Epstein Secrets

Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of E.W., Mr. Kuvin, Esq. was present on behalf of B.B., Assistant State Attorney Barbara Burns was present on behalf of

st Palm Beach, FL 33401 William J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Bo

o & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00180847 1 ON BEHALF O

ring action on her own behalf, and can only sue by and through a guardi- an ad litem, next friend or other duly ap- Page 8 pointed representative); Kingsley v. Kings- ley, 623 So.2d 780, 784 (Fla. 5th DCA 1993)(guardian ad !item or next friend is required to represent a minor in a termina- tion of paren

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of M., Assistant State Attorney Barbara Burns was present-on behalf-of-the

o & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231347 2 1 ON BEHAL

bring action on her own behalf, and can only sue by and through a guardi- an ad litem, next friend or other duly ap- Page 8 pointed re sentative); Kingsley v. Kings- ley, 623 .2d 780, 784 (Fla. 5th DCA 1993)(guardian ad liters or next friend is required to represent a minor in a termina- tion (,parent

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of Assistant State-Attorney Barbara Burns-was present on behalf-of-the Sta

o & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232467 2 1 ON BEHAL

her own behalf, and can only sue by and through a guardi- an ad litem, next friend or other duly ap- Page 9 of 11 Page 8 pointed representative); Kingsley v. Kings- ley, 623 So.2d 780, 784 (Fla. 5th DCA 1993)(guardian ad fitern or next friend is required to represent a minor in a termina- tion of pare

is raising, the Court must "take the factual allegations in the complaint as true and construe them in the light most favorable to the plaintiffs." Edwards v. Prime, Inc., 602 F.3d 1276, 1291 (11ih Cir. 2010). In the current posture of this case, the victims have pending a motion for "summary judgment"

ity to review this case. CONCLUSION The Court should deny the Government's motion to dismiss. DATED: December 5, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Te

bad faith, resorted to trickery and deception, or been guilty of fraud, injustice or unfairness will appeal in vain to a court of conscience." In re Kingsley, 518 F.3d 874, 878 (11th Cir. 2008). The victims request an opportunity to brief all these issues at greater length — once discovery in this case i

appropriate equitable remedy."). And the CVRA is obviously "remedial legislation" that should be broadly construed to achieve its remedial purposes. Edwards. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008). A good illustration of the broad power of district courts to remedy CVRA violation

ity to review this case. CONCLUSION The Court should deny the Government's motion to dismiss. DATED: December 5, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, UT \Ill A Tile UTOTAO 0. T M.TDIN A XT Tip T and Paul G. Cassell Pro Hac Vice Attorneys for Ja

bad faith, resorted to trickery and deception, or been guilty of fraud, injustice or unfairness will appeal in vain to a court of conscience." In re Kingsley, 518 F.3d 874, 878 (11th Cir. 2008). The victims request an opportunity to brief all these issues at greater length — once discovery in this case

in East Brunswick on Feb. 24, according to an FBI complaint in the case. The informant was wearing an audio and video recording device." Powers "is Edwards' girlfriend, according to the complaint. Edwards made various other purchases of drugs and sold them to the confidential source from January to Mar

der area and lasted longer than a series of air raids 24 hours earlier in which 42 Palestinians were killed." The New York limes (5/16, Abuheweila, Kingsley, 20.6M) reports, "Local media reports said among the targets that were hit early Monday were the main coastal road west of Gaza City, security comp