Epstein Secrets

SERVICE LIST Jane Does 1 and 2'. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell S.J. I uinne olle e of Law at the Attorneys for Jane Doe # 1 and Jane Doe #

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

cord, atty work product; deliberative process privilege Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011, 12:23 p.m., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

SERVICE LIST Jane Does 1 and 2'. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale FL 33301-3268 Paul G. Cassell S.J. Quinney College o

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

aul 12:23 p.m., information, handwritten between and Cassell to May 3, 2011, atty work product; law enforcement investigatiory record RE: OPR Inquiry — request for with post-it note attached with attorney notes on telephone call and Howard with Suppl. Box 3 P-013948 Thru P-013951 E-mail, t

already entered a binding non-prosecution agreement with Jeffrey Epstein. The government is without 6 EFTA00191204 knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S. Attorney's Office concerning the need to federally prosecute Epstein for sex offenses committed against Jane Do

rally prosecute Epstein for sex offenses committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government denies the assertion that Edwards worked on that letter on July 3, 2008. Except as otherwise admitted above, the government denies Request No. 12. 13. (a) The government admits that

cord, atty work product; deliberative process privilege Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011, 12:23 p.m., RE: OPR Inquiry — request for infonnation, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

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 (

Florida matter Suppl. Box 3 P-013947 E-mail, to May 3, 2011, for atty work product; law enforcement investigatiory record 12:23 p.m., RE: OPR Inquiry — request information, with post-it note attached with handwritten attorney notes on tele 'hone call between and with and Suppl. Box 3 P-0139

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

ion of the materials at issue. DATED: August 16.2013 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 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

secutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011,12:23 pan., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter