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

judgment is proper as a matter of law. See Davis v. Hathaway, 408 So. 2d 688, 689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43. B. Epstein's Claims Regarding Edwards Have Absolutely No Factual Basis. 5 EFTA00725973 This is not a complicated case for granting summary judgment. To the co

copy was also sent via first-claim mail to Jack Alan Goldberger ATfERBURY GOLDBERG & WEISS, P.A. 250

A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil Suit and to Pursue his Counterclaim for Compensatory and Punitive Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80

EMAIL) The Florida Bar Adria E. Quintela, Esq. Alan Anthony Pascal, Esq. Lake Shore Plaza II 1300 C

nkruptcy Court. That Motion is set for hearing for January 27, 2011. A Notice of Filing containing that Motion was filed with this Court [DE 1197]. B. Epstein's Attempts to Involve this Court in the State Litigation Despite that summary and protective order motions are pending in state court, Epstein contin