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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
Suite 1400 West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 38 EFTA00726036
• 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
oldberger, Esq. Atterbu Goldber er et al. West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman P.L. Fort Lauderdale, FL 33301 AROLA Flori ar No.: SER CE LIST 24 EFTA00725992 DEF
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
Suite 1400 West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 38 EFTA00081219
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
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. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman. P.L. 38 EFTA00188903 EFTA00188904 Case 9:08-cv-80736-KAivi Document 291-16 Entered o
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
Page: HOUSE_OVERSIGHT_010596 →Suite 1400 West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc 8S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 43 HOUSE_OVERSIGHT_010608
Page: HOUSE_OVERSIGHT_010608 →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 →h Suite 1400 West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 43 HOUSE_OVERSIGHT_013361 --
Page: HOUSE_OVERSIGHT_013363 →Entities connected to both Bill Richardson and Gary M. Farmer

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