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Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 21 of 27 Page 395 1 Q, Allright. And you might find drugs? 2 A. Yes. 3 Q. And some pretty wild parties? 4 A. Yes. 5 Q. Now, with regard to the women who came to 6 give massages, of those women, of those 7 approximately fifteen that you described, how many 8 of them came more than one -- more than one 9 occasion? 10 MR. HOROWITZ: Form. ll THE WITNESS: I'd say more than half. 12 BY MR. CRITTON: 13 Q. So maybe seven, eight, nine, ten? 14 A. Yes. 15 Q. Of those people that came on -- of those 16 seven to ten that came on more than one occasion, 17 did those individuals come on many occasions? 18 A. Yes. 19 Q. And as to the women who were -- who you 20 understood were coming to give the massages -- ai MR. EDWARDS: Form. 22 MR. CRITTON: I'm not done yet. 23 THE VIDEOGRAPHER: I need to go off the 24 record for a second. 25 (Thereupon, an interruption was had.) Page 396 1 THE VIDEOGRAPHER: We're back on the 2 record. 3 BY MR. CRITTON: 4 Q. Mr. Rodriguez, I want to turn to the -- 5 stay with the women who came to give or at least 6 were called to give the massages. 7 You were shown a number of message pads, 8 I think Mr. Mermelstein who represents a number of 9 -- or atleast certainly Jane Doe 2 and some 10 others, you were identified or shown a bunch of 11 message pads that had I think in most instances 12 your initials, A.R. Do you recall that? 13 A. Yes, Ido. 14 Q. I think one of the individuals that you 15 identified that called often was C.W.? 16 A. Yes. WOMNAUAWNHHE MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. And I don't know whether he asked, do you remember a person named T.M.? A. Yes. Q. And would she call from time to time asking if she could come to give a massage just like C.W,? MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q. So at least those two individuals, they were overtly, that is, they were asking whether they could come to give Mr. Epstein a massage. Correct? A. They will call and they will say I need to talk to Sarah, and Sarah fifteen minutes later will tell, Alfredo, we're going to have a massage with so and so. Q. So either C.W. or T.M. would call to ask if they could come and then a massage would be set then they would show up? A. That's correct, sir. Q. Okay. And from time to time they would bring other people as well? That's correct. Both C.W, and T.M.? Yes, Of the females that -- the women that came 2 to the house, did you ever see anyone force any of these women onto the property? A. No, sir. Q. Did you ever see anyone force them into the house? A. No. Q. Did you ever see anyone force them into the kitchen? A. No, sir. Q. Did you ever use any force, any type of intimidation or coercion to bring them into the house and get them into the kitchen? oro> This lady called on a regular basis, or at least from looking at your pad she would call on a pretty regular basis. Is that true? A. Yes. Q. And she and others who are reflected on those message pads, they were calling to come to give massages. Correct? A—No;sit= Q. Did you ever observe Ms. Kellen using any force or intimidation or coercion -- A. No, I did not. Q. -- with any of these individuals? A. Idid not. MR. EDWARDS: Object to the form. BY MR. EDWARDS: ha Did Ms. M. -- let me use the initials Page 397 "33 (Pages 395 to 398) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000347 GIUFFRE00 1037