Epstein Secrets

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

he 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 Docket 05/03/2011 Page 5 of 31 DISC

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

he 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 Docket 05/03/2011 Page 5 of 31 DISC

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

he 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 Docket 05/03/2011 Page 5 of 31 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

he 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 FLSD Docket 05/03/2011 Page 5 of 31

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

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 Document 79.1 Entered on FLSD Doc

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

the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson.. Intl Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 08-80736-CV-MARRA 000794 EFTA00230618 v , Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docke