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S criminal defense attorneys); (iii)Bill Clinton (Former President of the Untied States); EFTA00725302 Epstein v. RRA, et al. Page 15 (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 48. The above-named individuals were friends of EPSTEIN with whom he ha
t matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Tommy Mottola (American Music Executive); (ii) Mortimer Zuckerman (well known Publisher of U.S. News & World Report and commentator and financier); (iii)Bill Ri
ing equipment and former law enforcement officers who would sift through a potential defendants' garbage. 31. Additionally, Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the EFTA00725297 Epstein v. RRA, et al.
ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (I) David
sor, constitutional attomey and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (I) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE
nts could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy ... as a showpiece as bai
or, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE
ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David
nts could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy ... as a showpiece as bai
or, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE
ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David
nts could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy ... as a showpiece as bai
ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David
constitutional attorney . and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE
ants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attomey William Scherer represents multiple Rothstein related investors. He Indicated in an article that RRA/Rothstein had used the "Epstein Ploy ... as a showpiece as bai
ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and J) David
professor, constitutional attorney . and one of EPSTEIN'S criminal defense attorneys); Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and J) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEI
nts could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy ... as a showpiece as bai
onstitutional attorney . • and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEI
ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David
nts could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein. Ploy ... as a showpiece as ba
t matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Tommy Mottola (American Music Executive); (ii) Mortimer Zuckerman, (well known Publisher (US. News & Work Report), commentator and financier); (iii)Bill Richard
ing equipment and former law enforcement officers who would sift through a potential defendants' garbage. 50. Additionally, Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy ... as a showpiece as bai
WITNESSES 104. Jose .h Pagnano WEST PALM BEACH, FL 33401 105. Ste han Kossl CAMBRIDGE MA 02138-1802 106. Cecile Deon • ST THOMAS VI 00802 107. Tommy Mottola PALM BEACH FL 33480-3012 108. Mike Sanka 449 S BEVERLY DR STE 101 BEVERLY HILLS, CA 90212 109. S/A Witness #105 110. William "Bill" Rile CORA
robable cause and malice. Will testify as to the falsity of the claims made by Epstein against Edwards and the propriety of Edwards' actions. 14. William Scherer, Esquire 633 S Federal Hwy #800 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable
rd Law professor, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); ill Clinton (Former President of the United States); T mmy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE
nts could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy ... as a showpiece as bai
Entities connected to both Tommy Mottola and William Scherer

Jeffrey Epstein
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSONLeon Black
PERSONScott Rothstein
PERSON
Prince Andrew
PERSON
Donald Trump
PERSONJane Doe
PERSON
Bill Clinton
PERSON
George W. Bush
PERSONJack Goldberger
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Joe Biden
PERSON
David Copperfield
PERSONDarren Indyke
PERSONJack Scarola
PERSONLarry Visoski
PERSON
Bill Richardson
PERSON