Epstein Secrets

and for each such card, identify, state or describe the name and address of the financial institution that issued the card (i.e. VISA, MasterCard, American Express, bank, etc.); the name of the person to whom the card was issued (i.e, the name printed on the card), the card number printed on such card, and the

Date Pledged Indebtedness or Assigned 10. For each account receivable, or note receivable you had immediately prior to the commencement of this Action, at the beginning of each calendar year thereafter during the period in question and as of the present date, set forth the name, address and teleph

and for each such card, identify, state or describe the name and address of the financial institution that issued the card (i.e. VISA, MasterCard, American Express, bank, etc.), the name of the person to whom the card was issued (i.e, the name printed on the card), the card number printed on such card, the acco

rogatories contractors or individuals (including, wi ' • services provided to or for the benefit of you, Jane Doe andk in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreem

and for each such card, identify, state or describe the name and address of the financial institution that issued the card (i.e. VISA, MasterCard, American Express, bank, etc.), the name of the person to whom the card was issued (i.e, the name printed on the card), the card number printed on such card, the acco

(including, without limitation, witnesses) for services provided to or for the benefit of you, LM, EW, Jane Doe and/or M) in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreem

and told that the Government was contem- plating the repudiation of the Agreement. Hoffen- berg also arranged for DCC to pay certain of his personal American Express bills. Additionally, Hoffenberg obtained free labor at DCC's expense by using several employees on DCC's payroll to do the work of his publication

s disagreement between the parties is properly the subject of Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting Memorandum of Law (D.E. 47) which is currently pending before this Court.