Epstein File EFTA00597991: Deposition, Documentary and Proffer (DS9)

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Epstein File EFTA00597991: Deposition, Documentary and Proffer (DS9)

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This document is a supplement to Bradley Edwards' proffer in support of a motion for leave to amend to assert a claim, dated July 29, 2011, and served via fax. It references exhibits to depositions of A.J. Discala, Dean Kretschmar, and Michael Legamaro, and addresses documentary evidence responsive to Edwards' Request for Production served June 9, 2011, regarding claims against Epstein.

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documentary proffer metadata

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Excerpt 1

However, exhibits to the **deposition** of A.J. Discala, Dean Kretschmar, and Michael Legamaro due fit and are responsive to this request.

Excerpt 2

Response to Edwards' Request for Production served June 9, 2011, and the Request which demonstrates that Epstein does not have and has never had any **documentary**

Excerpt 3

EDWARDS, individually, and , individually, Defendant, / SUPPLEMENT TO BRADLEY EDWARDS' **PROFFER** IN SUPPORT OF MOTION FOR LEAVE TO AMEND TO ASSERT CLAIM