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orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume
unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t
ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,
ourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free fro
he background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the Brit
s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?” the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private.” The media.frenzy did not begin iri full until a decade later. In September 2002, Epstein was flun
0s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo
iction And Authority. (1) The Court’s Supervision of the Grand Jury Process and Its Authority to Order Public Disclosure of the Epstein Evidence. 60. The Florida Supreme Court has noted that “in states such as Florida, where the grand jury is preserved, it is an important appendage of the court which impanels it. At the sam
background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the Bri
beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private." The media frenzy did not begin in full until a decade later. In September 2002, Epstein was fl
s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo
she wanted a sealed copy of the agreement filed in his case, and Goldberger concurred that he wanted it sealed. Belohlavek later signed off on it. The Florida Supreme Court has expressed "serious concern" and launched an all-out inquiry into sealing procedures across the state following media reports in 2006 of entire
orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume
unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t
ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,
Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free fro
stions as well: Q. What connection, if any, did Ghislaine Maxwell have to [your three clients]? MR. SCAROL
uct privilege. Id. at 126-127. Edwards wrongfully claimed the work product privilege for these questions as well: Q. What connection, if any, did Ghislaine Maxwell have to [your three clients]? MR. SCAROLA: Objection, work product. Instruct you not to answer. Id. at 155.6 Q. Who did [Mike Fisten] go to Califo
by this time already put considerable allegations concerning the answer to this question into the records. Obviously, his clients' interaction with Maxwell was not intended to be kept in confidence. 7 EFTA00606632 Q. Who other than Mr. Fisten from an investigator, from an internal investigator at
ranscript at 50, 54, 91, 100-104, 114, 126,-127, 155, 170, 181, 184-187, 192, 198-202, 205-206, 208-210, 212, 215-217; Exhibit 1. Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), gave this general definition of work product saying what it is and what it is no
l courtroom in New York City in May. But on the eve of trial, the defamation suit Edwards filed against Epstein's longtime friend, British socialite Ghislaine Maxwell, was settled. The terms are confidential. 2 EFTA_R1_01882451 EFTA02645844 Edwards filed the suit on behalf of who previously came out of hidin
d, who denied the allegations, included former President Bill Clinton and Great Britain's Prince Andrew, both regular guests on Epstein's jet. When Maxwell called claims "obvious lies," Edwards sued her. While all the dozens of other lawsuits Epstein has faced have been settled, Scarola vows the malici
inst Epstein's longtime friend, British socialite Ghislaine Maxwell, was settled. The terms are confidential
ey Bradley Edwards filed against the Palm Beach billionaire has been on hold for years while various appeals were filed. With the issues resolved by the Florida Supreme Court last month, Circuit Judge Donald Hafele said the jury trial should begin Dec. 5. EFTA_R1_01882450 EFTA02645843 While attorney Jack Scarola, who
ut I am just going through the questions that refused to be answered at this time. Next it discusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she neither -- would you agree that neither Jane Doe nor LM" -- who are, again, Mr. Edwards' two clients
scusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she ne
12 13 14 15 16 17 18 19 20 21 22 23 24 25 -- the case had basically not been actively prosecuted in this court until June 2017 when the Florida Supreme Court issued its final ruling. So should the Court grant our motion, we did preserve the right to redepose Mr. Edwards on these issues. We feel not onl
Entities connected to both Ghislaine Maxwell and the Florida Supreme Court

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONLeon Black
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON