Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Do- .at 01/21/2015 Page 20 of 20 NOTIFICATION OF IDENTIFIED VICTIM SEPTEMBER 3, 2008 PAGE 3 OF 3 directly, he can be reached at +1 305 358-2800. If you have already selected other counsel to represent you, or if you do so in the future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack Goldberger as s th t u h at Atterbury Gonberger and Weiss, , (561) 659-8300. In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Joscfsberg can provide further guidance on this issue, or if you select another attorney to represent you, that attorney can review the Court's order in the matter of In re Jane Does I and 2, United States District Court for the Southern District of Florida Court File No. 08- 80736-C1V-MARRA. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take pan in or otherwise assist in civil litigation. Thank you for all of your assistance during the course of the federal and state investigations and please accept the heartfelt regards of myself and Special Agents Kuyrkendall, Slater, and Richards for your health and well-being. Sincerely, R. Alexander Acosta United States Attorney By: cc: Robert Joscfsberg, Esq. Jack Goldberger, Esq. A. Marie Villafaha Assistant United States Attorney EFTA00188808

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Case 9:08-cv-80736-KAM ,,ocument 291-2 Entered on FLSD 01/21/2015 Page 1 of 9 EXHIBIT 2 EFTA00188810

Case 9:08-cv-80736-KAM Jcument 291-2 Entered on FLSD U. 01/21/2015 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 Stales Case No. : 08-80736-Civ-Marra/Johnson Dear Mr. Ferrer: As you know, we have been in litigation for more than six years on a case under the Crime Victims' Rights Act — a case that involves decisions that were all made before you took office and that gave Jeffrey Epstein an expansive non-prosecution agreement. Several years ago you were nice enough to meet with us and one of our clients to discuss the case, which we 'really I appreciated. More recently we contacted the line attorneys working on the case to see if we could reach some stipulated facts on various issues surrounding the case. It is in that spirit of trying to avoid unnecessary battles that we wanted to alert you to a motion we are preparing to file to see whether this could be a stipulated motion. Our CVRA case is brought on behalf of two sexual assault victims — Jane Doe #1 and Jane Doe #2. We would like to add a third victim to the case — Jane Doe #3. Her true name is although we would seek to keep her identity confidential during the proceedings. We contacted your office about prosecuting the crimes Jeffrey Epstein committed against her a couple years ago when we realized that she was not includes in the NPA; however, we were told that despite not knowing about this particular victim when the agreement with Epstein was reached, the NPA was drafted so broadly as to preclude criminal charges for the crimes committed against her. Adding her to the case will not expand the issues in the case. Nor will it result in any new discovery or additional delay. EFTA00188811

Case 9:08-cv-80736-KAM ...ocument 291-2 Entered on FLSD L.,,,ket 01/21/2015 Page 3 of 9 Wifredo A. Ferrer August 20, 2014 Page 2 Jane Doc #3 was sexually abused numerous times by Jeffrey Epstein. Shc is keenly interested in having our CVRA case fairly resolved. We also note that, under the CVRA, Justice Department prosecutors are obligated to use their "best efforts" to help protect crime victims' rights. As such, we ask for your stipulation to this amendment. A copy of our soon-to-be-filed motion is attached. We wanted to show you what it looked like in hopes that you might be able to support it. We would, of course, be glad to consider making any changes to the motion that would help gamer your support. Thanks in advance for considering this request. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Bradley J. Edwards BJE::mwk Enclosure Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman, P.L. EFTA00188812

Case 9:08-cv-80736-KAM .document 291-2 Entered on FLSD L„„ket 01/21/2015 Page 4 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES r JANE DOE #3'S MOTION TO JOIN CVRA ACTION COME NOW Jane Doe #3, by and through undersigned counsel, to move this Court to join this action. Because Jane Doe #3's rights have been violated in the same way as the two other victims, and because the Crime Victims' Rights Act (CVRA) contains no statute of limitations, she should be allowed to join this action. As the Court is aware, more than six years ago Jane Doe #1 filed the present action against the United States, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771. She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered into a secret non-prosecution agreement regarding those crimes in violation of her rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the action. Both Jane Doe 111 and Jane Doe #2 specifically argued that the government had failed to protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In response. the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. EFTA00188813

Case 9:08-cv-80736-KAM -document 291-2 Entered on FLSD _Ket 01/21/2015 Page 5 of 9 Last June, the Court rejected the United States' position. The Court concluded that the CVRA extended rights to Jane Doe til and Jane Doe #2 even though charges were never filed. The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had "standing" to assert violations of the CVRA rights. DE 189. The Court deferred ruling on whether the two victims would be entitled to relief, pending development of a fuller evidentiary record. Jane Doe #31 was sexually abused by Jeffrey Epstein more than twenty times in and alter the summer of 2002. Thereafter, in 2007, when the United States entered into its non- prosecution agreement with Epstein, the United States had identified more than 40 victims by name and knew that many more existed. Jane Doe #3 was unknown to the United States, yet the United States entered into an agreement with Epstein — the NPA — which purports to preclude prosecution against Epstein in the Southern District of Florida, even for serious sexual offenses against Jane Doe #3 that are not barred by the Statute of Limitations. Jane Doe #3 was never even contacted by the United States, yet the United States contracted away her rights. Jane Doe #3 now moves to join the action filed by Jane Doe #1 and Jane Doe #2. She believes that her rights were violated in the same fashion as the other victims. Adding her to this case will not prejudice the United States. Jane Doe #3 does not seek any additional discovery beyond that previously sought by Jane Doe #1 and Jane Doe #2. Accordingly. the United States will not be prejudiced or burdened by adding her to this case. Indeed, adding her to this case may simplify certain issues, as it appears that the United States 1 Because she was sexually assaulted as a minor, Jane Doc #3 proceeds in this motion by way of a pseudonym. 2 EFTA00188814

Case 9:08-cv-80736-KAM ,,ocument 291-2 Entered on FLSD D,..Ket 01/21/2015 Page 6 of 9 made no effort whatsoever to inform her about the non-prosecution agreement and cannot possibly argue otherwise, in contrast to certain limited steps that the United States may argue to have taken with regard to Jane Doe #1 and Jane Doe #2. The CVRA does not contain any statute of limitations for filing an action to enforce rights under the statute. Accordingly, her motion should be granted. Jane Doe #1 and Jane Doe #2 support the motion. The United States 'insert position xxxxxxxxxxxxxxxx I. CONCLUSION Jane Doe #3 should be allowed to join this action. A proposed order allowing her to join is attached to this pleading. DATED: August 20, 2014 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 3 EFTA00188815

Case 9:08-cv-80736-KAM —ocument 291-2 Entered on FLSD D,..Ket 01/21/2015 Page 7 of 9 MI& Attorneys for Jane Doe #3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on August 20, 2014, on the following using the Court's CM/ECF system: 500 S. Australian Ave., Suite 400 inis ma West Palm Beach, FL 33401 Attorneys for the Government Roy Black, Esq. Jackie Perczek Es . • Jay P. Lefkowitz Kirkland & Eli P Martin G. Weinberg. P.C. Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 4 EFTA00188816

Case 9:08-cv-80736-KAM Jcument 291-2 Entered on FLSD D. 01/21/2015 Page 8 of 9 1 SENDER: COMPLETE THIS SECTION Ill Complete Items 1, 2, and 3. Also complete hem 4 It Restricted Delivery Is desired. • Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back 01 the mailpiece, or on the front if space permits. 1. Article Addressed d to: FJ • 1,0 -Fre° 'Ferret,. S friltan €1/4/ &AAA to_n Nisi. Piet • qqt/6: "P" Miami, 33132- 3. Service Typo g °deed Mail' O Priority Mail Express" equered Paeturn Receipt to Merchandkre O Insured hail O Collect on Delivery 4. Restricted Del/very? lExtra Too) O Yes 2. Artk Mae PS Form 3811. July 2013 7012 2920 0002 1824 6972 Domestic Retum Receipt U.S. Postal Service,,., (CERTIFIED MAIL RECEIPT Domestic Man Onk No /nail/pace Covent°. Provided) t o : O ca nj C3 ru nturaidoeivw, O icriknornes,,__ reo cr ITl zilliPcubrio A Fond ru 0 O boa /42 72011 EFTA00188817

Case 9:08-cv-80736-KAM )cument 291-2 Entered on FLSD '<et 01/21/2015 Page 9 of 9 SENDER: COMPLETE THIS SECTION • Complete Items I. 2. and 3. Also complete item 4 it Restricted Delivery is desired. • Print your nano end address on the reverse so that yea can return the card to you. • Mach this card to the back ol the mailpeco. or on the front it space permits. 1. Ankle Addressed to: lAji redo erret) ' US A-Ihn-11 , €‘ TA 1, StA:sentQA O131-. r a qq ri 33/3z COMPLETE 774)5 SECTION ON DELIVERY 0 A9•It O Aneia* I C. Dare of Deng II YES. elk.. de.. cey addrig try adrlei m dem l? Yea --• ,C? AUG 3. Service Type E entk-yi tret Priority Marl Express_ rRogistoeed 55:Rarkm ?leapt /or Merchanda o insured mad 0 proem on °Ovary Fleatnewe Dairway?(Extre Fee) 0 yes 2. Ark (Tren PS Fomi. EFTA00188818

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Case 9:08-cv-80736-KAM _69cument 291-3 Entered on FLSD D. ,Ket 01/21/2015 Page 1 of 3 EXHIBIT 3 EFTA00188820

Case 9:08-cv-80736-KAM uocument 291-3 Entered on FLSD 01/21/2015 Page 2 of 3 iaui., Tam OmsActoon Personal Injury Wrongful Death Comm (((( litigation WWW.PATHT0JUSTICE COM Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. November 19. 2014 VIA CERTIFIED MAIL 7009 1680 0000 4959 2808 Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.G. 4th Street Miami. FL 33132 RE: Jane Does I and 2 1 United States Case No.: 08-80736-Civ-Marra/Johnson Dear Mr. Ferrer: I sent you a letter in August requesting your office's stipulation to our adding Jane Doe #3 in this case. Unfortunately. we did not receive a response from your office. We are hopeful that your lack of a response was simple oversight. In addition to following up on the August letter, we are now requesting your Stipulation to the adding of Jane Doe #4 as well. Her true name is She was identified by your office during the Federal Investigation, and consequently her name appeared on the list of victims attached to Mr. Epstein's Non-Prosecution Agreement. As we expressed in our personal meetings a couple years ago. we don't understand the tactical decision to be adversarial to the victims of known sexual abuse on every point in this litigation. Now that many of those issues we discussed have been resolved in our favor, it seems to make even more sense to avoid engaging in unnecessary battles that could only serve the purpose of delaying the victims' rights to have this case resolved on its merits. As I indicated in my August letter requesting your stipulation to the adding of Jane Doe #3, adding Jane Doe #4 will also not delay matters, so long as we can stipulate to her being added. Without a stipulation, we foresee litigation over this point, which will produce nothing but additional delay — and further question about your Office's commitment to full protection of victims' rights under the Crime Victims Rights Act. EFTA00188821

Case 9:08-cv-80736-KAM --Jcument 291-3 Entered on FLSD -Ket 01/21/2015 Page 3 of 3 Wifredo A. Ferrer November 19.2014 Page 2 Your office is very familiar with and her circumstance. She was sexually trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not only in this jurisdiction but throughout the United Slates and beyond. Unlike Jane Doe #3. Jane Doe #4 was included as a named victim in the NPA. There is no statute of limitations in bringing such claims, and I think we would agree that the current case is the best vehicle through which to bring these claims, as opposed to forcing us to file new actions and starting over on issues and claims inextricably intertwined with the current litigation. We don't see a good reason for denying our motion, so we anticipate prevailing at the end. But even if you were to object and prevail on the motion to add her to the current litigation, the only consequence would be that would then file a separate CVRA lawsuit, something she is entitled to do because the CVRA contains no time limit. We are simply trying avoid all this entirely unnecessary complication. We have, throughout this case, consciously avoided filing anything that would unnecessarily cast your office in a bad light, and it is again with that in mind that we request your stipulation here. We need this stipulation by December 10, 2014 to avoid delaying any other aspects of this case. We will not file any pleadings on this subject before that date. Lastly. we feel that we are once again at a stage in this litigation where it may make sense to meet again face-to-face to attempt to resolve, or at least narrow, some issues in an effort to avoid litigating some of the matters that we will be forced to litigate if the parties continue along this unreasonably adversarial path. Thanks in advance for considering this request. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Bradley J. Edwards BJE::mwk Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman, P.L. EFTA00188822

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Casa 9,08.-80,36-KAM -.amen, 291.4 Entered on ,S... -,...21,2015 Page 103 EXHIBITS 4 and 5 EFTA00188825

Case 9:08-cv-80736-KAM ‘document 291-4 Entered on FLSD D. _Ket 01/21/2015 Page 2 of 3 From: (USAFLS) Sent: Wednesday, December 03, 2014 1:03 PM To: Brad Edwards; (USAFLS) Cc: Paul Cassell Subject: RE: DoeiUS Brad, The US. Attorney has both your 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 ago, I told you that we represented and were considering adding her to this suit. At the time of our call we asked if you would agree to our adding her, and I understood that you would have to check with others. Consequently, I sent a couple of letters to Mr. Ferrer that I have attached to this email. I was hoping for a response letting me know that the Office would not oppose the amendments adding Doe 3 and 4. We also suggested in the letters that perhaps a meeting is in order at this point. I know you cannot speak for Mr. Ferrer on that point, which was another reason for addressing the letter to him. I realize our 11/19 letter asked for a response by the 10th. However, I was hoping you could give me some indication whether we will get an answer before the 10th (and perhaps what that answer will be), because if there will not be an agreement to adding these Plaintiffs then I want to get the Motion prepared. Let me know something as soon as you can. Thanks. Sincerely, &!(' Farmer, Jaffe, Wallis, Y i Edwards, Flatos & Lehrman, RL. Brad Edwards Board Certified Trial Attorney EFTA00188826

Case 9:08-cv-80736-KAM ,ocument 291-4 Entered on FLSD Dk....Ket 01/21/2015 Page 3 of 3 2 EFTA00188827

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Case 9:08-cv-80736-KAM iocument 291-5 Entered on FLSD 01/21/2015 Page 1 of 2 EXHIBIT 6 EFTA00188829

Case 9:08-cv-80736-KAM -document 291-5 Entered on FLSD L—ket 01/21/2015 Page 2 of 2 Subject: FW: Motion to Add Petitioners From: (USAFLS) Sent: Wednesday, December 10, 2014 4:49 PM To: Brad Edwards; Paul Cassell Subject: Motion to Add Petitioners Brad and Paul, The U.S. Attorney is on travel and I do not have an answer for you on whether the government will agree to the addition of two new petitioners. I appreciate you not filing your motion until December 10, 2014. If you need to file the motion, we understand. Thanks. 1 EFTA00188830

F e e E e 3 {4 EFTA00188831

Case 9:08-cv-80736-KAM Jcument 291-6 Entered on FLSD Di. ,et 01/21/2015 Page 1 of 2 EXHIBIT 7 EFTA00188832

Case 9:08-cv-80736-KAM -document 291-6 Entered on FLSD f.,.._.Ket 01/21/2015 Page 2 of 2 Subject: FW: Meeting in January 2015 From: (USAFLS) Sent: Tuesday, December 16, 2014 3:03 PM To: Brad Edwards; Paul Cassel Subject: Meeting in January 2015 Brad and Paul, We would like to schedule a meeting with the Executive Division, as you requested, for January 2015, at a time convenient for both of you. Also, do and wish to attend? Please let me know of a suitable time for all parties who wish to attend. Thanks. 1 EFTA00188833

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Case 9:08-cv-80736-KAM _ocument 291-7 Entered on FLSD DL-Ket 01/21/2015 Page 1 of 2 EXHIBIT EFTA00188835

Case 9:08-cv-80736-KAM Liocument 291-7 Entered on FLSD 01/21/2015 Page 2 of 2 Subject: FW: Meeting in January 2015 From: Brad Edwards Sent: Tuesday, December 16, 2014 3:49 PM To: Redacted (USAFLS); Paul Cassell Subject: RE: Meeting in January 2015 Thanks I am hopeful that we can use the meeting time to discuss a plan to bring this case to a streamlined resolution. I will check with the clients about attendance at the meeting. I believe that at least will want to attend. Paul and I will get you some dates that work on our end. In the meantime, I would like to get your agreement to our Motion to add • and as parties. They do not want to delay being added, and I see no reason for that delay anyway. Please let me know your position on that Motion. Thank you for getting back to me. We will get you some proposed meeting dates quickly and look forward to a productive meeting. Sincerely, Fanny; Jaffa, Wades Edwards, Fists, et Lehrman, RI.. Brad Edwards Board Certified Trial Attorney I EFTA00188836

I EFTA00188837

Case 9:08-cv-80736-KAM 'document 291-8 Entered on FLSD Lk ...Ket 01/21/2015 Page 1 of 2 EXHIBIT 9 EFTA00188838

Case 9:08-cv-80736-KAM Liocument 291-8 Entered on FLSD DI—Ket 01/21/2015 Page 2 of 2 Subject: FW: Meeting In January 2015 From: Brad Edwards Sent: Monday, December 22, 2014 12:17 PM To: Redacted (USARS); Paul Cassell Subject: RE: Meeting In January 2015 We have a few available dates to choose from. January 21-22 and 28-29. Hopefully one of those will work for you guys. On the motion to add and *, I don't believe you Indicated your position. As we said, we hoped you would agree, or at least not oppose, but either way we would like to know your position so that we can so inform the Court. Thanks again. Please let me know which meeting date works best so that those coming from out of town can make arrangements. Sincerely, Parravr, Joffe, Waxing, Echvards, Fists, te Lehrman, RL. Brad Edwards Board Certified Trial Attorney ;,,,,19(0.41D(.M9ii,9469 EFTA00188839

I EFTA00188840

Case 9:08-cv-80736-KAM L,ocument 291-9 Entered on FLSD .at 01/21/2015 Page 1 of 2 EXHIBIT 10 EFTA00188841

Case 9:08-cv-80736-KAM .,current 291-9 Entered on FLSD L ,et 01/21/2015 Page 2 of 2 Subject: FW: Meeting in January 2015 From: (USAFLS) Sent: Tuesday, December 23, 2014 6:19 PM To: Brad Edwards; Paul Cassell Subject: RE: Meeting in January 2015 Brad and Paul, We will let you know which dates are good for us. We actually wanted to discuss adding the new parties to the case at the meeting. Our position is that we oppose adding new petitioners at this stage of the litigation. Best Wishes for a wonderful holiday to you and your families. EFTA00188842

