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ities seem to have devolved in recent years. Juan Alessi, his longtime houseman, told police that toward
a local college. Maxwell never showed up in all the surveillance, only her stationery. Epstein's activities seem to have devolved in recent years. Juan Alessi, his longtime houseman, told police that toward the end of his employment, the girls were "younger and younger," and he often had to wash off vibra
house and shopped for Epstein for eight years and never had a direct conversation with him. He made it clear that he did "not want to encounter the Alessis during his stay in Palm Beach." One girl said that when she had sex with Epstein she closed her eyes and thought about cash. "In my mind, I'm like,
of the afterparty at Gaslight was Stella, Gwyneth Paltrow and Usher singing karaoke for the likes of Bono, Britney Spears, Liv Tyler, Debbie Harry, Russell Simmons, Graydon Carter, Christy Tur lington, Karolina Kurkova, Helena Christensen and others too fashionable to mention. Dueling Dems DON'T invite Ed Koc
tunity for new investors was closed, co-investors recall Epstein announcing that he'd found one at last: Dick Snyder then C.E.O. of the publisher Simon S: Schuster. who want- ed to put up approximately S500.000. (Nei- ther Epstein nor Snyder can now recall the investment. Yet in the 1989 deposition E
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
Salem, NY 10590 [email protected] Id Nicole Simmons Nicole Simmons 26 EFTA00605140
0209:58 Service Area Code Al Signed by A.RAMOS Bundle ID 000 surcharge ol 2.50% to Ihis shpinet0 Sender Reeirerit 27.50 -275 0.62 0.00 JOHN ALESSI JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY 100224843 US Transportation Charge Oiscounl Fuel Surcharge Courier Pickup Charge ERIC GANY EPS
Sender Reeirerit 27.50 -275 0.62 0.00 JOHN ALESSI JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY
1.0 lbs. 0.5 kgs Delivered Sep 10.20020997 E SIMMONS JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY
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
Lakes Rd. South Salem m i NY 105 0 Is/ Nicole Simmons Nicole Simmons 7 EFTA00617185
1 2.011:04. 0.9 FOS Oelivered Sep 06. 20020958 Semer, Area Code Al Sons by A,RAMOS Bur4le ID 000 Surcharge 012.50% le tels sNment Jenner JOHN ALESSI JEFFREY E EPSTEIN 457 MADISON AVE NEW VORK NY 100224841 US Transparlaken Charge DiSCOUre Fuel Surcharge Coller Pickup Charge ERIC GANY EPSTE
0 Surcharge 012.50% le tels sNment Jenner JOHN ALESSI JEFFREY E EPSTEIN 457 MADISON AVE NEW VORK NY
1.0 lbs. 0.5 legs Deilvered Sep 10.20020937 E SIMMONS JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY
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
Twin Lakes Rd. South Salem NY 105 0 Is/ Nicole Simmons Nicole Simmons 9 EFTA00595621 UNITED STATES
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 (
ity Street J. Stanley Pottinger SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405
lly Perry Lang/Adam Perry Lang/Adam Alessi/Juan Barnett/Richard n Richard Schoettle/0 Barnett/Richard Spann/Kelly Perry Lang/Adam R etynn Alessi/Juan Perry Lang/Adam Maxwell/Dhislane MarweIVGInslaIne BeIer/Susan Beller/Harry Belef/Naomi LegorettafRichardo Chwatero/Jack Borden/Andres
os rl Sanchez/Carlos Sanchez/Carlos rdi Simmonds/Nicholas n I/ hislaine hi n MIS BellerMarry Barnett/Richard Ochin/Patnck !An N otos Simmonds/Nicholas Simmonds/Nicholas Amount Balance 1.451 65 434,953.29 602 15 435,555.44 637.00 436.192.44 323 00 436.515,44 1.845.40 438.360.84
Entities connected to both Juan Alessi and Russell Simmons

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
FedEx
ORGANIZATION
Eric Trump
PERSON
NEW YORK NY
LOCATION
Alfredo Rodriguez
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Memphis
LOCATION
Donald Trump
PERSONLeon Black
PERSONMaria Farmer
PERSONLarry Visoski
PERSON
Bradley Edwards
PERSON
David Rodgers
PERSON
Ralph Lauren
PERSON
United States
LOCATION
Virginia Giuffre
PERSON