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

aintiffs generally rely on treatise material from Wright & Miller, 8 Federal Practice & Procedure Civ.2d, §2041, a

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

m and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh recollections is limited: The law also places limits on how cou

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

to prevent the Defendant from being present in the room where the Plaintiffs arc being deposed, Plaintiffs generally rely on treatise material from Wright & Miller, 8 asicral Practice & ?Paco:lure Civ.2d, §2041, and cases cited therein. The case of Gaella v. OnaSsis, 487 F.2d 986, at 997 (2d CG. 1973). cited by

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

to prevent the Defendant from being present in the room where the Plaintiffs are being deposed, Plaintiffs generally rely on treatise material from Wright & Miller, 8 Federal Practice & Procedure Civ.2d, §2041, and cases cited therein. The case of Oaella v. Onassis 487 F.2d 986, at 997 (2d Cr. 1973), cited by

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

to prevent the Defendant from being present in the room where the Plaintiffs are being deposed, Plaintiffs generally rely on treatise material from Wright & Miller, 8 Federal Practice & Procedure Civ.2d, §2041, and cases cited therein. The case of Oaella v. Onassis 487 F.2d 986, at 997 (2d Cr. 1973), cited by