Epstein Secrets

l 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 Professor), Edwards had sound legal basis for believing Mr. Dershowitz had relevant and discoverable information. See Statement of Und

of Undisputed Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Professor), Edwards had sound legal basis for believing Mr. Dershowitz had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(iii): With regard to former President Bill Clinton,

uted Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Professor), Edwards had

irls admissible. Juries considering punitive damages issues are plainly entitled to consider "the existence and frequency of similar past conduct." TXO Production Corp. v. Alliance Resources Corp., 509 U.S. 17 EFTA00725985 443, 462 n.28 (1993). This is because the Supreme Court recognizes "that a recidivist may b

istrict Court, Southern District of Florida Jack Alan Goldberger, Esq. Jooldberaeraaawpa.com Robert D

ilar to Jane Doe. Juries considering punitive damages issues are plainly entitled to consider "the existence and frequency of similar past conduct." TXO Production Corp. I. Alliance Resources Corp., 509 U.S. 443, 462 n.28 (1993). This is because Supreme Court holdings recognize "that a recidivist may be punished mor

sputed facts submitted by Mr. Edwards 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’ Statem

Exhibit “N” at 913. | 72. Edwards provided notice that he intended to depose Alan Dershowitz. Edwards possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with Epstem for many years; (b) in one news article Dershowitz comments that, “I’m on my 20th book... The only pers

vided notice of a possible deposition. 14. Epstein alleges that there was something improper in the fact that I notified him that I intended to take Alan Dershowitz’s deposition in the civil suiis against him. Dershowitz was properly noticed because: (a) Dershowitz has been friends with Epstein for many years; (b)