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IBIT 16 EFTA00081180 Case 9:08-cv-807m091349pept Z91-15 _EriterM ocp WERocisstifolf/E15 Page 2 of roio-< uoc 16q0,3 e 0 EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00081181 Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger phri N 7NRocieatgfe)10/§815 Page 3 of IN THE CIRCUI
ndants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undis
and punish Epstein for his crimes against them in whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane Doe, Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of Jane Doe. See Edwards Affidavit, "N" at ¶7. Included in thi
ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorn
legations - that Epstein paid her for a massage then forced her to give him oral sex and molested her in other ways when she was only 16 years old. Cordero was born a male, and in her complaint she alleges that Epstein told her during the "massage", "I love how young you are. You have a tight butt like
ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent..; on July 2, 2008, attorney
1/2015 Page 2 of 9 P ORAS Tam C leis Action Pe winal Injury Wconglul Otell Comer cal Lotqatton WWW.PATHTOJUSTICE COM Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. August 20, 2014 Wifredo A. Ferrer United States Attorney Southern District of Florida RE: Jane Does I and 21 United St
ns. Thank you for your anticipated cooperation. Bradley J. Edwards, Esq. (850) 224-7000 141004142-7011 WWW.S ARCYLAW CO
our letters and Is considering the matter, as well as your request for a meeting. I will try to get an answer for you as soon as possible. • From: Brad Edwards - Sent: Wednesday, December 03, 2014 2:12 PM To: Redacted (OWLS); Redacted (USAFLS) Cc: Paul Cassell Subject: Doe 'US When we spoke a few months a
legations - that Epstein paid her for a massage then forced her to give him oral sex and molested her in other ways when she was only 16 years old. Cordero was born a male, and in her complaint she alleges that Epstein told her during the "massage", "I love how young you are. You have a tight butt like
ndants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undis
this subject at his deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to him. "[I]t is well-settle
ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent..; on July 2, 2008, attorney
legations - that Epstein paid her for a massage then forced her to give him oral sex and molested her in other ways when she was only 16 years old. Cordero was born a male, and in her complaint she alleges that Epstein told her during the "massage", "I love how young you are. You have a tight butt like
INTIFF: 3 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN 4 425 North Andrews Avenue Suite 2 5 Fort Lauderdale, Florida 33301-3268 6 BY: BRADLEY EDWARDS, ESQ. 7 8 ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: 9 BURMAN, CRITTON, LUTTIER COLEMAN, LLP 10 303 Banyan Boulevard Suite 40C 11 West Pa
24 BY: ALAN S. ROSS, ESQ. 25 Also Present: Sean McGuire, Videographer U.S. Legal Support 0003 1 2 3 INDEX Page Direct Examination By Mr. Edwards 7 4 Cross-Examination By Mr. Mermelstein 111 Redirect Examination By Mr. Edwards 127 Recross-Examination By Mr. Mermelstein 133 6 7 Certif
in access Co underage minor 19 females for sex, correct? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. And do you know of trips that Kr. Cordero, 23 Mr. Brunel, and Mr. Epstein took to Brazil specifically 24 for the purposes of Mr. Epstein engaging in sex with 25 12-year-old girls? 0101
w how it is that met 3 Jeffrey Epstein? 4 A. I refuse to answer. 5 Q. Do you know Story Cowles? 6 A. I refuse to answer. 7 Q. You know who Sergio Cordero is? 8 A. I refuse to answer. 9 Q. Well, that's somebody who also assists 10 Mr. Epstein in bringing him. underage minor females for 11 sex, c
INTIFF: 3 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN 4 425 North Andrews Avenue Suite 2 5 Fort Lauderdale, Florida 33301-3268 6 BY: BRADLEY EDWARDS, ESQ. 7 8 ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN: BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach,
24 BY: ALAN S. ROSS, ESQ. 25 Also Present: Sean McGuire, Videographer U.S. Legal Support 0003 1 2 3 INDEX Page Direct Examination By Mr. Edwards 7 4 Cross-Examination By Mr. Mermelstein 111 Redirect Examination By Mr. Edwards 127 5 Recross-Examination By Mr. Mermelstein 133 6 7 Cer
in access to underage minor 19 females for sex, correct? 20 MR. PIKE: Form. 21 A. I refuse to answer. 22 Q. And do you know of trips that Mr. Cordero, 23 Mr. Brunel, and Mr. Epstein took to Brazil specifically 24 for the purposes of Mr. Epstein engaging in sex with 25 12-year-old girls? 0101
w how it is that met 3 Jeffrey Epstein? 4 A. I refuse to answer. 5 Q. Do you know Story Cowles? 6 A. I refuse to answer. 7 Q. You know who Sergio Cordero is? 8 A. I refuse to answer. 9 Q. Well, that's somebody who also assists 10 Mr. Epstein in bringing him underage minor females for 11 sex, co
as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B
victims and the public," Berger said. "The public should be outraged it has gone as far as it has." A second attorney representing the women, Brad Edwards, has seen the sealed document A federal judge allowed him and his clients to view it, but not to discuss its con- tents. Edwards said the wom
he women, Brad Edwards, has seen the sealed document A federal judge allowed him and his clients to view it, but not to discuss its con- tents. Edwards said the women were "outraged" at what had been negotiated without their knowledge. A reporter asked Edwards if he thought Epstein re- ceived
uoted her MySpace page as saying she fantasized about being with multiple partners. A New York appel- late court sided with the tabloid, saying that Cordero herself gave the public the reasonable impression of promiscuity. Ya think? or e-mall EFTA00183946 IN THE DISTRICT COURT OF APPEAL OF THE STATE
, State Attorney's Office- West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401, William J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 4 Shullman, Robert D. Critton, BURMAN, CRITTON, LUTTIER, & COLEMAN, . this 11 day of June, 2009. Deanna K. B
e women, Brad Edwards, has seen the sealed document. A federal judge allowed him and his clients to view it, but not to discuss its con- tents. Edwards said the women were "outraged" at what had been negotiated without their knowledge. A reporter asked Edwards if he thought Epstein re- ceived
iam J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 4 Shullman, Rober
quoted her *Space page as saying she fantasized about being with multiple partners. A New York appel- late court sided with the tabloid, saying that Cordero herself gave the public the reasonable impression of promiscuity. Ya think? Got a news tip? Call Jose at (5611820-4725 or e-mail jose_lamblet@pbpo
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN BY: BRADLEY EDWARDS, ESQ. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301-3268 ALSO PRESENT: MICHAEL FISTEN U.S. Legal Support (305) 373-8404 EFT
as called as a witness by the Plaintiff and, after having been first duly sworn, was examined and testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: Q. Tell us your name. A. Q. And just to the get to the point, you know who Jeffrey Epstein is? A. Yes. Q. And you've met him before? A.
, you know, I brought her to my house and I said, you're not going out at night; you're only 13, 14, and that's my responsibility. Q. Do you know Sergio Cordero? A. Yes. Q. And do you know what Sergio's role was in getting girls or something for Jeffrey Epstein? A. Yeah. That -- that is something that
3, 2010 U.S. Legal Support (561) 835-0220 EFTA00181769 2 1 2 3 4 6 7 April 13,2010 INDEX WITNESS DIRECT CROSS REDIRECT RECROSS BY MR. EDWARDS 5 98 BY MR. HOROWITZ 65 BY MR. LANGINO 77 BY MS. EZELL 8I 10 EXHIBITS 11 PLAINTIFF'S FOR IDENTIFICATION 12 I Message dated August 21,
16 17 18 19 20 21 22 23 24 25 Q Do you profit from sex trafficking or children? MR. YAREMA: Object to the form. A Fifth. Q Do you know Sergio Cordero? A Fifth. Q A Q criminal enterprise that Is designed to molest underage minor females, to be organized? MR. YAREMA: Object to the form. A Fif
to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F’ — Deposition of Bradley Edwards dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” — Order of HOUSE_OVERSIGHT_013305 --- PAGE BREAK
Page: HOUSE_OVERSIGHT_013305 →dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, tomes
Page: HOUSE_OVERSIGHT_013333 →llegations - that Epstein paid her for a massage then forced her to give him oral sex and molested her in other ways when she was only 16 years old. Cordero was born a male, and in her complaint she 19 HOUSE_OVERSIGHT_013337 --- PAGE BREAK --- alleges that Epstein told her during the “massage”, “I love
Page: HOUSE_OVERSIGHT_013338 →Entities connected to both Bradley Edwards and Sergio Cordero

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONRobert D. Critton
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION