Epstein admits that some of the claims initially filed by him against Edwards are delineated in Paragraph 11 and its subparts, but submits that the Initial Complaint speaks for itself and that to the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph II of his Count

rds adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 3 of 8 throughout Epstein's Initial Complaint. Any suggestion that L.M.'s deposition is needed "solely" as a result of the Court's December 5, 2017 ruling is therefore absurd. 4. Jane Doe is a

ne Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶1148, 49. The litigation practices giving rise to pr

ial complaint, Epstein emphatically stated that "[t]his lawsuit is filed and will be vigorously pursued against all these defendants." See Epstein's Initial Complaint at `Summary'. (Emphasis added). In accordance with this representation to the Court, Epstein made no attempt to stay his newly-filed civil case pen

ane Doe v. Jefrey Epstein, 08-80893-C1V Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶¶ 48, 49. In addition, on July 24, 2009, while he wa