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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 11 of 27 Page 355 Q. I'm not trying to make you a sex expert. Also, I assume that when you've been in CVS or Walgreens, for that matter Publix or Winn Dixie I assume that you've -- I don't want to assume anything. Have you ever been in an aisle where you've actually seen condoms being sold? A. Yes. Q. And where lubricants are being sold? 10 A. Yes. li Q. And as well as massage oils and other types of oils actually are sold in those kinds of 13 stores? WDNDUDAWNE 14 A. Yes. 15 Q. And they're available so that someone 16 walking through Walgreens or Publix or CVS could 17 actually take it off the shelf, put it in their 18 cart, go up and pay for it and take it home? 19 A. Yes. 20 Q. Allright. In the photographs that you 21 talked about, and if I understood you correctly, at least during the time that you were there, Mr. Rodriguez, in '04 and '05 there were -- you said that there were -- I think you said downstairs -- and I'm talking about really from the kitchen area Page 356 up the back stairway, or what would be the kitchen stairway to the upper floor, there was I think you said, but correct me if I'm wrong, please, that you don't recall seeing there being any pictures or photographs of any nude women. Is that correct? A. They were not nude women in the staircase. Q. That's all I'm talking about right now. In that area you never saw any pictures, or photographs, paintings, any type of depiction of a nude woman on that staircase going upstairs. Correct? A. Correct. Q. Allright. And I think you said downstairs you saw a picture of -- the only [2 y' that displayed some form of -- I don’ t want to say nudity because it's probably not that, but of some portion of their body that was exposed, and I think you described it as her cheek. A. Yes, that's upstairs. Q. That's upstairs? A. Upstairs. Q. And that was -- was it Eva; is that how 1 2 3 4 5 6 7 8 Page 357 you say her name? A. Yes, her mother. Q. Okay. It's Eva's daughter, there was a picture where someone it looked like was pulling on their swimsuit? A. Yes. Q. Do you recall ever seeing the old Coppertone -- A. Yes. Q. Let me ask the question. I know you know what this is. Have you ever seen the old Coppertone commercials and billboards that used to be plastered all over certainly Florida and other places where there is a cute little girl who appears to be two, three, four years old and someone is pulling down at least a portion of her swimsuit so she's exposing a small portion of her cheek is exposed? A. Yes. Q. Okay. Is that what the picture of the young girl looked like that is Mr. Epstein's God daughter? A. More or less, yes. Q. Allright. And downstairs in the kitchen Page 358 were there any pictures of women in any stage of undress? A. No. Q. And then I think you said as you walk upstairs, or as you walked up the stairway from the kitchen at the top of the landing, I think you described -- did you describe it as the foyer? A. Yes. Q. Okay. But it's really the landing, the upstairs landing? A. Yes. Q. I think you said there were -- there was -- were or was a three by five picture or pictures? A. Yes. Q. Of women in some stage of undress? Q. Okay. And when you say three by five, I assume you meant three feet? Three feet. . By five feet? Yes. . Were they photographs? Yes, they were photographs. And I think you also told us that you eC —) 23 (Pages 355 to 358) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000337 GIUFFRE001027