97 pages purportedly were provided to an undercover officer in exchange for $50,000. /d. at §§ 8-11. Mr. Rodriguez subsequently was prosecuted and imprisoned for this bribery and obstruction scheme. These actions and conviction, which did not occur until after the deposition Plaintiff seeks to proffer, are quintessential character impeachment evidence that no one has ever examined Mr. Rodriguez about. Given Mr. Rodriguez’s death in 2015, it is now impossible cross examine him on these issues. Submission of Mr. Rodriguez’s testimony without the ability to confront the witness or cross-examine on him on his credibility is improper under Fed. R. Civ. P. 32(a)(8), Fed. R. Evid. 403, 405, 609, 801, 802 & 804. The format and content of the copy of deposition produced also makes its admission improper. While nine deposition exhibits were marked for identification, only one of the exhibits has been produced. Thus, it is impossible to determine the probative value, if any, of the questioning concerning deposition exhibits (including the identification of pictures) because they are unavailable. Similarly, throughout the deposition, the persons being discussed are referred to only by a first initial or first and last initial. From the content, it is impossible to determine who is being discussed or the age of any particular individual. Under 401, 402 and 403, any admission of this incomplete deposition would be improper. 16