Epstein Secrets

sell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 8411

that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June 14 and he has nothing to do with the remaining depositions. Mr. Rizzo, in fact, was practically gleeful to be a witness: Doc.

ations are not explicitly referenced in his plea deal. The Washington Post (07/21, Rizzo), Los Angeles Times (07/21, Battaglio), Daily Beast (07/21, Bolies), Rolling Stone (07/21, Rawnsley), New York Post (07/21, DeGregory), and Business Insider (07/21, Davis) also reported on the story. A 'Help Me' Si

ed himself as a girl in some of those communications. Those allegations are not explicitly referenced in his plea deal. The Washington Post (07/21, Rizzo), Los Angeles Times (07/21, Battaglio), Daily Beast (07/21, Bolies), Rolling Stone (07/21, Rawnsley), New York Post (07/21, DeGregory), and Business

following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boule

trial. She has now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailable.' With respect to Mr. Rizzo, she concedes he resides within 100 miles of the courthouse, and provides no basis to claim that he cannot be served. Based on these confessions, th

m's Petition; CVRA-authorized analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and related materials for persons identified as litigation Assertion by Victims Jane Does #15, 16, 17, 18, 19, Past Employees, M

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product