HOUSE_OVERSIGHT_029320.jpg
2.11 MB
Extraction Summary
8
People
4
Organizations
2
Locations
2
Events
5
Relationships
5
Quotes
Document Information
Type:
Legal filing / court document (likely a memorandum in support of summary judgment)
File Size:
2.11 MB
Summary
This legal document, dated September 12, 2013, outlines attorney Edwards' defense against Epstein's claims of improper litigation tactics. Edwards asserts he had a sound legal basis to pursue discovery and depositions from high-profile individuals—including Donald Trump, Bill Clinton, Alan Dershowitz, David Copperfield, and Bill Richardson—believing they possessed relevant information regarding Epstein's alleged sexual assaults. The document argues these individuals were identified as Epstein's 'close friends' and that seeking their testimony met the legal standard for discovery.
People (8)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Subject of litigation |
Alleged that Edwards improperly pursued discovery from his close friends regarding sexual assault cases.
|
| Edwards | Attorney |
Brad Edwards (implied); defending his decision to seek discovery/depositions from high-profile individuals.
|
| Donald Trump | Potential Witness |
Edwards claimed sound legal basis for believing he had relevant information.
|
| Alan Dershowitz | Potential Witness |
Harvard Law Professor; Edwards claimed sound legal basis for believing he had relevant information.
|
| Bill Clinton | Potential Witness |
Former President; Edwards claimed sound legal basis for believing he had relevant information.
|
| Tommy Mottola | Potential Witness |
Former Sony Record executive; Edwards notes he was not the attorney who noticed Mottola's deposition.
|
| David Copperfield | Potential Witness |
Illusionist; Edwards claimed sound legal basis for believing he had relevant information.
|
| Bill Richardson | Potential Witness |
Former New Mexico Governor; named on Edwards' witness list.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Harvard Law |
Affiliated with Alan Dershowitz
|
|
| Sony Record |
Affiliated with Tommy Mottola
|
|
| SDBS |
Law firm logo at bottom of page (likely Searcy Denney Scarola Barnhart & Shipley)
|
|
| House Oversight Committee |
Implied by Bates stamp HOUSE_OVERSIGHT_029320
|
Timeline (2 events)
Unspecified
Discovery/Depositions pursued by Edwards
Litigation process
Locations (2)
| Location | Context |
|---|---|
|
Associated with Governor Bill Richardson
|
|
|
Implied by legal citation 'Fla. R. Civ. P. 1.280(b)'
|
Relationships (5)
Document refers to the group as 'Epstein's close friends'
Document refers to the group as 'Epstein's close friends'
Document refers to the group as 'Epstein's close friends'
Document refers to the group as 'Epstein's close friends'
Document refers to the group as 'Epstein's close friends'
Key Quotes (5)
"Epstein also alleged that Edwards improperly pursued discovery from some of Epstein’s close friends."Source
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Quote #1
"Each of the friends of Epstein were and are reasonably believed to possess discoverable information."Source
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Quote #2
"With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information."Source
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Quote #3
"With regard to former President Bill Clinton, Edwards had sound legal basis for believing former President Clinton had relevant and discoverable information."Source
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Quote #4
"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."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,476 characters)
Thursday, September 12, 2013
Page 6
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.
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:
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:
• 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.
Mr. Trump had relevant and discoverable information. See Statement of
Undisputed Facts filed in support of Edwards’ Motion for Summary Judgment.
• 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.
legal basis for believing Mr. Dershowitz had relevant and discoverable
information. See Statement of Undisputed Facts.
• 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.
for believing former President Clinton had relevant and discoverable
information. See Statement of Undisputed Facts.
• 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.
not the attorney that noticed Mr. Mottola’s deposition. See Statement of
Undisputed Facts.
• 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.
for believing Mr. Copperfield had relevant and discoverable information. See
Statement of Undisputed Facts.
• 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.
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 lead to the discovery of admissible evidence." Fla. R.
Civ. P. 1.280(b), and all of the challenged depositions clearly met that standard.
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 lead to the discovery of admissible evidence." Fla. R.
Civ. P. 1.280(b), and all of the challenged depositions clearly met that standard.
SDBS
HOUSE_OVERSIGHT_029320
HOUSE_OVERSIGHT_029320
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