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ask was assigned to Farmer Jaffe (where Mr. Edwards was a partner). In order to conduct the review, Farmer Jaffe wanted the 27,000 pages printed and Bates stamped so it could segregate out alleged privileged and unresponsive documents. Farmer Jaffe, however, did not want to incur the cost of reproduci
would only encompass claims that had matured at the time of signing the release. SoUile v. Gaines Const. Co., 281 So. 558, 560-61 (Ha. 3d DCA 1983); Martinez v. Preferred Care Partners, Inc. 223 So. 3d 1117, 1118 (Fla. 3d DCA 2017). In the release between Mr. Epstein and Fowler White, Mr. Epstein waived
7, Kukreti), Just the News (10/27, Mittelstadt), Newsweek (10/27, Stanton), New York Post (10/27, Crane), Patch (10/27, Bornhoft), Telegraph (10/27, Bates), and UPI (10/27, Benson). California Man Part of Extremist Network Accused of Animal Abuse, Sexually Exploiting Minor KPIX (CBS-5) (10/27, Fang)
ludes semen and sperm, has been entered into the FBI's national criminal database as belonging to the "putative perpetrator" of the crime, excluding Martinez. The article noted that despite this evidence, Martinez's latest habeas corpus petition was recommended for denial by Judge Susan Barclay, with his
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min
rc "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (51° Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi
Entities connected to both Bates and Martinez

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONSouthern District
LOCATION
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Denver
LOCATIONLeon Black
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Virginia Giuffre
PERSON
Colorado
LOCATIONJane Doe
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Donald Trump
PERSON