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of 40 EXHIBIT 16 EFTA00081180 Case 9:08-cv-807m091349pept Z91-15 _EriterM ocp WERocisstifolf/E15 Page 2 of roio-< uoc 16q0,3 e 0 EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00081181 Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger phri N 7NRocieatgfe)10/§815 Page 3 of I
02 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged was used to have sex with underage
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; He's pals with a passel of Nobel Prize—winning scientists, CEOs like L
ies."). Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
mmediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor
notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at 116. 74. Edwards gave notice that he intended to take David Copperfield's deposition. Edwards p
vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here
or leave to file the supplemental argument contained herein on the following grounds: 1. The trial judge entered summary final judgment in favor of Epstein on the ground that the litigation privilege bars the malicious prosecution and abuse of process claims filed against Epstein by the appellant, Brad
unrelated to the underlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFI JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) _ - Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25t
e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle
. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUP
18th day of September, 2015, a copy of the foregoing was emailed to those on the list below. s/ Paul Morris SERVICE LIST: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. Philip M. Burlington Burlington & Rockenbach, P.A. Imo Tonja Haddad Coleman -18- EFTA00612500 W. Chester Brewer, Jr. W. Chest
BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 I ANSWER BRIEF OF APPELLEE JEFFR
as its finding that the litigation privilege was applicable specifically to Edwards's claims for malicious prosecution and abuse of process against Epstein, constituted issues of law. DelMonico, 116 So. 3d at 1211 (stating the determination of whether the litigation privilege extends to the alleged tor
BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. FOURTH DISTRICT COURT OF APP
aced. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy was electronically served to the following on February , 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.
FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA BRADLEY J. EDWARDS, CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 Appellant, v. JEFFREY EPSTEIN, Appellee. I MOTION FOR APPELLATE ATTORNEYS' FEES AND COSTS Appellee, Jeffrey Epstein, moves for an order determining his entitlement to appella
nt to Section 768.79, Florida Statutes and Florida Rule of Civil Procedure 1.442. By order of February 3, 2015, the trial court has determined that Epstein is entitled to trial court fees and costs pursuant to Florida Statute Section 768.79 and Florida Rule of Civil Procedure 1.442. The amount of these
2 L.T. Case No.: 502009CA040800 Appellant, v. JEFFREY EPSTEIN, Appellee. I MOTION FOR APPELLATE ATTO
the trial court to determine the amount of the fees and costs. I HEREBY CERTIFY that electronically to the following this William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.
adings and discovery responses, and as conceded by Edwards's counsel at oral argument, the events giving rise to Edwards's purported claims against Epstein occurred solely in the course of, and were related to, the litigation, just as occurred in the Wolfe case, mandating Summary Judgment. Wolfe v. For
ced. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy was electronically served to the following on February 25, 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. 3409 Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Av
Entities connected to both Jeffrey Epstein and Denny Scarola Barnhart

George Mitchell
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSON
Mark Epstein
PERSON
Michael Jackson
PERSONScott Rothstein
PERSONJack Scarola
PERSONTonja Haddad Coleman
PERSON
Supreme Court
ORGANIZATIONAce Greenberg
PERSONGoldberger & Weiss
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION