A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A y!k N?M??N rC f?Nla3 Yz N?q qr NEeD K?i N?M?qr EeD k??O d6 I I i i CTX GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 The undersigned will address this i greater detail in a further memorand but the document should be considered in njunctio with the evidence and testimony already presented as well with the anticipated-t stimony Mr Adler I HEREBY C_ERTIFY that a copy oqheforegoing was furnished via Email to all co 265nsef 267listed below this 14TH day of November FRED HADDAD P.A Qne Financial Plaza Fort Lauder_ Tel Fax ee FredHaddadLaw.com_ Page of 267COUNSEL.LIST Jack 267Scarola,Esq E-mail jsx searcylaw.com mep searcylaw.com Palrri Beach Lakes Blvd West Palm Beach Florida Jack Goldberger Esq E-mail jgoldberger agwpa.c smahoney agwpa.com Australian A venue South Suite West Palin Beach Elodda Marc urik Esq E-mail marc nurikla com One East Broward Blyd Suite F_ort Lauderdale Florida Bradley ds Esq E-mail bie.efile pathtojust ce.com staff.efile pathtojustice.com AndrewsAvenue Suite Fort Lauderdale Florida Tonja Haddad Coleman Esq E-mail tonja tonjahaddad.com debbie tonjahaddad.com th Str et Suite301 Fort.Lauderdale Florida Lilly Ai1h Sanchez Esq E-mail lsanchez thelsfirm.co_m Brickell A venue th Floor Miami Florida Page of JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEiN individually and BRADLEY EDWARDS individually Defendants IN THE CIRCUITCOURT OF THE 15TH JUDICIAL CIRCUITIN AND FOR PALM BEACH COUNTY FLORIDA Case CA STATEMENT OF UNDISPUTED FACTS Defendant Bradley Edwards Esq offers the following specific facts as the undisputed material facts in this case Each of the following facts is numbered separately and individually to facilitate Epsteins required compliance with Fla Civ The adverse party shall identify any summary judgment evidence on which the adverse party relies All referenced exhibits and attachments have previously been filed with the Court and provided to Epstein Sexual Abuse of Children By Epstein I Defendant Epstein has a sexual preference for young children Deposition of Jeffrey Epstein Mar at hereinafter Epstein Depo Deposition Attachment When questioned about this subject at his deposition Epstein invoked bis Fifth Amendment right to remain silent rather than make an incriminating adP1issic,n Accordingly Edwards is entitled to the adverse inference against Epstein that had Epstein answered the answer would have been unfavorable to him lt is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to Epstein repeatedly sexually _assaulted more than forty young girls on numerous occasion between in his mansion in West Palm Beach Florida These sexual assaults incl:uded vaginal penetration Epstein abused many of the girls dozens if not hundreds of times Epstein Depo at How many times have you engaged in oral sex with females under the age of A Invocation of the Fifth Amendment Deposition of Jane Doe September and continued March at minor girl sexually abused at least times by Epstein hereinafter Jane Doe Depo Deposition Attachment id vaginal penetration by Epstein with his finger vaginal penetration by Epstein with a massager Deposition of L.M September at hereinafter L.M Depo Deposition Attachment describing the manner in which Epstein abused her _beginning when LM was years old touching her vagiria witl:i his fingers and vibrator at line she was personally molested by Epstein more than times at line and line and line describing that in addition to being personally molested by Epstein she was paid per underage girl she brought Epstein and she brought him more than sev nty underage girls she told him that she did not want to bring him any more girls and he insisted that she continue to bring him underage girls Deposition of E.W May hereinafter E.W Depo Deposition Attachment at and describing Epsteins abuse of her beginning at age when he paid her for touching her vagina inserting his fingers and civil actions when they refuse to testify in response to probative evidence offered against them Baxter Palmigiano U.S accord Vasquez State So.2d_ Fla App The reason for this rule is both logical and utilitarian A party may not trample upon the rights of others and then escape the consequences by invoking a constitutional privilege at least not in a civil setting Fraser Security and Inv Corp So.2d Fla App using a vibrator-and he also paid her for each other underage female E.W brought him to molest She-brought him betwee1120 and underage females Deposition ofJan_e Doe date he einafter Jane Doe Depo Deposition Att13:chment at and she describes first being taken to Epstein at years old lBeing fmgered by him having him se a vibrator on me grabbing my nipples smelling my butt jerking off in front of me licking my dit several At all relevant times Edwards has had_ a good faith basis to conclude and did conclude that Epstein was able to access a large nuniber of underage girls tlrrough a pyramid abuse scheme in which he paid underage victims i::ash for each other underage victim that she brought to him See Palm Beach Police Incident Report at hereinafter Incident Report Exhibit A The Palm Beach Police Incident Report details Epsteins scheme for molesting underage females Among other things the Incident Report outlines some of the experiences of other Epstein victims When S.G a year_ old minor at the time was brought to Epsteins home she was taken-upstairs by a woman she believed to be Epsteins assistant The woman st rted to fix up the room putting covers on th massage tabie and bringing lotions out The as istanr then left the room and ld S.G that Epstein would be up in a second Epstein waiked oyer to S.G and told her to take her clothes off in a stern voice S.G states in the rep_ort she did not know what to do as she 267was the only one there S.G took off her sh_irt leaving her bra on Epstein then in a towel told her to take off everything S.G removed her pants leaving In upp rt of all ass1frtions concerning the actions Edwards tqok what Edwards learned in the course or his representation of hi clients Edwardss good faith beliefs and the foundation for those beliefs see Edwards Affidavit and specifically paragraphs and ofthatAffidavit For clarify depositions attached to this memorandum wilLbe identified numerically as attachments etc while exhibits attached to this memorandum will be identified alphabetically as exhibits A etc on her thong panties Epstein then instructed S.G to give him a massage As S.G gave Epstein a massage Epstein turned around and masturbated S.G was so disgusted she did not say anything Epstein told her she had a really hot body Id at In the report S.G admitted seeing Jeffrey Epsteins penis and stated she thought Epstein was on steroids because he was a really built guy and his wee wee was very tiny Id at The_exact number of minor girls who Epstein assaulted is known only to Epstein However Edwards had a good faith basis to believe and did in fact believe that Epsteins victims were substantially more than forty in number In addition to the deposition excerpts from twq of his many victims above about the number of underage girls brought to Epstein and the Palm Beach incident report there is overwhelming proof that the number of underage girls molested by Epstein through his_scheine was in the hundreds See Complaint Jane Doe Epstein hereinafter Jane Doe complaint Exhibit see also Deposition of Jeffrey Epstein April at and Epstein invoking the 5th on questions about his daily abuse and molestation of children Depositlon Attachment At all relevant times Edwards has had a good faith basis to believe and did in fact believe that Epstein and his attorneys knew of the seriousness of the criminal investigation against him and corresponded constantly with the United States Attorneys Office in an attempt to avoid the filing of numerous federal felony offen_ses which effort was successful See Correspondence from U.S Attorneys Office to Epstein hereinafter U.S Attorneys Correspondence Composite Exhibit provided in discovery during the Jane Doe Epstein case At all relevant times Edwards has had a good faith basis to believe and did in fact believe that more specifically Epsteins attorneys lrnew of Epsteins scheme to recruitminors for sex and also knew that these minors had civil actions that they could bring against him In fact there was much communication between Epsteins attorneys arid the United States Prosecutors in a joint attempt to minimize Epsteins civil exposure For example on October Assistant U.S Attorney Marie Villafana sent an email attached hereto as Exhibit to JayLefkowitz col.insel for Epstein with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein The letter reads in pertinent part The undersigned as counsel for the United States of America and Jeffrey Epstein jointly write to you to provide information relevant to your service as a Special Master in the selection of an attorney to represent several young women who may have civil damages claims against Mr Epstein The U.S Attorneys Office and the Federal Bureau of Investigation Gointly referred to as the United States have conducted an investigation of Jeffrey Epstein regarding.his solicitation of minor females in Palm Beach County to engage in prostitution Mr Epstein through his assistants would recruit underage females to travel to his home in Palm Beach to engage in lewd conduct in exchange for money Based upon the invesjgation the United States has identified forty young women _who can be characterized as victims pursuant to USC Some of those wonien went to Mr Epsteins home only once some went there as much as times or more Some of the womens conduct was limited to performing _a topless or nude massage while Mr Epstein-masturbated himself For other women the conduct escalated to full sexual intercourse As part of the resolution of the case Epstein has agreed that he would not contest jurisdiction in the Southern District of Florida for any victiin who chose to sue him for damages pursuant to USC Mr Epstein agreed to provide an attorney for victims who elected to proceed exclusively pursuant to that section and agreed to waive any challenge to liability under that section up to an amount agreed to by the parties The parties _have agreed to 267submit the selection of an attorney to a Special Master At all relevant times Edwards ha_s had a good faith basis to believe and did in fact bell eve that L.M was in fact a victim of Epsteins criminal abuse because L;M was one of the minor females that the United States Attorneys Office recognized as a victim L.M sworn deposition testimony and the adverse inference-drawn from Epsteins refusal to testify confirm that Epstein began sexually assaulting LM when she was years old and continued to molest i her oi:i more than fifty occasions over three years Epstein Depo Attachment at Did you ever engage in any sexual conduct with L.M A Invocation of_ the Fifth Amendment see also Epstein Depo April Attachment at LM was an underage female that you first abused when she was years old is that correct A Invocation of Fifth Amendment Epstein was also given ample opportunity to explain why he engaged in sexual activity with L.M beginning when L.M was years old and why he has molested minors on an everyday basis for years and he invoked his 5th amendment right rather than provide explanation See Epstein Deposition February at Deposition Attachment Epstein also sexually assaulted E.W beginning when she was years old and did so on numerous occasions See E.W Depo Attachment at Another of the minor girls Epstein sexually assaulted was Jane Doe the abuse began when Jane Doe was years _old Rather than incriminate himself Epstein invoked the 5th amendment to questions about him digitally penetrating Does vagina using vibrators on her vagina and masturbating and ejaculating in her presence Epstein Depo April Attachment at When Edwardss clients L.M E.W and Jane Doe were or years old each was brought to Epsteins home multiple times by another underage victim Epstein engaged in one or more of the following acts with each of the then-minor girls at his mansion receiving a topless or completely nude massage using a vibrator ort her vagina masturbating in her pre ence ejaculating in her presence touching breast or buttocks or vagina or the clothes covering her sexual organs and demanding that she bring him other underage gir1s Epstein and his co-conspirators used the telephone to contact these girls to entice or induce them into going to his mansion for sexual ibuse Epstein also made E.W perform oral sex on him an,d was to perform sex acts on Nadia Marcinkova Epsteins live-in ex slave in Epsteins presence See Plaintiff Jane Does Notice Regarding Evidence of Similar Acts Sexual Assault filed in Jane Doe Epstein No S.D Fla as DE hereinafter Rule Notice Exhibit Jane Doe Depo Attachment at L.M Depo Attachment at E.W Depo Attachment at At all relevant times E1wards ha_s had a good faith basis to believe and did in fact believe that yet another of th_e minor gir1s Epstein sexually assaulted was C.L When she was approximately years old C.L was brought to Epsteins home by another underage victim WJ;iile a minor she was at Epsteins home on multiple occasions Epstein engaged in one or more of the following acts with her while she was a minor at his house topless or completely nude massage on Epstein Epstein used a vibrator on her vagina Epstein masturbated in her presence Epstein_ ejaculated in her presence Epstein also demanded that she bring him other underage girls See Ruie Notice Exhibit Incident Report Exhibit A At all relevant times Edwards has had a good faith basis to believe and did in fact believe that yet another gir1 Epstein sexually assault was AH When she was approximately years old she was brou ht to Epsteins home by another underage victim While a minor she was atEpsteins home on multiple occasions Epstein engaged in one or more of the following acts with her while she was a minor at his house topless or completely nude massage on Epstein Epstein used a vibrator ori her vagina Epstein masturbated in her presence Epstein ejaculated in her presence Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs was made to perform sex acts on Epstein made to perform sex acts on Nadia Marcinkova in Epsteins presence Epstein also forcibly raped this underage victim as he held her head down against her will and pumped his penis inside her while she was screaming No See Rule Notice Exhibit Incident Report Exhibit A at specifically discussing the rape A.H remembered that she climaxed and w,as removing herself from the massage table A.H asked for a sheet of paper.and drew the massage table in the master bathroom and where Epstein Marcinkova and she were Epstein turned A.H on to her stomach on the massage bed arid inserted his penis into her vagina A.H stated Epstein began to pump his penis in her vagina A.H became upset over this She said her head was being held against the bed forcibly as he continued to pump inside her She screamed no and Epstein stopped A.H advised there were times that she was so sore when she left Epsteins house A.H advised she was ripped torn in her vagina area A.H advised she had difficulty walki11g to the car after leaving the house because she was so sore Without _detailing each fact known about Epste_ins abuse of the many und rage girls Edwards has had a good faith basis to believe and did in fact believe at all relevant times that Epstein also abused other victims in ways closely similar to those described in the preceding paragraphs Epsteins additional victims include the following a ong many other young girls S.G A.D V.A N.R J.S V.Z J.A F.E M.L M.D D.D and D.N These girls were between the ages of and when Epstein abused them See Rule Notice Exhibit Deposition ofE.Vj Oeposition Attachment One of Mr Epsteins household employees Mr Alfyedo Rodriguez saw numerous underage girls coming into Eps.teins mansion for purported massages See Rodriguez Depo at Deposition Attachment Rodriguez was aware that toys and vibrators were found in Epsteins bedroom after purported massages id at Rodriguez thought-what Epstein was doing was wron given the extreme youth of the girls he saw Id at Alfredo Rodriguez took 267ajo al from Epsteins computer that reflected rnany the names of underage females Epstein abused across the country and the world including locations such as Michigan California West Palm Beach Ne York New Mexico arid Paris Fra ce See Journal hereinafter The Journal or Holy Grail Exhibit identifying among other Epstein acquaintances females that Rodriguez believes were underage under the heading labeled Massages Rodriguez was later charged in a criminal mplaint with obstruction of justice in connection with trying to obtain from civil attorneys pursuing civil sexual assault cases against Epstein as payment for producing the book to the attorneys See_ Criminal Complaint at U.S Rodriguez No S.D Fla Exhibit Rodriguez stated he needed money because the journal was his property and that he was afraid that Jeffrey Epstein would make him disappear unless he had an insurance policy i.e the jou 265ial Id at Because of the importance_ of the information in the journal to the civil cases Mr Rodriguez called it Holy Grail In the Holy Grail or The Journal among the many names listed along with the.abused girls are some of the people that Epstein alleges in his Complaint had no connection whatsoevert,with the litigation in this case See e.g Journal Exhibit at Donald Trump at Bill Clinton phone numbers listed under Doug ds Federal I vestigationand Plea Agreemeni With Epstein In approximately the FBI and the U.S Attorneys Office in the Southern District of Florida learned of Epsteins repeated sexual abuse of minor girls They began a criminal investigation into federal offenses related to his crimes See U.S Attorneys Correspondence Exhibit At all relevant times Edwards has had a good faith basis to believe and did in fact believe that to avoid the Gove_rnment learning about his abuse of minor girls Epstein threatened his employees and demanded th tthey n:ot cooperate with the government Epsteins aggressive witness tampering was so severe that the United States Attorneys Office prepared negotiated plea agreements containing these charges For example in a September email from AUSA Villafana to Lefkowitz attached hereto as-Exhibit she attached the proposed plea agreement describing Epsteins witness tampering as follows UNITED STATES vs JEFFREY EPSTEIN PLEA PROFFER On August FBI Special Agents Nesbitt Kuyrkendall and Jason Richards traveled to the home of Leslie Groff to serve her with a federal grand jury subpoena with an investigation pending in the Southern District of Florida Ms Groff works as the personal assistant of the defendant Ms Groff began speaking with the agents and then excused herself to go upstairs to check on her sleeping child While upstairs Ms Groff lephoned the defendant Jeffrey Epstein and informed him that the FBI agents were at her home Mr Epstein instructed Ms Grpff not to speak with the agents and reprimanded her for allowing them into her home Mr Epstein applied pressure to keep Ms Groff from complying with the grand jury subpoenas that the agents had served upon her In particular Mr Epstein warned Ms Groff against turning 267over documents and electron_ic evidence responsive to the subpoena arid pressured her to delay her appearance before the grand jury in the Southern District of Florida This conversationoccurred when Mr Epstein was aboard his privately owned civilian aircraft in Miami in the Southern District of Florida His pilot had filed a flight plan showing the parties were about to return to Teterboro NJ After the conversation with Ms Groff Mr Epstein became concerned that the FBI would try to serve his traveling companion Nadia Marcinkova with a similar grand jury subpoena In fact the agents were preparing to serve Ms Marcinkova with a target letter when the flight landed in Teterboro Mr Epstein then redirected his airplane making the pilot file a new flight plan to travel to the US Virgin Islands instead of the New York City area thereby keeping the Special Agents from serving the target letter on Nadia Marcinkova During the flight the defendant verbally harassed Ms Marcinkova harassing and pressuring her not to cooperate with the grand jurys investigation thereby hindering and dissuading her from reporting the commission of a violation of federal law to a law enforcement officer namely Special Agents of the FBI Epstein also threatened and harassed Sarah Kellen against cooperating against him as well Edwards learned that the Palm Beach police department-investigation ultimately led to the execution of a search warrant at Epsteins mansion in tober See Police Incident Report Exhibit A Edwards learned that at around the same time the Palin Beach Police Department also 267began investigating Epsteins sexual abuse of inor girls They also collected evidence of Epsteins involvement with minor girls and his obsession with training sex slaves including pulling information from Epsteins trash Their investigation showed th Epstein ordered from Amazon.com on about September such books as SMlOl A Realistic Introduction by Jay Wiseman SlaveCraft Roadmaps for Erotic Servitude Principles Skills and Tools by Guy Baldwin and Training with Miss Abernathy A Workbook for Erotic Slaves and Their Owners by Christina Abernathy See Receipt for Sex Slave Books Exhibit I The Palm Beach incident reports provided Edwards with the names of numerous witnesses that participated in Epsteins child molestation criminal enterprise and also provided I Edwards with some insight into how far-reaching Epst ins power was and how addicted Epstein was.to sex-with children See Incident Report Exhibit A The Palm Beach Police Department also collected Epsteins message pads which provided other names of people that also lmew Epsteins scheme to molest _children See Message Pads Exhibit note the names of underage females have been redacted to protect theanonymity of the underage sex abuse victims Those message pads show clear indication that Epsteins staff was frequently working to scheduie multiple young girls between the ages of and years old literally every day often two or three times per day Id light of all of the information of numerous crimes committed by Epstein Edwards learned that the U.S Attorneys Office began preparing the filing of federal criminal charges against Epstein For example in addition to the_ witness tampering and money laundering charges the U;S Attorneys Office prepared an 82-page prosecution memo and a page indictment of Epst in related to his sexual abuse of children On September at PM AUSA Villafana wrote to Epsteins courisel Jay Lefkowitz Jay I hate to have to be firm about this but we need to wrap this up by Monday I will not miss my indictment date when this has dragged on for several weeks already and then if things fali apart be left in a less advantageous position than before the negotiations I have had an 82-page pros memo and page indictment sitting on the shelf since May to engage in these negotiations There has to be an ending date and that date is Monday _These and other communications are within the correspondence attached as Composite Exhibit Edwards learned that rather than face the filing of federal felony criminal charges Epstein through his attorneys engaged in plea bargain discussions As a result of those discussions on September Epstein signed an agreement _with the U.S Attorneys Office for the Southern District of Florida._ Under the agreement Ep_ tein agreed to plead guilty to an indictment pending against him in the th Judicial Circuit in and for Palm Beach County charging him with solicitation of prostitution and procurement of minors for prostitution Epstein also agreed that he would receive a thirty month _sentence including months of jail tim,e and months of community control In exchange the U.S Attorneys Office agreed not to pursue any federaLchargesagainst Epstein See Non-Prosecution Agreement Exhibit Part of the Non-Prosecution Agreement that Epstein negotiated was a provision in whic:h the federal government agreed not to prosecute Epsteins co-conspirators The co conspirators procured minor females to be molested by Epstein One 6f the co-conspirators Nadia Marcinkova even participated in the sex acts with 225minors including E.W and Epstein See Incident Report Exhi it A at position of Nadia 267Marcinkova April hereinafter Marcinkova Depa at Deposition attachment Under the Non-Prosecution Agreement Epstein was to use his best efforts to enter into his guilty pleas by October However Edwards learned that Epstein violated his agreement with the U.S Attorneys Office to do sc and cieiayed eritry.ofhis plea See Letter from U.S Attorney Alexander.Acosta to Lilly Ann Sanchez Dec Exhibit L"r On January and again on May E.W and L.M received letters from the FBI advising them that this case is currently un_der investigation This can be a lengthy process and we request your continued patience while we conduct a thorough investigation Letters attached at Composite Exhibit_ This document is idence that th FBI did not notify E.W and L.M that a plea agreement had already been reached that would block federal pr_osecution of Epstein Nor did the FBI notify E.W and L.M of any of the parts of the plea agreement Nor did the FBI or other federal authorities confe_r with E.W and L.M about the plea See id In Edw.ards believed in good faith that criminal prosecution of Epstein was extremely important his clients E.W and L.M and that they desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of _Epstein The letters that they had received around January suggested that a criminal investigation of Epstein was on-going and that they would be contacted before the federal government reached any final resolution of that investigation See id Edwards Agrees to Serve as Legal Counsel for Three Victims of Epsteins Sexual Assaults In out April Bradley Edwards Esq was a licensed attorney in Florida practicing as a sole practitioner As a former prosecutor he was well versed in civil cases that involved criminal acts including sexual assaults Three of the many girls Epstein had abused L.M E.W and Jane Doe all requested that Edwards represent them civilly and secure appropriate monetary damages against Epstein for repeated acts of sexual abuse while they were minor girls Two of the girls L.M and also requested that dwards_ Tepresent them in connection with a concern that the Federal Bureau of Investigation FBI and U.S Attorneys Office might be arranging a plea bargain for the criminal offenses committed by Epstein without providing them the legal rights to which they were entitled including the right to be notified of plea discussions and the right to confer with prosecutors about any plea arrangement See Affidavit of Bradley Edwards Esq at r1 r4 hereinafter Edwards Affidavit Exhibit On