Epstein Secrets

18205 Biscayne Bolevard Suite 2218 Miami, FL 33160 Received by MIMAI-DADE PROCESS, INC. on the 24th day of July, 2009 at 4:00 pm to be served on ALFREDO RODRIGUEZ, 11349 SW 86 LANE, MIAMI, FL. I, RAFAEL (BUDA) GONZALEZ. do hereby affirm that on the 25th day of July, 2009 at 5:24 pm, I: Individually Served the

09, Alfredo Rodriguez, a nonparty, was personally served a subpoena duces tecum to appear for deposition on July 29, 2009 ("the subpoena'). I The I Rodriguez was originally scheduled to appear for deposition on July 23, 2009, but failed to appear, claiming that he had "car troubles." Plaintiffs' counsel a

Road 13 Suite 228 North Miami, Eland,' 14 August 7, 2009 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 CC 20 ALFREDO RODRIGUEZ 21 22 taken on behalf of the Plaintiffs pursuant 23 to a Re-Notice of Taking Continued Videotaped 24 Deposition (Duces Team) 25 Page 272 Page 271 1

469 Entered on FLSD Docket 02/17/2010 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 0840811, 08-80893, 09-80469,

one want to put on the 14 in this case, Alfredo Rodriguez. Are you familiar with IS record what case this

4 most that you've made over the five-year period you've 5 worked for Mr. Epstein? 6 A Yes, sir. 7 0 At the time when you — when we took B Alfredo Rodriguez's deposition, he described you as a 9 very religious Catholic woman. Does that accurately 10 describe you? 11 MR. CRITTON: Let me Just object to

know the schedule, we 16 receive a call, then we prepare. he's coming. 17 O You say we receive a call. Who receives the 18 call? 19 A Either Alfredo or Janusz. 20 O Depending on who the house manager is at the 21 time? 22 A Yes. 23 O And the call comes from whom, from Ghislaine 24 or fr

2 4 1 UNITED STATES DISTRICT COURT 1 - - - 2 SOU tHERN DISTRICT OF FLORIDA 2 INDEX CASE No.08-CV-80119-CIV-MARRNJOHNSON 3 - - • 3 4 4 JANE DOE NO. 2, 5 5 WITNESS: DIRECT CROSS REDIRECT RECROSS Plaintiff, 6 7 JEFFREY EPSTEIN. LOUELLA RABUTO 6 Defendant 7 9 Related Cases: 8 BY MR.

• But you do recall writing messages on this type of pad for Mr. Epstein, correct? A Correct. MR. CRITTON: Stuart, that was exhibit what at Mr. Rodriguez's deposition? MR. MERMELSTEIN: Exhibit 1 at Mr. Rodriguez's deposition. MR. CRITTON: Okay. BY MR. MERMELSTEIN: O In the period 2004 to 2008 bef

t bottom? A I did not know. Q And how did you -- did you do anything in response to this? A No. I went to, what's this, to kitchen and I told Alfredo not to go to the pool. Q And this was the only time you ever remember seeing a girl who wasn't wearing a top at the pool? • 0 ESQUIRE Toll Free

Q Okay. Did she always treat you with respect? A Yes. Q And i think you told us that she's the one who actually hired you? A Correct. Q Was Alfredo Rodriguez the person responsible for hiring you, or was it Ms. Maxwell? A Ms. Maxwell. Q And when you started, you first said that you thought -- well, l

ICT COURT SOUTHERN DISTRICT OF FLORIDA 4 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE No.08-CV-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

fic list of victims thatthe U.S. Attorriey'.s Office knew abqut when i.t pe_nn~d the deal in 200?. If~dditional vi_ctims are listed •in the journal Rqdriguez stole, .HoroWitz said federal prosecutors co.uld reopen the investigation., "It opens the door for further prosecution," he said. In addition, tQ

teenage girls, an attorney representing seven of the victims said Friday. New details about the contents of the journal were released this week when.Alfredo Rodriguez, who worked as a property manager for the Palm Beach resident, pleaded guilty to obstruction ofjustice for lying to federal agents when asked if he h

specific list,of victims that the U.S. Attorney's Office knew about when it penned the deal in 2007. If additional victims are listed in the journal Rodriguez stole) Horowitz said federal prosecutors could reopen the investigation., Tt:opens the door for further prosecution,” he said. In addition to turning

e. Thank you. THE COURT: Thanks very much. MR. EDWARDS: I believe my next client who is going to speak is probably going to speak as Jane Doe. JANE DOE NO. 1: Yes, Jane Doe. THE COURT: We'll say Jane Doe No. 1, just for the record. JANE DOE NO. 1: Okay. Thank you for allowing us to speak today.

ctive Order pursuant to Fed.R.Civ.P. 26(c). In support, Epstein states: Procedural Background 1. This court entered an order (DE 555) stating that Alfredo Rodriguez ("Rodriguez")(DE 469), must produce, to the extent in his possession, "...any and all journal, notes, diaries, and writings relating to Jeffrey Eps

her third parties or attach any portion of same to any pleadings pending the outcome of the Rule 4 Appeal. att infra A roument 3. As set forth in Rodriguez's deposition, he was an employee of Epstein. Rodriguez Deposition, Exhibit "A" at p. 12-13. Moreover, as an individual employee, Rodriguez claims

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

e with Subpoena and for Order of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a respon

der of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a response in opposition to the subject Motion has passed and Mr. Rodriguez has elected to not file a response to the Motion. Noting Mr. Rodriguez' failure to file a response to the Motion, it is hereby ORDERED AND ADJUDGED

t 555 Entered on FLSD Docket 06/01/2010 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-8046

(4) the emotional distress was severe." Gallogly Rodriguez, 970 So. 2d 470, 471 (Fla. 2d DCA 2007) (citing L

Docket 08)18:2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a, JANE DOE NO. I, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. MOTION TO REMAND Plaintiff Jane Doe moves the Court to remand this action to state court fo

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.

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08•CV.80119•CIV•MARRAIJOIINSON JANE DOE NO. 2. Plaintiff. n. JEFFREY EPSTEIN. Defendant. Related cases: 08.10232. 0840360. 9840381 08.10994. 0640993. 0840811. 08.80893. 09.80169. 09.10

(4) the emotional distress was severe." Gallogly Rodriguez, 970 So. 2d 470, 471 (Fla. 2d DCA 2007) (citing L

ed FLSD Docket 10/03/.. J8 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80804-OV-MARRA/JOHNSON JANE DOE, a/k/a JANE DOE NO. 1, Plaintiff, 1. JEFFREY EPSTEIN, , and Defendants. OPINION AND ORDER REMANDING CASE TO STATE COURT THIS CAUSE is before the Court on Plainti