Epstein Secrets

. the 1 more. ‘than 500 entries on the docket sheét for’ ‘Jane we + : 7 : “4 Doe’ s (consolidated) case will confirm (see-Case no. 9:08- 30119 (S.D: Fla. ): (case number. for consolidated eee Rongee : . cases on discovery), Jane Doe.and other. plaintiffs have made exhaustive attempts to, obtain inform

accordingly provided notice of a possible deposition. Epstein alleges that Tommy Mottola was improperly noticed with a deposition. I did not notice Mattola for deposition. He was noticed for deposition by a law firm representing another one of Epstein’s victims — not by me. Epstein alleges that there wa

ROCEEDINGS Deposition taken before Cynthia Hopkins, Registered Professional Reporter and Florida Professional Reporter, and Notary Public in and for the State of Florida at Large, in the above cause. and JACK. ALAN GOLDBERGER, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South Suite 1400 West Pal

response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule “is both logical and utilitarian. A party may not trample upon the rights of others and then escape the conseque

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit “N” at (16. 74. Edwards gave notic

in support of his Motion for Summary Judgment, 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, para

the litigation of his abuse of process claim against Edwards. For support, he relies primarily on the decision of Wolfe v. Foreman, 2013 WL 3724763 (Fla. 3d DCA July 17, 2013), wherein the Third District found that the litigation privilege barred both an abuse of process claim and a malicious prosecut