Epstein Secrets

ly published: The basis for Ms. defamation claim is a January 2, 2016 press statement issued by Defendant to the international press as follows: "Jane Doe 3 is Victoria Roberts — so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations are not new a

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

ly published: The basis for Ms. defamation claim is a January 2, 2016 press statement issued by Defendant to the international press as follows: "Jane Doe 3 is — so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations are not new and have been ful

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

ecL, Ex. A, p. 4. The very first line describing Jane Doe #3 Circumstances is false, ft read: "In 1999, Jane

above, such invocation has no bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative. Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which Ms. Maxwell or the Court could identify the subject matter of their expected te