Epstein Secrets

of Undisputed Facts. • Complaint ¶38(iv): 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. • Complaint ¶38(v): With regard to illusionist David Copperfield, Edwards had sound legal basis

ton had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(iv): 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. • Complaint ¶38(v): With regard to illusi

It is not enough for the opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 (Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (F1a.1979) (same). Moreover, it is well-recognized that the non-moving party faced with a summary judgment motion supported by

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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

HOUSE_OVERSIGHT_013348 --- 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