Epstein Secrets

6th day of August, 2013. /s/ Bradley J. Edw rds BRADLEY J. EDWARDS, ESQ. Attachments: 1. October 3, 2011, request for pr

nt to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this 16th day of August, 2013. /s/ Bradley J. Edw rds BRADLEY J. EDWARDS, ESQ. Attachments: 1. October 3, 2011, request for production; 2. June 24, 2013, supplemental request for production; and 3.

fication obligations, the USAO altered the language that was ultimately contained in the July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards. Except as otherwise admitted above, the government denies Request No. 2(d). (e) At least in part as a result of the negotiations, Jane Doe #1 and

ys to reduce any such burden. DATED: October 3. 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 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

rt S Mermelstein LEAD ATTORNEY;ATTORNEY TO BE NOTICED Mermelstein & Horowitz PA 18205 Biscayne Boulevard Suite 2218 Miami , FL 33160 USA Fax: !Bradley James Friwards LEAD ATTORNEY;ATTORNEY TO BE NOTICED Farmer Jaffe Weissing Edwards Fistos & Lehrman PL 425 N Andrews Avenue Suite 2 Fort Lauderdale , FL 33301 U

sol Plaintiff Jane Doe Consol Plaintiff C.M.A. Consol Plaintiff Adam D. Horowitz LEAD ATTORNEY;ATTORNEY TO BE NOTICED Farmer. Jaffe. Weissina, Edwards, Fistos. Lehrman. P.L. 425 North Andrews Avenue Suite 2 Fort Lauderdale , FL 33301 A Fax: Jeffrey Marc Herman LEAD ATTORNEY;ATTORNEY TO BE NOTI

uart) (Entered: 05/05/2010) 538 Minute Entry for proceedings held before Judge Kenneth A. Marra: Status Conference held on 5/6/2010. Adam Horowitz, Bradley Edwards, Katherine Ezell f r PI in iff nd Michael Pike, Robert Critton for Defendant. Court Reporter: Stephen Franklin, [email protected]

Exhibit A)(Horowitz, Adam) (Entered: 12/21/2009) 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachm

Defendant Class Code: CLOSED Closed: Yes Statute: 28:1331 Jury Demand: Plaintiff Demand Amount: $0 NOS Description: Personal Injury Attorneys Bradley James Edwards [COR LD NTC] Farmer Jaffe Weissing Edwards Fistos 8. Lehrman PL 425 N Andrews Avenue Suite 2 Fort Lauderdale , FL 33301 USA 954-524-2820 Fax:

m P. Dimitrouleas on 9/21/2010. (lk) (Entered: 09/21/2010) STRICKEN CERTIFICATE OF SERVICE by M. J. Proof of Service Summons on Defendant, Epstein (Edwards. Bradley) Modified on 11/3/2010 (Is). (Stricken per DE #10) (Entered: 10/29/2010) STRICKEN CERTIFICATE OF SERVICE by M. J. Proof of Service of Subp

d: 05/05/2010) 05/06/2010 538 Minute Entry for proceedings held before Judge Kenneth A. Marra: Status Conference held on 5/6/2010. Adam Horowitz, Bradley Edwards. Katherine Ezell for Plaintiff and Michael Pike, Robert Critton for Defendant. Court Reporter: Stephen Franklin. 561-514-3768 / Stephen_Franklin@fls

orowitz, Adam) (Entered: 12/21/2009) 12/29/2009 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachme

in & Horowitz, P.A. 18205 Biscayne Boulevard 3 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos &

3 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 424 N. Andrews Avenue, Su

ompel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe No. 4, and states: I. On Dec

8-80232, 08-80380, 08-80381, 08-80993, 08-80994 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos

l Women's Center to Comply with Subpoena Duces Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and state: I. On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's Center to Comply with Subpoena Duce

AL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM (DE 431) AND DEFENDANT EPSTEIN'S MOTION TO COMPEL PRESIDENTIAL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM AS TO JANE FOE NO.4 (DE 443) Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Notice

m Beach County, Florida, Case No. 50-2009 CA 040800XXXX MB AG. The action is entitled Jeffrey Epstein, Plaintiff vs. Scott Rothstein, individually, Bradley J. Edwards, individually, and L.M., individually. 5. On or about April 17, 2010, counsel for EPSTEIN in the state court had served a Subpoena Duces Tecum for

ff vs. Scott Rothstein, individually, Bradley J. Edwards, individually, and L.M., individually. 5. On or

ally, Bradley J. Edwards, individually, and L.M., individually. 5. On or about April 17, 2010, counsel for EPSTEIN in the state court had served a Subpoena Duces Tecum for Deposition - Documents Only, on STETTIN in his capacity as Trustee, in an attempt to obtain documents relevant to issues in the state court case

ntained, inter alia, in the attached affidavit of Bradley J. Edwards, Esq. The victims have also concurrently filed itemize

ocket 08/16/2013 Page 9 of 10 DATED: August 16, 2013 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 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

DDITIONAL PERSONAL INFORMATION SSN DOB Gender LexID(sm) 090-44-XXXX 111953 Male 000752546965 (Age 64) Subject Summary Name Variations 1: EDWARDS. JEFFERY 2: EPSTEIN, J 3: EPSTEIN, JEFFERY 4: EPSTEIN, JEFFERY E 5: EPSTEIN, JEFFREY 6: EPSTEIN. JEFFREY E 7: EPSTEIN. JERRERY 8: EPSTI

nal version, responsive, chain, grand jury, crime victims, federal government, non-prosecution, investigative COUNSEL: Mi For Jane Doe, Petitioner: Bradley James Edwards, LEAD ATTORNEY, Farmer Jaffe Weissing Edwards Fistos & Lehrman PL, Fort Lauderdale, FL; Jay C. Howell, PRO HAC VICE, Jay Howell & Associates PA, Ja

documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure

Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,PL 424 N. Andrews Avenue, Suite #2 Ft. Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 9

l Women's Center to Comply with Subpoena Duces Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and state: I. On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's Center to Comply with Subpoena Duce

ue . .. ." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of remembering

the proper remedy.38 Indeed, none of the Second Circuit cases applying Martindell contemplate suppression as a remedy. See, e.g., In re Grand Jut), Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1224 (remanding for findings "on whether the protective order was improvidently granted or whether the government