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.

DEPOSITIONS AND MOTION FOR SANCTIONS 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 3

se that is at the heart of this case. Document Request No. 26: All documents relating to commun" • the following individuals from 1999 — present: Jean Luc Brunel an You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly

llowing individuals from 1999 — present: Jean Luc Brunel an You indicate that you are withholding documen

following individuals from 1999 — present: Jean Luc Brunel an You indicate that you are withholding documen

/18 Page 1 of 14 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Cit UT 84112 Tele hone: December 13, 2018 VIA CM/ECF Honorable Magistrate Judge Sarah Netburn United States District Court Thurg

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

FFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] Is/ N

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

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 SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405

pstein will answer your questions, and o22200 16 then, you know, not -- not getting information, Maxwell 022203 17 evading the deposition. 022206 18 Jean Luc Brunel was another person who seemed o22200 19 to be very much involved in -- in trafficking the girls, o2z2210 20 and it was the same situation. A depositi

swers, you know, who is involved, which 022216 22 girls are involved, what are their names, what's -~ 022217 23 what's going on? o2:22:18 24 And so Brunel's deposition is set and then 022223 25 he -~ he finagles out of it too. I don't recall exactly ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 29 of 38

022203 17 evading the deposition. 022206 18 Jean Luc Brunel was another person who seemed o22200 19 to be ver

4-2822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice Motion Pending S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 Telephone:801-585-5202 Facsimile:801-585-6833 E-Mail:[email protected] Attorneys for Plaintiffs Bradley J. Edwa