June attorney Edwards a eed to represent E.W on July attorney Edwards agreed to represent Jane Doe an on July attorney Edwards agreed to represent LM in connection with the sexual assaults committed by Epstein and to insure that their rights as victims of crimes were protected in the uiminal process on-:going against Epste Mr Edwards and his three clients executed written retention agreements See id at r2 In mid June of Edwards contacted AUSA Villafana to inform her that he represented Jane Doe and later Jane Doe AUSA Villafana did not advise that a plea agreement had already bee negotiate_d with Epsteins attorneys that would block federal prosecution To the contrary AUSA Villafana mentioned a possible indictment AUSA Villafana did indicate that federal investigators had concrete evidence and information that Epstein had sexually molested many imderage minor females including E.W LM and Jane Doe See id at r4 Edwards also requested from the U.S Attorneys Office the information that they had collected regarding Epsteins sexual abuse of his clients However the U.S Attorneys Office declined to provide any such information to Edwards It similarly declined to provide any such h1formation to the other attorneys who represented victims of Epsteins sexual assat1lts At the very least this includes the items that were confi cated in the search warrant of Epsteins home including dildos 267vibrators massage table oils and additional message pads See Pr perty Receipt Exhibit On Friday June at approximately p.m AUSA Villafana received a copy of Epsteins proposed state plea agreement and le:nned that the plea was scheduled for a.m Monday June AUSA Villafana called Edwards to provide notice to his clients regarding the hearing AUSA Villafana did not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility of federal prosecution Pl.J!Suant to the plea agreement See Edwards Affidavit Exhibit at Under the Crime Victims Rights Act CVRA U.S.C victims of federal crimes including E.W and L.M are entitled to basic rights during any plea bargaining process including the right to be treated with fairness the right to confer with prosecutors regarding any plea and the right to be heard regarding any plea The process that was fo1lowed leading to the non-prosecution of Epstein violated these rights of E.W and L.M See Emergency Petn for Victims Enforcement of Crime Victims Rights No KAM S.D Fla Exhibit Pr Because of the violation of the CVRA on July Edwards filed an action in the District Court for the Southern District of Florida Case No seeking to enforce the rights of E.W and L.M That action alleged that the U.S Attorneys Office had failed to provide E.W and L.M the rights to which they were entitled under the Act including the right to be notified about a plea agreement and to confer with prosecutors regarding it See id On July Edwards took E.W and L.M with him to the hearing on the CVRA action It was only at this bearing that both victims learned for the first time that the plea deal was already done with Epstein and that the criminal case against Epstein had been effectively terminated by the U.S Attorneys office See Hearing Transcript July Exhibit Edwards learned that Jane Doe felt so strongly that the plea bargain was inappropriate that she made her own determination to appear on a television program and exercise her First Amendment rights to criticize the unduly lenient plea bargain Epstein received in a criminal case The CVRA action that Edwards filed was recently administratively closed and Edwards filed a Motion to reopen that proceeding See No S.D Fla Epstein Entry of Guilty Pleas to Sex Offenses 4L Ultimately on June in 267the Fifteenth Judicial Circuit in Palm Beach Co nty Florida defendant Epstein entered pleas of guilty to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes.of prostitution See Plea Colloquy Exhibit As a c.ondition of that plea and in exchange for the Federal Government not prosecuting the Defendant Epstein additionally entered into an agreement with the Federal Gov mment acknowledging that appr ximately thirty-four other young giris could receive payments from hi under the federal statute providing for compensation to victims of child sex al abuse U.S.C As had been agreed months before the U.S Attorneys Office did not prosecute Epstein federally for his sexual abuse of these minor girls See Addendum to Non-Prosecution Agreement Exhibit in redacted form to protect the identities of the minors involved Because Epstein became a 267convicted sex offe der he was not to have contact with any of his victims During the course of his guilty pleas on June Palm Beach Cir uit Court Judge Deborah Dale Pucillo dered Epstein not to have any contact direct or indirect with any victims She also expressly stated that her no-contact order applied to all of the victims Similar orders Yere entered by the federal court handling some of the civil cases against Epstein The fede al court stated that it fi it necessary to state clearly that Defendant is under this courts order not to have direct or indirect contact ith any plaintiffs Order Case No S.D Fla DE at emphasis added see also Order Case No DE at emphasis added Edwards Files Civil Suits Against Epstein Edwards had a good faith belief that is lients _felt angry and betrayed by the criminal system and wished to prosecute and punish Epstein for his crimes against them in I whatever avenue remained open to them On August at the request of his client Jane Do Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for h,is sexual assault of Jane Doe See Edwards Affidavit at Included in this complaint was a RICO count that explained how Epstein ran a criminal conspiracy to procure young girls for him to sex:ually abuse See Complaint Jane Doe Epstein Exhibit On September at the request of his client E.W Brad Edwards filed a-civil 267suit against Jeffrey Epstein to recover damages for his sexual assault of E.W ee Complaint E.W Epstein Exhibit On September at the request of his client L.M Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sex al assault of L.M See Complaint L.M Epstein Exhibit Jane Does federal 267complaint 267indicated that she sought damages of more than Listing the amount of damages sought in the coinplaint:was in ac;:cord with oth civil suits that were filed against Epstein before any lawsuit filed by Edwards See Complaint Jane Doe Epstein ibit filed by_Herman and Mermelst in PA At bout the same time as Edwards filect his three lawsuits against Epstein other civil attorneys ere filing similar lawsuits against Epstein For example on or about April another law firm Herman and Mermelstein filed the first civil action agrunst Epstein on behalf of one of its seven clients who were molested by Epstein The complaints that attorney He an filed on beqalf of his seven clients ere 267_similar in tenor and tone to the complaint that Edwards filed ori behalf of his three clients See id Over the next year and a half more than other similar civil actions were filed by vanous attorneys against Epstein alleging sexual assault o_f minor girls These complaints were also similar in tenor and tone to the complaint that Edwards 225filed on behalf of his clients These complaints are all public record and-have not b_een attached but are available in this Courts files and the files of the U.S District Court for the Southem District of Florida In-addition to the complaints filed against Epstein in Florida a female in New York Ava Cordero filed a lawsuit against Epsteini Ne York.making similar allegations that Epstein paid her for a massage then forced her to give him oral sex and molested her in other ways when she was only years old Cordero was born_ a male and in her complaint she all ges that Epstein told her during the massage I love how young you are You have a tight butt like a baby See Jeff Epstein Sued for Repeated Sexual Assaults on Teen New York Post October by Dareh Gregorian link at 6CA3 EBF1BEF68F5DE14BFB2CAA5C37E0 267See Article attached hereto as Exhibit Edwards three complaints against Epstein contained less detail about sexual abuse than as one example a complaint filed by attorney Robert Josephsberg from the law firm of Podhtirst Orseck See Complaint Jane Doe Epstein Exhibit As recounted in detail in this Complaint Jane Doe was years olq wh Ghislaine Maxwell discovered her and lured her to Epsteins house Maxwell and Epstein forced to have sex with both of them and within weeks Maxwell and Epstein were flying her all over the world According to the Complaint Jane Doe was forced to live as one of Epsteins underage sex slaves for years and was forced to have sex with not only Maxweli and Epstein but also other politicians businessmen royalty academicians etc She was even made to watch Epstein have se with three 12-year-old French giris that were sent to him for his birthday by a French citizen that is a friend of Epsteins Luckily Jane Doe escaped to Austr lia to get away from Epstein and Maxwells sexual abuse Edwards learned that in addition to civil suits that were filed in court against Epstein at around the same time other attorneys engaged in pre-filing settlement discussions with Epstein Rather than face filed civil suits in these cases Epstein paid money settlements to more than other women who had sexually abused while they were minors See articles regar:ding settlements attached hereto as Composite Exhibit Epstein Obstruction of Normal Discovery and Attacks on His Victims Once Edwards filed his civil complaints for his three clients he began the normal process of discovery for cases such as these He se_nt standard discovery requests to Epstein about his se ual abtise of the minor girls including requests for admissions request for production and interrogatories See Edwards Affidavit Exhibit at and Rather than answer any substantive questions about his sexual abus and his conspiracy for procuring minor girls for him to abuse Epstei11 invoked his 5th amendt:nent right against self incrimination An example of Epsteins.refusal to answer is attac ed as Composite Exhibit original discovery propounded to Epstein and his responses invoking 5th amendment During the discovery phase of the civil cases filed against Epstein Epsteins deposition was tak at least five times During all of _those depositions Epstein refused to answer any substantive questions about his sexual abuse of minor girls See e.g Deposition Attachments and During these depositions Epstein further attempted to obstruct legitimate questioning by inserting a variety of irrelevant information about his case As one of innumerable examples on March Mr Horowitz representing seven victims Jane Does asked In did you rub Jane Doe 3s vagina A Excuse me Id like to answer that 267question as I would like to answer mostly every question youve asked me.here today however upon advice of counsel I cannot answer that question Theyve advised me I must assert rriy Sixth Amendment Fifth Amendment and Fourteenth Amendment Rights against self--ex,cuse me against--under the Constitution And though your partner Jeffrey Herman was disbarred after filing this lawsuit a statement that was untru Mr Edwards partner sits in jail for I fabricating cases of a sexual nature fleecing unsuspecting Florida investors and others out of millions of dollars for cases of a sexual nature wit4--Idlike to answer your questions however if 1--Iim told that if I do so I risk losing my counsels representation therefore I must accept their advice Epstein deposition March at Deposition attachment When.Edwards had the opportunity to take Epsteins deposition he only asked reasonable questions all of which related to the merits of the cases against Epstein All de ositions of Epstein in which Mr Edwards participated on behalf of is clients are attached to this motion See Edwards Affidavit Exhibit at and Deposition attachments and Cf with Deposition of Epste_in taken by an attorney representing BB one in which Edwards was not participating http://w.youtube.com/watch?v V-dgoEyYXx4 and http://w.youtube.com/watch?v YCNiYltW-rO Edwardss efforts to obtain information about Epsteins organization for procuring young girls was also blocked because Epsteins co-conspirators took the Fifth Deposition of Sarah Kellen _March hereinafter Kellen Depo Deposition attachment Deposition of Nadia Marcinkova April Deposition attachment Deposition of Adriana Mucinska Ross March hereinafter Ross Depo Deposition attachment Each of these co-conspirators invoked their respective rights against self incrimination as to all relevant questions and the depositions have been attached At aU relevant times Edwards has had a good faith basis to believe and did in fact believe Sarah Kellen was an employee of Epsteins and had been identified as a defendant in at least one of the complaints against Epstein for her role in bringing girls to Epsteins mansion to be abuseq At the deposition she was represented by Bruce Reinhart She invoked the Fifth on all substantive questions regarding her role in arranging for minor girls to come to Epsteins mansion to be sexually abused Reinhart had previously been an Assistant United States Attorney in the U.S Attorneys Office for the Southern District of Florida when Epstein was being inve 267stigated criminally by Reinharts office Reinhart left the United States Attorneys Office and was immediately hired by Epstein to represent Epsteins pilots and cer13:in co corispirators during the civil cases against Epstein See Edwar Affidavit Exhibit at r1 Edwards also had other lines of legitimate dis _overy blocked through the efforts of Epstein and others For example Edwards learned through deposition_that Ghislaine Maxwell was involved in managing Epsteins affairs and companies See deposition of Epsteins house manager Janusz Banziak February at page lines Deposition Attachment See deposition of Epsteins housekeeper Louella Rabuyo October page lines Deposition Attachment See deposition of Epsteins pilot Larry Eugene Morrison October page Deposition Attachment See deposition of Alfredo Rodriguez August page and Deposition Attachment See also Prince Andrews Friend Ghislaine Maxwell Some Underage Girls and A Very Disturbing Story September by Wendy Leigh link at 1895OHANNA SJOBERG Exhibit AA Alfredo Rodriguez testified that Maxwell took photos of girls without the girls knowledge kept the images on her computer knew he names of the underage girls and their respective phone numbers and other underage victims were molested by Epstein and Maxwell tog ther See Deposition of Rodriguez Deposition attachment at and In reasonable reliance_ on this and other information Edwards served Max.well for deposition in See Deposition Notice attached as Exhibit BB Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Gresser and Edwards understood that her attorney was paid for directly or indirectly by Epstein She was reluctant to give her deposition and Edwards tried fo work with her attorney to take her deposition on terms that would be acceptable to both sides The result was the attached confidentiality agreement under which Maxwell agreed to drop any objections to the deposition attached hereto as Exhibit CC Max.well however contrived to avoid the deposition On June one day before Edwards was to fly to NY to take Maxwells deposition her attorney informed Edwards that Maxwells mother was deathly ill and Maxwell was consequently flying to England with no intention of returning to the United States Despite that assertion Ghislaine Maxwell was in fact in the country on July as she attended the wedding of Chelsea Clinton former President Clintons _daughter and was captured in a photograph taken for OK magazine Photos from Issue of the publication See US Weekly dated August are attached hereto as Exhibit DD and Edwards Affidavit Exhibit at Maxwell is not the only 225important witness to lie to avoid deposition by Edwards Upon review of the.message pads that were taken from Epsteins home in the police trash pulls seeExhibit supra many were from Jean Luc Brunel a French citizen and one of Epsteins closest pals He left messages for Epstein One dated said He has a teacher for you to teach you how to speak Russian She is years old not blonde Lessons are free and you can have your st today if you call See Messages taken from Jean Luc Brunel are attached hereto a_s Exhibit EE In light ofthese circumstances of the case this message reasonably suggested to Edwards that Brunel might have been prqcuring two eight-year-old girls for Epstein to sexually abuse According _to widely circulated press reports reviewed by Edwards Brunel is in his sixties and has a reputation throughout the world and especially in the modeling industry as a cocaine addict that has for yem:s molested children through modeling agencies while acting as their agent conduct that has been the bject of critical reports books several news 267articles and a Mii:mtes ocumentary on Brunels sexual exploitation of underage models See _0/08/women-are-objects.html attached _hereto as Exhibit FF Edwards learned that Brunel is also someone that visited Epstein on aprroximately o_ccasio while Epstein was in jail See Epsteins jail visitor log attached as Exhibit GG Edwards learned that Brunel currently runs the modeling agency MC2 a company r:which Epstein provides financial support See Message Pads attached as:Exhibit supra anci Sworn Statement of MC2 ei:nployee Maritza Vasquez June Maritza Vasquez Sworn Statement attached at Exhibit HH at Employees of MC2 told Edwards that Epsteins numerous condos at East Street in New York were used to house yourig models Edwards was told that MC2 modeling _agency affiliated with Epstein and Brunel brought underage girls from all over the world promising them modeling contracts Epstein and Brund would then obtain a visa for these girls then would charge the underage girls rent presumably to live as underage prostitutes in the condos See Maritza Vasquez Sworn Statement Exhibit Hl:J at and In view of this __ information suggesting Brunel could provide significant evidence of Epsteins trafficking in young girls for sexual abuse Edwards had Brunel served in New York for deposition See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit II Before the_ deposition took place Brunels attorney Tama Kudman of West Palm Beach contacted Edwards to delay the deposition date Eventually Kridman informed Edwards in January that Brunel had left the country and was back in France with no plans to return This information was untrue Brunel was actually staying-with Epstein in West Beach See Banasiak_ deposition deposition attachment at and see also pages from Epsteins probation file evidencing Jean Luc_ Brunel JLB staying at his house during that relevant period of time attached Exhibit JJ As a result Edwards filed a Motion for Contempt attached hereto as Exhibit KK Bec use Epstein settled this case the motion was never ruled upon Edwards was also informed.that Epstein paid for not only Brunels-representation during the civil process but also paid for legal representation for Sarah Kellen Epsteins executive assistant and procurer of girls for him to buse Larry Visoski Epsteins personal pilot Da.ve Rogers Epsteins personal pilot Larry Harrison Epsteins personal pilot Louella Rabuy Epsteins housekeeper Nadia Marcinkova Epsteins live-in sex slave Ghislaine Ma cwell manager of Epsteins affairs and businesses Mark Epstein Epsteins brother and Janusz Banasiak Epsteins house manager It was nearly impossible to take a deposition of someone that would have helpful information that was not represented by an attorney paid for by Epstein See Edwards Affidavit Exhibit at While Epstein and others were preventing any legitimate disc 267overy into his sexual abuse of minor girls at _the same time he was engaging through his attorneys in brutal qu stioning of the girls who had filed civil suits againsfhim questioning so savage that it made local headl1nes See Jane Musgrave Victims Seeking Sex offenders Millions See Painful Pt;i,sts Used Against Them Palm Beach Post News Jan available at httJ millions-see-painful pasts-192988.html attached hereto as Exhibit LL Edwards Pursues Other Lines of Discovery Because of Epsteins thwarting of discovery and attacks on Edwards clients Edwards was forced to pursue other avenues of disc very Edwards only pursued legitimate discovery designed to further the cases filed against Epstein See Edwards Affidavit Exhibit at rv Edwards notified Epsteins attorneys of his intent to take Bill Clintons deposition Edwards possessed a legitimate basis for doing so a Clinton was friends with Ghislaine Maxwell who was Epsteins longtime companion and helped to run Epsteins companies kept images of naked underage children on her_ computer helped to recruit underage children for Epstein engaged in lesbian with underage females that she procured for Epstei_n arid phe tographed underage females in sexually explicit poses and kept child pornography on her computer it was national news when Clinton traveled with Epstein aboard Epsteins private plane to Africa and the news articles classified Clinton as Epsteins friend the complaint filed on behalf of Jane Doe No stated generally that she was required by Epstein to be sexually exploited by not only Epstein but also Epsteins adult male peers including royalty politicians academicians businessmen and/or other professional and personal acquaintances categories Clinton and acquaintances of Clinton fall into The flight logs showed Clinton traveling on Epsteins plane on Il!Ilerous occasions between and See Flight logs attached hereto as Exhibit MM Clinton traveled on many of those flights with Ghislaine Maxwell Sarah Kellen and Adriana cinska all employees and/or co-conspirators of Epsteins that were closely connected to Epstein child exploitation and sexual abu The documents clearly show that Clinton frequently flew with Epstein aboard his plane then suddenly stopped raising the suspicion that the friendship abruptly ended perhaps because of events related to Epsteins sexual abuse of children Epsteins personal phone directory from his co puter contains e-mail addresses for Clinton.along with21 phone numbers for him including those for his assistant Doug Barid his schedulers and what app ar to be Clintons personal numbers This information certainly leads one to believe that Clinton might well be a source of tel vant information and efforts toobtain discovery from him were reasonably calculated to lead to admissible evidence See Exhibits AA Dff and MM and Edwards Affidavit Exhibit at Bradley Edwards Esq provided notice Plat he intended to take_ the deposition of Donald Trump Edwards possessed a legitimate basis for doing so a The message pads confiscated from Epsteins home indicated that Trump called Epsteins West Palm Beach mansion on several occasions during the time period most relevant to my Edwardss clients complaints Ti-ump was quot in a Vanity Fair article about Epstein as saying Ive known Jeff for fift en years Terrific guy/_ Hes a lot of fun to be with It is even said that he likes beautiful women as much as I do and many of them are on the younger side No doubt about it Jeffrey enjoys his social life Jeffrey Epstein International Moneyman of Mystery Hes pals with a passel of Nobel Prize-winning scientists CEOs like Leslie Wexner of the Limited socialite Ghislaine Maxwell even Donald Trump But it wasnt until he flew Bill Clinton Kevin Spacey and Chris Tucker to Africa on his private Boeing that the world began to wonder who is By Landon Thomas See article attached hereto as Exhibit NN Trump allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually assaulted an underage girl at the club Jane Doe No complaint alleged that Jane Doe was initially approached at Trumps Maralago by Ghislaine Maxwell and recruited to be well and Epsteins underage sex slave Mark Epstein Jeffrrey Epsteins brother testified that Trump flew on Jeffrey Epsteins plane with him the same pl.ane that Jane Doe alleged was used to have sex with underage girls Trump.had been to Epsteins home in Pal:i;n Beach Epsteins phone directory from his computer contains phone numbers for Donald Trump including emergency numbers car mbers and numbers to Trumps security guard and houseman Based on this information Edwards reasonably believed that Trump might have relevant infonnation to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition See deposition of Mark Epstein September at Deposition Attachment See Jane Doe Epstein Exhibit Exhibit Exhibit"J and See Edwards Affidavit Exhibit at iB Edwards provided notice that he intended to depose Alan Dershowitz Edwards possessed a legitimate basis for doing so a DershO titz is believed to have been friends with Epstein for many years in one news article Dershowitz comments that Im on my 20th book The only person outside ofmy immediate family that I send drafts to is Jeffrey The Talented Mr Epstein By Vicky Ward on January in Published Work Vanity Fair See article attached as Exhibit Epsteins housekeeper Alfredo Rodriguez testified that Dershowitz stayed at Epsteins house during the years when Epstein was assaulting minor females on a daily basis Rodriguez testified that Dershowitz was at Epsteins hc;mse at times when underage females where there being molest by Epstein see Alfredo Rodriguez deposi.tion at Dershowitz reportedly assisted in attempting to persuade the Palin Beach State Attorneys Office that because the underage females alleged to have been victims of Epsteins abuse lacked credibility and could not be believed that they were at Epsteins house when Dershowitz himself was an eyewitness to their presence at the house Jane Doe No stated generally that Epstein forced her to be sexually exploited by not ortly Epstein but also Epsteins adult male peers including royalty politicians academicians bu;inessmen and/or other professional and personal acquaintances categories that Dershowitz and acquaintances of Dershowitz fall into during the years Alan Dershow tz was on Epsteins plane_ on several occasions according to the flight logs produced Epsteins pilot and information described above suggested that sexual assaults may have taken place on the plane Epstein onated Million one year to the university at which Dershowitz_ teaches Based on this information Edwards had a reasonable basis to believe that Dershowitz might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition See Dershowitz letters to the State Attorneys office attached as Exhibit PP Deposition of Alfredo Rodriguez at Flight Logs Exhibit MM Exhibits a,nd and Edwards Affidavit Exhibit at Epsteins complaint alleges that Edwards provided notice that he wished to take the:deposition ofToinmy Mattola That assertion is untrue Mr Mattolas deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley See Edwards Affidavit Exhibit Edwards gave notice that he intended to take _David Copperfields deposition Edwards possessed a legitimate basis for doing so