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

L 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 EFTA00617185

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

dley 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

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

, Ste. 2 Ft. Lauderdale, FL 33301 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] Id Nicole Simmons Nicole Simmons 26 EFTA00605140