Epstein Secrets

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

essions, the Motion in Limine to exclude the use of the designated portions of these depositions in toto must be granted. B. As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable Plaintiff's argument concerning Phillip Esplin fails to acknowledge or even address the cases cited that require that

n of Sky Roberts May 24, 2016 Deposition of Lynn Trude Miller May 26, 2016 Deposition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10 2016 De osition of Rinaldo Rizzo June 20 2016 Deposition of June 21, 2016 Deposition of Jose

lson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00090987 FOIA CONFI

n of Sky Roberts May 24, 2016 Deposition of Lynn Trude Miller May 26, 2016 Deposition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10, 2016 De sition of Rinaldo Rizzo June 20, 2016 Deposition of June 21, 2016 Deposition of Jos

lson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19, 2019 EFTA00090984 FOIA CONFIDENTIAL TREAT