Epstein Secrets

l had provided. The U.S. Attorney's Office called attorney Edwards to provide notice to his clients regarding the h

WVVW.PATHTOJUSTICECOM Oro Tam Class Attie., Personal Injury Wrongful Death Commercial Liogation Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. January 29, 2015 Wilfredo A. Ferrer United States Attorney Southern District of Florida 99 N.E. 4th Street Miami, FL 3

u personally so that they could bring their concerns to your attention. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University of Utah• BJE: mwk Enclosures This daytime business address is provided for identif

sed in the Crime Victims' Rights Act. DATED this 7th day of July, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsimil

ld apply. Since the earliest days of our nation, it has been settled law that "where there is a legal right, there is also a legal remedy . . . .." Marbury-v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). Moreover, "[i]f the right is created by a federal statute, the federal courts have

tion of Epstein's federal case, on July 3, 2008, attorney Edwards sent a letter to the U.S. Attorney's Office comm

stitutional principle of separation of powers. Attorneys and Law Firms *1198 Paul Cassell, University of Utah College of Law, SALT LAKE CITY, UT, Bradley James Edwards, EdwardsPottinger, LLC, FORT LAUDERDALE, FL, for Petitioner. Richard Christian Komando, Bradley Garrison & Komando, ORANGE PARK, FL, for Amicus C

her. The U.S. Attorney's Office continued to conceal the existence of the NPA from all the victims for months to come. In mid- June *1233 of 2008, Bradley Edwards, the Fort Lauderdale, Florida attorney for several of Epstein's victims, contacted AUSA Villafana to inform her that he represented Jane Doe I and

for several of Epstein's victims, contacted AUSA Villafana to inform her that he represented Jane Doe I and, later, Jane Doe 2. AUSA Villafana and Edwards discussed the possibility of federal charges being filed against Epstein in the future. Edwards was led to believe that federal charges could stil

opriate equitable remedy"). Furthermore, it has long been an "indisputable rule, that where there is a legal right, there is also a legal remedy." Marbury v. Madison, 5 U.S. 1 Cranch 137, 163, 2 L.Ed. 60 (1803) (quoting 3 William Blackstone, Commentaries *23). For that reason, "[w]here legal rights ha

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards v. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, 27 EFTA00178083 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

This argument contradicts fundamental American jurisprudence, which holds that "where there is a legal right, there is also a legal remedy . .." Marbury v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). 'I'he victims have deferred full briefing on the remedy issue because they understa

l had provided. The U.S. Attorney's Office called attorney Edwards to provide notice to his clients regarding the h

that, should CEOS reject Epstein's objections to the agreement, then U.S. Attorneys Correspondence at 290-91. 39. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an Epstein victim by the U.S. Attorney's Office, received a letter from the FBI advising her that "Whis case is cur

gal counsel. In May 2008, the Office sent a similar letter stating "your case is currently investigation" to another victim (represented by attorney Bradley J. Edwards). As late as the middle of June 2008 — more than eight months after the non-prosecution agreement had been signed -- the Assistant U.S. Attorney ha

ld apply. Since the earliest days of our nation, it has been settled law that "where there is a legal right, there is also a legal remedy . . . .." Marbury v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). Moreover, "[l]t' the right is created by a federal statute, the federal courts hav

that, should CEOS reject Epstein's objections to the agreement, then U.S. Attorneys Correspondence at 290-91. 39. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an Epstein victim by the U.S. Attorney's Office, received a letter from the FBI advising her that "Mk case is curre

gal counsel. In May 2008, the Office sent a similar letter stating "your case is currently investigation" to another victim (represented by attorney Bradley J. Edwards). As late as the middle of June 2008 — more than eight months after the non-prosecution agreement had been signed — the Assistant U.S. Attorney han

l had provided. The U.S. Attorney's Office called attorney Edwards to provide notice to his clients regarding the h

ould apply. Since the earliest days of our nation, it has been settled law that "where there is a legal right, there is also a legal remedy . . .." Marbury v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). Moreover, "[i]f the right is created by a federal statute, the federal courts have

is raising, the Court must "take the factual allegations in the complaint as true and construe them in the light most favorable to the plaintiffs." Edwards v. Prime, Inc., 602 F.3d 1276, 1291 (11ih Cir. 2010). In the current posture of this case, the victims have pending a motion for "summary judgment"

ity to review this case. CONCLUSION The Court should deny the Government's motion to dismiss. DATED: December 5, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Te

the CVRA. Since the earliest days of our nation, it has been settled law that "where there is a legal right, there is also a legal remedy . . . .." Marbury v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). Moreover, "[i]f the right is created by a federal statute, the federal courts have