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WCONTDUNEWNE Page 467 that matter anyone else who was upstairs? A. Yes. MR. HOROWITZ: Form. MR. EDWARDS: Form. MR, WILLITS: Object to the form, MR. CRITTON: Thank you, MS. EZELL: I just have a couple of questions. EXAMINATION BY MS. EZELL; Q. Following up on that, you did however see this same young woman asleep naked in the sauna? A, Yes, ma'am. Q. And you did along with Louella find and -- and you did also find sex toys and massagers of various kinds and creams scattered around on several occasions after these young women had bee! upstairs with Mr. Epstein? MR. CRITTON: Object to form, asked and answered about six times. THE WITNESS; Yes, MS. EZELL: No other questions. MR. EDWARDS: Sorry, last one. It has nothing to do with this report. EXAMINATION Page 468 BY MR. EDWARDS: Q. During Mr. Critton's questioning he asked you about whether or not we had ever shown you a previous taped statement that you had given to a police officer, and we did not do that; did we? A. No. Q. We can represent to you that we don't have it to show it to you otherwise we would like to do that. However, he asked you did you tell the police officers at that time that the girls appeared to be 18 years or older, and I believe that you said when you gave the statement to the police that you did; right, say that? A. Yes. that because you were fearful of reprise from Ms. Maxwell and Mr. Epstein, A. That's correct. MR, CRITTON: Form. BY MR. EDWARDS: Q. Okay. Is everything that you've said today and told us today, is it true? A. Yes. Q. To the best of your knowledge? Case 1:15-cv-07433-LAP Document 1331-11 WAOnNauUaAWrHe Filed 01/05/24 Page 7 of 8 . Yes. MR. EDWARDS: Nothing else. MR. WILLITS: Is it my turn? MR. EDWARDS: Yes. EXAMINATION BY MR. WILLITS: Q. Mr. Rodriguez, you mentioned the last time about a lady who was an obvious professional masseuse by the name of Johanna. Do you remember that? Yes, I da remember. Did you ever pay her? . Yes, sir. . Okay, How much did you pay her? A. It was between 200 and 500, sir, but somewnere in that -- between those two amounts. Q. For Johanna? A. Yes, sir. MR. WILLITS: Okay. I don’t have any other questions. MR. CRITTON: You have a right to read this deposition when the other part is typed and make any changes that you want. Would you like to do that? It's your right a hundred percent, The court reporter can provide you or whoever set your deposition -- THE WITNESS: 1 tried to be truthful. MR. CRITTON; All you have to do is tell her you would like to waive. Do you waive the reading and signing? MR. EDWARDS; You can either read or you can waive reading? THE WITNESS: I don't understand what I have to do. MR. CRITTON: Why don't we go off the record and you can explain it to him. MR, EDWARDS: We can go off the record, THE VIDEOGRAPHER: Off the record. (Thereupon, a discussion was held off the “THE WITNESS: Waive. } (Thereupon, the deposition was concluded at 5:30 p.m.) | 51 (Pages 467 to 470) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000365 GIUFFRE002364