{"efta_number": "EFTA02788266", "page_count": 6, "url": "https://epstein-data.com/EFTA02788266", "pdf_url": "https://epstein-data.com/pdf/EFTA02788266.pdf", "pages": [{"efta_number": "EFTA02788266", "page_number": 0, "text_content": "Case 1:15-cs-07433-LAP\n\nDocument 1256-13\n\nFiled 05/03122\n\nPage 1 of 6\n\nEXHIBIT A\n\nEFTA02788266\n\n", "char_count": 96}, {"efta_number": "EFTA02788266", "page_number": 1, "text_content": "Case 1:15-cv-07433-LAP\n\nDocument 1256-13\n\nFiled 05/03/22\n\nPage 2 of 6\n\nPage 1\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\nx\n\nPlaintiff,\nCase No.:\n15-cv-07433-RWS\n\n-againstGHISLAINE MAXWELL,\nDefendant.\n\nx\n**CONFIDENTIAL**\n\nVideotaped deposition of RINALDO\nRIZZO, taken pursuant to subpoena, was\nheld at the law offices of Boies\nSchiller & Flexner, 333 Main Street,\nArmonk, New York, commencing June 10,\n2016, 10:06 a.m., on the above date,\nbefore Leslie Fagin, a Court Reporter\nand Notary Public in the State of New\nYork.\nMAGNA LEGAL SERVICES\n1200 Avenue of the Americas\nNew York, New York 10026\n(866) 624-6221\n\nMAGNA 0\n\nLEGAL SERVICES\n\nEFTA02788267\n\n", "char_count": 666}, {"efta_number": "EFTA02788266", "page_number": 2, "text_content": "Case 1:15-cv-07433-LAP\n\nDocument 1256-13\n\nFiled 05/03/22\n\nPage 3 of 6\n\nPage 2\nAPPEARANCES:\nJAFFE WEISSESG\nLEHRMAN. P.L.\nAttorneys for PLandiff\n425N. Mathews Avenue\nFort Lauderdale Florida 33301\nBRAD\nBY.\nESQL1RE\n\n9\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nFISTOS ft\n\nHADDON\nAttorneys to Defendant\nI50 East 10th Avenue\nDawn. Colorado 80203\nBY.\nJEFFREY S PAGLIUCA. ESQUIRE\n\n10\n11\n12\n13\n\nPage 4\n\nFREEMAN\nLLP\nAttorneys for the Witness\n228 East 48th Street\nNew Yak. New York 10017\nESQ\nBY\nROBERT\n\n14\n15\nAlso Present\n16\nRODOLFO DURAN, Videortaphet\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nIt Rizzo - Confidential\nRizzo.\nTHE VIDEOGRAPHER: Will the court\nreporter please swear in the witness.\nRINALDO RIZZO,\ncalled as a witness, having been duly\nsworn by a Notary Public. was\nexamined and testified as follows:\nEXAMINATION BY\nMR.\nQ. Mr. Rizzo, can you tell us your\nfull name for the record?\nA. Rinaldo A. Rizzo.\nQ. And what is your date of birth?\nA.\nQ. 111.\naddress?\nA.\nt is your educational\nbackground?\nA. I have a management degree with a\nminor in business law from Texas A&M\nUniversity. and I have a degree in applied\nscience in hospitality and culinary arts from\nthe Culinary Institute of America.\n\nPage 3\n1\n2\n3\n4\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n\nTHE VIDEOGRAPHER: This is DVD No.\nl in the video-recorded deposition of\nill\nRizzo, in the matter of\nversus Ghislaine Maxwell. in the\nUnited States District Court, Southern\nDistrict of New York. This deposition\nis being held at 333 Main Street in\nArmonk. New York. June 10. 2016. at\napproximately 10:06 a.m.\nMy name is Rodolfo Duran. I am the\nlegal video specialist. The court\nreporter is Leslie Fagin, and we're both\nin association with Magna Legal\nServices.\nWill counsel please introduce\nthemselves.\nMR.\n: Brad\nI\nsin\nthe plaintiff.\n\n21\n22\n23\n24\n25\n\nMR. PAGLIUCA: Jeff Pagliuca.\nappearingao ehalf of Ms. Maxwell.\nMR.\njagkrt =.\nwith the\nfirm of Freeman =.\nLLP,\nrepresenting the deponent. Rinaldo\n\nPage 5\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nR. Rizzo - Confidential\nQ. Are you married?\nA. Yes.\nQ. Who are ou married to?\nA.\nQ. ow ong ve you been married?\nA. We've been together 27 years, so\n22.\nQ. And do you have children?\nA. Yes.\nQ. How many?\nA. One.\nQ. Since graduating, what has been\nyour profession?\nA. It is called private service or\ndomestic service.\nQ. What does that mean?\nA. My role is to work within a family\nas a desired position that's offered to me.\nand most of it's been in management or\nsupport of household staff.\nQ. Was there a time when you worked in\nie usehold of Glenn\nand Eva\nA. Yes.\n\nMAGNA 0\nL\n\n2 (Pages 2 to 5)\n\nOAL S t itvic Es\n\nEFTA02788268\n\n", "char_count": 2656}, {"efta_number": "EFTA02788266", "page_number": 3, "text_content": "Case 1:15-cv-07433-LAP\n\nDocument 1256-13\n\nFiled 05/03/22\n\nPage 4 of 6\n\nPage 126\n\nPage 128\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\n1\nR. Rizzo - Confidential\n2\nfired abruptly at this point, right?\nA. Correct.\n3\n4\nQ. You went and retained counsel to\n,\nsue the Dubins, their entity and\n5\nall of them, right?\n6\nA. Correct.\n7\n8\nQ. I take it you were deposed in\nconnection with that litigation, correct?\n9\nA. Correct.\n10\n11\nQ. Now, during that litigation, that\n12\nlitigation meaning the reference in Exhibit\n13\n3, 13-cv-8864, did you ever tell anyone about\nthe interactions with Mr. Epstein that you\n14\ndescribed here today?\n15\nA. No, I did not.\n16\n17\nQ. That was not a part of your\nlawsuit, correct?\n18\n19\nA. Could you restate the question? I\n20\ndon't understand what -21\nQ. You didn't raise that as an issue\n22\nas to why you were suing the Dubins in 2013,\nright?\n23\n24\nA. No, I did not.\nTHE VIDEOGRAPHER: The time is\n25\n127\nPage\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nR. Rizzo - Confidential\n12:41. We are going off the record.\n(Recess.)\nTHE VIDEOGRAPHER: The time is\n12:47 p.m. We arc back on the record.\nThis begins DVD No. 3.\nBY MR. PAGLIUCA:\nQ. I just have a few more questions.\nI'm going to finish off with your employment.\nSo after this lawsuit was\nconcluded, referenced in Exhibit 3, have you\nworked since then?\nA. No, I have not.\nQ. Has your wife worked since then?\nA. On and off, yes.\nQ. How is it that you are currently\nsupportingyourself?\nA. I'm on disability.\nQ. That's as a result of your back\ninjury?\nA. Yes, and my hip injury.\nQ. I didn't realize you had a hip\ninjury, I'm sony. Is that Social Security\ndisability?\nA. Yes, it is.\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nR. Rizzo - Confidential\nQ. The lawsuit with the Dubins\nreferenced in Exhibit 3 was settled, I take\nit?\nA. Correct.\nQ. That was pursuant to a confidential\nsettlement agreement?\nA. Correct.\nQ. And I am assuming that you received\na sum of money to settle that litigation, is\nthat correct?\nA. Coned.\nQ. And I'm not going to ask you the\ndetails about that, but in case I need to do\nsomething, let me put it this way. If I\nchoose to subpoena that settlement agreement\nfrom the Dubins, are you going to have any\nobjection to that, or is it all right if we\ndo that as far as you are concerned?\nA. I would have to discuss it with my\nlawyer.\nMR. PAGLIUCA: I can talk to you\nabout that, if we decide to do it.\nQ. I just want to turn now, and this\nis the last series of questions I have, what\nPage 129\nR. Rizzo - Confidential\nyou did in advance of coming here today.\nHave you talked to Mr.\nbefore?\nA. Yes.\n.._And when have you talked to Mr.\nA. I don't recall the exact date and\ntime.\nQ. Did Mr\ncall you or did you\ncall Mr.\nfirst?\nA. I called him.\nQ. When did you call Mr.\nA. I don't recall the exact date and\ntime.\nQ. Years ago, days ago, months ago?\nA. Ifs been at least over a\nQ. Why did you call Mr.\n.\nA. At the time I was having a very\nhard time with my attorney. My wife and I\nhad discussed the issue. As my wife put it,\nwe needed an attorney with balls and she had\nbeen keeping track of the Jeffrey Epstein\nissue, and la\nin our conversation -MR.\n: Let me stop you there.\n\nMAGNA 0\n\n33\n\n(Pages 126 to 129)\n\nLEGAL SERVICES\n\nEFTA02788269\n\n", "char_count": 3294}, {"efta_number": "EFTA02788266", "page_number": 4, "text_content": "Case 1:15-cv-07433-LAP\n\nDocument 1256-13\n\nFiled 05/03/22\n\nPage 5 of 6\nPage 132\n\nPage 130\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\n1\nR. Rizzo - Confidential\n2\nThere is a privilege of spousal\nprivilege, so please don't disclose\n3\n4\nconversations you had with your wife.\nTHE WITNESS: Sorry.\n5\n6\nMR.\n: You can answer the\n7\nquestion why you called, but you don't\n8\nneed to disclose anything about\n9\nconversations with your wife.\n10\nA. I was looking for an attorney that\n11\nbasically could handle this kind of\nsituation, and I felt like, from what I had\n12\n13\nread, that Mr.\nwas probably someone I\n14\nneeded to attain, if I could.\n15\nQ. And so the, you referenced\n16\ndissatisfaction with an attorney. I'm\n17\nassuming that was the attorney that filed\n18\nthis 13-cv-8664 action, is that correct?\n19\nA. Correct.\n20\nQ. So you weren't happy with that\n21\nlawyer and you were looking for a more\n22\naggressive lawyer?\n23\nA. Correct, or someone that could work\n24\nwith my lawyer.\n25\nG. The point being you were looking to\nPage 131\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nR. Rizzo - Confidential\nrecover some form of compensation, I take it,\nfrom the Dubins or Mr. Epstein?\nA. I was hoping -- how does Mr.\nEpstein -Q. I don't know. I'm asking the\nquestion.\nA. That's incorrect.\nQ. You were seeking to get\ncompensation from the Dubins, though?\nA. Correct.\nQ. And that was the point of you\nis that, however you\ncalling Mr.\nlearned it, you learned about the E ein\nlitigation and you knew Mr.\nwas\ninvolved in the Epstein litigation?\nA. Correct.\n. The point of you contacting Mr.\nwas to see if he could represent you\nin some litigation involving the Dubins in\nwhich you would collect money, is that right?\nA. Correct.\nQ. And so when you called Mr.\nwhat do you recall telling him?\nMR.\nAt this point, I object\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nR. Rizzo - Confidential\non attorney/client privilege grounds.\nThe conversation is privileged for the\npurpose of seeking legal advice.\nMR. PAGLIUCA: I don't understand.\nMr.\nis the lawyer for the\nwitness.\nMR.\nI am the lawyer for the\nwitness.\nMR. PAGLIUCA: I know, I'm not\nasking aboSu.\nMR.\nHe called Mr.\nfor the\nto determine whether MI\ncould represent him in some\ncapacity in that other lawsuit, so the\nconversations is privileged.\nMR. PAGLIUCA: I'm going to\ndisagree, and you know we may need to\nrevisit that issue respectfully.\nMR.\n: Fair enough.\nMR. PAGLIUCA: Let me put some\nparameters on this that don't ask for\ncommunications.\nMR.\n: Ask a question and I\nwill object or not.\nPage 133\nR. Rizzo - Confidential\n'think\nyou said you called Mr.\nabout a year ago?\nA. More or less, correct.\nQ. I didn't print out the docket\nsheet, but do you recall when you settled the\n13-cv-8664 case?\nA. To the best of my recollection. I\nthink it was in December.\nQ. Of?\nA. I don't recall. I mean, it's last\nyear.\ntelling me what you told\nMr.\nwhat was the purpose of your\ncalling -- I think you already told me this,\nso I won't reask it. Never mind.\nDid you just speak with Mr.\nover the phone?\nA. Correct, yes.\nQ. And I take it Mr.\ndid not\nbecome your lawyer in connection with any\nlitigation ai,he Dubins, correct?\nMR.\n: You may answer that.\nA. Correct.\nQ. And Mr.\nin some fashion\n\nMAGNA°\n\n34\n\n(Pages 130 to 133)\n\nLEGAL SERVICES\n\nEFTA02788270\n\n", "char_count": 3335}, {"efta_number": "EFTA02788266", "page_number": 5, "text_content": "Case 1:15-cv-07433-LAP\n\nDocument 1256-13\n\nFiled 05/03/22\n\nPage 134\n\nPage 6 of 6\nPage 136\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\n1\nR. Rizzo - Confidential\n2\nindicated to you that he wasn't going to be\n3\nyour lawyer in connection with litigation,\n4\ncorrect?\n5\nMR.\n: Objection. Do not\n6\nanswer tImirivilege grounds.\n7\nQ. Mr.\nnever became your\n8\nlawyer, is that right?\n9\nA. Correct.\n10\nQ. After that conversation, did you\n11\nhave an -- after you understood that Mr.\n12\nwas not your lawyer, Si\nhave\n13\nfurther conversations with Mr.\n14\nA. No, I did not.\n15\nQ. You may object to this, but I need\n16\nto ask this question. In the first\n17\nconversation that\nwith Mr.\n18\ndid you tell Mr.\nthe things that\n19\nyou've toldlit r today?\n20\nMR.\n: Objection. Do not\n21\nanswer.\n22\nMR. PAGLIUCA: Privilege?\n23\nMR.\n: Yes.\n24\nMR. PAGLIUCA: So just so the\n25\nrecord is clear, it seems to me this\nPage 135\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nR. Rizzo - Confidential\nwould be a subject matter waiver of\neverything that he has talked about.\ndon't know why it makes a difference if\nabout it now and he told\nhe isat\nMr.\nI think he can talk about\nwhat he said to Mr.\n. It seems\nto me th r i waiver here.\nMR.\n• You are presuming what\nhe said to Mr.\n. And secondly,\njust because, even if that were the\ncase, I'm not saying it is, just because\nyou testify to incidents which you tell\nyour attorney about doesn't mean the\ndisclosures to your attorney are not\nprivileged.\nMR. PAGLIUCA: Fair enough. We can\nargue about this later if we need to.\nBY MR. PAGLIUCA:\nQ. Other than Mr.\nand your\nwife and your current attorney, have you\ntalked to anyone else about the things that\nyou've talked about here today?\nA. No, I have not.\nQ. I think you answered this question,\n\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nR. Rizzo - Confidential\nbut I want to make sure.\nat first conversation with\nMr.\ndid you speak with Mr.\nagain in advance of this deposition today?\n: You may answer that.\nMR.\nA. No, I have not.\nQ. Do you know, did Mr.\nprovide a list of questions to your lawyer,\nwho is here today, for you to provide those\nanswers to your lawyer to give to Mr.\nMR.\n: I advise the witness to\nonly answer that question to the extent\nhe knows it outside of any conversations\nthat he might have had with me, which\nare privileged.\nA. No.\nQ. So let me explain that question,\nand here is my issue with that, and I don't\nknow if this happened or didn't happen, but\nif there are questions that mtgiven\nproposed to you by Mr.\nand you give\nthem to the client with the expectation he is\ngoing to give that information to you to give\nPage 137\nR. Rizzo - Confidential\nto Mr.\nit's not privileged.\nMR.\n: I can represent that\ndidn't happen.\nMR. PAGLIUCA: That solves the\nproblem.\nQ. I'm just closing the loop on this\nand then we are done.\nHave you spoken to anyone who is\naffiliated with Mr.\neither another\nlawyer in his office, paralegal, an\ninvestigator, about the things that you've\ntalked about here today?\nA. No, I have not.\nMR. PAGLIUCA: That's all I have.\nMR.\n: I don't have any\nquestions. I appreciate you taking the\ntime. Sorry about your injury.\nTHE VIDEOGRAPHER: The time is\n12:58 p.m. and we are going off the\nrecord.\n(Recess.)\nTHE VIDEOGRAPHER: Back on the\nrecord.\nMR. PAGLIUCA: Ths_parties have\n\nMAGNA°\n\n35 (Pages 134 to 137)\n\nLEGAL SERVICES\n\nEFTA02788271\n\n", "char_count": 3393}]}