Epstein Secrets

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

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at 116. 74. Edwards gave not

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

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave not

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

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at ¶16. 74. Edwards gave not

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

in support of his Motion for Summary Judgment, Edwards had a sound legal basis for believing that Donald Trump, Allen Dershowitz, Bill Clinton, Tommy Mattola, David Copperfield and Governor Bill Richardson had relevant and discoverable information (Exhibit “A” — Edwards’ Statement of Undisputed Facts, para

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, tomes

a discussions and the right to confer with prosecutors about any plea arrangement). See 14 HOUSE_OVERSIGHT_010579 --- PAGE BREAK --- Affidavit of Bradley J. Edwards, Esq. at {1 - 2, §4 (hereinafter “Edwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorney E

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorn

e 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 this c

73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit “N” at (16. 74. Edwards gave notic

NAUGHT. - Dated this 23” day of April, 2010. _ Brad Feats Esq.. “The fatagaite, instrument was acknowledged before me this 234 day of or, 2010 by BRAD _ EDWARDS, who i is ersonally, known to me. oe : 2 ee ee em oe aeseacancctinl ramen Soap enbaf ond attanan NU Fe rermasou me 1, 2012 Denes a PRL. Sindee l

TS f ) , Epstein v. Edwards, et al. Case No.;: 50 2009 CA 040800XXXXMBAG EXHIBIT N HOUSE_OVERSIGHT_013467 --- PAGE BREAK --- 1. 7. AFFIDAVIT OF BRADLEY JAMES EDWARDS I am an attorney in good standing with the Florida Bar and admitted to practice in the Southern District of Florida. I am currently a partner in the

accordingly provided notice of a possible deposition. Epstein alleges that Tommy Mottola was improperly noticed with a deposition. I did not notice Mattola for deposition. He was noticed for deposition by a law firm representing another one of Epstein’s victims — not by me. Epstein alleges that there wa