Epstein Secrets

atement of Undisputed Facts. 12 EFTA00725980 In addition, if Epstein had thought that there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising an

judgment is proper as a matter of law. See Davis v. Hathaway, 408 So. 2d 688, 689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43. B. Epstein's Claims Regarding Edwards Have Absolutely No Factual Basis. 5 EFTA00725973 This is not a complicated case for granting summary judgment. To the co

girls) had happened in New York, he (Epstein) would have received only a $200 fine (id); • Epstein made very negative and derogatory comments about Jane Doe's attorney Brad Edwards and that Edwards was the one causing all of Epstein's problems (i.e., the civil suits brought by Jane Doe and other girls) (i

A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil Suit and to Pursue his Counterclaim for Compensatory and Punitive Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80

une 30, 2010, listed all named victims ofJeffrey Epstein as fact witnesses for trial, which of course included Jane Doe. As such, any argument that Jane Doe's deposition is needed "solely" as a result of a recent Court ruling is also absurd. 5. Rather, Epstein was obviously well-aware of the relevance of

ated by the Court, that the depositions be needed "solely" as a result of a recent ruling, and the Motion should be denied on those grounds alone. B. Epstein's Prior Counsel Failed to Set L.M. and Jane Doe's Depositions, Despite Requesting and Receiving Dates for Their Depositions in August 2017. 7. The M