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OMANDNRWNKE Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 15 of 134 Page 50 J. Epstein - Confidential BY MR. CASSELL: Q._ Sir, isn't it true that Alfredo Rodriguez reported to Maxwell in 2005? MR. PAGLIUCA: Object to form and foundation. There's no evidence to suggest that he reported to Ms. Maxwell. THE WITNESS: Fifth. BY MR. CASSELL: Who is Sarah Kellen? Fifth. You know Sarah Kellen, don't you? . Fifth. Q. What did Sarah Kellen do for you at your Palm Beach mansion? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Did Alfredo Rodriguez work for you in 2005? A. Fifth. Q. How many years did Alfredo Rodriguez work for you? A. Fifth. OMNDWNWKRWNE Page 52 J. Epstein - Confidential MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Sarah Kellen and Ghislaine Maxwell both assisted in the solicitation of true? MR. PAGLIUCA: Obj c to form and foundation. Again, there is no evidence to suggest that that's true. And, Mr. Cassell, if you have some good faith basis and you want to put it on the record, that's fine. I have the Palm Beach Police Department reports here. We deposed Detective Racari. You know, as well as I do, that there's no evidence to suggest that Ms. Maxwell was involved wit i at all. MR. CASSELL: I move to strike the speaking objections. They're improper in this deposition. And there's a time and a place to put on both your point of views on these issues and, of course, our point of view as well. MR. PAGLIUCA: Well, that's fine. You Page 51 J. Epstein - Confidential Q. Sarah Kellen reported to Maxwell, true? MR. PAGLIUCA: Object to form and foundation. There's no evidence to suggest that Miss Kellen reported to Miss Maxwell. THE WITNESS: Fifth. BY MR. CASSELL: Q. Mr. Epstein, you could give us lots of evidence that Sarah Kellen reported to Maxwell, true? MR. PAGLIUCA: Object to form. Foundation. Argumentative. THE WITNESS: Fifth. BY MR. CASSELL: Q. Sarah Kellen and Ghislaine Maxwell both assisted you in the solicitation of S.G., true? MR. PAGLIUCA: Object to form and foundation. And, again, there's no evidence to show that Miss Maxwell participated in the solicitation of anybody. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please give us all the evidence that Maxwell participated in the solicitation of minors. MAGNA® Page 53 J. Epstein - Confidential know, if we can understand that my form and oundation objection encompasses what you're deeming as speaking objections, I can certainly truncate this and just make my orm and foundation objections. MR. CASSELL: My understanding of the proper procedure is, you should object on orm and foundation unless I ask for further clarification. That's all you need to make the record. MR. PAGLIUCA: Okay. And that form and oundation objection, then, would include my position that there's no good faith basis to be asking these questions; is that correct? MR. CASSELL: That's correct. That would be your position. And of course, our position would be to the contrary. MR. PAGLIUCA: I understand. I'm just trying to make sure that we're not waiving anything, and I'm happy just to -- MR. CASSELL: Sure. MR. PAGLIUCA: -- simply to object to form and foundation, preserving any objections I have to the questioning and the 14 (Pages 50 to 53) LEGAL SERVICES