Epstein Secrets

limit, yet her proposed depositions are not calculated to lead to admissible evidence in this case. By way of example, Plaintiff identifies ), and Jeffrey Epstein as alleged "co-conspirators" with each other. She requests the depositions of each. Plaintiff anticipates each will invoke the Fifth Amendment — in

harassing questions Plaintiff posed to her concerning her adult, consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein would serve Plaintiff's goal to make a convoluted legal argument, not to actually seek discoverable information. In light of this, the "burden or e

UMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. E

and (identified as assistants to Ms. Maxwell or Mr. Epstein). The information Plaintiff claims each of the wi

ached by Ghislaine Maxwell," and continuing that "Maxwell persuaded Jane Doe 143 (who was only fifteen years old) to come to Epstein's mansion ..." Menninger Decl., N. A at 26-29. No amount of "circumstantial evidence" can overcome the fact that Ms. Maxwell's statement was correct and that statements in the Jo

has simply moved to another, less public forum. Mr. Edwards, in his renewed application, admits that he is a party in active litigation involving Jeffrey Epstein. This litigation involves claims by Mr. Epstein that Mr. Edwards actively participated in a scheme to defraud investors based on falsified claims by

dwards, in his renewed application, admits that he is a party in active litigation involving Jeffrey Epstein. This litigation involves claims by Mr. Epstein that Mr. Edwards actively participated in a scheme to defraud investors based on falsified claims by "victims" of Mr. Epstein. Mr. Edwards has coun

hat he is a party in active litigation involving Jeffrey Epstein. This litigation involves claims by Mr. E

ffrey Epstein. This litigation involves claims by Mr. Epstein that Mr. Edwards actively participated in a sche

Court," as referenced in Motion for Paul Cassell to Appear (Doc. #112), because defense counsel had not received any such supplemental materials. [Menninger Decl. Ex. A]. Ms. McCawley responded that her "staff is scanning them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel se

Plaintiff for use at trial and states as follows: I. PLAINTIFF CANNOT SATSIFY THE LEGAL REQUIREMENTS FOR USE OF CERTAIN DEPOSITIONS AT TRIAL A. Jeffrey Epstein and Ronald Rizzo Are Not Unavailable Plaintiff cannot claim that Jeffery Epstein and Ronald Rizzo are "unavailable witnesses" whose testimony can b

testimony, even attempted to serve these witnesses or obtain their attendance at trial. She has now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailable.' With respect to Mr. Rizzo, she concedes he resides within 100 miles of the courthouse, and pro

Y PLAINTIFF FOR USE AT TRIAL Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

s now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailab

threats to people on the telephone? MR. PAGLIUCA: Object to form and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh

Denver, CO 80203 By: Laura A. Henninger, Esq. Jeffrey S. Pagliuca, Esq. USDC SDNY DOCUMENT ELECTRONI

ty participated in this email 19 EFTA R1 00011995 EFTA01734205 Case 1:15-cv-07433-RWS Document 125 Mled O5/02i16 Page 20 of 31 correspondence." Menninger Decl. 1 117 Supp. Reply at 5 n.2, Documents .11045-46 contain communications between Defendant and Barden; however, documents 81047-51 -include Gow (and