Epstein Secrets

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

at Giuffre was sexually abused as ' Jane Doe No. 3 is Virginia Roberts Giuffre, and will hereinafter be referred to as “Guiuffre.” > See Exhibit 1, CNN International, New Day, January 6, 2015. See also Exhibit 2, Australian Broadcasting System (ABC), January 6, 2015. “My goal is to bring charges against the client

ternational USA Executive Officer Inc. Adrian Gore Chief Executive Officer Discovery Holdings Ltd

Delong Professor, Practice of Social Entrepreneurship, Fuqua School of Business Anchor, CNN Marketplace Middle East President Duke University CNN International Georgetown University Member of the Managing Board and Siemens AG Chief Executive Officer, Siemens Energy Chairman of the Board of Management Bay

ternational USA Executive Officer Inc. Adrian Gore Chief Executive Officer Discovery Holdings Ltd

Professor, Practice of Social Duke University USA Entrepreneurship, Fuqua School of Business John K. Defterios Anchor, CNN Marketplace Middle CNN International United Kingdom East John J. DeGioia President Georgetown University USA Wolfgang J. Dehen Member of the Managing Board and Siemens AG Germa

to jail, the lawyers should be disbarred and everybody should understand that I am completely and totally innocent.” (emphasis added). See Exhibit 3, CNN International, New Day, January 6, 2015. “My goal is to bring charges against the client and require her to speak in court.” (emphasis added). See Exhibit 4, Austr

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

us Group LLC JCDecaux SA Cisco Duke University CNN International Georgetown University Siemens AG Bayer AG Dell

akrishnan Pravin Gordhan llene S. Gordon Adrian Gore Sergey Gorkov Barry M. Gosin Sigmund Gottlieb Nik