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ou about the people you named. 13 A. What do you mean by *personal relationship," 13 Have you had a social relationship with Tommy 14 sir? 14 Mottola? 15 Q. Have you socialized with him? 15 A. The names in my Complaint are strictly as a 16 A. Yes, sir. 16 reaction to the abusive discovery p
and 14th Amendment Rights. 7 Copperfield? 8 BY MR. SCAROLA: 8 A. As a reaction to, once again, the abusive 9 Q. Have you ever socialized with Tommy Mottola`. 9 discovery process of bringing in names of people that 10 A. This is the type of questions where people who 10 have absolutely nothing to do
mplaint, I'm asking you about the people you named. 13 A. What do you mean by *personal relationship," 13 Have you had a social relationship with Tommy 14 sir? 14 Mottola? 15 Q. Have you socialized with him? 15 A. The names in my Complaint are strictly as a 16 A. Yes, sir. 16 reaction to th
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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
first offender . . . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance." BMW of North America, Inc. v. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In addition, juries can consider other similar acts evidence as part of the deterrence ca
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be home runs in both instances." But there are other thoughts tickling the back of Alleck's mind as well. A passion- ate liberal he campaigned for Al Gore, cares deeply about political issues, and is extremely well inlbrmed. He entertains him- self by writing imaginary political speeches in his head.
well. A passion- ate liberal he campaigned for Al Gore, cares deeply about political issues, and is ex
as relevant information, but I don't think he'll tell you the truth. JS: Ok. Alan Dershowitz. I: Yes. JS: David Copperfield. Don't know. JS: Tommy Matola. EFTA00614121 adv. Epstein Telephone interview with Page 23 of 23 1 Don't know. JS: Prince Andrew. 1 Yes, he would know a lot of the truth
are that you remember that you consider to be famous people. e: Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton. There was Al (7) Gore, there was a whole bunch of models, I wouldn't really honestly be able to give their names. There was Matt Owning the producer of the simpons cartoo
has relevant information, but I don't think he'll tell youthe truth. J5: Ok. Alan Dershowitz. V: Yes. JS: David Copperfield. V: Don't know. iS: Tommy Matola. Edwards adv. Epstein Telephone interview with Page 23 of 23 V: Don't know. JS: Prince Andrew. V: Yes, he would know a lot of the truth. Again,
ember that you consider to be famous people. EFTA01657699 V: Ok, there was Naomi Campbell, Heidi Kium, there was Bill Clinton. There was Al (?) Gore, there was a whole bunch of models, I wouldn't really honestly be able to give their names. There was Matt Groning the producer of the simpons cart
elevant information, but I don't think he'll tell you the truth. JS: Ok. Alan Dershowitz. V: Yes. JS: David Copperfield. V: Don't know. JS: Tommy Matola. EFTA01657736 Edwards adv. Epstein Telephone interview with Page 23 of 23 V: Don't know. JS: Prince Andrew. V: Yes, he would know a lot of
are that you remember that you consider to be famous people. V: Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton. There was Al (?) Gore, there was a whole bunch of models, I wouldn't really honestly be able to give their names. There was Matt Groning the producer of the simpons carto
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 →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
Page: HOUSE_OVERSIGHT_013349 →di Klum, there was Bill Clinton. There was Al (?) Gore, there was a whole bunch of models, I wouldn’t re
Page: HOUSE_OVERSIGHT_012120 →relevant information, but I don’t think he’ II tell you the truth. JS: Ok. Alan Dershowitz. V: Yes. JS: | David Copperfield. V: Don’t know. JS: Tommy Matola. HOUSE_OVERSIGHT_012128 --- PAGE BREAK --- Edwards adv. Epstein Telephone interview with Virginia Roberts Page 23 of 23 V: Don’t know. JS: Princ
Page: HOUSE_OVERSIGHT_012129 →di Klum, there was Bill Clinton. There was Al (?) Gore, there was a whole bunch of models, I wouldn’t re
Page: HOUSE_OVERSIGHT_015569 →relevant information, but I don’t think he’ II tell you the truth. JS: Ok. Alan Dershowitz. V: Yes. JS: | David Copperfield. V: Don’t know. JS: Tommy Matola. HOUSE_OVERSIGHT_015577 --- PAGE BREAK --- Edwards adv. Epstein Telephone interview with Virginia Roberts Page 23 of 23 V: Don’t know. JS: Princ
Page: HOUSE_OVERSIGHT_015578 →Entities connected to both Tommy Mottola and Al Gore

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Bill Clinton
PERSON
Prince Andrew
PERSON
Marc Rich
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
Joe Biden
PERSON
Woody Allen
PERSON
United States
LOCATIONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Richard Kahn
PERSON
John F. Kennedy
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON