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orts, before his recent incarceration (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, including international financial contac
company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefo
ve person lmowledge of the matters set forth herein. I am an attorney licensed to practice in the State of Utah since 1992. My office is located at the University of Utah College of Law, where I am a law professor. Along with other attorneys, I represent plaintiff Jane Doe in this matter. 2. It appears that defendant Jeffrey Epstei
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 →rls, along with attorney Jay Howell (an attomey in Jacksonville, Florida with Jay Howell & Associates) and Professor Paul Cassell (a law professor at the University of Utah College Of Law). I filed state court actions on behalf of L.M. and E.W. and a federal court action on behalf of Jane Doe. All of the cases were filed in the summer
Page: HOUSE_OVERSIGHT_013363 →rls, along with attorney Jay Howell (an attomey in Jacksonville, Florida with Jay Howell & Associates) and Professor Paul Cassell (a law professor at the University of Utah College Of Law). I filed state court actions on behalf of L.M. and E.W. and a federal court action on behalf of Jane Doe. All of the cases were filed in the summer
Page: HOUSE_OVERSIGHT_013468 →ed that Ghislaine Maxwell was in fact in the country on approximately July 31, 2010, as she attended the wedding of Chelsea Clinton (former President Clinton’s daughter) and was captured in a photograph taken for US Weekly magazine. 13. Epstein alleges that there was something improper in the fact that I
Page: HOUSE_OVERSIGHT_013470 →e attended the wedding of Chelsea Clinton (former President Clinton’s daughter) and was captured in a photograph take
Page: HOUSE_OVERSIGHT_013470 →provided notice of a possible deposition. Epstein alleges that there was something improper in the fact that I notified him that I intended to take Bill Clinton’s deposition. Clinton was properly noticed because: (a) it was well known that Clinton was friends with Ghislaine Maxwell, and several witnesses had pr
Page: HOUSE_OVERSIGHT_013471 →Entities connected to both Bill Clinton and the University of Utah College Of Law

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Les Wexner
PERSONJane Doe
PERSONMaria Farmer
PERSONJack Goldberger
PERSONDoug Band
PERSON
Vicky Ward
PERSON
Michael Cohen
PERSON
Kenneth Marra
PERSON
Alfredo Rodriguez
PERSON
Chris Tucker
PERSON
Paul Cassell
PERSON
U.S. Virgin Islands
LOCATIONScott Rothstein
PERSON