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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
under oath at the state sentencing." See DE 361, Statement of Undisputed Fact 80 (not disputed by the Government). Similarly, on December 6, 2007, AUSA Sloman sent a letter to Epstein's defense counsel that explained: Finally, let me address your objections to the draft Victim Notification Letter. You wr
er the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane Doe 5 and the other victims.116 101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Mr. Edwards asked to meet to provide
19, 22-23; Exhibit 99; Exhibit 101. 124 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Declaration of Brad Edwards (Exhibit 102). 35 EFTA00804362 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 36 of 57 109. Had they known that the
g and a hearing on the issue of the remedy for the violations of their rights. DATED: February 10, 2016 Respectfully Submitted, AI sae, p. Samna Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Telephone Facsimile E
o make a statement under oath at the state sentencing."' 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d
er the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane Doe 5 and the other victims.116 101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Mr. Edwards asked to meet to provide
19, 22-23; Exhibit 99; Exhibit 101. 124 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Declaration of Brad Edwards (Exhibit 102). 35 EFTA00591639 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 36 of 57 109. Had they known that the
g and a hearing on the issue of the remedy for the violations of their rights. DATED: February 10, 2016 Respectfully Submitted, AI sae, p. Samna Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Telephone Facsimile E
o make a statement under oath at the state sentencing."' 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d
9.) The May 30, 2008 victim letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA . (DE 407 at ¶ 100.) In mid-June of 2008, Mr. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to
r. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to meet to provide information about the federal crimes committed by Epstein against these victims. The line prosecutor and Edwards discussed
ng the procedures for the third-party representative for the victims under the NPA's compensation provisions. (DE 407 at ¶ 64.) On October 25, 2007, AUSA Sloman sent a letter to Retired Judge Davis about selecting an attorney to represent the victims under the 11 EFTA00794132 Case 9:08-cv-80736-KAM Docum
ther plaintiffs' attorneys, such as First AUSA Sloman's former law partner, Jeffrey Herman (see below), and Ms. Villafana's confidential informant, Brad Edwards (see below), to obtain assistance from Ms. Villafana and the USAO in their cases against Mr. Epstein. Moreover, during the course of the civil liti
("RRA"). RRA, Mr. Rothstein and others at RRA perpetrated the largest Ponzi scheme in Florida's history, using the very same civil cases that Mr. Edwards litigated against Mr. Epstein to fleece investors out of millions of dollars. Incredibly, Ms. Villafana was working with Mr. Edwards on this obstruc
ll, engaged the attorney representative, Mr. Josefsberg, to obtain a settlement payment from Mr. Epstein under the NPA. On October 31, 2007, First AUSA Sloman emailed Mr. Epstein's counsel, confirming that "I understand that the plea and sentence will occur on or before the January 4th [2008] date." See O
9.) The May 30, 2008 victim letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA . (DE 407 at ¶ 100.) In mid-June of 2008, Mr. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to
r. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to meet to provide information about the federal crimes committed by Epstein against these victims. The line prosecutor and Edwards discussed
ng the procedures for the third-party representative for the victims under the NPA's compensation provisions. (DE 407 at ¶ 64.) On October 25, 2007, AUSA Sloman sent a letter to Retired Judge Davis about selecting an attorney to represent the victims under the 11 EFTA00081343 Case 9:08-cv-80736-KAM Docum
9.) The May 30, 2008 victim letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA . (DE 407 at ¶ 100.) In mid-June of 2008, Mr. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to
r. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to meet to provide information about the federal crimes committed by Epstein against these victims. The line prosecutor and Edwards discussed
ictims. (DE 407 at ¶ 76.) After these meetings with three victims, Epstein's defense team complained. (DE 407 at ¶ 77.) On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims about E
9.) The May 30, 2008 victim letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA . (DE 407 at ¶ 100.) In mid-June of 2008, Mr. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to
r. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to meet to provide information about the federal crimes committed by Epstein against these victims. The line prosecutor and Edwards discussed
ictims. (DE 407 at ¶ 76.) After these meetings with three victims, Epstein's defense team complained. (DE 407 at ¶ 77.) On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims about E
19, 22-23; Exhibit 99; Exhibit 101. 124 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4.6, 18-19, 22-23; Exhibit 99; Exhibit 101; Declaration of Brad Edwards (Exhibit 102). 35 EFTA00185492 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 36 of 57 109. Had they known that the
isonment. P-014977 thru P-014978 6/19/2008 email forwardin: 6/19/2008 email from to E. and (NB: Asserting privilege only for email. Attorney Edwards presumably has cop of his email to Attorney-Client Privilege Investigative Privilege P-014979 thru P-014980 6/23/2008 emails between . and (
o make a statement under oath at the state sentencing.s44 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d
Entities connected to both Bradley Edwards and AUSA Sloman

Jeffrey Epstein
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONFISTOS & LEHRMAN
ORGANIZATION
the University of Utah
ORGANIZATION
Dexter Lee
PERSON
Lesley Groff
PERSON
S.J. Quinney College of Law
ORGANIZATIONFBI
ORGANIZATIONRoy Black
PERSON