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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
age 23 of deposition of Epstein's housekeeper October 20, 2009, page 9, lines 17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition A
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
00726018 deposition of Epstein's housekeeper October 20, 2009, page 9, lines 17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition A
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
sition of Epstein's housekeeper Louella Rabuyo, October 20, 2009, page 9, lines 17-25 (Deposition Attachment #I7); See deposition of Epstein's pilot Larry Eugene Morrison, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition A
ases (or a part of them) to third parties. EDWARDS' office notified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Les Wexner (founder of the Limited Clothing Line, Victoria Secret etc...) and his wife Abigal Wexner
e depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) L
take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul);
acts with underage women? MR. CRITTON: Form. THE WITNESS: No.3 *** Plaintiffs counsel asked the following similar questions at the deposition of Larry Eugene Morrison, another one of Mr. Epstein's pilots: Q. Certainly you've read certain newspaper articles about the allegations, police reports, otherwise, the
fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump
osition of Epstein's housekeeper Louella Rabuyo, October 20, 2009, page 9, lines 17.25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Att
Page: HOUSE_OVERSIGHT_013341 →he deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads eaifisnated 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 was
Page: HOUSE_OVERSIGHT_013347 →had “no connection 9 HOUSE_OVERSIGHT_010574 --- PAGE BREAK --- whatsoever” with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 (Bill Clinton phone numbers listed under “Doug Bands”). ‘E ederal Investigation and Plea Agreement With Epstein 19. In approximately 2005, th
Page: HOUSE_OVERSIGHT_010575 →osition of Epstein's housekeeper Louella Rabuyo, October 20, 2009, page 9, lines 17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Att
Page: HOUSE_OVERSIGHT_010588 →he 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 was
Page: HOUSE_OVERSIGHT_010594 →Entities connected to both Donald Trump and Larry Eugene Morrison

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Bradley Edwards
PERSON
Michael Cohen
PERSONMartin Weinberg
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSON
Wilbur Ross
PERSONFBI
ORGANIZATION
Alfredo Rodriguez
PERSONJack Goldberger
PERSONJane Doe
PERSON