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

nt to the victims included this proposed stipulation: On July 9, 2008, AUSA Villafafla sent a victim notification to Jane Doe # I via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafia Declaration. That notification contains a written explanation of the full terms of the agreement

JUDGE 14 Appearances: 15 FOR THE PETITIONER Bradley J. Edwards, ESQ., and 16 Paul G. Cassell, ESQ. 1? FOR THE RESP

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 Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to pro

the improper deposition. 12. In mid-June 2008, Attorney Edwards contacted AUSA Villafafia to inform her that he

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11'h Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

nder Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton, Esq.

e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA Dexter Leo (noting Government's representation to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein whil

, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton

he first place, See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA (noting-Government's representation-to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein while Jeffrey

HSTEINSPOStotroL,u Aln-dit Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33394 Telephone Telecopier By. Bradley I. Edwards Florida Bar Non= William UBerger Florida ar N . 3 EFTA00232414 • p ro v k i? J IN me cRIMINAI. DI% 'SION OP u I . dui r RT OF TI If!

uite 400 West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA Dexter Lee (noting Government's representation to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein whil

See Attachment 1 (Oct. 9, 2008, Letter from Brad Edwards, Esq. to AUS Indeed, it appears that the Govern

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA Dexter Lee (noting Government's representation to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein whil

See Attachment 1 (Oct. 9, 2008, Letter from Brad Edwards, Esq. to AUSA Dexter Lee). Indeed, it appears tha

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA Dexter Lee (noting Government's representation to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein whil

See Attachment 1 (Oct. 9, 2008, Letter from Brad Edwards, Esq. to AUSA Dexter Lee). Indeed, it appears tha

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

08 Page 8 of 8 Ann Marie C. ViBefana, AUSA United States Attorneys Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 al Brad Edwards • • U U ll Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 I HEREBY FURTHER CERTIFY that on September 25, 2008, a true a

e description of another feature of the non- U U U U prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad . . Edwards, Esq. to AUSA Dexter Lee (rioting Government's representation to victims of a right to recover at least 5150,000 in damages from Jeffrey Epstein whi

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (li ' Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

ve provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct 15, 2008 Letter from Brad Edwards, Esq, to AUSA (noting Goverament-s represen ' teflon to victims of atight to recover at least $150,000 in damages from Jeffrey Epstein while Jeff

Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC By: s/ Brad Edwards Brad Ed

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown'); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

orldwide media for dissemination. We have seen similar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, through his counsel, filed a motion for summary judgment along with a statement of facts that was appended as an exhibit. The statement of facts it

arm; [2] the precision with which the order is drawn; [3] the availability of a less onerous alternative; and [4] the duration of the order." In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987). H. THERE IS GOOD CAUSE TO ISSUE THE PROTECTIVE CONFIDENTIALITY ORDER Even though the Eleventh Circuit has rul

orldwide media for dissemination. We have seen similar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, through his counsel, filed a motion for summary judgment along with a statement of facts that was appended as an exhibit. The statement of facts it

arm; [2] the precision with which the order is drawn; [3] the availability of a less onerous alternative; and [4] the duration of the order." In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987). H. THERE IS GOOD CAUSE TO ISSUE THE PROTECTIVE CONFIDENTIALITY ORDER Even though the Eleventh Circuit has rul