Epstein Secrets

vidual witnesses with knowledge regarding the facts of this case, yet provided addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witnesses such as "all other then-minor girls, whose identities Plaintiff will attempt to determine" and "

ounsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witness

heir counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categorie

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

e story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not pub

ue New York, NY 10022 7. (live) c/o Justine Harris Sher Tremonte 80 Broad Street, 13th Fl. New York, NY 10004 8. MI (live) New York, NY 9. Dershowitz (live) c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 14 EFTA00792769 10. Anthony DiVirgilio (live) In

leaders and now it is alleged by Ms. Roberts that Alan Dershowitz is involved and having sexual relatio

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recor

3301 125. 126. Zack Bryan Wellin' on, Florida 127. 128. Larry Morrison WELLINGTON, FL 33449 129. Story Cowles WEST PALM BEACH, FL 33401 130. Alan Dershowitz CAMBRIDGE, MA 02138 or EFTA00798055 DESCRIPTION OF WITNESSES NEW YORK, NY 10017. Subject to assertions of privilege 131. Michael Dawson Palm

tory Cowles WEST PALM BEACH, FL 33401 130. Alan Dershowitz CAMBRIDGE, MA 02138 or EFTA00798055 DESCRIPT

assertions of privilege 76. Donald Trtunp c/o Alan Garten, Esq. 725 Fifth Avenue EFTA00798051 DE

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

time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms claims are obvious lies and should be treated as such and not publicised

nsbury Square 5. Richard Barnett (live) 6. Custodian of Records (live) The Mar-a-Lago Club, Inc. 725 Fifth Avenue New York, NY 10022 7. 8. 9. Dershowitz (live) do Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 14 EFTA00617409 10. Anthony DiVirgilio (live) Inv

world leaders and now it is alleged by Ms. that Alan Dershowitz is involved and having sexual relatio

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 8. (video) 9. (video) 10. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeff

n Testimony and Exhibits) August 7, 2009 Designated Testimony of July 29, 2009 Designated Testimony of October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimony of Alan Dershowitz January 12, 2016 Designated Testimony of Alan Dershowitz January 16, 2016 Designated T

f October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimony of Alan D

ony of October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimon

ition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10 2016 De osition of Rinaldo Rizzo June 20 2016 Deposition of June 21, 2016 Deposition of Joseph Recarey June 23, 2016 Deposition of James Austrich June 24, 2016 Deposition of

rt Lauderdale, FL 33301• EFTA00585427 95. Alan Dershowitz Letter dated 4-19-06 and Statute 90.410. Also obj

t, Fort Lauderdale, FL 33301• EFTA00585427 95. Alan Dershowitz Letter dated 4-19-06 and Statute 90.41

8-04. 94. List of Trilateral Commission Members of 2003. 8 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301• EFTA00585427 95. Alan Dershowitz Letter dated 4-19-06 and Statute 90.410. Also objected to as possible attorney/client privilege. 96. Guy Fronstin letter dated 4-17-06. Also object

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