Epstein Secrets

to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by Jane Doe. (Attachments: # 1 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: 10/16/20

nt to the victims included this proposed stipulation: On July 9, 2008, AUSA Villafafla sent a victim notification to Jane Doe # I via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafia Declaration. That notification contains a written explanation of the full terms of the agreement

JUDGE 14 Appearances: 15 FOR THE PETITIONER Bradley J. Edwards, ESQ., and 16 Paul G. Cassell, ESQ. 1? FOR THE RESP

s based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to pro

the improper deposition. 12. In mid-June 2008, Attorney Edwards contacted AUSA Villafafia to inform her that he

s 1-32. For the Plaintiff: Bradley Edwards, Esquire For the Defendant: Dexter Lee, AUSA Maria Villafana, AUSA STEVEN M. IARIM CLERK U. S. GIST. S. D. of FLA-MV GJT C. sedans ,v • •••I, • .hrt/...•0•1•••41•, OFFICIAL REPO NG SERVICES, LLC (954) -8204 EFTA00177297 Case 9:08-cv-i ,-KAM Doc

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN MATTER OF APPLICATION OF BRADLEY JAMES EDWARDS SEEKING CPLR 3102(E) ORDER FOR DAILY NEWS, L.P. TO PRODUCE TAPE RECORDING Index No. 112345/10 REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF MOTI

stein has ulterior motives and purposes in exercising such illegal, improper, and perverted use of process. His real purpose was to put pressure on Edwards„ and other victims by publishing what amounts to nothing more than a press release issued under the cloak of protection of the litigation privilege."

gation about that very subject in Florida. Movant Bradley J. Edwards is involved in a hotly contested lawsuit, in whi

dmission Pending) (: " 4—'4 ;telte) 332 S. 1400 E. Salt Lake City UT 84112 Telephone: Facsimile: E-Mail: cassel 1 DOlaw. utah.ed u Counsel for Bradley James Edwards 13 EFTA00729050 AFFIRMATION OF SERVICE As agreed in advance with counsel for the Daily News, I HEREBY AFFIRM that on November 11, 2010, I cause

ts Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores v. Cooper Tire and Rubber Co.,

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/

1 and JANE DOE #2, petitioners, VS. UNITED STATES OF AMERICA, respondent. FILED by D.C. JUN 1 8 2013 STEVEN ht. LARNOFIE CL ERK U S DIST L.T S. D. of FIA - WILL — ORDER DENYING GOVERNMENT'S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION & ORDER LIFTING STAY OF DISCOVERY THIS CAUSE

with fairness"). In addition, your proposed stipulation states that: "On July 9, 2008, sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. which is attached as Exhibit 6 to the Declaration. That notification contains a written explanation of the full terms of the agreement between Ep

stipulation regarding my contact with the office is somewhat abbreviated. I wonder what you would think about the following: In mid-June 2008, Mr. Edwards contacted to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federa

SE NO. 08-80736-Civ-MARRA/JOHNSON CERTIFICATION OF EMERGENCY FILPFAike D.C. ELECTRONIC JULY 7, 2008 STEVEN M. LARIMORE CLERK U.S. OUST. CT. S. D. Of FLA. • MIAMI I hereby certify that, as a member of the Bar of this Court, I have carefully examined this matter and it is a true emergency. I f

exual violence and objectification. In R. J. Herbele & V. Grace (Eds.), Theorizing sexual violence (pp. 14-30). New York. NY: Routledge. Diaz. A.. Edwards, S., Neal. W. P., Ludmer, P.. Sondike, S. B.. Kess- ler. C..... Nucci. A. T. (2004). Obtaining a history of sexual victimization from adolescent fem

st-rape medical care in a national sample of women. American Journal of Preventive Medicine. 19, 214-219. Roberts, S. T., Watlington• C. G.. Nett, S. D., & Batten. S. V. (2010). Sexual trauma disclosure in clinical settings: Addressing diversity. Journal of Trauma & Disassociation. 11, 244-259. Sur

G. S. (2009). Children: Suggestibility of. In C. Edwards (Ed.), Wley encyclopedia offorensic science (pp.

-75. Howe, M., Goodman, G. S., & Cicchetti, D. (2008). Stress, trauma, and memory development. NY: Cambridge University Press. Ogle, C. M., Block, S. D., Culver, M., Harris, L. T., Augusti, E. M., & Goodman, G. S. (2008). Accuracy and specificity of autobiographical memory in childhood trauma victims