Epstein Secrets

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 Page 272 1 JANE DOE NO. Ii, CASE NO: 08-CV.80469 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant. 6 JANE DOE NO

15 A. No, sir. 16 MR. WILLITS: I don't have any other 17 questions. 18 CROSS EXAMINATION 19 BY MR. CRITTON: 20 Q. Mr. Rodriguez, my name is Bob Critton and 21 I represent Mr. Epstein as you're aware, I have a 22 few questions for you. 23 What I would like to remind you at the 24 start of this is

in NY Appeal. We can assess how best to deal with its aftermath if we prevail which we have a substantial chance to do. 2) I am finishing the 4 vol Tatum state depo. Protective Order requires notice/ct order to use but I have seen no Order precluding use of excerpts of written transcript. Will check w

ber of their staff) ...or an expert. The written transcript is not included in the Order. Before you show the written transcript, I will check with Bob Critton. The portions of the written tr that show that as to LM (a) no interstate nexus, travel, force and (b) arguably no sexual act within federal statuto

, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 05995 04/01/2009 Bradley Edwards Carolyn Edwards Third party subpoenas for Tatum/Courtney Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence;

issible evidence; protected by privacy rights 02045-02046 09/04/2009 Attorneys at RRA Bradley J. Edwards E.W., Doe v. Epstein — Letter from Bob Critton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect