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ether, regardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00205046 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Do
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
ether, regardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00205077 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Do
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
ether, regardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). EFTA00230005 • • • Case 9:08-cv-80736-KAM Document 79.1 Entered on FLSD
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
ether, regardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int'l Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00230040 v , Case 9:08-cv-80736-KAM Document 79-1 Entered on FLS
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
ether, regardless of the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson' Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). 3 08-80736-CV-MARRA 000759 EFTA00230583 • • • Case 9:08-cv-80736-KAM D
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
Entities connected to both Hudson and the West Palm Beach Office

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Michael Jackson
PERSON
Scarlett Johansson
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
George W. Bush
PERSON
Prince Andrew
PERSON
Prince Charles
PERSON
Supreme Court
ORGANIZATION
Ghislaine Maxwell
PERSON
Eric Trump
PERSONFBI
ORGANIZATION
Minneapolis
LOCATIONthe Southern District
LOCATION
James Baker
PERSON
Michigan
LOCATION
Wilbur Ross
PERSON
Marc Rich
PERSON