Epstein Secrets

Road Suite 228 13 North Miami, Florida August 7, 2009 14 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 of 20 ALFREDO RODRIGUEZ 21 22 23 24 25 taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Deposition (Duces Tecum) Page 273 Page 272 1

19 21 20 21 22 22 23 23 24 24 25 25 Page 276 1 CONTINUED INDEX OF EXAMINATION 1 2 WITNESS DIRECT CROSS REDIRECT RECROSS 2 3 3 ALFREDO RODRIGUEZ 4 4 5 (8y Ms. Ezell) 278 441, 467 5 6 (By Mr. Willits) 334 453, 469 7 6 (Ely Mr. Critton) 338 464 7 9 (By Mr. Edwards) 419, 454, 468 10 8

rter and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is a continuation of the deposition of Alfredo Rodriguez. Today is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in the witness? Ther

east have been plead in the complaint for 101 is '99 -- I'm sorry, '98 through 2002, with Jane Doe 102 the Spring of -- Spring/Summer of 2003. Mr. Rodriguez never even began employment until '04 and '05. I think her questioning I think -- I can't say she doesn't have standing based on the court order,

to tell her that there was someone at the 9 kitchen door to give a massage? 10 A. She was inside the house so I call her on 11 her cell and say, Alfredo, leave them in the 12 kitchen, but I don't know where she was. 13 Q. Okay. Did she have an office? 14 A. No, ma'am. 15 Q. Did she have a compu

the names of any of the 14 programs -- computer programs -- 15 MR. WILLITS: I am missing something. 16 Whose questioning now? 17 MR. LANGINO: Adam Langino. 18 BY MR. LANGINO: 19 Q. Do you know the names of some of the main 20 computer programs that are used as part of your 21 routine as the house

s. 7 JEFFREY EPSTEIN. B Defendant. 9 10 11 12 1031 Ives Dairy Road 13 14 :5 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 of 20 ALFREDO RODRIGUEZ 21. 22 taken on behalf of the Plainbffs pursuant 23 to a Re-Notice of Taking Continued Videotaped 24 Depo9tlon (Duals Tatum) 25 - - - Page 2/3

1 Q. This document right here, is it 12 refreshing your recollection as to that night? 13 A. Yes. 14 MR. CRITTON: Form. 15 BY MRJDWARDS: 16 Q. Rodriguez quickly entered the house then 17 returned with a sealed envelope wit= first 18 name on It. 19 A. Yes. 20 Q. Do you remember who wrote her fir

to tell her that there was someone at the 9 kitchen door to give a massage? 10 A. She was inside the house so I call her on 11 her cell and say, Alfredo, leave them in the 12 kitchen, but I don't know where she was. 13 Q. Okay. Did she have an office? 14 A. No, ma'am. 15 Q. Did she have a compu

ay. 5 On Sunday, 11/28/2004, at approximate!), 6 19:00 hours, so we're talking about 7:00 at night, 7 the property manager of 358 El Brillo Way, Alfredo 8 Rodriguez, came to the station to complain there 9 was a strange vehide parked in the driveway. 10 A. Yes. 11 Q. That's true? 12 A. Yes. 13 Q. When O

ow the names of any of the 14 programs — computer programs -- 15 MR. WILLITS: I am missing something. 16 Whose questioning now? 17 MR. LANGINO: Adam Langino. 18 BY MR. LANGINO: 19 Q. Do you know the names of some of the main 20 computer programs that are used as part of your 21 routine as the house

the undersigned that they coordinate their efforts in joint conference calls at least two times per month. At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the witnesses for approximately six to eight hours, often repeating the same or sim

At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attor

e. 13. The undersigned and his partner, Mr. Luttier, had a court reporter and a videographer present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for the deposition. 3 09/12/2019 Page CONFIDENTIAL Agency to Agency

s 24 MR. CRITTON: Let me just note my objection. 24 that I mentioned that I think it was undera e was 25 as I did in A. Rod's deposition or Mr. Rodriguez's 25 for sure because Page 46 Page 48 1 deposition. that I know you're going to confiscate 1 2 Exhibit number I. I think it's inappropriate.

23 Mermelstein and Horowitz. representing Jane Does 23 A. No. 24 numbers two through eight. 24 Q. -- or an ad in the paper? 25 MR. LANGINO: Adam Langino. on behalf of 25 A. I had a company at that time used to take care Page 6 Page 8 1 MS. EZELL: Katherine Ezell from Podhurst 1 of a lot of res