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.

26 disclosures served on November 11, 2015 and two of the six were specifically mentioned in Plaintiff's Complaint. Finally, the fact that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June

Tony Figueroa (video) 6. (live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live) 15. Alfredo Rodriquez (video) 16. Dave Rogers (video) 12 EFTA00792767 17. (live) 18. Mic

Alexander Hall (voice recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live)

11. Alexander Hall (voice recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live)

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recor

o) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 8. (video) 9. (video) 10. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live) 15. Alfredo Rodriquez (video) 16. Dave Rogers (video) 12 EFTA00617407 17. (live) 18. Mic

. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live)

10. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live)

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 8. (video) 9. (video) 10. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeff

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

above, such invocation 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 te

South Africa) Valdson Cotrin (France) Jean Luc Brunel (France) 2 EFTA00098756 These are all people

e in South Africa) Valdson Cotrin (France) Jean Luc Brunel (France) 2 EFTA00098756 These are all people

Miles Alexander (South Africa) (Former managers of Little St. James estate) Cecelia Stein (Believed to be in South Africa) Valdson Cotrin (France) Jean Luc Brunel (France) 2 EFTA00098756 These are all people that may or may not cooperate during any criminal investigation. Inner Circle of Jeffrey Epstein —

FTA00098757 Victims Not Identified in the NPA People with Information Regarding Crimes Committed Outside Florida and Not Covered by the NPA "en Rinaldo Rizzo (New York) Former Employee of Glenn Dubin with knowledge of Epstein underage activity Igor Zinoview (Former Bodyguard in New York) Not loyal to E

relationship between Jeffrey Epstein and Jean Luc Brunel. 4 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort

ing relationship between Jeffrey Epstein and Jean Luc Brunel. 4 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort

ey Epstein. Also objected to as Improper/Confidential financial information. 25. All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel. 4 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301• EFTA00585423 26. All documents evidencing relationship between Jeffrey Ep

rn District of Florida 15. Records Custodian of the Federal Bureau of Investigations 16. Spencer Kuvin, Esquire 17. Theodore Leopold, Esquire 18. Rinaldo Rizzo 19. Adam Horowitz, Esquire 20. Isidro M. Garcia, Esquire 21. All of the Lawyers who Represented Victims of Jeffrey Epstein. This is so overbroad th