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cheme. EFTA00729418 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which
rivolous; 17. That the presentation of such evidence by counsel for JONES demonstrates a lack of a good faith basis to prevent same in violation of Federal Rule of Civil Procedure, 1 I: IS. That MORSE has demonstrated by clear and convincing evidence, ownership of these funds by JONES, that said funds are hereby frozen and no
cheme. EFTA00795602 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which
ut merit and frivoh • 17. Tha, presentation of such evidence by counsel for JONES demonstrates a lack of a basis to prevent same in violation of Federal Rule of Civil Procedure, 11: MORSE has demonstrated by clear and convincing evidence, ownership of these + funds by JONES, that said funds are hereby frozen and not subje
S was recruited and joined RRA in the spring of 2009, the tone and tenor of rhetoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing the court on various motions from being substantive on the facts pled to ridiculously inflammatory and sound-bi
rivolous; 17. That the presentation of such evidence by counsel for JONES demonstrates a lack of a good faith basis to prevent same in violation of Federal Rule of Civil Procedure, 11; 18. That MORSE has demonstrated by clear and convincing evidence, ownership of these funds by JONES, that said funds are hereby frozen and not
Entities connected to both Berger and Federal Rule of Civil Procedure

Jared Kushner
PERSON
George W. Bush
PERSON
Jeffrey Epstein
PERSON
Donald Trump
PERSONLeon Black
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Julie K. Brown
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Denver
LOCATION
Marc Rich
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Bradley Edwards
PERSONScott Rothstein
PERSON
United States
LOCATION
Joe Biden
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Department of Justice
ORGANIZATION
Alan Dershowitz
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Samantha Power
PERSONMaria Farmer
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