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ctive Order pursuant to Fed.R.Civ.P. 26(c). In support, Epstein states: Procedural Background 1. This court entered an order (DE 555) stating that Alfredo Rodriguez ("Rodriguez")(DE 469), must produce, to the extent in his possession, " ... any and all journal, notes, diaries, and writings relating to Jeffrey E
ing to Jeffrey Epstein including the journal described by Case 9:08-cv-80119-KAM Document 560 Entered on FLSD Docket 06/10/2010 Page 2 of 11 Rodriguez to Palm Beach Police that [allegedly) contains the names of girls who visited the residence." (the "journal" or "book") (DE 555, p.2) 2. On June 4
depositions "were not open to the public at common law"); Gannett Co. v. DePasguale, 443 U.S. 368, 396, 99 S.Ct. 2898, 2914, 61 L.Ed.2d 608 (1979) (Burger, C.J., concurring) ("[I]t has never occurred to anyone, so far as I am aware, that a pretrial deposition or pretrial interrogatories were other than
931 met near Mexico City on Sept. 17 with Jorge Rodriguez, a former Venezuelan vice president and close all
.com/article/us-health-coronavirus-brazil-vaccine/astrazeneca-covid-19-vaccine- trial-brazil-volunteer-dies-trial-to-continue-idUSICBN2762MO> (10/21, Burger) reports that "a source familiar with the matter told Reuters that the trial would have been suspended if the volunteer who died had received the C
However, USA Today <https://www.usatoday.com/story/news/health/2020/11/16/modema-pfizer-covid-vaccine- heres-what-we-know-thein/6308571002/> (11/16, Rodriguez, Weintraub, 10.3IM) reports all three vaccines "are among six candidate vaccines being supported by more than $10 billion in U.S taxpayer dollars. T
ealth- coronavirus-astrazeneca-oxford/decades-of-work-and-half-a-dose-of-fortune-drove-oxford-vaccine-success- idUSKBN2832NC> (11/23, Smout, Kelland, Burger) reports AstraZeneca "said it was a minor mistake that made the team realise how they could significantly boost the shot's success rate, to as much
t deploys an altered common cold virus to carry the genetic material of the coronavirus and produce an immune response." However, USA Today (11/16, Rodriguez, Weintraub, 10.31M) reports all three vaccines "are among six candidate vaccines being supported by more than $10 billion in U.S taxpayer dollars.
g two full doses one month apart was 62% effective." Combined, the data indicated "an average efficacy rate of 70%." Reuters (11/23, Smout, Kelland, Burger) reports AstraZeneca "said it was a minor mistake that made the team realise how they could significantly boost the shot's success rate, to as much
ign, met near Mexico City on Sept. 17 with Jorge Rodriguez, a former Venezuelan vice president and close all
dy in Brazil. ... Its trial here in the US was put on hold last month after a volunteer in Europe developed neurological symptoms." Reuters (10/21, Burger) reports that "a source familiar with the matter told Reuters that the trial would have been suspended if the volunteer who died had received the CO
e [McAllen] Monitor, McAllen Police Chief Victor Rodriguez said, "We have lost two brave public servants who
use What Donald Trump's 'Access Hollywood' Weekend Says About 2020 Disney World Opens Its Gates, With Virus Numbers Rising Washington Post: A $20 Burger's Pandemic Odyssey Florida Surge Shatters Record Democrats Sense Shift As Trump's Polls Drop Green Goal: Hottest City Finds Ways To Get Cool In T
KMBT_C654e-20190114185410
sses: Two of Epstein’s butlers gave Recarey sworn interviews, confirming that young girls had been coming and going at the house. One of the butlers, Alfredo Rodriguez, told Recarey that when he was tasked with cleaning up the master bath after Epstein’s sessions with the girls, he often discovered sex toys. Once, h
Page: HOUSE_OVERSIGHT_016442 →Once, he accidentally stumbled on a high school girl, whom he identified, sleeping naked in Epstein’s spa, he testified in a 2009 court deposition. Rodriguez said he was given the job of paying the girls, telling Recarey that he was “a human ATM machine” because he was ordered by Epstein to keep $2,000 on
Page: HOUSE_OVERSIGHT_016442 →light on why the District Attorney’s Office initially took the controversial decision to argue in favor of lenient treatment of Epstein.? As Justice Burger wrote, “[p]eople in an open society do not demand infallibility from their institutions, but it is difficult for them to accept what they are prohibi
Page: HOUSE_OVERSIGHT_016500 →dant. Bank Brussels Lambert v. Fiddler Gonzalez & Rodriguez, 171 F.3d 779, 784 (2d Cir.1999). Because these m
Page: HOUSE_OVERSIGHT_017869 →the United States. Accordingly, Plaintiffs may rely on their “purposefully directed” theory to establish these mini- mum contacts. But as existed in Burger King, Calder, and the three terrorism cases, Plaintiffs must allege some personal or direct involvement by the Defendants in the conduct giving rise
Page: HOUSE_OVERSIGHT_017874 →Entities connected to both Alfredo Rodriguez and Burger

Jeffrey Epstein
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
Donald Trump
PERSON
Lesley Groff
PERSON
United States
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Michael Jackson
PERSON
Julie K. Brown
PERSON
Prince Charles
PERSONMaria Farmer
PERSON
Joe Biden
PERSON