HOUSE_OVERSIGHT_029320.jpg

Thursday, September 12, 2013 Page 6 have been litigated and determined in that action. Obviously, any question of improper “pumping” of a particular case could have been resolved in that very case rather than re-litigated in satellite litigation. Epstein also alleged that Edwards improperly pursued discovery from some of Epstein’s close friends. Such discovery, Epstein claimed, was improper because Edwards knew that these individuals lacked any discoverable information about the sexual assault cases against Epstein. Each of the friends of Epstein were and are reasonably believed to possess discoverable information. The undisputed facts show the following with regard to each of the persons identified in Epstein’s complaint of improper targets of discovery: e With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts filed in support of Edwards’ Motion for Summary Judgment. e With regard to Alan Dershowitz (Harvard Law Professor), Edwards had sound legal basis for believing Mr. Dershowitz had relevant and discoverable information. See Statement of Undisputed Facts. e With regard to former President Bill Clinton, Edwards had sound legal basis for believing former President Clinton had relevant and discoverable information. See Statement of Undisputed Facts. e With regard to former Sony Record executive Tommy Mottola, Edwards was not the attorney that noticed Mr. Mottola’s deposition. See Statement of Undisputed Facts. e With regard to illusionist David Copperfield, Edwards had sound legal basis for believing Mr. Copperfield had relevant and discoverable information. See Statement of Undisputed Facts. e With regard to former New Mexico Governor Bill Richardson, Edwards had sound legal basis for naming Former New Mexico Governor Bill Richardson on his witness list. See Statement of Undisputed Facts. The anticipated trial of this lawsuit will require Edwards to testify about the propriety of his litigation decisions and to explain the bases for his good faith belief that each of the identified individuals had relevant information regarding Epstein’s serial molestations. The rules of discovery themselves provide that a deposition need only be “reasonably calculated to /ead to the discovery of admissible evidence.” Fla. R. Civ. P. 1.280(b), and all of the challenged depositions clearly met that standard. HOUSE_OVERSIGHT_029320