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Case 1:15-cv-07433-LAP Document 1335-4 DCDOMDADUBPWNHNFDWOWOWOAIDUOBWNE MNMNNDN NY Owe Wh Page 318 G Maxwell - Confidential Rodriguez turned this document over to the FBI, are you aware he described it as a document that came from your computer? MR. PAGLIUCA: Objection to the form and foundation. A. Ihave no idea what he said or didn't say, so if you want me to reference something he said, you need to show it to me. Q. Did you keep this document, an electronic copy of it, on your personal computer? A. Idon't recollect. Q. Ifyou had to update something, for example, if there was a new number, a new individual that Jeffrey had hired that you were going to track, would you input that information into this document on your computer? MR. PAGLIUCA: Objection to the form and foundation. A. I've already testified that I'm not responsible for updating and keeping these records. Q. Did you have this document on your Filed 01/09/24 Page 82 of 106 DMIDHTBPWNHRFPDOANHA UY BWNHE MNNNNND OApBWNHEOW G Maxwell - Confidential 2004, 2005, so, no. Q. But I'm sorry, correct me if I'm misunderstanding your testimony, I thought you said when you were working with Jeffrey, that this document existed and it was something you utilized? A. Ican't possibly tell you what numbers were added or not added subsequent to my departure. Q. So you can't recall if you added any of these numbers? MR. PAGLIUCA: Objection to the form and foundation, mischaracterizes the witness' testimony. Q. Are there any numbers on here or names that you recognize that you would have entered into this section? A. [already testified that I'm not responsible for inputting numbers and names into this so I would not be able to tell you. Q. Are there any names or numbers under this section, Massage Florida, that you would have provided to an assistant to input into this document? DAIANDUBWNHRFPOWOWAAINDUOBWNH Page 319 G Maxwell - Confidential computer, your personal computer? A. I told you, I don't recollect having this document on my computer. Q. Do you know what computers this document was on, if more than one? A. I'm sorry, this is a long time ago and I don't recall exactly how this was all managed. Q. Ifyou didn't create this document, do you know who did? MR. PAGLIUCA: Objection to the form and foundation. A. I don't. Q. I'm going to direct your attention to part of this document. It's towards the back, it's going to be page 91 and it has bates label Giuffre 001663. I'm going to direct your attention to the section that says, Massage Florida. Did you input any of the names or numbers under that section? MR. PAGLIUCA: Objection to form and foundation. A. So this document is produced in AIYDMNBWNHRPOWOAINIAATBRWNHE NNNNN ND OPBWNROW Page 321 G Maxwell - Confidential A. Ican't possibly say. Q. Do you see under Massage Florida, about halfway down the first column, do you see a number that says Johanna's cell? MR. PAGLIUCA: What page? Q. It's 91, Bates number 001663. About halfway down, it says in the first column, it says Johanna's cell. Do you see that? A. Ido. Q. Would you have provided after, I know you didn't hire her, Jeffrey hired her but after you brought her to Jeffrey, would you have given her cell phone number to an assistant to input into this document? MR. PAGLIUCA: Objection to form and foundation. A. I didn't bring her to Jeffrey, the way you characterize and I would have no knowledge of how this number ended up in this book. Q. I believe you, and I will try to use your words so we are clear, you met Johanna, is that correct? 81 (Pages 318 to 321) MAGNA® LEGAL SERVICES