Epstein Secrets

5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstei

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 14 and he has nothing to do with the remaining depositions. Mr. Rizzo, in fact, was practically gleeful to be a witness: Doc.

ortedly interviewing witnesses and issuing subpoenas as part of their investigation. The New York Post (01/17, Thaler), and the Independent (01/17, Ross) also reported on the story. Eric Adams Hauls in $650,000 for NYC Mayor's Legal Defense Fund Amid Federal Investigation The Washington Examiner (01

er, Molina, Perlman) also reported on the story. MS-13 Terrorized Northern Virginia by Killing at Random, Witnesses Say The Washington Post (01/17, Rizzo) reported that the MS-13 members had been cruising all night in a gray Mercedes, searching for rival gang members to kill in Maryland or Virginia so

5-year-old Zottola hired 37-year-old hitman Himen Ross, who also received a life sentence, to kill both

ori), The Guardian (04/18, Singh), Axios (04/18, Fischer), Fox News (04/18, Wulfsohn), BBC News (04/18, Debusmann), CNBC (04/18, Mangan, Breuninger, Rizzo), Al Jazeera (04/18, Staff Writer), ABC News (04/18, Katersky, Rubin), Rolling Stone (04/18, Bort, Legaspi), The Intercept (04/18, Maass), Business

ct Court for the Dis- trict of South Carolina, G. Ross Anderson, Jr., J., certified class, and lender a

s unquestionably protected from unwarrant- generally only permitted in "extraordinary ed interference by prosecutorial officials; circumstances," Rizzo v. Goods, 423 U.S. whether the investigation actually involved 362, 379, 96 S.Ct 598, 608, 46 L.Ed2d 661 any unwarranted intrusions into their sat

vid M. Rosen, Ant. U. S. Atty., ar- gued, Robert D. Kingaland, U. S. Atty., St. Louis, Mo., on brief, for appellee. Before GIBSON, Chief Judge, and ROSS and WEBSTER,' Circuit Judges. GIBSON, Chief Judge. This case involves charged violations of the Mann Act arising out of certain inter- state acti

irect evidence, it may properly be adduced from the conduct of the parti United States, 304 F.24 810, 825 (8th CI and the attending circumstances. Rizzo cert. denied, 871 U.S. 890,C S.Ct 188, 9 LEd.2d 123 (1962); Goode United States, 58 F2d 106, 107 (8th CG. 191222). [24] The conduct of the part

47 Thru P-003751 File folder entitled "Adrian Ross" containing subpoena and correspondence regardi

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product