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

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave not

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

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave not

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

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at 116. 74. Edwards gave not

fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump

in support of his Motion for Summary Judgment, Edwards had a sound legal basis for believing that Donald Trump, Allen Dershowitz, Bill Clinton, Tommy Mattola, David Copperfield and Governor Bill Richardson had relevant and discoverable information (Exhibit “A” — Edwards’ Statement of Undisputed Facts, para

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

fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump

otograph taken for US Weekly magazine. 13. Epstein alleges that there was something improper in the fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump was properly noticed because: (a) after review of the message pads confiscated from Epstein’s home,

s that there was something improper in the fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump was properly noticed because: (a) after review of the message pads confiscated from Epstein’s home, the legal and investigative team assisting my cli

accordingly provided notice of a possible deposition. Epstein alleges that Tommy Mottola was improperly noticed with a deposition. I did not notice Mattola for deposition. He was noticed for deposition by a law firm representing another one of Epstein’s victims — not by me. Epstein alleges that there wa

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

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

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit “N” at (16. 74. Edwards gave notic