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this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00188873 Case 9:08-cv-807.
S CHNITORRA SPO• MTN B. SUWVAN 2.4 KABUL IThlY DONALD J. WARD 'C. CALM MAMMA le 0112:21RIGEL 'EARL LOOP
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
r Acts of Sexual Assault, filed in Jane Doe I. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice") (Exhibit "E"); Jane Doe Depo., Attachment #2, at 379-380; 5. Depo., Attachment #3, at 416;5. Depo, Attachment #4, at 205. 12. At all relevant times Edwards has had a good fait
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
r Acts of Sexual Assault, filed in Jane Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice") (Exhibit "E"); Jane Doe Depo., Attachment #2, at 379-381.1. Depo., Attachment #3, at 416;M. Depo, Attachment #4, at 205. 12. At all relevant times Edwards has had a good basi
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
r Acts of Sexual Assault, filed in Jane Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice") (Exhibit "E"); Jane Doe Depo., Attachment #2, at 379-380; L.M. Depo., Attachment #3, at 416; E.W. Depo, Attachment #4, at 205. 12. At all relevant times Edwards has had a good
Entities connected to both Donald Trump and Jane Doe Depo

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Michael Cohen
PERSON
New York
LOCATION
Barry Diller
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSON
Samantha Power
PERSON
Wilbur Ross
PERSONFBI
ORGANIZATION
Alfredo Rodriguez
PERSON