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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
Beach, FL 33409 (561) 68 561 fax OL Flori No.: 169440 37 EFTA00726035 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian
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
ce list. Jack Scarola Searc Denne Scarol Barnhart & Shipley West Palm Beach, FL 33409 By: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbu Goldber er et al. West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Ma
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 EFTA00081189 Case 9:08-cv-807attotAme 2Niall ogerrl eocroFaCAyocitaWW015 Page 11 of (Bill Clinton phone numbers listed under "Doug Ba
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 Edwards's clients' complaints; (b) Trump wa
this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00081189 Case 9:08-cv-807a
ed that Jane Doe 102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be
/21/2015 Page 40 of Case 09-34791-RBR Doc 1604E8 Filed 04/08/11 Page 39 of 39 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian
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
Page: HOUSE_OVERSIGHT_013347 →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,
Page: HOUSE_OVERSIGHT_013365 →Entities connected to both Donald Trump and FOWLER WHITE BURNETT P.A.

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Michael Cohen
PERSONMartin Weinberg
PERSON
New York
LOCATIONMaria Farmer
PERSON
Alexander Acosta
PERSON
Samantha Power
PERSONFBI
ORGANIZATION
Alfredo Rodriguez
PERSONJack Goldberger
PERSON