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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
73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave not
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
73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave not
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
73. Epstein's complaint alleges that Edwards provided 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 not
ugh his undersigned counsel, hereby submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein’s Motion for Summary Judgment. Epstein seeks Summary Judgment on the claims of abuse of process and malicious prosecution set forth in Brad Edwards’ Fourth Amended Counterclaim. Each of th
Page: HOUSE_OVERSIGHT_013304 →in support of his Motion for Summary Judgment, Edwards had a sound legal basis for believing that Donald Trump, Allen Dershowitz, Bill Clinton, Tommy Mattola, David Copperfield and Governor Bill Richardson had relevant and discoverable information (Exhibit “A” — Edwards’ Statement of Undisputed Facts, para
Page: HOUSE_OVERSIGHT_013309 →Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Depos
Page: HOUSE_OVERSIGHT_013319 →stein hee ‘also ‘Heei sanvedl: “with: nterrogatories ‘ad ‘requests. “for . 7 » production; all requests. have been met: with 5th amendment assertions Pane Epstein’ has not given Tan Ween oe By: ' Jane, Doe's: complaint: contains. a punitive ‘damages: clainn, and Mr Tistein: he “also. . a elected: to tiivoke th
Page: HOUSE_OVERSIGHT_013463 →ion that any of those people (other than. . Mr- Dershowitz) have spoken to Mr. Epstein about Jane Doe or.any of the other. specific victims of Mr. '- .Epstein’s molestation. Mr. Dershowitz ‘is acting as an ‘attorney for Mr. Epstein, and therefore it is. ; 4 presumably unlikely to question him about any admi
Page: HOUSE_OVERSIGHT_013465 →102 was initially approached at Trump’s Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein’s underage sex slave; (€) Mark Epstein (Jeffrey 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 g
Page: HOUSE_OVERSIGHT_013470 →owing 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 party
Page: HOUSE_OVERSIGHT_010566 →Epstein, Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
Page: HOUSE_OVERSIGHT_010566 →tz (attached hereto as Exhibit “H”), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER” On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards traveled to the home of Leslie Groff to serve her with a f
Page: HOUSE_OVERSIGHT_010575 →73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit “N” at (16. 74. Edwards gave notic
Page: HOUSE_OVERSIGHT_010596 →Entities connected to both Jeffrey Epstein and Mattola

Lesley Groff
PERSONLarry Visoski
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSONJanusz Banasiak
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Jean-Luc Brunel
PERSONMartin Weinberg
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON