Epstein Secrets

y directly. Such 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 docum

or will testify at trial. Plaintiff deposed David Rodgers, Juan Alessi and Ghislaine Maxwell. Having had

f Intent To Offer Statements Under, If Necessary, The Residual Hearsay Rule via ECF on the following: Sigrid S. McCawley Meredith Schultz BOLES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale Lauderdale FL 33301 E I Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS

mulative 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 employees), as well as and (identified as assista

osition testimony of former Palm Beach Detective Joe Recarey and former Palm Beach Police Chief Michael Reiter are duplicative of each other. 4 Mr. Rodgers deposition, held last Friday and requiring a separate trip to Florida for Colorado counsel after the scheduled court hearing on Thursday, served sim

Response in Opposition to Motion to Exceed Presumptive Ten Deposition Limit via ECF on the following: Sigrid S. McCawley Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 383 S. University Street J. Stanley Pottinger

or naught. Also, defense counsel then had to travel to New York for the June 2 hearing and back to Florida for a deposition of another witness, Mr. Rogers, that had been scheduled without input from defense counsel. Counsel for Plaintiff makes much of her efforts to serve witnesses Epstein, and =. Sh

ANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] mschul

DYKE: Attorney-client, work product 4 and common interests. 5 BY MR. EDWARDS: 6 Q. What we have here is only the fraction of 7 flights where Dave Rogers was one of the pilots. 8 Can you help us get the flight logs from Larry 9 Visosky, Larry Morrison, any of the flight logs from 10 the helicopte

1 APPEARANCES (Continued): 2 3 On behalf of Jeffrey Epstein: 4 5 Sligi BY: DARREN K. INDYKE, ESQ. (Via phone) 6 7 On behalf of 8 BOIES, SCHILLER & FLEXNER, LLP 9 BY: SIGRID STONE MCCAWLEY, ESQ. 10 11 12 ALSO PRESENT: 13 Edward J. Pozzuoli, Special Master 14 Sean D. Reyes, Utah Attorney General