Giuffre_Maxwell_Batch6_p00144.png

Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 4 of 8 RICHARD WILLITS, ESQ. 2290 10th AVenue North Suite 404 Lake Worth, Florida 33461 Attomey for C.M.A. Appeared via telephone. BURMAN, CRITTON, LUTTIER & COLEMAN, LLP BY: ROBERT CRITTON, ESQ. 515 North Flagler Drive Suite 400 West Palm Beach, Florida 33401 Attomay for Jeffrey Epstein. ALSO PRESENT: JOE LANGSAM, VIDEOGRAPHER CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ (By Ms, Ezell) 278 441, 467 (By Mr. Willits) 334 453, 469 (By Mr, Critton) 338 4A (By Mr. Edwards) 419, 454, 468 (By Mr. Langino) 452 CONTINUED INDEX OF EXHIBITS PLAINTIFF'S PAGE 3 Drawing 315 5 Photograph 331 6 Photograph 331 7 Photagraph 331 8 Photograph 331 9 Report 446 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. Ezell.) Page 275 WANDUBWUNe Deposition taken before MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is a continuation of the deposition of Alfredo Rodriguez. Today is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in the witness? Thereupon, ALFREDO RODRIGUEZ, having been first duly sworn or affirmed, was examined and testified as follows: MR. CRITTON: Before we get started just with regard to Ms. Ezell represents Jane Doe 101 and 102, the alleged time of her incidents as of least have been plead in the complaint for 101 is '99 -- I'm sorry, '98 through 2002, with Jane Doe 102 the Spring of -- Spring/Summer of 2003, Mr, Rodriguez never even began employment until '04 and ‘05. I think her questioning I think -- I can't say she doesn’t have standing based on the court order, but I would say it's completely irrelevant and immaterial and has no probative value with regard to this particular witness based upon the two clients at least that are in suit at this point in time, MS. EZELL: As Mr. Critton well knows I represent a number of other clients whose cases have not been filed and J believe we do have standing to ask questions, and I do intend to do that today, EXAMINATION BY MS, EZELL: Q. Mr. Rodriguez, you stated last time that there were guests at the house, frequent guests, friends from Harvard. Do you remember that testimony? Q. And was there a lawyer from Harvard name Alan Dershowitz? A. Yes, ma'am. Q. And are you familiar with the fact that he’s a famous author and famous lawyer? A. Yes, ma'am, Q. How often during the six months or so 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 GIUFFREO023 16