Epstein Secrets

esses Emmy Taylor, JoJo Fontanilla. and Michael Reiter. (Doc. #224 at 2 n.4) She does not state her int

nly seeks to take three de ositions beyond the limit of ten and that she no longer seeks depositions of witnesses Emmy Taylor, JoJo Fontanilla. and Michael Reiter. (Doc. #224 at 2 n.4) She does not state her intentions with respect to other witnesses, like Maria Alessi, that she noticed but never deposed. Howe

DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 3

the issue of punitive damages. 11 Chief Michael Reiter Palm Beach Police Department 345 South County R

to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. 11 Chief Michael Reiter Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 2-3 Expected to testify about the malicious prosecution elements of absen

38. c/o Bradley Edwards, Esq. FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 39. Paul Cassell, Esq. 383 S. University Street Salt Lake City Utah, UT 84112 40. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 Fr. LAUDERDALE, FL 33301

is intended to prevent. Similarly, the expected deposition testimony of former Palm Beach Detective Joe Recarey and former Palm Beach Police Chief Michael Reiter are duplicative of each other. 4 Mr. Rodgers deposition, held last Friday and requiring a separate trip to Florida for Colorado counsel after the s

ecarey and former Palm Beach Police Chief Michael Reiter are duplicative of each other. 4 Mr. Rodgers dep

Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 383 S. University Street J. Stanley Pottinger SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405

this point -- I don't mean to distract you, but | think the record would be more complete if [ indicated that I did get a phone eall last night from Michael, who told me that he had received numerous phone calls and texts from Virginia Roberts trying to persuade her not to talk to me or cooperate with me

pletely exonerate me. And if your clients had just called me, at the courtesy of simply calling me, I would have been able to point them to Professor Michael Porter of the Harvard Business fo On HM fF WN NNN NNN EH HM eB bb pp pp ob WN FO @ ON A MB WN HO A. Where? Where? Can you point to that? BY MR. SCAROLA:

4-2822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice Motion Pending S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 Telephone:801-585-5202 Facsimile:801-585-6833 E-Mail:[email protected] Attorneys for Plaintiffs Bradley J. Edwa