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

es of America Respondent Class Code: OPEN Closed: Statute: Jury Demand: None Demand Amount: $0 NOS Description: Other Civil Rights Attorneys Bradley James Edwards LEAD ATTORNEY;ATTORNEY TO BE NOTICED Farmer Jaffe Weissing Edwards Fistos & Lehrman PL Jav C. Howell PRO HAC VICE;ATTORNEY TO BE NOTICED Jay How

y 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: 10/16/2008) 10/16/2008 31 REPLY to Response to Motion re 28 MOTION to Unseal Document Non

cument. Signed by Judge Kenneth A. Marra on 2/12/2009. (ir) (Entered: 02/12/2009) 04/09/2009 37 NOTICE by Jane Doe of Change of Firm Affiliation (Edwards, Bradley) (Entered: 04/09/2009) 09/08/2010 38 Administrative Order Closing Case. Signed by Judge Kenneth A. Marra on 9/8/2010. (tb) (Entered: 09/

s due by 9/3/2013 (Attachments: # 1 Affidavit of Bradley J. Edwards, Esq.)(Edwards, Bradley) (Entered: 08/16/2013) 226 Re

13) NOTICE by United States of America of Filing Declaration of OPR Counsel Ro in . A h on (Attachments: # 1 Exhibit B - Declaration of OPR Counsel Robin C. Ashton) ) (Entered: 10/18/2013) REPLY to Response to Motion re 226 Renewed MOTION for Order Directing the U.S. Attorney's Office Not to Withhold Relevan

6th day of August, 2013. /s/ Bradley J. Edw rds BRADLEY J. EDWARDS, ESQ. Attachments: 1. October 3, 2011, request for pr

nt to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this 16th day of August, 2013. /s/ Bradley J. Edw rds BRADLEY J. EDWARDS, ESQ. Attachments: 1. October 3, 2011, request for production; 2. June 24, 2013, supplemental request for production; and 3.

fication obligations, the USAO altered the language that was ultimately contained in the July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards. Except as otherwise admitted above, the government denies Request No. 2(d). (e) At least in part as a result of the negotiations, Jane Doe #1 and

ys to reduce any such burden. DATED: October 3. 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 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

ith regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter, marked 'Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. Ferrer, with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the lette

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE No. 1 and JANE DOE No. 2 I UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS 1. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar

United States 10 Attorney. And we have seated in the front row FBI 11 Special Agent Becker Kendall and Jason 12 Thank you, Your Honor. 13 MR. EDWARDS: Good morning, Your Honor. Brad 14 Edwards on behalf of the petitioners. Petitioners 15 16 17 18 19 20 21 the victim's reply, which was fil

fense was confirmed when she was interviewed by 'Attorney Edwards filed his Motion on behalf of "Jane Doc," without

nd JANE DOE No. 2 I UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS 1. I

with regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter marked `Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. = with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the letter was

d JANE DOE No. 2 v. UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS 1. I

ons and Government Answers 24 EFTA00208631 Case 9:00-cv-80736-KAM Document 225-1 Entered on FLSD Docket 0811612013 Page 25 of 64 EXHIBIT 1 To Brad Edwards Affidavit EFTA00208632 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 26 of 64 UNITED STATES DISTRICT COURT SOUTH

1 Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. EFTA00208645 Case 9:00-cv-80736-KAM Document 225-1 Entered on FLSD Docket 0811612013 Page 39 of 64 EXHIBIT 2 To Brad E

with regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter marked 'Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the letter was or was not ci

d JANE DOE No. 2 v. UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS I. I

ons and Government Answers 24 EFTA00081139 Case 9:00-cv-80736-KAM Document 225-1 Entered on FLSD Docket D8/16/2013 Page 25 of 64 EXHIBIT 1 To Brad Edwards Affidavit EFTA00081140 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 26 of 64 UNITED STATES DISTRICT COURT SOUTH

ys to reduce any such burden. DATED: October 3. 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 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

ith regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter, marked `Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. Ferrer, with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the lette

Case 9:08-cv-80736-KAM Document 362-30 Entered on FLSD Docket 02/10/2016 Page 2 of 2 .(USAFLS) From: Brad Edwards ([email protected]) Sent: ThillwARV ie 9908 11:34 AM To: p (USAFLS) Subject: Jeff Epstein I have information and concerns that I would

et 02/10/2016 Page 2 of 2 .(USAFLS) From: Brad Edwards ([email protected]) Sent: ThillwARV ie 99

d JANE DOE No. 2 v. UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS 1. I

h regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Leteri_ marked `Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. =, with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the letter wa

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

ld have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court makin

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

ld have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court makin

y to which requests, the Government should be required to provide such a responsive document. DATED: October 28, 2013 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 an

such a responsive document. DATED: October 28, 2013 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 and Paul G. Cassell Pro Hac Vice S.J. Quinney College

tantive information that was "collected" during the OPR investigation. Where in the log is the information that was collected? The declaration from Robin C. Ashton, Counsel of OPR, only deepens the mysteries swirling around the Government's privilege log. For example, Ashton asserts "deliberative process" priv