Epstein Secrets

to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Ep

evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch

ke the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave notice that he intended to take David Copperfield's deposition. Edwards possessed a l

to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at ¶17. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Ep

evidence. See Edwards Affidavit, Exhibit "N" at ¶17. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch

ke the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at 116. 74. Edwards gave notice that he intended to take David Copperfield's deposition. Edwards possessed a l

evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch

to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Ep

ke the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave notice that he intended to take David Copperfield's deposition. Edwards possessed a l

Co. v. Plaza Materials Corp., 908 So.2d 360, 374 (Fla. 2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982) 5. Wright v. Yurko, 446 So.2d 1162, 1165 (Fla. 5th DCA 19

DATED this day of , 20 . Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Phone: Fax: Attorneys for Plaintiff(s) Shipley, P.A. EFTA00722714 v, Epstein, et al Case No. 50 2008CA025129=O(MB Al SDT Without Deposition Page3 CERTIFICATION OF RESPONSE TO SUBPOENA DUCE

Co. v. Plaza Materials Corp., 908 So.2d 360, 374 (Fla. 2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982) 5. Wright v. Yurko, 446 So.2d 1162, 1165 (Fla. 5th DCA 19

hed list, this V day of February, 2009. Jack Scarola Florida Bar No.: 189440 Jack P. Hill Florida Bar No.: 0547808 Attorneys for Plaintiff(s) Shipley, P.A. EFTA00614441 A.C. v. Epstein, et al Case No. 50 2008CA025129XXXXMB Al Notice of Production from Non-Party Page 3 COUNSEL LIST sissi At

According, Count I is required to be dismissed as Chapter 800, which references lewd conduct, does not create a private right of action. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990), per curiam, (Dismissal of plaintiffs civil complaint affirmed where parental kidnapping statutes concerned only

4 Lake Worth , FL 33461 Fax: Emai : ree r otmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Jack Patrick Hill Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Boulevard PO Drawer 3626 West Palm Beach , FL 33402-3626 PIM Email: represented by Bruce Reinhart Bruce E. Reinhart, P.A.

ant to a criminal statute that provides no civil remedy, her complaint is properly dismissed for failure to state a cause of action. See Mantoothl. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA 1990) (per curiam) (affirming dismissal of plaintiff's claim for parental kidnapping where "the mentioned statut

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Consol Plaintiff represented by Jack Patrick Hill Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Boulevard PO Drawer 3626 , FL 33402-3626 Fax: 22/11.... Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Richard Horace Will

gment, Edwards had a sound legal basis for believing that Donald Trump, Allen Dershowitz, Bill Clinton, Tommy Mattola, David Copperfield and Governor Bill Richardson had relevant and discoverable information (Exhibit “A” — Edwards’ Statement of Undisputed Facts, paragraphs 69-81). That belief was reinforced by the

ake the: deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit ““N” at 16. 74. Edwards gave notice that he intended to take David Copperfield's deposition. Edwards possessed a leg