Epstein Secrets

IAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BR

DS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"),

es of Civil Procedure, hereby files this Motion for Summary Judgment on the sole remaining count of Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Fourth Amended Counterclaim, Malicious Prosecution. In order to prevail on this count, Edwards must prove that there was an absence of probable c

he New York Times, the Wall Street Journal, the Florida Sun- Sentinal and other media outlets reported that Scott Rothstein, the partner of plaintiff Brad Edwards, had fled to Morocco to evade criminal prosecution for using their law firm, Rothstein, Rosenfeldt, Adler ("RRA"), to perpetrate a massive Ponzi sch

never, ever, ever, no, never. Jeffrey is an awesome man, no. At the end of her interview, [LM] was asked if she had any questions for the agents or AUSA Villafana. [LM] responded: A. No, but I hope — I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a

s clients regarding the hearing. AUSA encouraged Attorney Edwards and his client to attend and address the Court at

can be a lengthy process and we request you[r] continued patience while we conduct a thorough investigation." 20. On May 30, 2008, another of Mr. Edwards's clients who was recognized as a victim of Epstein by the FBI, received a letter from the FBI advising her that "Rlhis case is currently under inv

facts and to adopt their proposed schedule. A proposed order to that effect is attached. SO AGREED AND STIPULATED TO, THIS DAY OF DECEMBER, 2010. BRADLEY J. EDWARDS PAUL G. CASSELL COUNSEL FOR VICTIMS. WIFREDO A. FERRER UNITED STATES ATTORNEY EFTA00207833 By: EFTA00207834 UNITED STATES DISTRICT COURT S

pulate that this correspondence accurately reflects communications between Epstein and the Justice Department. 8. At the time of plea discussions, AUSA Villafana had drafted an 82-page prosecution memorandum outlining federal offenses committed by Epstein (including offenses committed against Jane Doe #1 and

to the limited extent that the events described concerned April 2007. Several months later, Jane Doe 2 obtained new counsel not paid for by Epstein, Bradley J. Edwards, and circumstances changed. 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. 1

osecution — which Jane Doe 1 has specifically disputed by her affidavit. See Jane Doe 1 Decl., DE 361-26; see also Edwards Decl., DE 225-1 at 17-18; Edwards Affidavit of Aug. II, 2017 at 11 11-25; Victims S.J. Mot., DE 361 at1 71 & n.85;172 & n.86; 173 & n.87; 1 74 & n.88; 1 75 & n.89; 1 76 & n.90; 1 77

respect 12 EFTA00799885 Case 9:08-cv-80736-KAM Document 415 Entered on FLSD Docket 08/11/2017 Page 13 of 14 to what AUSA Villafana told attorney Brad Edwards. See generally Edwards Affidavit of Aug. 11, 2017, particularly at 911 11-25. Edwards Decl. (filed contemporaneously with this response). DATED: Au

To the extent that the Government is going to rely on representations about its internal motivations in making certain decisions (i.e., what things AUSA Villafana and the FBI agents "concluded" as part of making decisions), the victims respectfully request an opportunity to depose or cross-examine the relevan

ters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 11. Your Affiant's letter to T.M. was hand-deliver

e initially refused to speak with investigators. S.R.'s status as a victim of a federal offense was confirmed when she was interviewed by 'Attorney Edwards filed his Motion on behalf of "Jane Doe," without identifying which of his clients is the purported victim. Accordingly, I will address facts relate

fense was confirmed when she was interviewed by 'Attorney Edwards filed his Motion on behalf of "Jane Doe," without

in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr

ters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 1). Your Affiant's letter to T.M. was hand-deliver

uly 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC Re: Jeffrey Epstein, IDENTIFIED VICTIM Dear Mr. Edwards: NOTIFICATION OF By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the foll

fense was confirmed when she was interviewed by 'Attorney Edwards filed his Motion on behalf of "Jane Doe," without

in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr

s based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Ito inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide inf

AK --- Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 7 of 16 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafana secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lew

nment sent to the victims included this proposed stipulation: On July 9, 2008, AUSA as sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Declaration. That notification contains a written explanation of the full terms of the agreement between Eps

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad®pathtoj

n the West Palm Beach office of the U.S. Attorney's Office, and supervised portions of the criminal investigation of Jeffrey Epstein. 8. assisted AUSA Villafana during the criminal investigation of.leffrey Epstein. 9. In his revious capacity as Deputy Chief of the Criminal Division, U.S. Attorney's Office

1 Phone: (561) 582-7600 Fax: (561) 588-8819 lawyerwillits(il1aol.com reelrhw(Zil,hotmail.com Counsel for Plaintiff in Related Case No. 08-80811 Brad Edwards, Esq. Law Office of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, FL 33020 Phone: (954) 414-8033 Fax: (954) 924-1530

ael Tein, former counsel for Defendant, along with Mr. Jack Goldberger, who still represents Defendant, entered into a verbal agreement at the time AUSA Villafana provided the USAO List to them, whereby neither Defendant, Jeffrey Epstein, nor his agents would have any direct or indirect contact with the victi