Epstein Secrets

this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00188873 Case 9:08-cv-807.

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ed that Jane Doe 102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be

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 EFTA00188873 Case 9:08-cv-807.36-KA6. Doc gmeOt 291-15 Egere.d oriSI Jocket 1/21/2M.5 Page 11 of t;ase OU-34/9-r<btrt uoc 1604 rueo

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

ook, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit. For clarity, depositions attached to this memorandum will be identified numerically as att

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

tions Edwards took, what Edwards learned in the course of his representation of his clients, goo beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that A [davit. For clarity, depositions attached to this memorandum will be identified numerically as atta

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

ook, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit. For clarity, depositions attached to this memorandum will be identified numerically as att