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Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 336 of 465 Page 335 G Maxwell - Confidential would say. Q. Did you ever threaten Alfredo Rodriguez in any way if he were to disclose information he learned from his employment with Jeffrey Epstein? MR. PAGLIUCA: Objection to the form and foundation. A. I'm happy to answer. No, I never threatened him in any way. Q. Were you concerned that he was going to disclose that Jeffrey Epstein was trafficking underage girls? MR. PAGLIUCA: Objection to the form and foundation. A. First of all, there are so many things wrong with that question, but I have no knowledge of what you are talking about. Q. Have you ever contacted or instructed anyone to contact any witness in this case for the purposes of threatening them not to testify in this case? MR. PAGLIUCA: Objection to the form and foundation. A. I have never called anybody with MAGNA® LEGAL SERVICES