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

y J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] Id Nicole Simmons Nicole Simmons 26 EFTA00605140

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

ISTOS & 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 EFTA00617185

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

le FL 33301 Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale. FL 33301 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem NY 105 0 Is/ Nicole Simmons Nicole Simmons 9 EFTA00595621 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NE

Dershowitz inside the Epstcin mansion during time periods when Epstein was involved in sexually abusing minor girls. For example, houschold employee Juan Alessi testified under oath that one of the famous visitors who came to (he Epstein mansion was “a very famous lawyer that I’m sure you know, Alan Dershowit

isitors who came to (he Epstein mansion was “a very famous lawyer that I’m sure you know, Alan Dershowitz.” (Alessi Depo., at 73:22-25.) According to Alessi's sworn testimony, Dershowitz came to the mansion “pretty often . . . at least four or five times a year” and would stay “two [or] three days.” (73:2

To the best of my recollection, | did not inform Mr Boies of our intentions and, to my knowledge, neither he, nor his partner Ms, McCawley, nor atto Stan Pottinger, were informed in advance of the date or contents of the filing, uy 33. In the course of those public attacks, Mr. Dershowitz made a number of state