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no such offer had ever been 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 Dershowitz (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);
rivolous; 17. That the presentation of such evidence by counsel for JONES demonstrates a lack of a good faith basis to prevent same in violation of Federal Rule of Civil Procedure, 1 I: IS. That MORSE has demonstrated by clear and convincing evidence, ownership of these funds by JONES, that said funds are hereby frozen and no
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);
ut merit and frivoh • 17. Tha, presentation of such evidence by counsel for JONES demonstrates a lack of a basis to prevent same in violation of Federal Rule of Civil Procedure, 11: MORSE has demonstrated by clear and convincing evidence, ownership of these + funds by JONES, that said funds are hereby frozen and not subje
no such offer had ever been 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 Dershowitz (noted Harvard Law professor, constitutional attorney . • and one of EPSTEIN'S crim
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);
rivolous; 17. That the presentation of such evidence by counsel for JONES demonstrates a lack of a good faith basis to prevent same in violation of Federal Rule of Civil Procedure, 11; 18. That MORSE has demonstrated by clear and convincing evidence, ownership of these funds by JONES, that said funds are hereby frozen and not
Entities connected to both Donald Trump and Federal Rule of Civil Procedure

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Joe Biden
PERSON
Julie K. Brown
PERSON
Jared Kushner
PERSON
United States
LOCATION
Bradley Edwards
PERSON
New York
LOCATIONMaria Farmer
PERSON
Samantha Power
PERSONJane Doe
PERSON
Scarlett Johansson
PERSON