Epstein Secrets

came and found the old car in the driveway? 19 20 A. Exactly, yes, with the police, yes. 20 21 Q. How did you remember that it was Tony 21 22 Figueroa? 22 23 A. It's the only person, male that I 23 24 remember. 24 25 Q. But you don't know his name? 25 Page 445 alrie, I guess. was to help

scayne Boulevard Suite 2218 MINN, FlorIda 33160 Attorney for lane Doe 2, 3, 4, 5, 6, and 7. 5 6 7 8 10 11 12 13 14 PODHURST ORSEOC BY: KATHERINE W. EZELL, ESQ. 15 25 West Hagler Street Suite BOO 16 Miami, Rorida 33130 Attorney for Jane Doe 101 and 102. 17 18 LEOPOLD-KUVIN 19 BY: ADAM 3. LANG

24 25 25 Page 276 1 CONTINUED INDEX OF EXAMINATION 1 2 WITNESS DIRECT CROSS REDIRECT RECROSS 2 3 3 ALFREDO RODRIGUEZ 4 4 5 (8y Ms. Ezell) 278 441, 467 5 6 (By Mr. Willits) 334 453, 469 7 6 (Ely Mr. Critton) 338 464 7 9 (By Mr. Edwards) 419, 454, 468 10 8 11 9 (By Mr

without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the sh

d Case No. 08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Str

equesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity must include speci

3401 561-832-7732 561-832-7137 F [email protected] Counselfor·Plaintiff in Related Case No. 08- , 80469 • Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] kezell@p

en 19 you came and found the old car in the driveway? 20 A. Exactly, yes, with the police, yes. 21 Q. How did you remember that it was Tony 22 Figueroa? 23 A. It's the only person, male that I 24 remember. 25 Q. But you don't know his name? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

GUEZ, having been first duly sworn or affirmed, was examined and testified as follows: MR. CRITTON: Before we get started just with regard to Ms. Ezell represents Jane Doe 101 and 102, the alleged time of her incidents as of least have been plead in the complaint for 101 is '99 -- I'm sorry, '98