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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
Epstein and settlements in those cases (191 48-52); invocation of the Fifth Amendment by Epstein and alleged co-conspirators in depositions taken in the "Epstein Actions" M., ■., and Jane Doe) and other similar lawsuits (111 54-58); "blocking" of discovery by various witnesses (9191 59-66); Epstein's purported asso
n, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint (2) Noticing and subpoenaing for deposition the following people: (3) (a) Donald Trump (a real estate investor and television personality); (b) Alan Dershowitz (a renowned Harvard Law Professor and one of Epstein's criminal defense
eposition the following people: (3) (a) Donald Trump (a real estate investor and television personali
g for deposition the following people: (3) (a) Donald Trump (a real estate investor and television per
L.M. v. Epstein ("LM"), Case No. 50-2008 CA 028051XXXXMB-AB; and E.W. v. Epstein ("EW" or "Jane Doe #2"), 50- 2008 CA 028058XXXXMB-AB (collectively, the "Epstein Actions"). 9. The lead attorney for RRA handling the Epstein Actions was Defendant Edwards. 10. Beginning in approximately the spring of 2009 through Oct
ORIDA 33401 • (561) 802-9044 EFTA00584222 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint (3) (a) (b) Donald Trump (a real estate investor and television personality); Alan Dershowitz (a renowned Harvard Law Professor and one of Epstein's criminal defense lawye
Second Amended Complaint (3) (a) (b) Donald Trump (a real estate investor and television personali
XXXMBAG Second Amended Complaint (3) (a) (b) Donald Trump (a real estate investor and television per
L.M. v. Epstein ("LM"), Case No. 50-2008 CA 028051XXXXMB-AB; and E.W. v. Epstein ("EW" or "Jane Doe #2"), 50- 2008 CA 028058XXXXMB-AB (collectively, the "Epstein Actions"). 9. The lead attorney for RRA handling the Epstein Actions was Defendant Edwards. 10. Beginning in approximately the spring of 2009 through Oct
Entities connected to both Donald Trump and the "Epstein Actions

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSONMartin Weinberg
PERSON
Barry Diller
PERSONFBI
ORGANIZATIONJack Goldberger
PERSONJane Doe
PERSONthe Southern District
LOCATION
Oliver Stone
PERSONBerger
PERSONScott Rothstein
PERSON
Paul Cassell
PERSONJack Scarola
PERSON
Mark Epstein
PERSON
David Copperfield
PERSON
Broward County
LOCATIONMarc S. Nurik
PERSON