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tion of Epstein's federal case, on July 3, 2008, attorney Edwards sent a letter to the U.S. Attorney's Office comm
stitutional principle of separation of powers. Attorneys and Law Firms *1198 Paul Cassell, University of Utah College of Law, SALT LAKE CITY, UT, Bradley James Edwards, EdwardsPottinger, LLC, FORT LAUDERDALE, FL, for Petitioner. Richard Christian Komando, Bradley Garrison & Komando, ORANGE PARK, FL, for Amicus C
her. The U.S. Attorney's Office continued to conceal the existence of the NPA from all the victims for months to come. In mid- June *1233 of 2008, Bradley Edwards, the Fort Lauderdale, Florida attorney for several of Epstein's victims, contacted AUSA Villafana to inform her that he represented Jane Doe I and
for several of Epstein's victims, contacted AUSA Villafana to inform her that he represented Jane Doe I and, later, Jane Doe 2. AUSA Villafana and Edwards discussed the possibility of federal charges being filed against Epstein in the future. Edwards was led to believe that federal charges could stil
P.C., New York, NY (4) Lilly Ann Sanchez, Fowler White Burnett, Miami, FL; (5) Jack A. Goldberger, Goldberger & Weiss, West Palm Beach, FL; and (6) Joe D. Whitley, Alston & Bird, Washington D.C.; as well as Harvard Law Professor Alan Dershowitz. While not all attorneys participated in each defense presentation
6/30/08 BSI 6/27/2008 AUSA Villafafia notifies Attorney Edwards of upcoming change of plea and urges his clients
#33, #37 (via Michael E. Dutko), #38, #44 biaJeffni Herman) 8-90 9/W2008 Victim notification letters to #36, #35 (via Brad Edwards), #42, #43 (via Brad Edwards) B-9I 9/12/2008 Notification of Identified Victim letter #39 B-92 9/15/2008 Mailed victim notification letters for #I8 and #32 15-93 9/17/2008-
77 6/27/2008 Counsel for Epstein advise USAO of Epstein state court change of plea on 6/30/08 BSI 6/27/2008 AUSA Villafafia notifies Attorney Edwards of upcoming change of plea and urges his clients to attend 6/27/2008 USAO notifies Palm Beach Police Chief Reiter of upcoming change of plea. He
9 Villafafia Roy Black Letter in response to 11/02/09 letter re Epstein's place of employment with attached Complaint against Scott Rothstein and Bradley J. Edwards 1/4/2010 Villafafia Spencer Kuvin Letter re computer seized by FBI 1/20/2010 Villafalia Roy Black Letter re attorney's fees 1/21/2010 Villaf
Letter stating the defense will respond to Acosta letter by 12/10/07, and attaching " the independent ethics opinions of Judge Herbert J. Stern and Joe D. Whitley" 12/7/2007 Alan Dershwitz Herbert J. Stem Letter - 27 pages 12/7/2007 Kenneth Starr R. Alexander Acosta Independent ethics opinions of Judge H
nce of NPA, which is later incorporated into state court record. 6/30/2008 Notes from calls to Michael Danchuk and Richard Willets, Jeff I lerman, Brad Edwards, Ted Leopold, and Mike Dutko B-55 6/30/2008 Research re State Work Release 6/30/2008 Draft notification of identified victims letters to Guy Lew
t _ 6/27/2008 Counsel for Epstein advise USAO of Epstein state court change of plea on 6/30/08 B ;1 6/27/2008 AUSA Villafana notifies Attorney Edwards of upcoming change of plea and urges his clients to attend 6/27/2008 USAO notifies Palm Beach Police Chief Reiter of upcoming change of plea. Ile
6/30/08 B ;1 6/27/2008 AUSA Villafana notifies Attorney Edwards of upcoming change of plea and urges his clients
Letter stating the defense will respond to Acosta letter by 12/10/07, and attaching "the independent ethics opinions of Judge Herbert J. Stern and Joe D. Whitley" 12/7/2007 Alan Dershwitz Herbert J. Stem Letter - 27 pages 12/7/2007 Kenneth Starr R. Alexander Acosta Independent ethics opinions of Judge H
cedures. I don't remember saying anything different in this case. I did not see any FBI letters in this case prior to collecting the FBI letters to Brad Edwards' clients in connection with the Jane Doe I United States litigation. I did not instruct the FBI to include the language about the case being under in
y Circuit Court (Exhibit B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I liv received a call from attorney Brad ards, who told me that he represented Individual #43, who is also Jane Doe #1 in the Jane Doe United States lawsuit. Mr. Edwards expressed an interest
a call from attorney Brad ards, who told me that he represented Individual #43, who is also Jane Doe #1 in the Jane Doe United States lawsuit. Mr. Edwards expressed an interest in assisting with the case. We were still waiting to hear about whether we would be moving " On the State side, Lefkowitz has
nce and the federal interest in the case. At this point, Epstein sought review from Deputy Attorney General Mark Filip (Exhibit B- 33), and he hired Joe Whitley to join his defense team. I was informed that Epstein's deadline to enter his guilty plea would be extended again, and we continued preparing for in
n court file. CONCLUSION The Court should deny Epstein's motion for a protective order (DE 247). DATED: May 16, 2014 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell 18 EFTA00209253 Attorneys for Jane Doe I and
for a protective order (DE 247). DATED: May 16, 2014 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell 18 EFTA00209253 Attorneys for Jane Doe I and Jane Doe 2 4 The daytime business address indicated a
e vast bulk of the correspondence was drafted by other attorneys, including Kenneth W. Starr, Jay P. Lefkowitz, Gerald P Lefcourt, Alan Dershowitz, Joe D. Whitley, Stephanie D. Thacker, and Lilly Ann Sanchez. It is not clear whether the motion is designed to cover these persons and, if so, what standing Roy Bl
United States litigation, asserting that his clients wanted to 4 1 few days after Jeffrey Epstein entered his guilty plea in state court, attorney Brad Edwards filed suit on behalf of one of the victims identified in the federal investigation (later expanded to include I second victim who had been identifie
ng aside the NPA would not benefit his clients, and he sued Epstein on behalf of I number of victims under the NPA. I did what I could to assist Mr. Edwards, other attorneys, including Mr. Josefsberg, the attorney selected by the Special Master, and the Court, to locate victims, provide signed copies of
nce and the federal interest in the case. At this point, Epstein sought review from Deputy Attorney General Mark Filip (Exhibit B- 33), and he hired Joe Whitley to join his defense team. I was informed that Epstein's deadline to enter his guilty plea would be extended again, and we continued preparinii indic
ther plaintiffs' attorneys, such as First AUSA Sloman's former law partner, Jeffrey Herman (see below), and Ms. Villafana's confidential informant, Brad Edwards (see below), to obtain assistance from Ms. Villafana and the USAO in their cases against Mr. Epstein. Moreover, during the course of the civil liti
("RRA"). RRA, Mr. Rothstein and others at RRA perpetrated the largest Ponzi scheme in Florida's history, using the very same civil cases that Mr. Edwards litigated against Mr. Epstein to fleece investors out of millions of dollars. Incredibly, Ms. Villafana was working with Mr. Edwards on this obstruc
er, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Martin Weinberg, Stephanie Thacker, Guy Lewis, Mike Tein, Joe Whitley and Herb Rosen, have expressed sincere outrage over this wholly unwarranted and duplicative 18-month federal investigation of purely local conduct
ted May 30, 2008, RE: , (2 pages); Author: Twiller Smith, Victim Specialist, Federal Bureau of Investigation, West Palm Beach, Florida. Letter to Brad Edwards, Esq., dated July 9, 2008, RE: Jeffrey Epstein/C.W.: Notification of Identified Victim (2 pages); Author: A. Marie Villafana. Letter to Brad Edward
ation, West Palm Beach, Florida. Letter to Brad Edwards, Esq., dated July 9, 2008, RE: Jeffrey Epstein/C.
Letter to Honorable Mark Filip, Deputy Attorney General, dated May 19, 2008, No Subject (8 pages), Authors: Kenneth W. Starr, Kirkland & Ellis, and Joe D. Whitley, Alston & Bird 8 EFTA00191193 Letter to Honorable Mark Filip, Deputy Attorney General, dated May 27, 2008, No Subject (2 pages), Authors: Kenne
im's Reply to Opposition to Victim's Motion to Unseal Non-Prosecution Agreement in Jane Doe No. 1, et aL v. M., 08-80736; 2) 10/9/2008 letter from Edwards48 tee: false statements by the government; and 3) 10/15/2008 letter from Edwards to ■ re: whether Epstein violated the non-prosecution agreement 2
on to Stay Proceedings Pending Jane Doe No. 1 Reaching Age of Majority, Jane Doe No. 1, et aL v. Epstein, 08-80069 (filed by Jane Doe's mother) 38 Joe D. Whitley, Alston & Bird LLP. " Pages appear to be missing from this letter. PRIVILEGED & CONFIDENTIAL 8 EFTA00296186 CHRONOLOGY OF JEFFREY EPSTEIN'S DOC
Entities connected to both Bradley Edwards and Joe D. Whitley

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
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONRobert D. Critton
PERSONLeon Black
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSON
Donald Trump
PERSON
Salt Lake City
LOCATION