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Case 1:15-cv-07433-LAP Document 1331-16 Filed 01/05/24 Page 8 of 10 (3) it is more probative on the point for which it is offered than any other evidence that the proponent can obtain through reasonable efforts; and (4) admitting it will best serve the purposes of these rules and the interests of justice. There is nothing trustworthy about Mr. Rodriguez or his statements. Mr. Rodriguez is a convicted criminal, and was convicted for obstruction of justice based on the very testimony Plaintiff seeks to admit. He either created evidence to use in those proceedings, or he hid evidence in them. Either way, his entire testimony is inherently untrustworthy. Mr. Rodriguez has no knowledge of any fact material to this case. He flatly testifies that he had never heard or, met or seen the Plaintiff. He worked for Mr. Epstein over 2 years after Plaintiff left the country. Nothing Mr. Rodriguez could have possibly testified to, even if he was alive, has any bearing on any material fact. Plaintiff's attempt to claim that Mr. Rodriguez’s testimony “is more probative on the point for which it is offered than any other evidence that the proponent can obtain through reasonable efforts” is at best disingenuous. Plaintiff has designated the testimony of Juan Alessi, Mr. Rodriguez’s predecessor who held that position during the timeframe in which Plaintiff claims to have been held as a “‘sex slave” by Mr. Epstein. It simply defies logic to claim that Mr. Rodriguez’ testimony would somehow be more probative than that of the person in his same position at the time Plaintiff alleges she was being held captive as a sex slave. Finally, nothing about the testimony will best serve the purposes of the rules or evidence or justice. Mr. Rodriguez’s testimony is nothing more than hearsay and speculation, as pointed out in the specific objections. The purpose of the rules is thwarted, not served, by the admission of any portion of this wholly irrelevant and improper testimony.