4
Shared Docs
2
Same-Page
10 / 4
Mentions
ershowitz knew the Joinder Motion to be "well-founded." For example, Jane Doe No. 3 has made statements to the media about meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. [ADD SENTENCE ON THIS:4a'so goes to what Cassell and Edwards knew or sh
82660 accounts of her alleged interactions with President Clinton and Vice President Gore are complete fabrication
ment are inapposite because they involved attempts to obtain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her po
o. 3's accounts of her alleged interactions with President Clinton and Vice President Gore are complete fabrications
ershowitz knew the Joinder Motion to be "well-founded." For example, Jane Doe No. 3 has made statements to the media about meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. Dershowitz is entitled to explore the veracity of Jane Doe No. 3's acco
ment are inapposite because they involved attempts to obtain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her po
spite that assertion, Ghislaine Maxwell was in fact in the country on July 31, 2010, as she attended the wedding of Chelsea Clinton (former President Clinton’s daughter) and was captured in a photograph taken for OK magazine. Photos from Issue 809 of the publication See US Weekly dated August 16, 2010 are
Page: HOUSE_OVERSIGHT_013342 →e attended the wedding of Chelsea Clinton (former President Clinton’s daughter) and was captured in a photograph take
Page: HOUSE_OVERSIGHT_013342 →further the cases filed against Epstein. See Edwards Affidavit, Exhibit “N” at (11. - 70. Edwards notified Epstein’s attorneys of his intent to take Bill Clinton's deposition. Edwards possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine Maxwell who was Epstein's longtime companion an
Page: HOUSE_OVERSIGHT_013345 →ntiary hearing is not required. See Strasser v. Yalmanchi, 677 So.2d 22, 23 (Fla. 4th DCA 1996), rev. dismissed, 699 So.2d 1372 (Fla. 1997); Solis v. Calvo, 689 So.2d 366, 369, n.2 (Fla. 3d DCA 1997). In fact, a hearing is not even required provided the trial court identifies the filings of the parties a
Page: HOUSE_OVERSIGHT_013397 →at Roberts made false statements in a publicly filed affidavit about being present at a private island in the US Virgin Islands when former President Clinton was there. Indeed, former FBI Director Louis Freeh determined based on the response of the federal government to a FOIA request that the absence of r
Page: HOUSE_OVERSIGHT_015593 →ivate island in the US Virgin Islands when former President Clinton was there. Indeed, former FBI Director Louis Free
Page: HOUSE_OVERSIGHT_015593 →R. Civ. P. 1.280(c). Defendant’s overly broad subpoena to non- party, Jane Doe No. 3, goes so far as to seek documents relating to former President, Bill Clinton and former Vice President, Al Gore, which, even if such documents existed, would be absolutely irrelevant to the Florida Defamation Action. See Toled
Page: HOUSE_OVERSIGHT_015604 →at the contents of the “subpoena is a classic ‘fishing expedition’ and the trial court’s order departs from the essential requirements of the law.”); Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986) (quashing subpoena served on wife’s bank for financial records finding them irrelevant: “indeed, the
Page: HOUSE_OVERSIGHT_015606 →Entities connected to both Bill Clinton and Calvo

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Virginia Giuffre
PERSONJane Doe
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Vicky Ward
PERSON
Kenneth Marra
PERSONMartin Weinberg
PERSON
Al Gore
PERSON
Paul Cassell
PERSON
U.S. Virgin Islands
LOCATION
Colorado
LOCATION
David Boies
PERSONJack Scarola
PERSON