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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 22 of 27 Pas ge 399 1 that way it will show up correctly. 1 Q. Did any of them ever appear to be 2 Did T.M. ever use from what you saw, did 2 frightened? 3 she ever use any force or coercion or intimidation 3 MR. HOROWITZ: Form. 4 with any of the women that she brought to the 4 THE WITNESS: No. 5 house? 5 BY MR. CRITTON: 6 MR. HOROWITZ: Form. 6 Q. Did any of the women appear to be 7 MR. EDWARDS: Object to the form. 7 fearful? 8 THE WITNESS: No, sir. 8 A. No. 9 BY MR. CRITTON: 9 Q. Did any of them appear to be 10 Q. Okay. I'm just talking about what you 10 uncomfortable in coming into the house? 11 observed during the time. And you know what I ll MR. EDWARDS: Form. 12 mean by force? 12 THE WITNESS: No. 13 A. Yes. 13 BY MR. CRITTON: 14 Q. You know what I mean by intimidation? 14 Q. At any time did any of them express to 15 A. Yes. 15 you verbally that they were in fear when they came 16 Q. Could to be verbal intimidation or 16 into the house? 17 coercion, either verbally or using some form of 17 A. No, sir. 18 her body, or their bodies. 18 Q. Did any one of the fifteen girls that 19 A. Yeah, I understand that. 19 came to the back door, then into the kitchen, and 20 MR. EDWARDS: Form. 20 prior to your leaving them in the kitchen say, Mr. 21 MR. HOROWITZ: Form. 21 Rodriguez, or Alfredo, or sir, could you get me 22 MS. EZELL: Objection, form. 22 out of here? 23 BY MR. CRITTON: 24 Q. When C.W. brought individuals to the house, did you ever see her use any force or 23 A. No, sir. 24 Q. Did any of them tell you verbally that they were uncomfortable? Page 400 1 __ intimidation or coercion from what you could 1 A. No. 2. observe with those women who had come to givea | 2 Q. Did anyone say help me or I'm scared? 3 massage? 3 A. No. 4 A. No. 4 Q. Did all of them appear to be at least 5 MR. EDWARDS: Form. 5 when they came to the back door in a reasonably 6 MR, HOROWITZ: Form. 6 good mood? 7 MS. EZELL: Form. 7, A. Yes. 8 BY MR. CRITTON: 8 Q. They all appeared to be happy? 9 Q. With any of the fifteen women that you 9 A. Yes. 10 observed who came to the home to give massages 11 during the time period ‘04 through I think you 12 said February of '05, the time period I think was 13 it August, Mr. Rodriguez -- 14 A. August, 15 Q. -- August of '04 through February of '05? March of '05. 10 Q. Smile, I'd say interact with you verbally 11 in your greetings? 12 A. That's correct. 13 Q. Did any one of the fifteen girls that you 14 observed during the August ‘04 through March 2005 time period from your personal observation appear to be there -- appear to be at the Epstein home MR. EDWARDS: Object to the form. MR. HOROWITZ: Object to the form, 20 THE WITNESS: No. 21 BY MR. CRITTON: 22 Q. Did any one of the fifteen women who came 23 to give the massage ever tell you that they had been forced to come to the house or coerced into 18 A. Yes. 19 Q. Okay. That's the time period I'm 20 focussing on. 21 Of the approximately fifteen women that 22 you came to see to give massages that you let in 23 the back door after punching the security code, did any of them ever appear to be scared? Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000348 GIUFFRE001038