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HOUSE_OVERSIGHT_010747

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Case 9:08-cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 13 of 19 Q. And did you have any knowledge of why [Dershowitz] was visiting there? A. No ma’am. Q. And do you have any idea whether or not Mr. Dershowitz was also receiving massages? A. I don’t know, Ma’am. Q. As to whether any of those women were ever associated with Mr. Dershowitz would it be a correct statement that you have absolutely no knowledge? A. I don’t know, sir. Q. Okay. Were you in any way attempting in your response to Ms. Ezell to imply that Mr. Dershowitz had a massage by one of these young ladies? A. I don’t know, sir. Q. You have no knowledge? A. No, sir. (Rodriguez Depo. Tr. at 279, 280, 385, 386.) To be sure, Rodriguez does testify that Prof. Dershowtiz was at Epstein’s home when young females were present at the home — an allegation which Dershowitz strenuously denies. However, Rodriguez did not testify that Prof. Dershowitz saw, interacted with, or touched any of these females. Instead, when asked what Prof. Dershowitz did “while those girls were at the house,” Rodriguez answered “He will read a book with a glass of wine by the pool, stay inside.” (Id. at 426, 427.) When asked if Prof. Dershowitz ever even spoke to any of the girls, or “even knew that they were there” Rodriguez answered “IT don’t know.” (Id. at 427.) This is consistent with the fact that Epstein’s home is very large and has separate closed-off quarters where Epstein resided. Prof. Dershowitz never stepped into these private quarters. Jane Doe #3 also relies upon the September 8, 2009 deposition testimony of Mr. Juan Alessi to “corroborate” Jane Doe #3’s sensational and false allegations regarding Prof. Dershowitz. However, a more complete examination of that testimony reveals that Alessi did not make any allegations of any wrong doing by Dershowitz. (See, DE 291-17, hereinafter 13 HOUSE_OVERSIGHT_010747

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