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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 recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live) 15. Alfredo Rodriquez (video
iller (video) 27. Frederick M. Miller, M.D. (live) 4800 Cherry Creek South Drive Denver, CO 80246 28. Dr. Steven Olson (video) 29. (video) 30. Joseph Recarey (video) 31. Sky Roberts (video) 32. David Rodgers (video) 16 EFTA00792771 33. Gregory B. Taylor (live) Kyle D. Jacobson Taylor, Jacobson & As
live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recording) 1
nted by the Plaintiff in her case in chief, Ms. Maxwell may offer testimony from the following witnesses at trial: 1. Ghislaine Maxwell (live) c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 2. Kathy Alexander (live) Michaelhouse Pvt Bag X1 Balgowan KwaZulu-Natal 3
28. Dr. Steven Olson (video) 29. IM 30. Joseph Recarey (video) 31. Sky Roberts (video) 32. David Rodge
24. Peter Kent live 25. Guy Louthan (live) 26. Lynn Miller (video) 27. Frederick M. Miller, M.D. (live) 28. Dr. Steven Olson (video) 29. IM 30. Joseph Recarey (video) 31. Sky Roberts (video) 32. David Rodgers (video) 16 EFTA00617411 35. Katie Vaughan-Edwards (live) Orchard End Fittleton 36. Vicky W
ented by the Plaintiff in her case in chief, Ms. Maxwell may offer testimony from the following witnesses at trial: 1. Ghislaine Maxwell (live) do Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 2. Kathy (live) 3. Miles (live) 4. Philip Barden (live) Devonshires So
I think in 7 2005 and going through 2006. The detective initially assigned 8 to the case was a woman named Michelle Pagan, and then 9 Detective Recarey took over the investigation from Ms. Pagan. 10 There were a number of things, according to the reports -- 11 although we don't really have any act
ive you that as the backdrop, your Honor, because 17 then next what seems to happen is very curious, in my 18 experience, and was testified to by Detective Recarey. The 19 police get crossways with the state attorney's office in 20 Florida, and there is a complete distrust between the two 21 agencies. As a
ask that the Court simply apply the law in 25 Tillery. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794661 107 H3v1giu2 1 Oh, Ms. Menninger reminds me, your Honor -- and I 2 think the Court and I are on the same page on this as well -- 3 the tax argument made by Mr. Cassell. Indeed, Ms
nning I think in 7 2005 and going through 2006. The detective initially assigned 8 to the case was a woman named Michelle Pagan, and then 9 Detective Recarey took over the investigation from Ms. Pagan. 1) There were a number of things, according to the reports -- ai although we don't really have any actual
I give you that as the backdrop, your Honor, because Ly then next what seems to happen is very curious, in my 18 experience, and was testified to by Detective Recarey. The 19 police get crossways with the state attorney's office in 20 Florida, and there is a complete distrust between the two 21. agencies. As a resu
CT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011409 10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 107 H3vlgiu2 Oh, Ms. Menninger reminds me, your Honor -- and I think the Court and I are on the same page on this as well -- the tax argument made by Mr. Cassell. Indeed, Ms. Max
sely the type of testimony the presumptive limit 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
ion testimony of former Palm Beach Detective Joe Recarey and former Palm Beach Police Chief Michael Reiter
f, v. GHISLATNE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghis
Entities connected to both Joe Recarey and Laura Menninger

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSON
Prince Andrew
PERSON
Denver
LOCATIONSouthern District
LOCATION
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
United States
LOCATIONLeon Black
PERSON
Paul Cassell
PERSONthe Southern District
LOCATIONSigrid McCawley
PERSON
Colorado
LOCATION
George W. Bush
PERSONBates
PERSON
David Boies
PERSON
Foreman
PERSON