Epstein Secrets

The Palm Beach Post's (the "Post") Motion to Intervene and Petition for Access to certain court records in this case. It is our understanding that Bradley Edwards and William Berger of Rothstein Rosenfeldt Adler have filed a similar motion on behalf of a non-party known as =11 and that a motion is set for he

• •••••••• ••••••••••••••• • To: R. Alexander Acosta, Esq. Fax: Judith Stevenson Arco, Esq. Michael McAuliffe, Esq, Jack Alan Goldberger, Esq. Brad ley J. Edwards, Esq. William J. Berger, Esq. From: Deanna K. Shullman, Esq. Date: 06/01/2009 Re: State v. J. Epstein Pages: 6 Urgent U For review U I Pl

el for Plaintiff in Related Case No. 80811 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

hael McAuliffe, Esq. Jack Alan Coldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. From: »minne K. Shullm

y failing to perform or to offer to per- form will suffer forfeiture. Restatement (Second)of Contracts § 241 (1981). In United States v. Fitch, the Sixth Circuit adopted a somewhat more rigorous stand- ard, holding that the government must prove a "bad faith, intentional, substantial omission" on the part o

d 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 "Otis 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

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

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehr

damus relief in the court of appeals under 18 U.S.C. § 3771(dX3). Relying upon appellate court decisions from other circuits, including Stewart, the Sixth Circuit found that § 3771(e)'s definitional requirement that a victim be "directly and proximately harmed" encompassed the traditional "but for" and proxim

Case 9:08-cv-80893-KAM Document 38 Entered on FLSD Docket 04/17/2009 Page 17 of 18 Respectfully Submitted, Plaintiff, by One of Her Counsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone

Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id. The cases of U.S. v. Siegel, supra (11th Cir. 1998), and U.S. v. Edwards, supra (3d Cir. 1998), also support Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of

he issue and determined travel is not necessary to sustain such a conviction. In United States v. Bailey, 228 F.3d 637, 639-40 (6th Cir. 2000), the Sixth Circuit affirmed a conviction under Section 2422(b) where the defendant sent e-mails proposing oral sex and attempted to set up meetings with minor females

behalf of I maestcd Pam Farmer, Jafre, Weissing. Edwards, Fistos & Lehrman. P L. [email protected]

nt is also admitted to practice before the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE BURNETT, P.A., who is qualified to practice

behalf of I maestcd Pam Farmer, Jafre, Weissing. Edwards, Fistos & Lehrman. P L. [email protected]

nt is also admitted to practice before the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE BURNETT, P.A., who is qualified to practice