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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 6 of 27 WOWNAUAWNHE Page 335 Q. Do you remember whether she came to the 1 house on more than one occasion? 2 A. I heard her name several times from 3 Sarah, sir, but beyond that I cannot say anything 4 else. 5 Q. Okay. Who have you talked to about your 6 knowledge of Mr. Epstein in the last year? 7 A. My wife. 8 Q. Anyone else? 9 A. No, sir. 10 Q. Well, you talked to Mr. Critton. 11 A. We have a conversation in West Palm 12 Beach. 13 Q. Yes. So you talked to your wife, you 14 talked to Mr, Critton? 15 A. Yes. 16 Q. Had you talked to anyone else in the last 17 year about Epstein? 18 A. No. 19 Q. Did you talk to Mr. Goldberger? 20 A. Yeah, I called Mr. Goldberger first 21 before I talked to Mr. Critton. 22 Q. Okay. So we have your wife, we have Mr. 23 Critton, and we have Mr. Goldberger. 24 Do we have anyone else that you talked to in the last year? 1 A. No, sir. 2 Q. How about Mr. Epstein of course? 3 A. No. 4 Q. Where did you usually keep the journal 5 with the names of the girls, in what part of the 6 house? Zz A. In the staff house. 8 Q. Sorry? 9 A. The staff house, the guest house. 10 Q. Right. But you said you had a journal at tt your own residence with the names of the girls. 12 A. I give the whole journal and all the information regarding this case, sir, to Detective Joe Recarey, sir. Q. Okay. And the materials that you gave to kept at your own personal residence? A. Yes, they were with me, sir. Q. Okay. When you gave the materials to the Detective, did all of the materials you gave to him come from your residence? A. Yes. Q. Do you remember exactly what you gave to Page 337 A. Igive him a list of notes that I used to take from frequent people -- I mean, people who used to frequent the house and -- I'm sorry, it's been a few years, I don't remember, but it was those years, like it was a file with my personal notes because he told me it was very important and he kind of said can I borrow this from you, and he still has those documents, sir. Q. So even though they pertain to Mr. Epstein you kept those notes at your residence? A. Yes, sir. Q. Okay. Where in your residence did you keep those notes before you gave them to the Detective? A. In my bedroom. Q. Did you have a file cabinet or -- A. No. Q. -- chester drawers or something? A. No, they were laying next to some other papers that I have. Q. Did the other papers pertain to Mr. Epstein? A. No, no, nothing else related to Mr. Epstein. Q. I'm just confused as to why you told us before that you had a journal at home and today you say that you gave everything to the Detective. MR. CRITTON: Form. You also may have missed a portion of his earlier testimony if you couldn't hear something, but go ahead. MR. WILLITS: Most likely. THE WITNESS: What I said was I thought I had some information, and then I look with my daughter and we couldn't find anything, and I remember now that I put everything in the file that I give to Detective Recarey. BY MR. WILLITS: Q. Did anyone help you assemble those papers to give to the Detective? A. No, sir. MR. WILLITS: I don't have any other questio CROSS EXAMINATION BY MR. CRITTON: Q. Mr. Rodriguez, my name is Bob Critton and I represent Mr. Epstein as you're aware, I have a few questions for you. What I would like to remind you at the start of this is if you know something, tell us, if you don't know something tell us that. 18 (Pages 335 to 338) Kress Court Reporting, Inc, 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000332 GIUFFRE00 1022