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5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstei
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
A00792761 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is o no
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
NDAM STREET NEW YORK, NY 10013 154. c o Akin S. Ross, Gs q. 155. 156. Alfredo Rodriguez 11349 SW 86
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
A00617401 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so n
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
Deposition of November 18, 2016 Deposition of Ross Gow January 17, 2017 De. osition of January 25
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
Deposition of November 18, 2016 Deposition of Ross Gow Index to BSF ShareFile Materials loaded on A
ition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10, 2016 De sition 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
Entities connected to both Wilbur Ross and Rinaldo Rizzo

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Prince Charles
PERSON
George Mitchell
PERSONEmmy Taylor
PERSON
Colorado
LOCATION
Bradley Edwards
PERSONMaria Farmer
PERSONFBI
ORGANIZATIONJane Doe
PERSON
Alfredo Rodriguez
PERSON
Vicky Ward
PERSON
David Rodgers
PERSON