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d JANE DOE No. 2 v. UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS 1. I
d Epstein held accountable the same way anyone else would be. I spoke about this with one of my friends around May 2008. I then called an attorney, Brad Edwards, around June 2008, understanding that he was hired to get the prosecutors to talk to us and hear the truth from me. That was especially important t
y other young teenagers to Epstein for the purpose of getting paid by Epstein. I wanted to assist the prosecutors in the investigation. I hired Mr. Edwards to let them know that I was cooperative and ready to tell them all of the helpful information I had. I understood that Mr. Edwards did that. I aut
ecutor disclosed the existence of the agreement, attorney Edwards could have taken steps to challenge the consummat
itable estoppel precludes challenging a document only where that party "must rely on the terms of the written agreement in asserting [her] claims." MS Dealer Service Corp. v. Franklin, 177 F.3d 942, 947 (11th Cir. 1999). Here, of course, the victims need not rely on the terms of the Government's non-prosecution agreem
n's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitioners with notice of the ti
800037 Case 9:08-cv-80736-KAM Document 427 Entered on FLSD Docket 10/10/2017 Page 31 of 32 Attorneys for Intervenor Jeffrey Epstein SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac
D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stres
elements of equitable estoppel since they are not relying upon the terms of the written agreement in asserting their claims. D.E. 416 at 57, citing MS Dealer Service Corp. v. Franklin 177 F.3d 942, 947 (11'h Cir. 1999). They maintain that their claims in this litigation are not based on the NPA, but the CVRA. This arg
n's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitioners with notice of the ti
tant United States Attorney 30 EFTA00800005 Case 9:08-cv-80736-KAM Document 425-1 Entered on FLSD Docket 10/06/2017 Page 32 of 33 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Paul G. Cassell Pro Hac Vice S.J. Quinney College of
D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stres
elements of equitable estoppel since they are not relying upon the terms of the written agreement in asserting their claims. D.E. 416 at 57, citing MS Dealer Service Corp. v. Franklin 177 F.3d 942, 947 (11th Cir. 1999). They maintain that their claims in this litigation are not based on the NPA, but the CVRA. This arg
Entities connected to both Bradley Edwards and MS Dealer Service Corp.

Jeffrey Epstein
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
United States
LOCATIONLeon Black
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
the University of Utah
ORGANIZATION
Dexter Lee
PERSON
S.J. Quinney College of Law
ORGANIZATIONAce Greenberg
PERSON
Oliver Stone
PERSONthe Eleventh Circuit
ORGANIZATIONBates
PERSON
Tampa
LOCATIONthe Fifteenth Judicial Circuit
ORGANIZATIONJacqueline Perczek
PERSON