Epstein Secrets

llp.com [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, 42

intentions with respect to other witnesses, like Maria Alessi, that she noticed but never deposed. Howev

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

riety of Edwards' actions. 29. do Brad Edwards, Farmer Jaffe Weissing 425 North Andrews Avenue Fort La

EWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 73. Maria Villafana 500 S. Australian Avenue, #400 West P

ll also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 21. Rinaldo Rizzo do Robert Lewis 228 East 45th Street I 17th Floor New York, NY 10017 2-3 Expected to testify about the malicious prosecution elements of absence

5-5202 Fax: 801-585-2750 [email protected] Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425

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

as Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: Fax: University of Utah 383 University Street Salt Lake Cit , UT 84112 Tel: Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: Fax: 49 Twin Lakes Road South Salem

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

ors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L

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