Epstein Secrets

Ross Gow, who Plaintiff began steps to depose under the Hague Convention in London last Friday, June 17. Plaintiff also seeks to untimely depose (3) Jean Luc Brunel, a witness she had noticed for a mid-June deposition, who apparently did not appear on that date with agreement and consent of Plaintiffs co

who Plaintiff began steps to depose under the Hague Convention in London last Friday, June 17. Plaintiff also seeks to untimely depose (3) Jean Luc Brunel, a witness she had noticed for a mid-June deposition, who apparently did not appear on that date with agreement and consent of Plaintiffs counsel.

on process falls far short of any such good faith showing and the request for leave to take Mr. Gow's testimony beyond July 1 should be denied. C. Jean Luc Brunel With regard to Jean Luc Brunel, Plaintiff simply asserts that he was "subpoenaed," and "set for mid-June deposition[]," but "through counsel" has "

ACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II.

wing: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING,

nt: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DOCUMENT REQUEST NO. 7 All video tapes, au

resent: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DOCUMENT REQUEST NO. 7 All video tapes, au

EOUEST NO. 6 All documents relating to communications with any of the following individuals from 1999 — resent: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DOCUMENT REQUEST NO. 7 All video tapes, audio tapes, photographs or any other print or electronic media relating to females under the age of

the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following w

nts relating to, and all media depicting, any of the following individuals from 1999 — present: Emmy Taylor, Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Luc Brunel, (a/k/a and or any females under the age of 18. (a/k/a 11. All Documents relating to any agreements (including by not limited to confidentiali

Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Luc Brunel, (a/k/a and or any females under the age of 18

or, Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Luc Brunel, (a/k/a and or any females under the age of 18

ey Epstein. INSTRUCTIONS 1. Production of Documents and items requested herein shall be made at the offices of Boies Schiller & Flexner, LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, no later than five (5) days before the date noticed for Your deposition, or, if an alternate date is a

All Documents relating to, and all media depicting, any of the following individuals from 1999 — present: , Eva Dubin, Glen Dubin, Alan Dershowitz, Jean Luc Brunel, (a/k/a or any females under the age of 18. 11. All Documents relating to any agreements (including by not limited to confidentiality agreements

Eva Dubin, Glen Dubin, Alan Dershowitz, Jean Luc Brunel, (a/k/a or any females under the age of 18. 11

, Eva Dubin, Glen Dubin, Alan Dershowitz, Jean Luc Brunel, (a/k/a or any females under the age of 18. 11

rey Epstein. INSTRUCTIONS 1 Production of Documents and items requested herein shall be made at the offices of Soaks Schiller & Flexner, LLP, 401 East Las Olas Boulevard, Suite 1200, Port Lauderdale, Florida 33301, no later than five (5) days before the date noticed for Your deposition, or, if an alternate date is a