Epstein Secrets

tion. The undisputed facts show the following with regard to each of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint

ach of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Pro

s complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believi

ump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See St

Hall v. Talcott, 191 So. 2d 40, 43 (Fla. 1966). It is not enough for the opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 (Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (F1a.1979) (same). Moreover, it is well-recognized that the non-moving party

PETER D WINCHESTER,VALERIE J MARRON,DONALD B MARKIN,SUSAN C NANETTE KASS RESIDEN

SCARPA,JOHN F COOLEY,WILLIAM O TRUMP,IVANA WAGNER,JOE GREENS PHARMACY

UEST,WINSTON SHULMAN,ALAN BALLINGER,WYNNE S CANTOR,IRIS QUICK,THOMAS C B

fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump

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

otograph taken for US Weekly magazine. 13. Epstein alleges that there was something improper in the fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump was properly noticed because: (a) after review of the message pads confiscated from Epstein’s home,