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Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 19 of 22 such pictures on Defendant’s computer. See McCawley Dec. at Exhibit 3, Rodriguez Dep. Tr. at 321-22, 371-73. Another important issue is Defendant’s involvement in the arranging for the girls to come to Epstein’s mansion for provide sexual massages. Here again, Mr. Rodriguez’s deposition provides direct testimony regarding Defendant’s involvement. See id. at 302-03, 366- 69. Third, Mr. Rodriguez’s testimony is more probative on the points for which it is offered than any other evidence that Ms. Giuffre can obtain through reasonable efforts. As the Court is aware, Ms. Giuffre has alleged that she was a victim of a sex trafficking organization run by Epstein, with the assistance of Defendant. Ms. Giuffre has attempted to secure testimony from persons in the organization, starting with Epstein. He took the Fifth on all substantive questions. Then Defendant suffered from convenient memory lapses about critical events and times. Moving down one more echelon in the organization, Ms. Giuffre took the depositions of Sarah Kellan and Nadia Marcinkova. Again, they both took the Fifth on all substantive questions. In stark contrast, Mr. Rodriguez was more than willing to testify. He had a regular job inside Epstein’s Palm Beach mansion and is thus able to provide testimony about what was occurring there during the critical 2005 time period, when girls who were later interviewed by the Palm Beach Police Department were brought there by Defendant to provide sexual massages for Epstein. Ms. Giuffre has diligently sought out other witnesses, but no other witnesses she can call can provide the testimony that Mr. Rodriguez will provide. Finally, admitting Mr. Rodriguez’s testimony will best serve the purposes of these rules and the interests of justice. The purposes of the Rules of Evidence prominently include “ascertaining the truth and securing a just result.” Fed. R. Evid. 102. This Court is well aware of the bitter roadblocks that Defendant has been throwing out to impede testimony about what was 15