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

J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & 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 EFTA0061

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

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 SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405

onnin v. Hubregsen, No. 08CIV.7674(PGG), 2009 WL 508269, at *3 (S.D.N.Y. Feb. 27, 2009) (citing Ritchie, 2008 WL 4178152 at *14; Stratavest Ltd. v. Rogers, 903 F.Supp. 663, 668 (S.D.N.Y.1995) (Sweet, J.) ("it is too early at this point in the proceeding [i.e., during discovery] to determine [whether co

75 Lexington Ave New York, New York 10022 (212) 446-2300 Paul Cassell (Seeking Pro Hac Vice) S.J. Quinney College of Law, University of Utah 383 S. University Street Salt Lake City, Utah 84112 (801) 858-5202 [email protected] Bradley J. Edwards (Seeking Pro Hac Vice) FARMER, JAFFE,WEISSING, EDWARD

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

DEPOSITIONS AND MOTION FOR SANCTIONS 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 3

ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 48' Lesley Groff c/o Mike Miller 1114 Avenue of the Americas New York, NY 10036 49. Dave Rogers c/o Bruce Reinhart 505 S. Flagler Drive, Ste 300 West Palm Beach, FL 33401 50. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS

38. c/o Bradley Edwards, Esq. FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 39. Paul Cassell, Esq. 383 S. University Street Salt Lake City Utah, UT 84112 40. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 Fr. LAUDERDALE, FL 33301

's number one co-conspirator who was actually named as such in the NM), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various

2 EFTA00068224 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Cit , UT 84112 Tele hone: January 20, 2016 U.S. Attorney Rose E. Rodriguez-Velez United States Attorney's Office Torre Chardon, S