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d; no such offer had 4 -be made. 38. EDWARDS' office also notified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Alan Dershowiti (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal
depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) A
ake the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul);
Litigation Team knew or should have known of the improper purpose that ROTHSTEIN was pursuing in the continuation of thMheme, ROTHSTEIN used RRA's Litigation Team in the EPSTEIN cases to put issues and evidence unrelated to and unnecessary to the claims pled in th Actions, but significantly beneficial to lu
6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P
19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Product;attorney client privilege;i
privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of adm
6007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv. 16057-16065 08/06/2009 Mercedes Estrada Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv. 15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in NY & OH Joint W/P
19 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Productattorney client privilege;ir
privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of adm
Entities connected to both Donald Trump and Litigation Team

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Barry Diller
PERSONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
Scarlett Johansson
PERSONJane Doe
PERSON
Les Wexner
PERSON
Oliver Stone
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
Paul Cassell
PERSONLarry Visoski
PERSON
Bear Stearns
ORGANIZATIONJack Scarola
PERSON