Epstein Secrets

IBIT 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 IN THE CIRCUI

ndants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undis

and punish Epstein for his crimes against them in whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane Doe, Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of Jane Doe. See Edwards Affidavit, "N" at ¶7. Included in thi

ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorn

ess. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable infer

ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent..; on July 2, 2008, attorney

1/2015 Page 2 of 9 P ORAS Tam C leis Action Pe winal Injury Wconglul Otell Comer cal Lotqatton WWW.PATHTOJUSTICE COM Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. August 20, 2014 Wifredo A. Ferrer United States Attorney Southern District of Florida RE: Jane Does I and 21 United St

ns. Thank you for your anticipated cooperation. Bradley J. Edwards, Esq. (850) 224-7000 141004142-7011 WWW.S ARCYLAW CO

our letters and Is considering the matter, as well as your request for a meeting. I will try to get an answer for you as soon as possible. • From: Brad Edwards - Sent: Wednesday, December 03, 2014 2:12 PM To: Redacted (OWLS); Redacted (USAFLS) Cc: Paul Cassell Subject: Doe 'US When we spoke a few months a

ess. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable infer

ndants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undis

this subject at his deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to him. "[I]t is well-settle

ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent..; on July 2, 2008, attorney

ess. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable infer

hat the case against him was abandoned due to lack of factual support. It is a mistake for anyone to conclude based upon Dershowitz’s statements that Bradley Edwards and Paul Cassell had determined that the allegations against Alan Dershowitz made by Virginia Roberts Giuffre were false or unfounded. Neither the te

plaintiff's counsel in the CVRA actions, Brad Edwards and Paul Cassell. Dershowitz, in nationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Dershowitz’s involvement with Epstei

r 4th, 2018 OR ee ee et ee ee et Just hours after convicted pedophile Jeffrey Epstein agreed to settle a civil case brought against him by attorney Bradley Edwards, Epstein’s lawyer from his past criminal case, Alan Dershowitz, discussed his former client on the Law&Crime Network. Epstein was accused of traffick

. These records prove incontrovertibly that I could not have been, and was not, where Roberts’ falsely claimed to have met me — a Caribbean Island, a New Mexico Ranch, a private jet, a Palm Beach mansion — during the relevant time period. I also called for an independent investigation by the former Director of th

s' counsel — Bradley J. Edwards — to discuss ways to reduce any such burden. DATED: April 11, 2015 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards Ile and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe 1, 2, 3 and 4 • This daytime business address is provided for identification and corresp

ome, please contact victims' counsel — Bradley J. Edwards — to discuss ways to reduce any such burden. DA

frey Epstein or his co-conspirators, including surveillance videos, photographs, or similar images taken in Epstein's Florida and New York mansions, New Mexico Ranch, or on Epstein's island in the U.S. Virgin Islands. Please also provide the same for Jane Doe 1, 2, and 4. If any of the videos, photographs or ima

ING ANY UNDUE BURDEN If you believe that complying with any of the foregoing requests would be unduly burdensome, please contact victims' counsel — Bradley J. Edwards — to discuss ways to reduce any such burden. DATED: April 11, 2015 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAF

ays to reduce any such burden. DATED: April 11, 2015 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe 1, 2, 3 and 4 • This daytime business address is provided for id

frey Epstein or his co-conspirators, including surveillance videos, photographs, or similar images taken in Epstein's Florida and New York mansions, New Mexico Ranch, or on Epstein's island in the U.S. Virgin Islands. Please also provide the same for Jane Doe 1, 2, and 4. If any of the videos, photographs or ima

to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F’ — Deposition of Bradley Edwards dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” — Order of HOUSE_OVERSIGHT_013305 --- PAGE BREAK

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, tomes

ed hereto as Exhibit “LL.” Edwards Pursues Other Lines of Discover 69. Because of Epstein’s thwarting of discovery and attacks on Edwards’s clients, Bdwards was forced to pursue other avenues of discovery. Edwards only pursued legitimate discovery designed to further the cases filed against Epstein. See E