Epstein Secrets

18205 Biscayne Bolevard Suite 2218 Miami, FL 33160 Received by MIMAI-DADE PROCESS, INC. on the 24th day of July, 2009 at 4:00 pm to be served on ALFREDO RODRIGUEZ, 11349 SW 86 LANE, MIAMI, FL. I, RAFAEL (BUDA) GONZALEZ. do hereby affirm that on the 25th day of July, 2009 at 5:24 pm, I: Individually Served the

09, Alfredo Rodriguez, a nonparty, was personally served a subpoena duces tecum to appear for deposition on July 29, 2009 ("the subpoena'). I The I Rodriguez was originally scheduled to appear for deposition on July 23, 2009, but failed to appear, claiming that he had "car troubles." Plaintiffs' counsel a

Road 13 Suite 228 North Miami, Eland,' 14 August 7, 2009 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 CC 20 ALFREDO RODRIGUEZ 21 22 taken on behalf of the Plaintiffs pursuant 23 to a Re-Notice of Taking Continued Videotaped 24 Deposition (Duces Team) 25 Page 272 Page 271 1

t is material to the guilt of Alfredo Rodriguez, regardless of whether that information was requested by the Defendant or not See United States v. Bagley, 473 U.S. 667 (1985). See e Fed.R.Crim P. 16(a)(IXE). Evidence is material that creates a reasonable probability that the outcome of a criminal pr

____________________________________/ PLAINTIFF JANE DOE NO. 2’s MOTION TO COMPEL COMPLIANCE WITH SUBPOENA AND FOR ORDER OF CONTEMPT AGAINST ALFREDO RODRIGUEZ, 1. On July 25, 2009, Alfredo Rodriguez, a nonparty, was personally served a subpoena duces tecum to appear for deposition on July 29, 2009 (“the

z, and Incorporated Memorandum of Law, pursuant to Fed.R.Civ.P. 45(e), and state as follows: 1 1 Rodriguez was originally scheduled to appear for deposition on July 23, 2009, but failed to appear, claiming that he had “car troubles.” Plaintiffs’ counsel

is material to the guilt of Alfredo Rodriguez, regardless of whether that information was requested by the Defendant or not. See United States v. Bagley, 473 U.S. 667 (1985). See also Fed.R.Crim P. 16(a)(1)(E). Evidence is material that creates a reasonable probability that the outcome of a crimina

____/ ORDER THIS CAUSE is before the Court on Plaintiff Jane Doe No.2's Motion to Compel Compliance with Subpoena and for Order of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a response in opposition to the subject Motion has passed and Mr. Rodriguez has elected to not file a respons

Order of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a response in opposition to the subject Motion has passed and Mr. Rodriguez has elected to not file a response to the Motion. Noting Mr. Rodriguez’ failure to file a response to the Motion, it is hereby ORDERED AND ADJUDGED

Rodriguez shall have three (3) days from receipt of said journal from the Government, to produce same to the Plaintiff herein. See United States v. Bagley, 473 U.S. 667 (1985) (U.S. Attorney’s Office has an affirmative duty to produce all evidence in their possession that is material to the guilt of the

Y investigation into this case (see Dkt. 63), or at any time thereafter. 15. We request the complete FBI's case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the government's production cover letter of August 21, 2020. 16. We request copies of the "82-page pros m

case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the gov

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

e with Subpoena and for Order of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a respon

der of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a response in opposition to the subject Motion has passed and Mr. Rodriguez has elected to not file a response to the Motion. Noting Mr. Rodriguez' failure to file a response to the Motion, it is hereby ORDERED AND ADJUDGED

Rodriguez shall have three (3) days from receipt of said journal from the Government, to produce same to the Plaintiff herein. See United States v. Bagley, 473 U.S. 667 (1985) (U.S. Attorney's Office has an affirmative duty to produce all evidence in their possession that is material to the guilt of t

case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the gov

Y investigation into this case (see Dkt. 63), or at any time thereafter. 15. We request the complete FBI's case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the government's production cover letter of August 21, 2020. 16. We request copies of the "82-page pros m

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

no additional information is necessary for trial preparation or to prevent surprise, so a bill of particulars is unwarranted...".); United States v. Rodriguez, No. 99 CR. 367 (DLC), 1999 WL 820558, at *2 (S.D.N.Y. Oct. 13, 1999) ("[T]he indictment, particularly when coupled with the discovery already prov

government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at

no additional information is necessary for trial preparation or to prevent surprise, so a bill of particulars is unwarranted...".); United States v. Rodriguez, No. 99 CR. 367 (DLC), 1999 WL 820558, at *2 (S.D.N.Y. Oct. 13, 1999) ("[T]he indictment, particularly when coupled with the discovery already prov

government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at

no additional information is necessary for trial preparation or to prevent surprise, so a bill of particulars is unwarranted...".); United States v. Rodriguez, No. 99 CR. 367 (DLC), 1999 WL 820558, at *2 (S.D.N.Y. Oct. 13, 1999) ("[T]he indictment, particularly when coupled with the discovery already prov

government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at

no additional information is necessary for trial preparation or to prevent surprise, so a bill of particulars is unwarranted...".); United States v. Rodriguez, No. 99 CR. 367 (DLC), 1999 WL 820558, at *2 (S.D.N.Y. Oct. 13, 1999) ("[T]he indictment, particularly when coupled with the discovery already prov

government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at