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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 7 of 27 WONAMNDWNY 22 23 24 25 Page 339 You're not required to speculate, you're not required to guess, you're not required to assume because some lawyers ask you a leading question or suggested in a report or like the police report like Mr. Mermelstein and Mr. Edwards did, that did you tell the police officers X, Y, or Z without showing you the statement. You're not required to guess, I want personal knowledge, not speculation. Do you understand? A. Yes, I do. Q. Allright. Now, when Mr. Edwards and -- Mr, Horowitz is here today for Mr. Mermelstein, but you remember a lawyer asked you some questions last time you were here? A. Yes. Q. That is he started and he went on for a few hours. Do you recall that? A. Yes, I remember. Q. He asked you do you remember telling the police officer Y, X, or Z. Do you remember that? Do you remember that's how he phrased his question? A. Yes, yes. Q. He never showed you a statement that you made to the police department; did he? Page 340 A. I'm sorry? Q. He didn't show you a document that said, question, you know, what is your name; answer, my name is Alfredo Rodriguez -- MR. WILLITS: Object to the form of the question. MR. CRITTON: You need to let me finish it first. MR. WILLITS: I'm sorry, I thought you were. BY MR. CRITTON: Q. He never showed you a statement of what the question was and the answer that you gave. True? MR. WILLITS: Object to the form of the question. 7 af don't exactly understand your question. BY MR. CRITTON: Q. Do you know what a deposition is? A. Yes, lam. Q. That's what you're doing here. MR. CRITTON: Could I borrow your deposition for just a minute? MR. HOROWITZ: The Tenet It's =e GRONBESwCMVauUaWNH 16 Page 341 marked up, no, you can't. MR. CRITTON: I just want to show him. Thank you, Cathy. BY MR. CRITTON: Q. This is the first what Ms. Ezell was kind enough to provide is the first part of your deposition, it was transcribed by the court reporter and provided by all counsel. Do you understand that? A. Yes, I understand that. Q. And no one has provided that to you yet today; have they? A. No. Q. Now, I think you told us that with the police officers you gave a taped statement. Did I understand you correctly? A. Yes. Q. And the only conversation that you had with the police officers, and it may have been a state attorney, it was somebody named Ms. Weiss who I think was referenced in the questions, the only time that you talked with at least Officer Recarey and the State Attorney's Office from Palm Beach County was in a taped statement. Is that correct? Page 342 |) A. No. Q. Did you talk with them separate and apart from that? A. Yes, I did. Q. Okay. Did they tape that statement? A. No. Q. You told us you also spoke with representatives of the FBI? A. Yes. Q. Okay. And you distinguished between the FBI and between Officer Recarey? A. Yes. Q. So how many times did Officer Recarey, or Detective Recarey, I think he’s from the Palm Beach Police Department speak with you? A. Like seeds or four mes. O A. Q. I'm sorry, one taped statement? A. Yes. Q. Allright. So as to whether or not if you said something to Officer Recarey or not that you would be able to confirm, that would only have been in a taped statement, one taped statement out |) of the bid sia three times he spoke "19 (Pages 339 to 342) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000333 GIUFFRE00 1023