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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
asked solely to poison the wel1.6 The Court recently sustained Plaintiffs objections to discovery requests geared solely to alleged sexual activity (D.E. 148, 149, and 150). Accordingly, the sword and shield doctrine does not apply to the illegitimate and irrelevant questions which Plaintiff declined
m Beach, Florida. cc: A Marie Villafaila, AUSA DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2
the person whom Petitioners refer to as "Jane Doe 5" also had been approached by the investigative team in 2007 but refused to speak with them. (See D.E. 14 at 1 3.) Regardless of the perceived strength of the corroborating evidence, it was and remains my professional opinion as an experienced prosec
nberg at Haley Capital, which was located in the Trump Tower. In late December 1993, Hoffenberg took Dr
EPSTEIN upon her, Plaintiff intends to rely exclusively on the statutory damages, rather than those damages which are available at common law. (See D.E. 113). If however, the Court rules that the statutory floor applies only one time, regardless of the number of times EPSTEIN committed an enumerated
Entities connected to both Donald Trump and D.E.

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Michael Cohen
PERSON
Stephen Hawking
PERSON
Prince Charles
PERSON
New York
LOCATIONMaria Farmer
PERSON
Alexander Acosta
PERSON
George Mitchell
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