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not "to ascertain the facts and fairly present [Edwards'] defenses." Id. 6 For example, Edwards' counsel asked Plaintiff whether he socialized with Donald Trump in the presence of women under the age of 18. Plaintiff responded by invoking his right against self-incrimination. (Plaintiff at 89). Plaintiff a
he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for depos
to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for
ot seek affirmative relief in a civil action and then invoke the Fifth Amendment to avoid giving discovery in matters pertinent to the litigation.' DeLisi v. Bankers, Ins. Ca, 436 So. 2d 1099, 1100 (Fla. 4th DCA 1983) (quoting City of St. Petersburg v. Haughton, 362 So. 2d 681, 685 (Fla. 2d DCA 1978) (
nberg at Haley Capital, which was located in the Trump Tower. In late December 1993, Hoffenberg took Dr
thout knowledge and deny. 2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 41" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination C
fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump
oid giving discovery, using the fifth amendment as both a ‘sword and a shield.” DePalma v. DePalma, 538 So. 2d 1290, 1290 (Fla. 4th DCA 1989)(quoting DeLisi v. Bankers Insurance Co., 436 So. 2d 1099 (Fla. 4th DCA 1983)). Put another way, “[a] civil litigant’s fifth amendment right to avoid self-incriminat
Page: HOUSE_OVERSIGHT_013316 →he deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads eaifisnated 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 Edwards’s clients’ complaints; (b) Trump was
Page: HOUSE_OVERSIGHT_013347 →Entities connected to both Donald Trump and DeLisi

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bill Clinton
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Michael Cohen
PERSON
Prince Charles
PERSONMartin Weinberg
PERSON
Alexander Acosta
PERSON
George Mitchell
PERSONMaria Farmer
PERSON
Samantha Power
PERSON
Supreme Court
ORGANIZATION
Wilbur Ross
PERSONFBI
ORGANIZATIONJack Goldberger
PERSON