Epstein Secrets

ositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

ons of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is

they coordinate their efforts in joint conference calls at least two times per month. At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the witnesses for approximately six to eight hours, often repeating the same or similar questions t

ons of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

verned discovery. 9. Interestingly, in Jane Doe 11, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional trauma" set forth in her complaint. Jane Doe No. 11 is also a Plai

09/04/2009 Attorneys at MA Mike Fisten Epstein Juan Alessi Work product; attorney/client privilege; irr

/2009 Attorneys at MA Mike Fisten Epstein Juan Alessi Work product; attorney/client privilege; irr

ted to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidenc

rights 02173 09/04/2009 Attorneys at. Epstein Juan Alessi Work product; attorney/client privilege; irr

s 02173 09/04/2009 Attorneys at. Epstein Juan Alessi Work product; attorney/client privilege; irr

not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at I Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidenc

9/04/2009 Attorneys at RRA Mike Fisten Epstein Juan Alessi Work product; attorney/client privilege; irr

2009 Attorneys at RRA Mike Fisten Epstein Juan Alessi Work product; attorney/client privilege; irr

ted to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidenc

09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday. September 8, 2009 10:12 am.-

he above cause. VIDEOGRAPFIER: Today is September 8, 2009. The time is 12 minutes after 10:00 in the morning. This is the videotaped deposition of Juan Alessi in the matter of Jane Doe number two versus Jeffrey Epstein. This deposition is being held at 2139 Palm Beach Lakes Boulevard in West Palm Beach F

44 22 one: 22 23 (Via tekpbone) 23 24 24 25 25 Page 6 Page 8 I Appearances contimied... 1 PROCEEDINGS 2 On behalf of the Plaintiff. Jane Doe II: 3 ISIDRO MANUEL GARCIA, ESQUIRE 2 — — — GARCIA EI.K1NS & BOEHRINGER 3 THE VIDEOGRAPHER: We are now on video 4 I record. This is Media No.

they coordinate their efforts in joint conference calls at least two times per month. At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the witnesses for approximately six to eight hours, often repeating the same or similar questions t

ons of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

ontinue to attempt to control how discovery is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition.

ons of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned

they coordinate their efforts in joint conference calls at least two times per month. At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the witnesses for approximately six to eight hours, often repeating the same or similar questions t

ontinue to attempt to control how discovery is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition.

989 09/04/2009 Bradley Edwards William Berger Alessi Depo W/P; Attorney Client Privilege; Irrelevant

/02/2009 Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint W/P Priv. 06861-06863 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv. 06876.06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891-06897 05/

989 09/04/2009 Bradley Edwards William Berger Alessi Depo W/P; Attorney Client Privilege; Irrelevant

/02/2009 Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint W/P Priv. 06861-06863 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv. 06876-06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891-06897 05/