Epstein Secrets

Attorney General, Counsel for Plaintiff Cassell, 160 East 300 South, Salt Lake City, Utah 84114; [email protected] to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, 425 North Andrews Avenue, Suite 2, Ft. Lauderdale, FL 33301; [email protected], to: Paul G. Cassell, Esq.,; [email protected], sperkins@

Request 24 seeks “All documents concerning, relating or referring to your assertion that you met former President Bill Clinton, former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Saint James Island in the U.S. Virgin Islands.” Defendant claims that this discovery would go to the is

President Bill Clinton, former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Sai

[email protected] to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, 425 North Andrews Avenue, Suite 2, Ft. Lau

broad subpoena to non- party, Jane Doe No. 3, goes so far as to seek documents relating to former President, Bill Clinton and former Vice President, Al Gore, which, even if such documents existed, would be absolutely irrelevant to the Florida Defamation Action. See Toledo v. Publix Super Markets, Inc., 30

ident, Bill Clinton and former Vice President, Al Gore, which, even if such documents existed, would be

rida. I am currently a partner in the law firm of Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman, P.L. > 2.

first offender . . . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance.” BMW of North America, Inc. Vv. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In addition, juries can consider other similar acts evidence as part of the deterrence calc