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Case 9:08-cv-80736-KAM uucument 291-10 Entered on FLSD 1.,-„Ket 01/21/2015 Page 1 of 7 EXHIBIT 11 EFTA00188844

Case 9:08-cv-80736-KAM Uucument 291-10 Entered on FLSD .et 01/21/2015 Page 2 of 7 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-15-000072 - 05 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. COMPLAINT Plaintiffs, BRADLEY J. EDWARDS and PAUL G. CASSELL, by and through their undersigned attorneys, sue the Defendant, ALAN M. DERSHOWITZ, and allege: 1. This is an action for damages in an amount in excess of the minimum jurisdictional limits of this Court. 2. PAUL G. CASSELL is a resident of the State of Utah, is sui juris, is a former United States federal judge, who is a professor at the S.J. Quinney College of Law at the University of Utah. He is and at all times material hereto has been a member in good standing of the Bar of the State of Utah and has been and continues to be admitted to practice pro hac vice in the State of Florida. 3. Prior to assuming his teaching responsibilities, PAUL G. CASSELL clerked first for the U.S. Court of Appeals for the D.C. Circuit (1984-1985) and then from 1985 to 1986 clerked for the United States Supreme Court before serving as an Associate Deputy Attorney EFTA00188845

Case 9:08-cv-80736-KAM L,,,,ument 291-10 Entered on FLSD 01/21/2015 Page 3 of 7 Edwards and Cassell'. Dershowttz Complaint General with the U.S. Justice Department and as an Assistant United States Attorney for the Eastern District of=1. 4. PAUL G. CASSELL was sworn in as a U.S. District Court Judge for the District of Utah in July of 2002 and served in that position for over 5 years before turning his full time attention to crime victims' rights and criminal justice reform. 5. PAUL G. CASSELL has at all material times enjoyed a highly favorable national reputation particularly related to his crime victims' rights work. 6. PAUL G. CASSELL has served as co-counsel with BRADLEY J. EDWARDS in representing the interests of multiple victims of billionaire, serial child abuser, Jeffrey Epstein, including in particular a pending action in Federal District Court for the Southern District of Florida under the federal Crime Victims' Rights Act (CVRA) which challenges the legality of a secret deal that immunized Jeffrey Epstein and associates of Epstein from federal criminal prosecution despite evidence that Epstein had sexually assaulted over 40 female minors on hundreds of occasions with the active help and participation of multiple associates. 7. BRADLEY J. EDWARDS is a resident of Broward County, Florida, is sui juris, and is and at all times material hereto has been an attorney duly licensed to practice law and regularly engaged in the practice of law throughout the State of Florida and beyond. 8. Despite having previously been the victim of character assassination by the Defendant, ALAN M. DERSHOWITZ'S associate and client, Jeffrey Epstein, BRADLEY J. EDWARDS enjoys a highly favorable national reputation particularly related to his work in defending the rights of child victims of sexual abuse. 2 EFTA00188846

Case 9:08-cv-80736-KAM uucument 291-10 Entered on FLSD L.....Ket 01/21/2015 Page 4 of 7 Edwards and Cassell. Dershowitz Complaint 9. Before entering the private practice of law, BRADLEY J. EDWARDS was a trial attorney at the Broward County State Attorney's Office responsible for the prosecution of many major and violent crimes. He is a Florida Bar Board Certified Civil Trial Attorney who has tried dozens of jury trials. BRADLEY J. EDWARDS has been profiled in The Best Lawyers in America and recognized by the National Trial Lawyers Association by inclusion in its "Top 40 Under 40" listing. BRADLEY J. EDWARDS' professional peers have given him a Martindale-Hubbell rating of "AV" attesting to the highest level of professional excellence and unquestionable ethics. 10. BRADLEY J. EDWARDS has been actively involved for the better part of the last decade in representing multiple victims of the billionaire, serial child abuser, Jeffrey Epstein. 11. Defendant, ALAN M. DERSHOWITZ, upon information and belief is a resident of the State of Florida and is sui juris. 12. Defendant, ALAN M. DERSHOWITZ, is an attorney whose involvement in multiple high-profile legal matters has enabled him to command easy access to mass media news sources. 13. Defendant, ALAN M. DERSHOWITZ, was one of a very large team of lawyers involved in defending Jeffrey Epstein during his criminal investigation, and according to DERSHOWITZ'S own public statements, DERSHOWITZ was responsible for negotiating Epstein's secret deal with the federal government which afforded protection not only to Epstein but to various of his associates as well. 3 EFTA00188847

Case 9:08-cv-80736-KAM is..n.ument 291-10 Entered on FLSD 01/21/2015 Page 5 of 7 Edwards and Cassell Dershowitz Complaint 14. In fulfillment of their obligations to two Epstein-victim clients, BRADLEY J. EDWARDS and PAUL G. CASSELL filed and have been aggressively prosecuting a legal action in the Federal District Court as previously described in Paragraph 6. 15. BRADLEY J. EDWARDS and PAUL G. CASSELL on behalf of two additional Epstein-victim clients sought the agreement of the federal government to permit those clients to intervene in the already pending CVRA action. The government declined to agree to the intervention, thus requiring EDWARDS and CASSELL to file legal pleadings seeking a Court Order permitting intervention on the basis of specifically alleged factual allegations. 16. Among the factual allegations made by EDWARDS and CASSELL were allegations that Defendant, DERSHOWITZ, had knowledge of and participation in Epstein's criminal conduct. 17. Immediately following the filing of what the Defendant, DERSHOWITZ, knew to be an entirely proper and well-founded pleading, DERSHOWITZ initiated a massive public media assault on the reputation and character of BRADLEY J. EDWARDS and PAUL G. CASSELL accusing them of intentionally lying in their filing, of having leveled knowingly false accusations against the Defendant, DERSHOWITZ, without ever conducting any investigation of the credibility of the accusations, and of having acted unethically to the extent that their willful misconduct warranted and required disbarment. 18. The details of Defendant, DERSHOWITZ'S character assassination of BRADLEY J. EDWARDS and PAUL G. CASSELL are typified by the contents of the CNN interview available to be accessed on the intemet at: 4 EFTA00188848

Case 9:08-cv-80736-KAM 1.,,....ument 291-10 Entered on FLSD L_ _..et 01/21/2015 Page 6 of 7 Edwards and Cassell Dershowitz Complaint http://www.enn.comhoic/o1/05/europe/prince-andrew-sex-abuse-allegationsfindex.htmlit That interview is incorporated herein by reference. 19. The same or substantially identical accusations of deliberate misconduct and unethical behavior warranting disbarment of the Plaintiffs were repeated by the Defendant, DERSHOWITZ, in multiple nationally televised interviews, in statements to and repeated by national and international print news sources, and various other forms nationally and internationally. 20. The Defendant, DERSHOWITZ'S statements were false and known by him to be false at the time they were made. DERSHOWITZ was speaking from his Miami residence at the time he made the false and defamatory statements. 21. Alternatively, DERSHOWITZ made the statements in reckless disregard of their truth or falsity, intending that the statements would provide support for DERSHOWITZ'S false protestations of his own innocence and direct attention away from DERSHOWITZ'S personal knowledge of and involvement in Epstein's criminal conduct and the subsequent cover up of that misconduct. 22. DERSHOWITZ'S statements were and are defamatory per se directly attacking the fitness of the Plaintiffs to engage in the honored profession of the practice of law. 23. DERSHOWITZ acted in willful, wanton, reckless, and intentional disregard of the rights of the Plaintiffs and under such circumstances as to warrant the imposition of punitive damages. 5 EFTA00188849

Case 9:08-cv-80736-KAM Lnicument 291-10 Entered on FLSD 01/21/2015 Page 7 of 7 Edwards and Cassell Dershowitz Complaint 24. As the statements made by DERSHOWITZ are defamatory per se, injury to the Plaintiffs is presumed as a matter of law. WHEREFORE, Plaintiffs demand judgment against the Defendant, ALAN M. DERSHOWITZ, for compensatory damages, costs, pre and post-judgment interest, and such other and further relief as the Court may deem appropriate under the circumstances. Plaintiffs reserve the right to assert claims for punitive damages upon satisfying the applicable statutory prerequisites. Plaintiffs further demand trial by jury. Dated this r day of January, 2015. Attorneys for Plaintiffs Scarola Barnhart & Shipley, P.A. 6 EFTA00188850

I I EFTA00188851

Case 9:08-cv-80736-KAM D.,..ument 291-11 Entered on FLED D,_.set 01/21/2015 Page 1 of 2 EXHIBIT 12 EFTA00188852

Case 9:08-cv-80736-KAM L....cument 291-11 Entered on FLSD D. _Ket 01/21/2015 Page 2 of 2 ALAN M. DERSHOWITZ 1575 MASSACHUSETTS AVENUE CAMBRIDGE • MASSACHUSETTS • 02138 August 15, 2011 Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley Re: Edwards adv. Epstein Dear Mr. Scarola: As you may know, I was Jeffrey Epstein's attorney when he submitted his guilty plea. Accordingly, "any knowledge" I may have in connection with that plea is privileged information. If you would let me know what non-privileged information you would seek from me, I would then be able to decide whether to cooperate. Sincerely, Alan ershowitz EFTA00188853

