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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
ovember 25, 2009, a 249 page Amended Complaint 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 meeti
STEIN'S criminal defense attorneys); ill Clinton (Former President of the United States); T mmy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work o
(former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals w
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
es in condos owned by Epstein" (191 65; see also 62-67); Edwards' rationalization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe
ll Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for deposition en 70-75); pur
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
(former President of Sony Record); and (I) David Copperfield (illusionist). 39. The above-named individuals w
iminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (I) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work o
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
iminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work o
(former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals w
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
iminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work o
(former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals w
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
iminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work o
(former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals w
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
(former President of Sony Record); and J) David Copperfield (illusionist). 39. The above-named individuals w
PSTEIN'S criminal defense attorneys); Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and J) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work o
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
riminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work o
(former President of Sony Record); and 1) David Copperfield (illusionist). 39. The above-named individuals w
Entities connected to both Dade County and David Copperfield

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Donald Trump
PERSONJane Doe
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONScott Rothstein
PERSON
Bill Clinton
PERSON
Prince Andrew
PERSON
Marc Rich
PERSON
George Mitchell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATIONMaria Farmer
PERSON
Lesley Groff
PERSON
Jean-Luc Brunel
PERSONthe Southern District
LOCATION