Epstein Secrets

• Complaint ¶40(i): With regard to former New Mexico Governor Bill Richardson, Edwards had sound legal basis for naming Former New Mexico Governor Bill Richardson on his witness list. See Statement of Undisputed Facts. It is worth noting that the standard for discovery is a very liberal one. To notice someone

): With regard to former New Mexico Governor Bill Richardson, Edwards had sound legal basis for naming Former

Hall v. Talcott, 191 So. 2d 40, 43 (Fla. 1966). It is not enough for the opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 (Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (F1a.1979) (same). Moreover, it is well-recognized that the non-moving party

MARCUS BEHRMAN,STANLEY J BERNSTEIN,RICHARD S MENIN,ROCHELLE PHILLIPS,GEORGE W

UEST,WINSTON SHULMAN,ALAN BALLINGER,WYNNE S CANTOR,IRIS QUICK,THOMAS C B

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

nt. See Holl v. Talcott, 191 So. 2d 40, 43 (Fla. 1966), It is not enough for the —— party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 (Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (Fla.1979) (same). | Moreover, it is well-recognized that the non-moving party