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

DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 3

anscript. BY MR. SCAROLA: Q. The following question was asked of ~ MR. SCOTT: The deposition transcript -- BY MR. SCAROLA: Q. -- of Mr. Juan - Mr. Juan Alessi and -- MR. SCOTT: Let me object to the -- first of all, let me object to this format because he has not been provided a part of the deposition. You'

is is improper. MR. SCAROLA: Okay. MR. SCOTT: Cross-examination, BY MR. SCAROLA: Q. Do you recall the following questions having been asked of Mr. Alessi and the following 274 early January of 2015 that Bradley Edwards and Paul Cassell had the sworn testimony of two - did you refer to them as house -

call the following questions having been asked of Mr. Alessi and the following 274 early January of 2015 tha

4-2822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice Motion Pending S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 Telephone:801-585-5202 Facsimile:801-585-6833 E-Mail:[email protected] Attorneys for Plaintiffs Bradley J. Edwa

86 Russell Adler Delray Beach, FL 87. Marie Alessi BOYTON BEACH, FL 33472 88. Janusz Banasiak 35

358 EL BRILLO WAY PALM BEACH FL, 33480 89. Beata Banasiak 358 EL BRILLO WAY PALM BEACH, FL 33480 EFTA00798052 DESCRIPTION OF WITNESSES 90. Juan Alessi BOYTON BEACH, FL 33472 91. 92. Jerry Goldsmith WEST PA I M BEACH, FL 33418-7942 93. 94. Valdson Cotrin Address Currently Unknown 95. 96.

38. c/o Bradley Edwards, Esq. FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 39. Paul Cassell, Esq. 383 S. University Street Salt Lake City Utah, UT 84112 40. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 Fr. LAUDERDALE, FL 33301

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

J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale. FL 33301 Paul G. Cassell 383 S. University Street Salt Lake City. UT 84112 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem m i NY 105 0 Is/ Nicole Simmons Nicole Simmons 7 EFTA0061

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

J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale. FL 33301 Paul G. Cassell 383 S. University Street Salt Lake Cit iSU UT 12 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem NY 105 0 Is/ Nicole Simmons Nicole Simmons 3 EFTA00595624

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 (

Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 383 S. University Street J. Stanley Pottinger SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405