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.

ANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: 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] mschul

hulz and May 25, 2016 correspondence from myself. 7. Attached as Exhibit F are true and correct copies of Notices of Subpoena with attachments for Jean Luc Brunel, served on February 16, 2016 and May 23, 2016, as well as correspondence regarding Mr. Brunei's deposition from counsel, Bradley Edwards. 8. Attac

otices of Subpoena with attachments for Jean Luc Brunel, served on February 16, 2016 and May 23, 2016, as

of Notices of Subpoena with attachments for Jean Luc Brunel, served on February 16, 2016 and May 23, 2016, as

to Complete Depositions and Motion for Sanctions for Violations of Rule 45 via ECF on the following: Sigrid S. McCawley Meridith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE,

tion 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 testimony. Thus, it is

intiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which

Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which

Response in Opposition to Motion to Exceed Presumptive Ten Deposition Limit via ECF on the following: Sigrid S. McCawley Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 383 S. University Street J. Stanley Pottinger

SPECIAL MASTER POZZUOLI: I do believe it 2 was nonresponsive in its entirety. Move 3 forward. Go ahead. 4 BY MR. EDWARDS: 5 Q. Do you know Jean-Luc Brunel? 6 A. No. 7 Q. Have you ever met him? 8 MR. INDYKE: Same objection, same 9 instruction. 10 A. I have no memory of ever meeting a man by

4 BY MR. EDWARDS: 5 Q. Do you know Jean-Luc Brunel? 6 A. No. 7 Q. Have you ever met him? 8 M

ead. 4 BY MR. EDWARDS: 5 Q. Do you know Jean-Luc Brunel? 6 A. No. 7 Q. Have you ever met him? 8 M

1 APPEARANCES (Continued): 2 3 On behalf of Jeffrey Epstein: 4 5 Sligi BY: DARREN K. INDYKE, ESQ. (Via phone) 6 7 On behalf of 8 BOIES, SCHILLER & FLEXNER, LLP 9 BY: SIGRID STONE MCCAWLEY, ESQ. 10 11 12 ALSO PRESENT: 13 Edward J. Pozzuoli, Special Master 14 Sean D. Reyes, Utah Attorney General