Epstein Secrets

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

he rights of others nd then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser.. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). EFTA00188866 Case 9:08-cv-807Ni Vam aKW 2WpeeerNar rai Rmiyocisstg21420n915 Page 4 of occasions between 2

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

rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). EFTA00725999 occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assau

tion. The undisputed facts show the following with regard to each of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint

ach of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Pro

s complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believi

ump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See St

rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993). And, in the proper circumstances, "'Silence is often evidence of the most persuasive character."

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

rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). EFTA00081182 Case 9:08.cv_807agg3498mot 2rKali564rgerNeocp0F4lapiyocisstggy aig15 Page 4 of orrasions bet