8
Shared Docs
7
Same-Page
9 / 8
Mentions
• 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
of such conduct that the law expressly permits the jury to make adverse inferences from a party's efforts to intimidate witnesses . . . :' Jost v. Ahmad, 730 So.2d 708, 711 (Fla. 2 nd Dist. Ct. App. 1998) (internal quotation omitted). To be clear, Epstein's attempt to tamper with witnesses is "not si
3) 146 United States v. Resendiz-Ponce, 549 U.S. 102 (2007) 227, 235 United States v. Ricco, 549 F.2d 264 (2d Cir. 1977) 61 United States v. Richardson, 512 F.2d 105 (3d Cir. 1975) 49 United States v. Richardson, 537 F.3d 951 (8th Cir. 2008) 293 United States v. Rioux, 930 F. Supp. 1558 (D. Co
2004) 47 Toussie v. United States, 397 U.S. 112 (1970) 48 United State v. Nader, 425 F. Supp. 3d 619 (E.D. Va. 2019) passim United States v. Ahmad, 992 F. Supp. 682 (S.D.N.Y. 1998) 166 United States v. Ahmed, No. 10 Cr. 131 (PKC), 2011 WL 5041456 (S.D.N.Y. Oct. 21,2011) 243 United States
or Victim-2 to testify about her abuse twice. Cl Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
ited States v. Shaw, 260 F. Supp. 2d 567,570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
r Victim-2 to testify about her abuse twice. Cf. Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
ted States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
r Victim-2 to testify about her abuse twice. Cf. Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
ted States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
r Victim-2 to testify about her abuse twice. See Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
ed States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] 112 EFTA00095204 raised by an affidavit of a person with personal k
r Victim-2 to testify about her abuse twice. Cf. Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
ted States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
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
Page: HOUSE_OVERSIGHT_013309 →ature of such conduct that the law expressly permits the jury to make adverse inferences from a party's efforts to intimidate witnesses... .” Jost v. Ahmad, 730 So.2d 708, 711 (Fla. 2" Dist. Ct. App. 1998) Gnternal quotation omitted). To be clear, Epstein’s attempt to tamper with witnesses is “not simply
Page: HOUSE_OVERSIGHT_013391 →Entities connected to both Bill Richardson and Ahmad

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSONJack Goldberger
PERSON
Donald Trump
PERSON
A. Marie Villafana
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSON
Virginia Giuffre
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSON
Kenneth Marra
PERSON
Prince Charles
PERSON