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IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.:50 2009 CA 040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein’s required complian
ted to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit “N” at 17. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein’s personal pilot testified to Richardson joining Epst
Page: HOUSE_OVERSIGHT_010596 →IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, Vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, / DEFENDANT/COUNTER-PLAINTIFF’S RESPONSE IN OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANT’S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF’S FOURTH AMENDED COUNTERCLAIM Defendant/Counter-Plaintiff Bradiey J. Edwards, by and thr
gment, 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, paragraphs 69-81). That belief was reinforced by the
Page: HOUSE_OVERSIGHT_013309 →Epstein Accusations (from Press Reporting) Name • Accusation Location Source(s) • Recruited by unidentified female brunette in her 20s outside of her high school in the fall of 2001, when she was 14. • Joint visits with unidentified female for a month. Then solo trips to Epstein's house. • Regularly gave Epstein massages. Sometimes he masturbated. Manipulated into stripping down to her panties during the massages. Paid $300 each time. • "He would also like when I would play with his
times. • Epstein directed her to have sex with Glen Dubin • also alleges Epstein and Maxwell told her to have sex with former New Mexico governor Bill Richardson; former Democratic Senate Majority Leader George Mitchell; the late MIT computer scientist Marvin Minsky; and MC2 model agency cofounder Jean Luc
Page: EFTA00022137 →Entities connected to both Bill Richardson and 301 E. 66th Street

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSONJack Goldberger
PERSON
Donald Trump
PERSON
A. Marie Villafana
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Marc Rich
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Bill Clinton
PERSON
Kenneth Marra
PERSON
Prince Charles
PERSON
George Mitchell
PERSONJane Doe
PERSON