Epstein Secrets

Epstein abused them. See Rule 413 Notice, Exhibit E; Deposition ofe., Deposition Attachment #4. 15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodr

guez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodriguez was aware that "sex toys" and vibrators were found in Epstein's bedroom after the purported massages. Id. at 223-28. Rodriguez thought what Epstein

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

stein abused them. See Rule 413 Notice, Exhibit E; Deposition of E.W., Deposition Attachment #4. 15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodr

guez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodriguez was aware that "sex toys" and vibrators were found in Epstein's bedroom after the purported massages. Id at 223-28. Rodriguez thought what Epstein w

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

Epstein abused them. See Rule 413 Notice, RYbibit E; Deposition of.., Deposition Attachment #4. 15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodr

attorneys pursuing civil sexual assault cases against Epstein as payment for producing the book to the attorneys. See Criminal Complaint at 2, U.S. I. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez stated he needed money because the journal was his "property" and that he was afrai

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

roduce admissible evidence to support the fact." Rodriguez v. City of Miami, Fla„ 907 F. Supp. 2d 1327, 1330

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