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AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Bradley J. Edwards, through counsel, hereby files this Reply to Jeffrey Epstein's Response in Opposition to Farmer Jaffe's Motion to Show Cause Why Fowler White and Je
ODUCTION Jeffrey Epstein's Motion, through one misstatement after another, amounts to nothing more than his continued baseless disparagement of Mr. Edwards, and a poor attempt to deflect from his wrongdoing and avoid the pertinent issues. [DE 6351]. In 2010, a subpoena was issued to the RRA trustee tha
, 325 F.2d 403, 407-08 (2d Cir.1963); Smith v. Annour Phannaceutical Co., 838 F.Supp. 1573, 1578 (S.D.Fla.1993); Schlazfer Nance & Co. v. Estate of Warhol, 742 F.Supp. 165, 166 (S.D.N.Y.1990)). Likewise, the Court has the "inherent authority to sanction a party who attempts to use in litigation materia
mitted, STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTEIN & To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Brad Edwards Attorney for Plaintiff Jane Doe 43 ALSTON & BIRD, LLP Alexander S Lorenzo John E. Stephenson, Jr. (Applic
By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTEIN & To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Brad Edwards Attorney for Plaintiff Jane Doe 43 ALSTON & BIRD, LLP Alexander S Lorenzo John E. Stephenson, Jr. (Application for admission pro hac vice pend
.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's represent
mim Michael C. Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: Steptoe stenos • JOHNSON 1.0 In accordance with the Court's May 15,
mim Michael C. Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Act
3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's representa
Michael C. Miller 1114 Avenue of the Americas New York. NY 10036 main www.steploe.com May 2017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Je
Michael C. Miller 1114 Avenue of the Americas New York. NY 10036 main www.steploe.com May 2017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffery Epstein, et al. Civil Action No.
3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's representa
CORBETT. EDWARD Untitled' 4.500 4.500 0 0 0 Narrows CORBETT. EDWARD Washington. DC April 1965 #14' 8.000 8.000 0 0 0 Narrows CORBETT. EDWARD Washington, DC 1970' 8.000 8.000 0 0 0 AP Narrows CORREGGIO Study of an Apostle 657.878 657.878 0 0 0 AP Narrows COSSIERS. JAN The head
0 8,500.000 6.250,000 6,250.000 0 AP Narrows WARHOL. ANDY Nine Multicolored Marilyns (Reversal Serie
as friends. Or they are the kind who, like John Edwards, seem to be one thing but then turn out to have a
y ardent about Israel, but he has come around. The main house on Saban's property is less of an art museum than Jon Shirley's, though it features a Warhol diptych of Golda Meir and Albert Einstein over the fireplace. The fund-raiser was held in back of the main house, under a tent. Addressing a hundre
g agents. Wilkinson advised that Epstein was a NYAA board member in the 1980's into the early 1990's. Epstein was a social acquaintance with artist Andy Warhol. Epstein allowed the board to have meetings at his apartment as well as his office space located in the Villard House, corner of Madison Avenue and
Page: EFTA02857863_p240 →stein was a social acquaintance with artist Andy Warhol. Epstein allowed the board to have meetings at h
Page: EFTA02857863_p240 →FICIAL RECORD FD-1036 (Rcv. 10-16-2009) UNCLASSIFIED FEDERAL BUREAU OF INVESTIGATION Import Form Form Type: OTHER Title:(U) Items received from Brad Edwards Approved By: SSA Drafted By: Case ID #: 31E-MM-108062 (U) EPSTEIN, JEFFREY Date: 07/05/2013 Synopsis: (U) To document items received by SA Ori
Page: EFTA02857863_p401 →ted to meet with FBI Agents in Sydney, Australia, along with the Australian police for the debriefing. On March 9, 2011, AUSA Civil Attorneys Edwards and Jaffe, Private Investigator Mike Fisten (protect identity) and writer met for the interview at the United States Attorney's Office in Fort Laud
Page: EFTA02857863_p403 →Entities connected to both Bradley Edwards and Andy Warhol

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Bill Clinton
PERSON