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I." Before the deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brune
tions Edwards took, what Edwards learned in the course of his representation of his clients, goo beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that A [davit. For clarity, depositions attached to this memorandum will be identified numerically as atta
IL" Before the deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brune
ook, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit. For clarity, depositions attached to this memorandum will be identified numerically as att
II." Before the deposition took place, Brunt's attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brune
ook, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit. For clarity, depositions attached to this memorandum will be identified numerically as att
Entities connected to both Kudman and Edwards Affidavit

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Jean-Luc Brunel
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSONFISTOS & LEHRMAN
ORGANIZATION
A. Marie Villafana
PERSONScott Rothstein
PERSON
Jeffrey Marc Herman
PERSONFlorida Bar
ORGANIZATION
Michael Cohen
PERSONHerman
PERSONBruce E. Reinhart
PERSON
Reinhart
PERSON
Les Wexner
PERSON