Epstein Secrets

rs that he that he was "one of M's many `Johns.— See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co.. Dec. 7, 2009) at 146(a), pertinent pages annexed as Ex. E to the Carroll Reply Dec1.12 As for alleged "derogatory remarks" about M., they would s

7 (N.Y. Sup. Ct. Feb. 28, 1996) 18 Bruno v. Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil-A. Inc. v. CFT Dev.. LLC 652 F. Supp. 2d 1252 (M.D. Fla. 2009) 12 Coop

er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were

nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o

er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were

nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o

er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were

nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o