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nvestigating the-ease Epstein. See Declaration of Bradley J. Edwards, Esq. at ¶¶ 1-2 (hereinafter "Edwards Declaration").
agreed-to-seek no mere less than $150,000 in damages against Epstein — an amount that Epstein argued later was limited to no more than $50,000). See Edwards Declaration, Exhibit "C" (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. At
ht the Importance of Vi.. Page 3 of 3 Lauderdale, Florida 33301 and may be reached at (800)400-1098 or (964) 624- 2820 Additional information about Brad Edwards or Farmer, Jaffe, Welssing, Edwards, Fistos 8 Lehrman. P.L. may be obtained from the fires webalte at swAv palhlotustIce com. FAQ4 I Contact Us I
iem-at—II—Ph AUSA Villafafia strongly encouraged Attorney Edwards and his client to attend and address the Court a
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ed on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E
SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-
istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa
d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the
Fowler White and Jeffrey Epstein Should Not be Held in Contempt of Court [D.E. 6366] (the "Order to Show Cause"), which directed Farmer Jaffe, Mr. Bradley Edwards, L.M., E.W., and Jane Doe to file a summary of their damages with the Court. EFTA00808138 Case 09-34791-R BR Doc 6427 Filed 08/16/18 Page 2 of
ause"), which directed Farmer Jaffe, Mr. Bradley Edwards, L.M., E.W., and Jane Doe to file a summary of th
Motion [D.E. 6393]. The Order to Show Cause directed the Intervenors to file a summary of damages, but the Order to Show Cause did not prohibit the Intervenors from filing additional pleadings, such as a List of Requested Relief. [D.E. 6366]. Intervenors remain required to file a summary damages, and the Co
than 27,000 pages of e-mails, thousands of which have been produced to Epstein and only 47 e-mails which Epstein identified as trial exhibits that Edwards claim are privileged. Indisputably, no court has deemed the documents on the disc or the 47 e-mails to be attorney-client privileged, or even addres
SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Counsel for Bradley J. Edwards Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Counsel for Farmer
the Intervenors' Depositions and to Compel their Mental Examinations (Epstein's "Motion") (D.E. 6440), and states: INTRODUCTION Inexplicably, the Intervenors' counsel insists on making the Intervenors relive (and attempt to re-litigate) their settled sexual abuse claims against Jeffrey Epstein. Although t
SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-
istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa
d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the
he bears the burden of proof. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY EFTA00205765 t with the Cler to receive noti Brad Edwards, Esq., Paul G. Cassell a ttorneys or ane oe an ane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. ' P.A. EFTA00205766 Attorneys for Interve
205765 t with the Cler to receive noti Brad Edwards, Esq., Paul G. Cassell a ttorneys or ane oe a
and information should be privileged under a common law plea negotiations privilege. In addition, in its initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the P
ALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800)DCXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. AGREED MEDIATION CONFIDEN ER TI-IIS CAUSE came before the Court upon th t of (1) Bradley J. Edwards
dividually, Defendants/Counter-Plaintiff. AGREED MEDIATION CONFIDEN ER TI-IIS CAUSE came before the Court upon th t of (1) Bradley J. Edwards ("Edwards"), (2) Jeffrey Epstein ("Epstein"), nors Jane Doe, M t and= (collectively, "Intervenors"), and (4) F' eissing Edwards Fistos and Lehrman ("Farmer
ds, Epstein and a repr m Farmer Jaffe who has the full authority to settle without further consultation shall app at the mediation in person. The Intervenors' counsel, who shall have full authority to settle the matter without further consultation, shall appear at the mediation by telephone. FILED: PALM
& APPELLATE LAW LINK& ROCKENBACH, PA August 14, 2018 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: 1555 Palm Beach Lakes, Blvd., Suite 930 West Palm Beach, FL 33401 TEL: (561) 847-4408 I FAX: (561) 855.2891 Atta
s to what the evidence will show into two subsections: (a) that J. Epstein did not violate the November 30, 2010 Order; and (b) that Farmer Jaffe, Edwards, and Intervenors have sustained no actual, compensatory losses, encompassing 07/25/18 SJL Work on preparation for two-day hearing In front of Jud
ards, or Intervenors 07/19/18 SJL Work on preparations for upcoming two-day hearing on more than twenty motions; review Motion to Strike filed by Intervenors in Bankruptcy Court proceeding; review B. Edwards' Responses to our Motion to Amend Exhibit List and our Motion to Compel Edwards to Identify Witn
. Nurick was there and Scarola. Nurick and Scarola were powwowing after the hearing. It's an important ruling for us to be able to tell the jury in Edwards that we still have a pending case against Rothstein. I suggest we set Rothstein for deposition. His deposition was very ineffectively taken before.
Palm Beach Lakes Blvd. Suite 930 MIS Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards August 7,2018 Invoice #1034 Date Services Hours Amount 07/02/18 TLC Follow up with D. Indyke re status of drafting; working on hearing folde
ntervenors Services 07/19/18 SJL Work on preparations for upcoming two-day hearing on more than twenty motions; review Motion to Strike filed by Intervenors in Bankruptcy Court proceeding; review B. Edwards' Responses to our Motion to Amend Exhibit List and our Motion to Compel Edwards to Identify Witn
ent from counsel. See Composite Exhibit 4. In a parallel article published in the Daily Business Review, Plaintiffs' counsel was quoted as follows: "Edwards said the -10- EFTA00605760 documents at this point will be disclosed only to the plaintiffs and will not become part of the public record." Id. (
d on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E
Entities connected to both Bradley Edwards and Intervenors

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATIONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATION
Department of Justice
ORGANIZATIONMartin Weinberg
PERSONFISTOS & LEHRMAN
ORGANIZATION