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mmediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor
ed to you in the public media express a willingness, indeed a strong desire, to submit to questioning under oath regarding your alleged knowledge of Jeffrey Epstein's extensive abuse of underage females as well as your alleged personal participation in those activities. As I am sure you will recall, our efforts to
you have already selected other counsel to represent you, or if you do so in the future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack Goldberger as s th t u h at Atterbury Gonberger and Weiss, , (561) 659-8300. In addition, there has been litigation between th
here is overwhelming proof that the number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 J Epstein, (hereinafter Jane Doe 102 complaint) (Exhibit "B"); see also Deposition of Jeffrey Epstein, April 14, 2010, at 442, 443, and 444 (Epstein invoking
nt. began speaking with the agents then excused herself to go upstairs to check on her sleeping child. While upstairs, NE telephoned the defendant, Jeffrey Epii informed him that the FBI agents were at her home. Mr. Epstein instructed not to speak with the agents and IN lmanded her for allowing them into h
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
ook, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit. For clarity, depositions attached to this memorandum will be identified numerically as att
egan speaking with the agents and then excused herself to go upstairs to check on her sleeping child. While upstairs, Ms. telephoned the defendant, Jeffrey Epsteiriand informed him that the FBI agents were at her home. Mr. Epstein instructed Ms= not to speak with the agents and reprimanded her for allowing them i
ing specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse part
. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). Sexual Abuse of Children Dv Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo."
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
ies."). Sexual Abuse of Children Dv Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
unediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor
tions Edwards took, what Edwards learned in the course of his representation of his clients, goo beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that A [davit. For clarity, depositions attached to this memorandum will be identified numerically as atta
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
ook, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit. For clarity, depositions attached to this memorandum will be identified numerically as att
the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.
ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai
Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,
she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for
fully supported by the undisputed facts agreed to by the Government, not to mention numerous disputed facts proffered by the victims. See generally Edwards Affidavit of Aug. II, 2017, at In 11-25. To the extent that there is any ambiguity in the plain language, the CVRA's legislative history full confirms this p
ere ever filed, but denied to the extent that the U.S. Attorney's Office agreed to reach — and did reach — a federal non-prosecution agreement with Epstein, which "resolved globally" Epstein's "federal criminal liability" for any violations of 18 U.S.C. § 371, 2423(b), 2422(b), and 1591(a), among other
for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Email: Attorneys for Jeffrey Epstein /s/ etadief p. Sdeoalua 14 EFTA00799887
ayne Boulevard Suite 1300 Email: Attorneys for Jeffrey Epstein /s/ etadief p. Sdeoalua 14 EFTA0079988
ered on FLSD Docket 08/11/2017 Page 4 of 14 For example, Bradley J. Edwards represented Jane Doe 2 in July 2008. See Edwards Decl., DE 225-1 at 17; Edwards Affidavit of Aug. 11, 2017 at 1 11,1 16; Jane Doe 2 Decl., 361-27 at 1-2. 14. Admitted to the extent that the events described occurred on specific dates, and
Entities connected to both Jeffrey Epstein and Edwards Affidavit
Larry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJanusz Banasiak
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Jean-Luc Brunel
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON
Teterboro
LOCATION