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154. c o Akin S. Ross, Gs q. 155. 156. Alfredo Rodriguez 11349 SW 86TH LN, Miami, FL C/O Federal Public
NY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION 153' Mark Epstein 30 VANDAM STREET NEW YORK, NY 10013 154. c o Akin S. Ross, Gs q. 155. 156. Alfredo Rodriguez 11349 SW 86TH LN, Miami, FL C/O Federal Public Defender or Bureau of Prisons 157. Scott Rothstein do Mark Nurik One East Broward Boulevard, Suite
pects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. 12 John Connolly do Simon & Schuster 1230 6th Avenue New York, New York 10020 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice
owitz visited Epstein “pretty often. I would say at least four or five times a year” and that he would “typically” stay two or three days. Similarly, Alfredo Rodriguez who worked for Epstein approximately only six months confirmed that during that six months period Dershowitz visited Epstein twice. 14 HOUSE_OVERS
d that he was never in Epstein’s residence in the presence of young women. As both Dershowitz and Epstein know, that assertion was also false. As Mr. Rodriguez has confirmed, there were “also young ladies in the house at the time he [Dershowitz] was there”. Mr. Rodriguez also confirmed that “Mr. Dershowitz w
ortunity for new investors was closed, co- investors recall Epstein announcing that he’d found one at last: Dick Snyder, then C.E.O. of the publisher Simon & Schuster, who wanted to put up approximately $500,000. (Neither Epstein nor Snyder can now recall the investment. Yet in the 1989 deposition Epstein said that
ir encounter or bad things could happen. Alfredo Rodriguez, a houseman, told police that at his boss's direc
cereal and milk. One 16-year-old told police that Epstein told her repeatedly not to tell anyone about their encounter or bad things could happen. Alfredo Rodriguez, a houseman, told police that at his boss's direction, he brought a pail of roses to a girl to congratulate her on her performance in a high-school
rtunity for new investors was closed, co-investors recall Epstein announcing that he'd found one at last: Dick Snyder, then C.E.O. of the publisher Simon & Schuster, who wanted to put up approximately $1O0,000. (Nei- tnerEpstein nor Snyder can now recall the investment. Yet in the 1989 deposi- tion Epstein said t
cereal and milk. One 16-year-old told police that Epstein told her repeatedly not to tell anyone about their encounter or bad things could happen. Alfredo Rodriguez, a houseman, told police that at his boss's direction, he brought a pail of roses to a girl to congratulate her on her performance in a high-school
ich had been left in a sink. Alfredo Rodriguez, a former house manager, told probers that he "knew" Epstein's masseuses were still in high school. Rodriguez also told of having to "wipe down" vibrators and sex toys post-massage and returning them to an armoire near Epstein's bed. It gets worse. About 22
unity for new investors was closed, co-investors recall Epstein announcing that he'd found one at last: Dick Snider. then C.E.O. of the publisher Simon & Schuster. who want- ed to put up approximately 5500.000. (Nei- ther Epstein nor Snyder can now recall the investment. Yet in the 1989 deposition Epstein sa
Ottawa sources said the extension was virtually inevitable given the seriousness of the crisis in the United States." According to Politico (7/13, Rodriguez, Lippman, 4.29M), the Administration is "planning to extend restrictions barring non-essential travel across the Mexican and Canadian borders until
e Hal Greenwald "denied the claim that Mary's book was in violation of a family settlement or that there was any wrong done by the book's publisher, Simon & Schuster." The Washington Post (7/13, Jacobs, 14.2M) says Greenwald's decision "prioritizes the First Amendment over a dated confidentiality agreement among
Entities connected to both Alfredo Rodriguez and Simon & Schuster

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Martha Stewart
PERSON
Marc Rich
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONDaphne Wallace
PERSON
George Mitchell
PERSON
Donald Trump
PERSON
United States
LOCATION
Lesley Groff
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Michael Jackson
PERSONMaria Farmer
PERSON