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puted "facts" is egregious. It is well settled that mere allegations do not constitute "facts" for purposes of summary judgment. See, e.g., Metro. Dade County v. Wilkey, 414 So. 2d 269, 271 (FIa. 3d DCA. 1982) ("[P]leadings are not admissible in evidence to prove or disprove a fact in issue.") (citing Hine
ricken. Finally, inadmissible and improper triple hearsay forms the basis of the "facts" set forth in ¶ 80, in which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Ru
n which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Rush. EDWARDS' "FACTS" PERTAINING TO OTHER PURPORTED ACTS OR WRONGS ARE NOT PROBATIVE AND ARE HIGH
and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROT
belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an
naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROT
belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an
naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROT
belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an
naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator nne (a former attorney, Broward County Sheriff and felon) assisted ROTH mak
ndlbe y)OTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator nne (a former attorney, Broward County Sheriff and felo
nt naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David an, ebbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROT
belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an
naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Vilieges, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROT
belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an
naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROT
belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an
naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Baden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
Entities connected to both Dade County and Michael Fisten

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSONJack Goldberger
PERSONMaria Farmer
PERSON
Bill Clinton
PERSONLeon Black
PERSON
United States
LOCATIONthe Southern District
LOCATION
Palm Beach County
LOCATION
Marc Rich
PERSONRussell Adler
PERSONMichael J. Pike
PERSON
David Copperfield
PERSON
Bill Richardson
PERSON