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

26 disclosures served on November 11, 2015 and two of the six were specifically mentioned in Plaintiff's Complaint. Finally, the fact that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June

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

ll also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 21. Rinaldo Rizzo do Robert Lewis 228 East 45th Street I 17th Floor New York, NY 10017 2-3 Expected to testify about the malicious prosecution elements of absence

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

above, such invocation has no bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative. Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which Ms. Maxwell or the Court could identify the subject matter of their expected te

79. Documents related to Jeffrey Epstein's investments. Also objected to as Improper/Confidential financial information. 80. Letter from Chief Michael Reiter to Barry Krischler. 81. List of planes owned by Jeffrey Epstein. Also objected to as Improper/Confidential financial information. 82. Letter fro

rbroad that Epstein cannot possibly make a determination as to whether or not he seeks to exclude anything under this exhibit identification. 108. Reiter letter to ICrisher dated 5-1-06. 109. Jail receipts of Jeffrey Epstein. 110. Police Report dated 11-28-04. 1 1 1. Compulsory Medial Examination

rn District of Florida 15. Records Custodian of the Federal Bureau of Investigations 16. Spencer Kuvin, Esquire 17. Theodore Leopold, Esquire 18. Rinaldo Rizzo 19. Adam Horowitz, Esquire 20. Isidro M. Garcia, Esquire 21. All of the Lawyers who Represented Victims of Jeffrey Epstein. This is so overbroad th