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. Alfredo Rodriquez (video) 16. Dave Rogers (video) 12 EFTA00792767 17. (live) 18. Michael Austrich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow (video) 23. Brittany Henderson (live or depo) 24. Any party to this action 25. Any and all wit
rich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
. Alfredo Rodriquez (video) 16. Dave Rogers (video) 12 EFTA00617407 17. (live) 18. Michael Austrich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow (video) 23. Brittany Henderson (live or depo) 24. Any party to this action 25. Any and all wit
rich (video) 19. Sky Roberts (video) 20. Juan Alessi (video) 21. Lynn Miller (video) 22. Ross Gow
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
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
fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the
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
fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the
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
ing offered for the truth of the matter asserted, we want to offer it to show Ms. Maxwell's state of mind when she issued her statement through Mr. Barden and Mr. Gow. So the huge problem with that, your Honor, which Ww ' ve already dealt with, is, Ms. Maxwell has no knowledge of what's in these poli
Entities connected to both Juan Alessi and Barden

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alfredo Rodriguez
PERSON
Alan Dershowitz
PERSON
David Rodgers
PERSON
Bradley Edwards
PERSONDarren Indyke
PERSONMaria Farmer
PERSONJack Goldberger
PERSONJoe Recarey
PERSON
George W. Bush
PERSON
Prince Andrew
PERSON
Jean-Luc Brunel
PERSON
Paul Cassell
PERSON
Virginia Giuffre
PERSON
United States
LOCATION
Kenneth Marra
PERSON
Vicky Ward
PERSON
Wilbur Ross
PERSONthe Southern District
LOCATION