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

) 19 Grochowski v. Phoenix Const., 318 F.3d 80, 86 (2d Cir.2003). 5 lantosca v. Benistar Admin. Svcs., Inc., 765 F.Supp.2d 79 (D. Mass. 2011) 6 LiButti v. United States, 107 F.3d 110, 121 (2d Cir. 1997) 16 Murphy v. Board of Educ., 196 F.R.D. 220, 222 (W.D.N.Y.2000) 19 Perfect Pearl Co., Inc. v

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

ing to conceal that from the jury or are we going to present 7 it to them? Well, the Second Circuit case that your Honor is 8 well familiar with, LiButti, sets out the factors that have 9 determined that issue, and one of the things we hear from the 10 defendant is, oh, it's never been applied in a

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

we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l

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

we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l