Epstein Secrets

pstein" (191 65; see also 62-67); Edwards' rationalization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe's Federal Rico clai

Third, evidence of a settlement or statements made during settlement negotiations are inadmissible to prove liability under §90.410, Fla. Stat. See Richardson v. State, 706 So. 2d 1349, 1355-1356 (Fla. 1998) ("Rule 3.172(h) and Section 90.410, Florida Statutes (1991), prohibit the admission of statements

CLUSION Based on the foregoing, Edwards' Renewed Motion for Summary Judgment should be denied. Dated: February 16, 2012. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christo

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

each Lakes Blvd West Palm Beach, FL 33409 (561) 68 561 fax OL Flori No.: 169440 37 EFTA00726035 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury

• 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

hose on the attached service list. Jack Scarola Searc Denne Scarol Barnhart & Shipley West Palm Beach, FL 33409 By: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbu Goldber er et al. West Palm Beach, FL 33401 Marc

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

Entered on FLSD Docket 01/21/2015 Page 40 of Case 09-34791-RBR Doc 1604E8 Filed 04/08/11 Page 39 of 39 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury

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

Entered on FLSD L_ Ket 01/21/2015 Page 40 of Case 09-34791-RBR Doc 16048 Filed 04/08/11 Page 39 of 39 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. P.A. FOWLER WHITE ETJRNE'IT Jack Alan Goldberger, Esq. A b Goldber er et al. Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Gary M. F

l-estate developer); Alan Dershowitz (one of Epstein's criminal defense lawyers); (c) Bill Clinton (former President of the United States); (d) Bill Richardson (Governor of New Mexico and former U.S. Representative and Ambassador to the United Nations); (e) Tommy Mattola (former President of Sony Records)

ormer President of the United States); (d) Bill Richardson (Governor of New Mexico and former U.S. Represen

rola, Esquire, Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. Respectfully submitted, Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone:

ted 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 Epst

139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_010607 --- PAGE BREAK --- SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldb

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

139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_013360 --- PAGE BREAK --- SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldb