Epstein Secrets

rs.")). 13 Id. at 19. 10 Id. at 1.3. 21 EFTA00605135 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 25 of 29 Notice of Deposition for Juan Alessi on May 31, 2016, without any conferral with counsel, in Florida, fully aware that defense counsel would be traveling from Colorado. Defense counsel,

would be traveling from Colorado. Defense counsel, in fact, did have to travel on Memorial Day to Florida for the 9:00 a.m. May 31 deposition. Mr. Alessi, however, did not appear on that date, believing that his deposition was for June 1, the same day that his wife had been subpoenaed to appear and be

ts, no deposition occurred on May 31. On June 1, Mr. Alessi appeared, but there was insufficient time to take

EMORANDUM OF LAW IN OPPOSITION TO EXTENDING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 303.831.7364 EFTA00605112 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/

LATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Ave

. Alfredo Rodriquez (video) 16. Dave Rogers (video) 12 EFTA00792767 17. (live) 18. Michael Austrich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow (video) 23. Brittany Henderson (live or depo) 24. Any party to this action 25. Any and all wit

rich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow

Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52025 Counsel for Plaintiff By: /s/ Jeffrey S. Pagliuca Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. Ty Gee (pro hac vice pending) HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Color

Fax: 303-832-2628 [email protected] Jeffrey Pagliuca: Haddon Morgan and Foreman, P.C. 150 East 10th

ch rule makes all the more sense for declarants who actually were deposed in this matter or will testify at trial. Plaintiff deposed David Rodgers, Juan Alessi and Ghislaine Maxwell. Having had the opportunity to question them concerning hearsay statements contained in the now proffered documents and to ob

at trial. Plaintiff deposed David Rodgers, Juan Alessi and Ghislaine Maxwell. Having had the opportunit

X 15-cv-07433-RWS RESPONSE TO PLAINTIFF'S NOTICE OF INTENT TO OFFER STATEMENTS UNDER, IF NECESSARY, THE RESIDUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00617178 Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby

DUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 Ea

. Alfredo Rodriquez (video) 16. Dave Rogers (video) 12 EFTA00617407 17. (live) 18. Michael Austrich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow (video) 23. Brittany Henderson (live or depo) 24. Any party to this action 25. Any and all wit

rich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow

rida 33301 Paul G. Cassell (Pm Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. 84112 Counsel for Plainttg, By: /s/ Jeffrey S. Pagliuca Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. Ty Gee (pro hac vice pending) HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Color

ndant's Trial Counsel: Laura Menninger: Jeffrey Pagliuca: Haddon, Morgan and Foreman, P.C. 150 East 10th

than any other evidence that the proponent can obtain through reasonable efforts" is at best disingenuous. Plaintiff has designated the testimony of Juan Alessi, Mr. Rodriguez's predecessor who held that position during the timeframe in which Plaintiff claims to have been held as a "sex slave" by Mr. Epstei

s. Plaintiff has designated the testimony of Juan Alessi, Mr. Rodriguez's predecessor who held that posit

EFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR USE AT TRIAL Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files h

7 18 19 20 21 22 23 24 25 MAG NA 0 LEGAL SERVICES EFTA00595627 2 3 INDEX Page 4 Examination by Mr. Edwards 4 Examination by Mr. Pagliuca 57 5 Further Examination by Mr. Edwards 68 6 7 8 EXHIBITS 9 Deposition Exhibit 1 6 Police Interview 10 11 12 13 14 15 16 17 1

on, the information purportedly sought is cumulative and duplicative. By way of example, Plaintiff has already deposed (a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4 (former Epstein Pilot). She further seeks to depose and Jo Fontanella (former Epstein household emp

lready deposed (a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4 (

XWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms.

DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395

ve come up from time to time in this case and come up 17 through different witnesses. Now the message pads come in in a 18 number of ways. One is Juan Alessi, who is one of the house 19 butlers. He testified that those were the messages for which 20 they recorded -- we showed him the messages. Yes, tha

ads come in in a 18 number of ways. One is Juan Alessi, who is one of the house 19 butlers. He testifi

ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B

These have come up from time to time in this case and come up through different witnesses. Now the message pads come in in a number of ways. One is Juan Alessi, who is one of the house butlers. He testified that those were the messages for which they recorded -- we showed him the messages. Yes, that's my

ge pads come in in a number of ways. One is Juan Alessi, who is one of the house butlers. He testified t

ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B

These have come up from time to time in this case and come up through different witnesses. Now the message pads come in ina number of ways. One is Juan Alessi, who is one of the house butlers. He testified that those were the messages for which they recorded we showed him the messages. Yes, that's my sign

age pads come in ina number of ways. One is Juan Alessi, who is one of the house butlers. He testified t

: In reply, your Honor, I think you can just see from the upset there what's going to be happening at this trial. This is the direct quote from Mr. Pagliuca. "Fantastical conspiracy". That's going to be the argument from the other side. They're obviously entitled to advance that argument. But that's wh