Epstein Secrets

ory I Cowles. 2. Jane Doe filed her Response [DE #540] to said Motion on May 7, 2010. 3. Jane Doe's Response, and the affidavit of her counsel, Bradley Edwards, attached as Exhibit A to said Response, is replete with unsupported factual assertions, conjecture, misrepresentations and patently false statemen

parate visitor's log which does not indicate the time they arrived and does not contain the names of any attorneys or paralegals. 6. Nevertheless, Edwards filed an affidavit affirmatively stating that "Many times, Story Cowles was visiting Epstein while another third party visitor was present, such as

s no evidence to support her conclusions. Accordingly, the Court should disregard these unsupported statements in determining Epstein's Motion. See Frasher v. Fox Distributing of S.W. Fla., Inc., 813 So. 2d 1017, 1020 (Fla. 2d DCA 2002) (holding that an affidavit "must not be based on hearsay or the pl

on Motion Page 23 of 24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. Counsel for Plaintiff in Related Case No. 08-80893 ounse o

-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfel

) (holding that a newspaper article, introduced to prove the truth of out of court statements contained therein, constitutes inadmissible hearsay); Frasher v. Fox Distributing of S.W. Fla.. Inc., 813 So. 2d 1017, 1020 (Ha. 2d DCA 2002) (holding that an affidavit supporting a prejudgment writ of attachm

ion Motion Page 23 of24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite

) (holding that a newspaper article, introduced to prove the truth of out of court statements contained therein, constitutes inadmissible hearsay); Frasher v. Fox Distributing of S.W. Fla., Inc., 813 So. 2d 1017, 1020 (Fla. 2d DCA 2002) (holding that an affidavit supporting a prejudgment writ of attach