Epstein Secrets

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

meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafla and I discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafla asked me to send any information that I want

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

" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafla) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to

LY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafla) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of

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

ent to the victims included this proposed stipulation: On July 9, 2008, AUSA Villafafta sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafla Declaration. That notification contains a written explanation of the full terms of the agreement

w. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafla to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes co

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

Public Prosecutor, Attorney Conduct at Issue Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafla) handwritten notes of interview Work product Investigative privilege • Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipa