Giuffre_Maxwell_Batch6_p00208.png

Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 24 of 27 Page 407 1 were leaving the house, did anyone ever tell you 2 that they had been injured? 3 A. No, sir. 4 Q. Did they ever tell you that they had been 5 forced to do something against their will? 6 A. No. 7 Q. Did they ever tell you that they had been 8 forced to do something inappropriate? 9 A. No. 10 Q. Did they ever tell you that they had been 11 assaulted in any way? 12 A. No. 13 Q. Did they ever tell you that they had been 14 inapprcpriately touched? 15 A. No. 16 MR. HOROWITZ: Form, This is a 17 cumulative. He's already told you the 18 limited contact he had. This is totally 19 inappropriate line of questions. 20 MR. CRITTON: Is that a form objection? 21 MR. HOROWITZ: You're exceeding the scope 22 of the direct because nobody asked him -- 23 MR. CRITTON: Form, you get form in 24 federal court, that's what you get. Give me 25 your form. Page 408 1 MR. HOROWITZ: Form, cumulative. 2 MR, CRITTON: Great. Why don't you let 3 me finish the question and then you can 4 object to it, 5 Could you give me back what my last 6 question was, please? Z. (Thereupon, a portion of the record was 8 read by the reporter.) 2 THE WITNESS: No. 10 BY MR. CRITTON: iL Q. Did they ever tell you that they had been 12 sexually assaulted in any way? 13 MR. EDWARDS: Form. 14 MR. HOROWITZ: Form. 15 THE WITNESS: No. 16 BY MR. CRITTON: 18 A. No. 19 Q. At any time did you hear anyone -- strike 20 that. 21 As to the women who came to give a 22 massage, did you ever hear anyone scream? 23 A. No, sir. 24 Q. Did you ever hear anyone cry out what 25 sounded like to you help? millions of dollars? Q. Okay. Are you aware that some of them are now claiming that they were sexually Page 409 1 MR, EDWARDS: Form. 2 THE WITNESS: No. 3 BY MR. CRITTON: | 4 Q. Did you ever hear anyone yell rape or iH 5 assault or battery? } 6 MR. HOROWITZ: Form. } 7 THE WITNESS: No, H 8 BY MR. CRITTON: ! 9 Q. Did you ever hear anyone yell out in 10 anger? i 11 A. No. I 12 Q. You've gone online, Mr. Rodriguez, and 13 looked at various articles or postings that have | 14 been made regarding these cases. Is that a fair H 15 statement? 16 A. I'm sorry? i 17 Q. If I understood your testimony from July 18 29th and a little bit today, is that you've gone 19 online and read some articles and/or what the f 20 police report may have said, that is, you've read 21 information that you've -- about these lawsuits 22 after the time that you left Mr. Epstein's 23 employment. ot A. Yes. 25 Q. Correct? Page 410 1 A. Yes. 2 Q. And, therefore, you have at least seen H 3 certain allegations and what people say occurred, f 4 or at least their recitation of what may have 5 occurred at Mr. Epstein's home. ' 6 A. Yes. f 7 Q. You have no personal knowledge one way or |} 8 the other. 9 MR. HOROWITZ: Object to the form. 10 MR. EDWARDS: Form. 11 BY MR. CRITTON: ! 12 Q. Correct? 3) A. That's correct. 14 Q. Are you also aware that the individuals } 15 who have filed lawsuits want in some instance 16 I! F 20 assaulted? 21 A. Yes. H 22 Q._ And battered? 23 A. Yes. ; 24 And you have no information, no personal 25 knowledge in that regard. Is that true? — —_ i 36 (Pages 407 to 410) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000350 GIUFFRE00 1040