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

he most persuasive character."' Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "evidence of the most

tion (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, including international financial contacts. See Affidavit of Paul Cassell

ons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that

President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he ha

ed long ago, "[s]ilence is often evidence of the most persuasive character."' Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S. ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-54 (1923)). This is plainly one of those situations. In a civil case, drawing an adverse inference is the proper action

tion (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, including international financial contacts. See Affidavit of Paul Cassell

President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has

ons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that

zed long ago, "[s]ilence is often evidence of the most persuasive character.'" Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S. ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-54 (1923)). This is plainly one of those situations. In a civil case, drawing an adverse inference is the proper action

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,

uted facts show the following with regard to each of the persons identified in Epstein's complaint of improper targets of discovery: • With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts filed in support

ns identified in Epstein's complaint of improper targets of discovery: • With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts filed in support of Edwards' Motion for Summary Judgment. • With regard

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

f the most persuasive character.'" Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. 4" Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "evidence of the most