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

rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993). And, in the proper circumstances, "'Silence is often evidence of the most persuasive character."

and Edwards Affidavit, Exhibit "N" at ¶14. 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, Exh

rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). EFTA00725999 occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assau

and Edwards Affidavit, Exhibit "N" at ¶14. 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 finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exh

rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). EFTA00081182 Case 9:08.cv_807agg3498mot 2rKali564rgerNeocp0F4lapiyocisstggy aig15 Page 4 of orrasions bet

and Edwards Affidavit, Exhibit "N" at /14. 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, Exh

he rights of others nd then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser.. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). EFTA00188866 Case 9:08-cv-807Ni Vam aKW 2WpeeerNar rai Rmiyocisstg21420n915 Page 4 of occasions between 2