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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.
depends on the diligence of the moving party."); Perfect Pearl Co., Inc. v. Majestic Pearl & Stone, Inc., 889 F. Supp. 2d 453, 457 (S.D.N.Y. 2012) (Engelmeyer, J.) ("To show good cause, a movant must demonstrate that it has been diligent, meaning that, despite its having exercised diligence, the applicable
tein associates who also rented apartments or ran businesses out of the building included an ex-girlfriend, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia
-girlfriend, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at the build
nd, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed s
he carried for the gang. But he still participated in the gang's violent activity. "You appear to have learned a very hard lesson a very hard way," Engelmeyer said. Walter could be out of jail in three years with good behavior, authorities said. Sapone said Walter joined the entourage to work for Tekashi,
nd, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed s
tein associates who also rented apartments or ran businesses out of the building included an ex-girlfriend, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia
-girlfriend, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at the build
he carried for the gang. But he still participated in the gang's violent activity. "You appear to have learned a very hard lesson a very hard way," Engelmeyer said. Walter could be out of jail in three years with good behavior, authorities said. Sapone said Walter joined the entourage to work for Tekashi,
tein associates who also rented apartments or ran businesses out of the building included an ex-girlfriend, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia
-girlfriend, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at the build
nd, his pilot, and his MC2 business partner, Jean-Luc Brunel. (One of Epstein's alleged victims has claimed s
he carried for the gang. But he still participated in the gang's violent activity. "You appear to have learned a very hard lesson a very hard way," Engelmeyer said. Walter could be out of jail in three years with good behavior, authorities said. Sapone said Walter joined the entourage to work for Tekashi,
Entities connected to both Jean-Luc Brunel and Engelmeyer

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
Donald Trump
PERSON
Joe Biden
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
Les Wexner
PERSON
John F. Kennedy
PERSONthe Southern District
LOCATION
Ehud Barak
PERSON
Sarah Kellen
PERSON
New York
LOCATIONFBI
ORGANIZATIONNadia Marcinkova
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Mark Epstein
PERSON