Epstein Secrets

people that Epstein alleges in his Complaint had "no connection whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00726006 (Bill Clinton phone numbers listed under "Doug Bands"). Federal Investigation and Plea ARreement With Epstein 19. In app

deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several occasions during the time period most relevant to my clients' complaints; (b) Trump was quoted

this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00726006 (Bill Clinton pho

ed that Jane Doe 102 was initially approached at Trump's Maralago by Ohislaine Maxwell and recruited to be

EFTA00726015 51. three complaints against Epstein contained less detail about sexual abuse than (as one example) a complaint filed by attorney= Josephsberg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit "B"). As recounted in detail in this Complaint, Jane Doe 102

6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P

19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Product;attorney client privilege;i

tos & Lehrman BATES DATE 12 FROM DESCRIPTION OBJECTION 04202.04206 09/08/2009 Bradley Edwards William Berger Epstein's attorneys & Bob Josephsberg have filed several motions on limits of the no contact order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to

6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P

19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Productattorney client privilege;ir

tos & Lehrman BATES DATE TO FROM DESCRIPTION DBJECTION 04202.04206 09/08/2009 Bradley Edwards William Berger Epstein's attorneys & Bob Josephsberg have filed several motions on limits of the no contact order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11366-11371 08/11/2009 Trump depo info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence

EFTA00296214 Privilege Log — Dated 2-23-2011 BATES RATE iv FROM DESCRIPTION OBJECTION 04202-04206 09/08/2009 Epstein's attorneys & Bob Josephsberg have filed several motions on limits of the no contact order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to