Epstein Secrets

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

tiff], (2) likely to be understood as defamatory by the ordinary person, (3) false, and (4) published with actual malice.'" Biro v. Conde Nast, 963 F. Stipp. 2d 255, 276 (S.D.N.Y. 2013), affd, 807 F.3d 541 (2d Cir. 2015), and aff'd, 622 F. App'x 67 (2d Cir. 2015). If Ms. Maxwell's statements are essenti

r assistance and the interview was concluded at this time. I recei ile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Wo s' telephone number was dialed on several occasions by . A background on Rodgers indicated he has

assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Wo s' telephone number was dialed on several occasions by . A background on Rodgers indicated he has a valid FAA pi of icense First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transpor

edy" (citing Villazon v. Prudential Health Care Plan, Inc. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of Florida's criminal extortion statute does not give rise to a civil cause of action for

ce and the interview was concluded at this time. I received a facsimile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, w o rest es in Lake Worth. Rod ers' telephone number was dialed on several occasions by . A background on Rodgers indicat

to David Rodgers, pilot for Mr. Epstein, w o rest es in Lake Worth. Rod ers' telephone number was dialed on several occasions by . A background on Rodgers indicated he has a valid FAA pi of icense First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transpor

edy" (citing Villazon v. Prudential Health Care Plan, Inc. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of Florida's criminal extortion statute does not give rise to a civil cause of action for