68. While Epstein and others were preventing any legitimate discovery into his sexual
abuse of minor girls, at the same time he was engaging (through his attorneys) in brutal
questioning of the girls who had filed civil suits against him, questioning so savage that it made
local headlines. See Jane Musgrave, Victims Seeking Sex offender’s Millions See Painful Pasts
Used Against Them, Palm Beach Post News, Jan. 23, 2010, available at
http://www.palmbeachpost.com/news/crime/victims-seeking-sex-offenders-millions-see-painful-
pasts-192988.html attached hereto as Exhibit “LL.”
Edwards Pursues Other Lines of Discovery
69. Because of Epstein’s thwarting of discovery and attacks on Edwards’s clients,
Edwards was forced to pursue other avenues of discovery. Edwards only pursued legitimate
discovery designed to further the cases filed against Epstein. See Edwards Affidavit, Exhibit
“N” at ¶11.
70. Edwards notified Epstein’s attorneys of his intent to take Bill Clinton's deposition.
Edwards possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine
Maxwell who was Epstein's longtime companion and helped to run Epstein’s companies, kept
images of naked underage children on her computer, helped to recruit underage children for
Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and
photographed underage females in sexually explicit poses and kept child pornography on her
computer; (b) it was national news when Clinton traveled with Epstein aboard Epstein’s private
plane to Africa and the news articles classified Clinton as Epstein’s friend. (c) the complaint
filed on behalf of Jane Doe No. 102 stated generally that she was required by Epstein to be
sexually exploited by not only Epstein but also Epstein’s “adult male peers, including royalty,
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HOUSE_OVERSIGHT_010592
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