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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
second charge of assaulting a different co-conspirator. DE 361 at 13-14,1 24 (citing US_Atty_Cor. at 29 (Exhibit 54); RFP WPB 000122 (Exhibit 55); RFP WPB 000125-000126 (Exhibit 56); RFP WA 000281 (Exhibit 57)). In response, the Government does not contend that the victims lack factual support for the
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
0076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235.000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex
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
0076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235.000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex
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 EFTA00184258 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
a hearing on the issue of the remedy for the violations of their rights. DATED: February 10, 2016 Respectfully Submitted, Is/ Flaky 9. Sdeatela Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FIS1'OS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2
00076 (Exhibit II); RFP WPB 000220 (Exhibit 12); RFP MR 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); REP WPB 000235-000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); REP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex
fication letters provided to their attorney, Brad Edwards. Al today's hearing, and over our objection, Jud
Agreement. In response to their petition. I filed a Declaration under seal that included the victim notification letters provided to their attorney, Brad Edwards. Al today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly. one piece or the Non-
ficer. 1) SIGNATURE DATE SIONAT RE IOU U 4Ily. .r. RECEIVED BY REASON i r DATE/TIME RECEIVED • - •-__-, • . . ' :-:' ... • Y pi , . RFP WPB 00048.6 - • EFTA00185092 Case 9:08-cv-80736-KAM Document 362-50 Entered on FLSD Docket 02/10/2016 Page 8 of 10 —a. Y. I r e n. ALT POPO Veen
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 Villafafla to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to pro
ent to the victims included this proposed stipulation: On July 9, 2008, AUSA Villafafta sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafla Declaration. That notification contains a written explanation of the full terms of the agreement
n or to discuss this matter in any way. Until then, I remain, • Very truly yours, Michael R. Thin cc; Jack Goldberger, Esq. 08-80736-CV-MARRA RFP WPB 000547 ••• • •I•MPISIM EFTA00185097 Case 9:08-cv-80736-KAM Document 362-52 Entered on FLSD Docket 02/10/2016 Page 1 of 17 EXHIBIT 122 EFTA0
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 (
0076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235.000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex
Entities connected to both Bradley Edwards and RFP WPB

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
United States
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Salt Lake City
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSON
Bill Clinton
PERSONFISTOS & LEHRMAN
ORGANIZATION