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

jury and the causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. I. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11ffi Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denia

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

ts that the victims have offered. DATED: March 21, 2011 Respectfully Submitted, l Bradley J. Edwards adley 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

n that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifredo A. Ferrer, Mar. I, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unreda

y, or property interest implicated in the CVRA, and courts arc hesitant to find that a substantive due process right has been created. See Collins I. City of Harker Heights. Texas, 503 U.S. 115, 5 EFTA00177151 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 6 of 9 125 (19

ters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, and Your Affiant's letter to was provided by the FBI. (Ex. I ). Your A Mantis letter to III was hand-delivered by myself to at t

ed to provide notification to victims in the short time that they had. jj Although all known victims were not notified, AUSA Ilindid call attorney Edwards to provide notice to his clients regarding the hearing. AUSA did this, even though she had no obligation to provide notice of a state court hearing

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

expand or create an exemption to Florida's public records law. Wait I. Florida Power & Light Co., 372 So. 2d 420 (Fla. 1979); Times Publishing Co. I. City of St. Petersburg, 558 So. 2d 487 (Fla. 2d DCA 1990). Principles of federal preemption under the Supremacy Clause may, in limited circumstances, a

ters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 1). Your Affiant's letter to T.M. was hand-deliver

uly 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC Re: Jeffrey Epstein, IDENTIFIED VICTIM Dear Mr. Edwards: NOTIFICATION OF By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the foll

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

expand or create an exemption to Florida's public records law. Wait I. Florida Power & Light Co., 372 So. 2d 420 (Fla. 1979); Times Publishing Co. I. City of St. Petersburg, 558 So. 2d 487 (Fla. 2d DCA 1990). Principles of federal preemption under the Supremacy Clause may, in limited circumstances, a

s of those signed acknowledgements to abide by the Protective Order were then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA00235149 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 4 of 7 5.) F

to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA0

jury and the causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. I. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial