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nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. Kam incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing req
more so in light of Epstein's admission in his lawsuit against M. and others that he that he was "one of M's many `Johns.— See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co.. Dec. 7, 2009) at 146(a), pertinent pages annexed as Ex. E to the C
t. 28, 1997) 15 iv EFTA00728012 Salvatorie Studios. Int'l v. Mako's. Inc., No. 01 Civ. 4430BSIDF. 2001 WL 913945 (S.D.N.Y. Aug. 14, 1991) 11 Schiller v. City of New York 2 245 F.R.D. 112 (S.D.N.Y. 2007) Solarex Corp. v. Arco Solar. Inc., 4 121 F.R.D. 163 (E.D.N.Y. 1988) Ulrich v. Coast Dental
nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. 1° Doe incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing
ges in his complaint against M. 13 12 The document is available online at http://www.scribd.com/doc/23947743/121009-epstein. "Complaint, Epstein v. Rothstein et al., II 42(h)(i) ("M. testified that she ... worked at various strip clubs; is an admitted prostitute and call girl; has a history of illegal dru
t. 28, 1997) 15 iv EFTA00207335 Salvatorie Studios. Int'l v. Mako's. Inc., No. 01 Civ. 4430BSIDF. 2001 WL 913945 (S.D.N.Y. Aug. 14, 1991) 11 Schiller v. City of New York 2 245 F.R.D. 112 (S.D.N.Y. 2007) Solarex Corp. v. Arco Solar. Inc., 4 121 F.R.D. 163 (E.D.N.Y. 1988) Ulrich v. Coast Dental
I had been informed repeatedly that they 7 participated in a major fraud with a man named 7 were in it for the money and that they expected to 8 Rothstein. that he should be in jail for the 8 earn a lot of money from representing her and others 9 Rothstein events. 9 in this case and that they pretend
ame, but 10 matter? 10 I don't remember his name. 11. A. Well. I cant imagine that mite relying 11 Another was — I mean — just hard to 12 on Scott Rothstein's credibility. 12 pinpoint names. but it was something that was 13 Q. I'm asking, did you know? 13 clearly in my mind that so many people were te
ning. He just walked in. 17 18 MS. McCAWLEY: On behalf of nonparty 18 19 Sigrid McCawley and my 19 20 colleague Meredith Schultz from Boles. Schiller 20 21 & Plexner. 21 22 22 MR. INDYKE: On behalf of Jeffrey Epstein. 23 23 Darren Indyke. 24 24 SPECIAL MASTER POZZUOLI: Ed Ponuoli as 2
Entities connected to both Scott Rothstein and Schiller

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSONSpencer Kuvin
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Sarah Kellen
PERSONLeon Black
PERSON
Bill Clinton
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION