Epstein Secrets

tervenor Date Filed: 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant represented by Bradley James Edwards Farmer Jaffe Wcissing Edwards Fistos &Lehrman PL 425 N Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 954-524-2820 Fax: 954-524-2822 Email:

toj2 Response in Opposition to Motion to Unseal Non—Prosecution Agreement filed by Jane Doe. (Attachments: fll. Exhibit October 9, 2008 letter from Brad Edwards, Esquire to AUSA Dexter Lee, #.2 Exhibit October 15, 2008 Letter from Brad Edwards, Esquire to AUSA Dexter Lee)(Edwards, Bradley) (Entered: 10/16/2

otion to Unseal Document. Signed by Judge- on 2/12/2009. (ir) (Entered: 02/12/2009) 04/09/2009 E NOTICE by Jane Doe of Change of Finn Affiliation (Edwards, Bradley) (Entered: 04/09/2009) 09/08/2010 a Administrative Order Closing Case. Signed by Judge on 9/8/2010. (tb) (Entered: 09/09/2010) 09/13/

m the prosecutor goes hand-in-hand with the lawyer's additional duty to "make suitable inquiry" to determine whether valid defenses exist. Jones v. Cunningham, 313 F.2d 347 (4th Cir. I 963) ("Of course, it is not for a lawyer to fabricate defenses, but he does have an affirmative obligation to make suitabl

litigation involving two other victims (Dkt 290.1, Dkt 311 at 12), and she was making herself publicly available by giving interviews to the and to Edwards and Scarola in 2011. She was an adult in 2008 (25) and 2011 (28). She has a responsibility to join the lawsuit prior to the completion of JE sentenc

ane Doe No. 4 as petitioners. A proposed first amended petition is attached to this pleading. DATED: February 6. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE. WEISSING, P.L. DWARDS. FIST0S & LEHRMAN, and Paul G. Cassell Pro Hoc Vice S.J. Quinney College of Law at the

what I am saying. I hope that these people will come forward and tell the truth. I hope that they will call my attorney in Fort Lauderdale, Florida L Brad Edwards — so that all &the information can be presented to the court about what has happened to me and others. 9 EFTA00188671 Case 9:08-cv-80736-KAM Doc

, or to imply any duty or obligation to any victim or other person for the breach of which the United States ... could be held liable in damages."); Cunningham. U.S Dept of Justice, 961 F. Supp. 2d. 226 (D.D.C. 2013) ("[The] CVRA expressly disallows a suit for damages against the federal government or its

Page 9 of 20 sexual offenses against children, and the Court should therefore look to the specific statute of limitations covering such crimes. See Edwards. Shalala, 64 F.3d 601, 605 (I I th Cir. 1995) ("[I]t appears contrary to the Supreme Court's directives . . . to apply a statute [of limitations] of

A00210686 Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 19 of 20 DATED: February 6.2015 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 the victims This d

or to imply any duty or obligation to any victim or other person for the breach of which the United States . . . could be held liable in damages."); Cunningham'. U.S. Dept. of Justice, 961 F. Supp. 2d. 226 (D.D.C. 2013) ("[The] CVRA expressly disallows a suit for damages against the federal government or i

me highflying societies in Manhattan and Palm Beach - socialized together in the past." Another report from The Daily Caller (7/8, News, 716K) says Bradley Edwards, a lawyer who represented Epstein's victims, "stated in court documents that Trump had barred Epstein" from Mar-A-Lago "because Epstein sexually as

The Daily Caller (7/8, News, 716K) says Bradley Edwards, a lawyer who represented Epstein's victims, "st

g away international inspectors or installing more centrifuges would also be triggers for sanctions, diplomats said." Another Washington Post (7/8, Cunningham, 14.2M) story indicates, however, that the uranium enrichment announcement "was designed to pressure Europe to reset the terms of the nuclear agree

mansion in New York City and on his private Caribbean island, Little Saint James. The suit was settled in 2018 under undisclosed terms.!-1§W9K141 Bradley Edwards' defamation v. Epstein (2018) A state civil lawsuit in Florida filed by attorney Bradley Edwards against Epstein was scheduled for trial in December

st opportunity to make their accusations in public. However, the case was settled on the first day of the trial, with Epstein publicly apolo • to Edwards; other terms of the settlement were confidential-14.171W- Epstein was accused of sex trafficking of minors at his mansion at.? Pat Tie streiA- V.

ern District cAPOL:lyestem ()Istria- SAPOI :Yorke Mid North ISA( Allison. Scott (SAPOL-TS&T); 8aulderstone, Christine (SAPOL). Bruhn John (SAINT ); Cunningham, Colin (SAPOLI; Ploov. Russell (SAPOL), pL:SAPOI. RES; s a a I rodeo a ujleal; A-beards. John (SAPDI ); fisher. Michael (SAPOLI; Gray- Robert Hil

TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006665 EFTA00158250 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff, III 3 BRADLEY J. EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS 4 FISTOS & LEHRMAN, P.L. 7 8 9 10 11 13 14 15 On behalf of the Defendant, Jeffrey Epstein and t

EFTA_00006665 EFTA00158250 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff, III 3 BRADLEY J. EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS 4 FISTOS & LEHRMAN, P.L. 7 8 9 10 11 13 14 15 On behalf of the Defendant, Jeffrey Epstein and the Witness: 16 17 JACK ALAN GOLDBERGER,

ein? 15 A. Directly across the street. 16 Q. Do you know what that person's name is who 17 owns that house? 18 A. Cunningham, last name is Cunningham, I think. 19 Q. Okay. And have you ever met that person 20 before? 21 A. No. 22 Q. Do you know of any occasion when that 23 person, Mr.

N AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Pla

“absence of records” response does not mean that records do not exist. It simply means that in the course of the search, no records were found. See Cunningham v. U.S. Dept. of Justice, 961 F.Supp. 2d 226, 236 (D.C. 2013) (court reasoning that “t]he adequacy of a search is measured by a standard of reasonab