Epsteins housekeeper and one of the only witnesses who did not appear for deposition with an Epstein bought attorney Alfredo Rodriguez testified that David Copperfield was a guest at Epsteins house on several_ occasions His name also appears frequently in the message pads confiscated from Epsteins house It has been pu licly reported that Copperfield himself has had allegations of sexual misconduct made against hirri by women claiming he sexually abused them and one of Epsteins sexual assault victims also alleged that Copperfield had touched her in an improper sexual way while she was at Epsteins house Mr Copperfield likely has relevant information and deposition was reasonably calculated to lead to the discovery of admissi?le evidence See Edwards Affidavit Exhibit at Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness Richardson was properly identified as a possible witness because Epsteins personal pilot testified to Richardson joining Epstein at Epsteins New Mexico Ranch There was information indicating that Epstein had young girls at his ranch which given the circumstances of the case raised the reasonable inference he was sexually abusing these girls as he had abused girls in West Pa:lm Beach and elsewhere Richard.son had also returned campaign donations that were given to him by Epstein indicating that he believed that ther was something about Epstein with which he did not want to be associated Richardson was not called to testify nor was he ever subpoenaed to testify See Edwards Affidavit Exhibit at,rl8 Edwards learned of allegations that Epstein engaged in sexual abuse of 267inors on his private aircraft See Jane f:?oe Complaint Exhibit Accordingly Edwards pursued discovery to confirm these allegations Discovery of the pilot and flight 267logs was proper in the cases brought by Edwards against Epstein Jane Doe filed a federal RICO claim against Epstein that was an active claim thr ugh much of the litigation The RICO claim alleged that Epstein ran an expansive criminal enterprise that involved_ and depended upon his plane travel Although Judge Marra dismissed the RICO claim at some point in the federal litigation the legal team representing Edyvards clients intended to pursue an appeal of that dismissal Moreover all of the subjects mentioned in the RICO claim remained relevant to other aspects of Jane Does claims against Epstein including in particular her claim for punitive damages See Edwards Affidavit Exhibit at rI Discovery of the pilot and flight logs was also proper in the cases brought by Edwards against Epstein because of the need to obtain evidence of a federal nexus Edwardss client Jane Do_e was proceeding to trial on a_federal claim under U.S.C Section is a federal statute which unlike relevant state statutes established a minimum level of recovery forvictims of the violation of its provisions Proceeding under the statute however required a federal nexus to the sexual assaults Jane Doe had two grounds on which to argue that such a nexus existed to her abuse by Epstein first his use of telephone to arrange for girls to be abused anci second his travel on planes in interstate commerce During the course of the litigation Edwards anticipated that Epstein would ar that Jane 267Does proof of the federal nexus was inadequate These fears were realized when Epstein fi ed a s1:1mmary judgment motiori raising this argument In response the other attorneys and Edwards representing Jane Doe used the flight log evidence to respond to_ Epstein;s summary judgment motion explaining that the flight logs-demoristrated that Epstein had traveled_ in interstate commerce for the purpose of facilitating his sexualas 267satilts Because Epstein chose to settle the case before trial Judge Maria did IJ.Ot rule on the summary judgment motion Edwards had further reason to believe and did iri fact believe that the pilot and flight iogs might contain relevant evidence for the cases against Epstein Jane Doe No Jnplaint outlined Epsteins daily sexual exploitatiOIJ and abuse of underage;minors as young as Years old and alleged that Epsteins plane was lSed to transport underage females to be sexually abused him and his friends The flight logs ac_cordingly were a potential source of information about either additional girls who were victims of Epsteins abuse or friends_ of Epstein who may have witnessed or even_ participat_ed in the abuse Based on this information Edwards reasonably pt1rsued the flight logs in discovery I In the fall of Epstein gave a recorded interview to George Rush a reporter with the New York Daily News about pending legal proceedings In that interview Epstein oemonstrated an utter lack of remorse for his crimes but indirectly admitted his crimes by stating:_ People do not like it when people make good_ and that was one reason he Epstein was being targeted by civil suits filed by young girls in Florida He Epstein had done nothing wrong He Epstein had gone to jail in Florida _for soliciting prostitution for no reason If the same thing i.e sexual abuse of minor girls had happened in New York he Epstein would have received only a fine Bradley Edwards was the one causing all of Epsteins problems i.e the civil suits brought hy Jane Doe and other girls L.M came to him as a prostitute and a drug user i.e came to Epstein for sex rather than Epsteinpursuing her All the girls suing him 267are only trying tc get a meal ticket The only thing he might have done wrong was to maybe cross the line a little too closely He Epstein was very upset that Edwards had subpoenaed Ghisline Maxwell that she was a good person that did nothing wrong i.e had done n,othing wrong even though she helped procure young girls to satisfy Epsteins sexual desires With regard to Jane Doe Epstein which involved an allegation that Epstein had repeatedly sexually abused a 15-year-old girl forced her to have sex with his friends and flew her on his private plane nationally and internationally for the purposes of sexually molesting and abusing her he Epstein flippantly said that the case was dismissed indicating that the allegations were ridiculous and untrue See Affidavit of Michael Fisten attached hereto as Exhibit QQ The Rush interview also demonstrated perjury a federal crime on the part of Epstein Epstein lied about not knowing George Ruc;h See Epstein Deposition February taken in L.M Jeffrey Epstein case page line through line Deposition 267attachment wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News This impression was given despite the fact that he gave a lengthy personal interview about details of the case that was tape recorded with George Rush I Epstein Harassment of Witnesses Against_Him At all relevant times Edwards has a gvod faith basis to believe and did in fact believe that Epstein engaged in threatening witnesses See Incident Report Exhibit A at U.S Attorneys Correspondence Exhibit Indictments drafted by Federal Government against Epstein and Edwards Affidavit Exhibit at Jl Despite three no contact orders entered against Epstein see Exhibit supra Edwards learned that Epstein continued to harass his victims For example Jane Doe had a trial set for her civil case against him on July As that trial date approached defendant Epstein intimidated her in violation of the judicial no-contact orders On.July I he had a private investigator tail Jane Doe following her every move stopping when she stopped driving when she drove refusing to pass when she ullP.d over When Jane Doe ultimately drove to her _home the private investigator then parked in his car approximately feet from Jane Doe house and flashed his high beam lights intermittently into the home Even more threateningly at about p.m when Jane Doe fled her home in the company of a retired police officer employed by Jane Does counsel the private investigator attempted to follow Jane Doe despite a request riot to do so The retired officer successfully took evasive action and placed Jane Doe in a secure undisclosed location that night Other harassing actions against Jane Doe also followed See Motion for Contempt filed by Edwards in Jane Doe Epstein detailing the event including Fisten Affidavit attached to Motion Composite Exhibit RR Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children The civil cases Edwards filed against Epstein on behalf of L.M E.W and Jane Doe were reasonably perceived by Edwards to be very strong cases Because Epstein had sexually assaulted these girls he had_ committed several serious torts against them and would be liable to them for appropriate damages See Preceding Undisputed Facts Because of the outrageousness of Epsteins sexual abuse of minor girls Edwards reasonably expected that Epstein.would also be liable for punitive damages to the girls Because Edwards could show that Epstein had molested children for years and designed a complex premeditated scheme to procure different minors everyday to satisfy his addiction to sex with minors the punitive damages would have to be sufficient to deter him from this illegal conduct that he had engaged in daily for ye rs Epstein was and_ is a billionaire See Complaint referring to Palm Beach Billionaire see also Epstein Deposition February at Deposition Attachment taking the Fifth when asked whether he is a billionaire Accordingly Edwards reasonably believed the punitive 267damages that would have to.be awarded against Epstein would have been substantial enough to punish him sev rely enough for his past conduct as well as deter him from repeating.his offenses in the future See Edwards Affidavit Exhibit at On July rather than face trial for the civil suits that had been filed against hini by L.M E.W and Jane Doe defendant Epstein settled the cases against him The terms of the:settlement are confidential the settlement amount are highly probative in the instant action as E:pstein bases his claims that Edwards was involved in the Ponzi scheme on Epsteins inability to ettle the L.M KW and Jane Doe cases for minimal value His continued inability to settle the claims for minimal value after the Ponzi scheme was uncovered would highly probative in discre.diting any causal relationship between the Ponzi scheme and Edwardss settlement negotiations ee Edwards Affidavit Exhibit at Edwards Non-Involvement in Fraud by Scott Rothstein From in or about through in or about Nove ber Scott Rothstein appears to have run a giant Ponzi scheme at his law firm of Rothstein Rosenfeldt and Adler P.A RR.A This Ponzi scheme involved Rothstein falsely informing investors that settlement agreements had been reached with putative defendants based upon claiins of sexual harassment and/or whistle-blower actions Rothstein falsely informed the investors that the potential settlement agreements were available for purchase Plea Agreement at United States Scott Rothstein No S.D Fla Jan attached hereto as Exhibit SS It has been alleged that among other cases that Rothstein _used to lure investors into his Ponzi scheme were thi cases against Epstein that were being bandied by Bradley Edwards Esq Edwards had no knowledge of the fraud or any such use of the Epstein cases See Edwards Affidavit Exhibit at Bradley Edwards Esq joined RRA in about April and left RRA in November a period of less than one year Edwards would not have joined RRA had he been aware that Scott Rothstein was running a giant Ponzi scheme at the firm Edwards left RRA shortly after learning ofRothsteins fraudulent scheme Id at is At no time prior to the public disclosure ofRothsteins Ponzi 267scheme did Edwards lmciw or have reason to believe that Rothstein was using legitimate claims that Edwards was prosecuting against Epstein for any fraudulent or otherwise illegitimate purpose ef at Edwards never substantively discussed the merits of any of his three cases against Epstein with Rothstein See Deposition of Bradley Edwards taken March at hereinafter Edwards Depo Deposition Attachment On July Bradley Edwards received a letter from the U.S Attorneys Office for the Southern District of Florida the office responsible for prosecuting Rothsteins Ponzi scheme The letter indicated that law enforcement agencies had determined that Edwards was a victim or potential victim of Scott Rothsteins federal crimes The letter informed Edwards of his rights as a victim of Rothstein fraud and promised to keep Edwards informed about subsequent developments in Rothstein prosecution See Letter attached hereto as Exhibit TT Jeffrey Epstein filed a complaint with the Florida Bar against Bradley Edwards Esq raising allegations that Edwards and others were involved in the wrongdoing of Scott Rothstein After investigating the claim the Florida Bar dismissed this complaint See Edwards Affidavit Exhibit at Epstein Takes the Fifth When Asked Substantive Questions About His Clai,n Against Edwards On March defendant Epstein was deposed about his awsuit against Edwards Rather than answer substantive questions about his lawsuit Epstein repeatedly invoked his Fifth Amendment privilege See Epstein Depo taken Deposition Attachment In h1s deposition Epstein t_ook the Fifth rather than answer the question Specifically what are the allegations against you wh_ich contend Mr Edwards ginned up Id at In his deposition Epstein took the Fifth rather than name people in California that Edwards had tried to dep se to increase the settlement value of the civil suit he was handling Id at In his deposition Epstein took the Fifth.rather than answer the question Do you know former President-Clinton personally Id In his deposition Epstein took the Fifth rather than answer.the question Are you now telling us that there were claims against you 267that were fabricated by Mr Edwards Id at In his deposition Epstein took the Fifth rather than answer the que ion ll which of Mr Edwards cases do you contend were fabricated Id In his deposition Epstein took the Fifth rather than answer the questio What is the:actual value that you contend the claim of E.W against you has Id at In his deposition Epstein tookthe Fifth ratherthan answer question about the actual value of the claimofL.M and Jane Doe againsthim Id In his deposition taken prior to the settlement ofEdwards;s cli nts claims against Epstein Epstein took the Fifth rather than answer the _question Is there._any pending claim ag inst you which you contend is fabricated Id at In his depos tion Epstein took the Fifth rather th answer the question Did you ever have damaging evidence in-your garbage Id at IP3 In his deposition Epstein took the Fifth rather than answer the question Did sexual assaults ever take place on a private-airplane on which you were a passenger Id at In 267his deposition Epstein took.the Fifth rather than answer the question Does a flight log kept for a private jet used by you contain the names of cel brities dignitaries or international figures Id at In his deposition Epstein took the fifth rather than answer the question Have you ever socialized-with DonaldTrump in the presence of females under the age of Id at In his deposition Epstein took the Fifth rather than answer the question Have you ever socialized with Alan Dei-showitz in the presence of females under the age of Id at In his deposition Epstein took the Fifth rather than answer the question Have you ever socialized with Mr Mottola in the presence females under the age of Id at In his deposition Epstein took the Fifth rather than answer the question Did you ever socialize with David Copperfield in the presence of females under the age of Id at In his deposition Epstein took the Fifth rather than answer the question Have you ever socialized with Mr Richardson Governor _of New Mexico and formerly U.S Representative and Ambassador to the United Nations iri the presence of females under the age of Id at In his deposition Epstein took-the Fifth rather than answer the question Have you ever sexually abused children Id at In his deposition Epstein took the Fifth rather than answer the question Did you have staff members that assisted you in scheduling appointments with underage females that is females under the age of Id at In his deposition Epstein took the Fifth rather than answer the question On how many occasions did.you solicit prostitution Id at In his deposition Epstein took the Fifth rather than answer the question How many minors have you procured for prostitution Id at In his deposition Epstein took the Fiftb rather than answer the question Have you ever coerced induced or enticed_ any minor to engage in any sexual act wit you Id at In his deposition Epstein took the Fifth rather than answer the question How many times have you engage in fondling underage females Id at In his deposition Epstein took the Fifth rather than answer the question How many times have you engaged in oral sex with females under the age of Id at In his deposition Epstein took the Fifth rath_er than answ:er the questio11 Do you have a personal sexual preference for children Id at In his deposition Epstein took the Fifth rather than_ answer the question Your Complaint at page paragraph says that RRA and the litigation team took an emotionally driven set of facts involving alleged innocent unsuspecting underage females and a Palm Beach billionaire and sought to tum it into a goldmine 267end of quote Who is the PalJ;II Beach bilHonaire referred to in that sentence Id In his deposition Epstein took the Fifth rather than answer the question Who are the people who are authorized to make payment to your lawyers on your behalf Id at In his deposition Epstein took the Fifth rather than answer _the question Is there anything in L.M.s Complaint that was filed _against you in September of which you contend to be false Id at CERTIFICATE OF SERVICE I HEREBY CERTIFY that on NovClber OJ copy ofthe foregoing bas been Served via Fax and U.S Mail to all those on the attached service list By JackScaq la Searcy Denney Scarola Barnhart Shipley Palm BeachLakes Blvd West PalmBeach FL fax Christopher Knight Esq Joseph Ackerman Esq FOWLER WHITE
