3
Shared Docs
0
Same-Page
3 / 7
Mentions
r the question: “Have +i ever socialized with Mr. Mottola in the presence of females under the age of 18?”
wards 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 Fac
Page: HOUSE_OVERSIGHT_013309 →id adverse inferences against parties to civil actions when they refuse to testify in 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. at 2001). The reason for this rule “is both logical and utilitarian.
Page: HOUSE_OVERSIGHT_013315 →the question: “Have you ever socialized with Mr. Mottola in the presence of females under the age of 18?”
g her vagina, inserting his fingers and civil actions when they refuse to testify in 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.
Page: HOUSE_OVERSIGHT_010567 →0 HOUSE_OVERSIGHT_010595 --- PAGE BREAK --- 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, Exhi
Page: HOUSE_OVERSIGHT_010596 →former President Clinton had relevant and discoverable information. See Statement of Undisputed Facts. • With regard to former Sony Record executive Tommy Mottola, Edwards was not the attorney that noticed Mr. Mottola's deposition. See Statement of Undisputed Facts. • With regard to illusionist David Copperfiel
Page: HOUSE_OVERSIGHT_029320 →mation. See Statement of Undisputed Facts. • With regard to former Sony Record executive Tommy Mottola, Edwards was not the attorney that noticed Mr. Mottola's deposition. See Statement of Undisputed Facts. • With regard to illusionist David Copperfield, Edwards had sound legal basis for believing Mr. Copp
Page: HOUSE_OVERSIGHT_029320 →id adverse inferences against parties to civil actions when they refuse to testify in 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.
Page: HOUSE_OVERSIGHT_029321 →Entities connected to both Palmigiano and Tommy Mottola

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Woody Allen
PERSONJane Doe
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLarry Visoski
PERSON
Kenneth Marra
PERSON
Jean-Luc Brunel
PERSONMaria Farmer
PERSONJack Scarola
PERSON
Michael Cohen
PERSON
Bill Richardson
PERSON
Sarah Kellen
PERSON