Epstein Secrets

to be "well-founded." For example, Jane Doe No. 3 has made statements to the media about meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. [ADD SENTENCE ON THIS:4a'so goes to what Cassell and Edwards knew or should have known when they file

bout meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. [AD

sition of Jane Doe No. 3. 21 EFTA00582669 Dated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 35

bout meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. De

to be "well-founded." For example, Jane Doe No. 3 has made statements to the media about meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. Dershowitz is entitled to explore the veracity of Jane Doe No. 3's accounts of these meetings, becaus

sition of Jane Doe No. 3. 19 EFTA00584080 Dated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 35

lief from that Confidentiality Order. Respectfully submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 [email protected] Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Flo

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

15595 --- PAGE BREAK --- Dated: February 3, 2016 Respectfully submitted, s/Thomas E. Scott Thomas E. Scott, FBN 149100 [email protected] Steven R. Safra, FBN 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156

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