EFTA00188854

Case 9:08-cv-80736-KAM Locument 291-12 Entered on FLSD D.—Ket 01/21/2015 Page 1 of 2 EXHIBIT 13 EFTA00188855

Case 9:08-cv-80736-KAM DL, _anent 29SrArno FLSD DENNEY (~WEBT PALM BEACH OFFlCE: SCAROLA BARNART e-SHIPHLEY. ATTORNEYS AT LAW IVSAYN SA BAREA-SARHES F. omoorrf BARNHART T. MARNE ems. III LWRIE J.SFIGOS BRIAN k DENNEY •EARL L DENIES JO BRENDA S. ROUSES JAMES W. OUSTAFSOK JR. JACK P. Ili DAVID IL KELLEY. a. VELUM B. ION& DARRYL L. LEWIS' 'WILLIAM A. NORTON • NEC 'JOHN M:IOLA tHRISTAN D. SEARCY WS A. SHIPLEY • CHRISTOPHER K. SPEW EMS AEIALIVAN KARIM ILTIWW 'C. CAVAN WANNER M SHAREHOLDERS 'DYAD CERTEREO SyGGONGED awn •'swam • kthearawerrre • tew ~MAE %sty • WASHNOTON DC PARALEGALS MAN AYSTEADA RANGY It Mlle* DAVOS. SWOPE JOHN C HOPKINS DEBORAH a KNAPP WWII I._ LEONARD. .10. ALOES PETER LOVE ROBERT W. AMER MARE P. PORGY KATHLEEN SUCH SIEVE It SAUDI BENNIE S. STARK WALTER A. STEIN August 23, 2011 Alan M. Dershowitz, Esquire Re: Edwards adv. Epstein Our File No.: 291874 Dear Mr. Dershowitz: at 01/21/2015 Page 2 of 2 Oral I 411ASSPF • THE TOWLE HOUSE We do not intend to inquire about any privileged communications or attorney work product. We do, however, have reason to believe that you have personally observed Jeffrey Epstein in the presence of underage females, and we would like the opportunity to question you under oath about those observations. Thank you for your anticipated cooperation. Bradley J. Edwards, Esq. (850) 224-7000 141004142-7011 WWW.S ARCYLAW COM EFTA00188856

EFTA00188857

Case 9:08-cv-80736-KAM Lnicument 291-13 Entered on FLSD L._ ,Ket 01/21/2015 Page 1 of 2 EXHIBIT 14 EFTA00188858

Case 9:08-cv-80736-KAM a Jment 29t AtEryan FLSD C. .;et 01/21/2015 Page 2 of 2 DENNEY WEST PAW MACH OFFICE' SCAROLA BARNHART ATTOITsICYS AT RAW'. POSALYN SIA IlAKEWONVMS 'F. GREGORY DAMMAM T.MARCH BASS. III LYME J.I3ROCIS OMAN It PINNEY ORSTIDA L MAIM 'AMMO GARCIA AMIESWLITHITAMON. JR. VON P ML DAVID It KELLEY, Jlt mum &lac' worm L urns' L NORTON NIEPIXY 'JOHN SCARIXA 'MMUS IX MARCY fl A. MOMS M CMISTOPSIM KS/EEO" arum P SAWN., ta KAREN LLCM 'C.CALVINWARRINER IS MOM= MIN. L. MOM JR, SHARDIOLOVIS bOAM CFRTIFC0 61.5116111101ED wantiCv um ARnJlO ▪ Aussocnusuris WISSISSPPI ' NEW HAMM* WA CC PARHAM'S: VIVIAN AY/ASMARA MNUf /A. DUFRESNE OAVO W MAMIE JOIN O HOPICHS CIANA LAN/CC MOOR/A It KNAPP MGM L tEOPORO JR. JAMES PETER LOPE ROOM W. PRISM HAM P PORGY KATHLEEN SIAM STEVE IA 57JRH SPAM S. STARK WALTER A STEIN VIA EMAIL AND U.S. MAIL [email protected] September 7, 2011 Alan M. Dershowitz, Esquire Re: Edwards adv. Epstein Our File No.: 291874 Dear Mr. Dershowitz: dG adi DUI 'AMASS °MCA' While we are certainly under no obligation to disclose either the basis for our wanting to depose you or the subject matter of our intended inquiry, we are willing to respond to your request as a matter of professional courtesy. Multiple individuals have placed you in the presence of Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the company of underage females subsequently identified as victims of Mr. Epstein's criminal molestations. This information is derived from both sworn testimony and private interviews. Your personal observations regarding such circumstances would clearly not involve any privileged communications, and it is those observations that will be the primary focus of our questioning. Please let us know when and where you will be available. Sincerely, Dictated But Not Signed By Jack Scarola To Expedite Delivery JACK SCAROLA JS/mep cc: Bradley J. Edwards, Esquire WWW.SEARCYLAWCOM EFTA00188859

EFTA00188860

Case 9:08-cv-80736-KAM L.,,,,;ument 291-14 Entered on FLSD L. Ket 01/21/2015 Page 1 of 2 EXHIBIT 15 EFTA00188861

Case 9:08-cv-80736-KAM L.,%;ument 291-14 Entered on FLSD D. xet 01(21/2015 Page 2 of 2 Subject: FW: Bradley Edwards'. Epstein Original Message From: Jack Scarola Sent: January 03, 2015 6:19 PM To: Alan Dershowitz Cc: Paul Cassell; William B. King; Brad Edwards; Mary E. Pirrotta Subject: Bradley Edwards I. Epstein Dear Mr. Dershowitz: Statements attributed to you in the public media express a willingness, indeed a strong desire, to submit to questioning under oath regarding your alleged knowledge of Jeffrey Epstein's extensive abuse of underage females as well as your alleged personal participation in those activities. As I am sure you will recall, our efforts to arrange such a deposition previously were unsuccessful, so we welcome your change of heart. Perhaps a convenient time would be in connection with your scheduled appearance in Miami on January 19. I assume a subpoena will not be necessary since the deposition will be taken pursuant to your request, but please let us know promptly if that assumption is inaccurate. Also, note that the deposition will be video recorded. Kindly bring with you all documentary and electronic evidence which you believe tends to refute the factual allegations made concerning you in the recent CVRA proceeding as well as passport pages reflecting your travels during the past ten years and copies of all photographs taken while you were a traveling companion or house guest of Jeffrey Epstein's. Thank you for your anticipated cooperation. Sincerely, Jack Scarola ****4 ******* #4.44,**4.4*****ii#4.***************************.$4 , titialMfi*********4..*******## Privileged and Confidential Electronic communication is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. 52510-2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify the sender immediately by e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you. l***************iiki*ii**************44,404***************************************4.0#4,*****.li EFTA00188862

c EFTA00188863

Case 9:08-cv-80736-KA... Document 291-15 Entered on FL:. Docket 01/21/2015 Page 1 of 40 EXHIBIT 16 EFTA00188864

Case 9:08-cv-807eaVA. 34Cmswt 20g.z11%4Ilernojik68nyocSstal,(20y3315 Page 2 of EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00188865

Case 9:08-cv-807aUty:.3a3sEmt 2Doc T6Q 3erFledn047(Jts/T'IooPage-Zoygg15 Page 3 of IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 50 2009 CA 0408003OOOCMBAG 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 compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment #1).1 2. Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous When questioned about 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-settled that the Fifth Amendment does not forbid adverse inferences against parties civil actions when they refuse to testify in response to mobative evidence offered against them." Baxter Pahnigiano, 425 U.S. 308, 318 (1976); accord Vasquez'. Slate, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A party may not trample upon the rights of others nd then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser.. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). EFTA00188866

Case 9:08-cv-807Ni Vam aKW 2WpeeerNar rai Rmiyocisstg21420n915 Page 4 of occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assaults included vaginal penetration. Epstein abused many of the girls dozens if not hundreds of times. Epstein Depo. at 109 ("Q: How many times have you engaged in oral sex with females under the age of 1ST' A: [Invocation of the Fifth Amendment]); Deposition of Jane Doe, September 24, 2009 and continued March 11, 2010, a15 =MMI EMEND MIE MINIM M=INIIMME MEE 2 NMI EFTA00188867

Case 9:08-cv-80702i1S:349git:MV 28?).al,p6Qtojergeocpc149.68/190c.itsstg232/20i/N15 Page 5 of 3. At all relevant times Edwards has had a good faith basis to conclude and did conclude' that Epstein was able to access a large number of underage girls through a pyramid abuse scheme in which he paid underage victims $2004300 cash for each other underage victim that she brought to him. See Palm Beach Police Incident Report at 87 (hereinafter "Incident Report") (Exhibit "A").3 The Palm Beach Police Incident Report details Epstein's scheme for molesting underage females. Among other things, the Incident Report outlines some of the experiences of other Epstein victims. When S.G, a 14 year old minor at the time, was brought to Epstein's home, she was taken upstairs by a woman she believed to be Epstein's assistant. The woman started to fix up the room, putting covers on the massage table and bringing lotions out. The "assistant" then left the room and told S.G. that Epstein would be up in a second. Epstein walked over to S.G. and told her to take her clothes off in a stem voice. S.G. states in the report she did not know what to do, as she was the only one there. S.G. took off her shirt, leaving her bra on. Epstein, then in a towel told her to take off everything. S.G. removed her pants leaving on her thong panties. Epstein then instructed S.G to give him a massage. As S.G gave Epstein a massage, Epstein turned around and masturbated. S.G. was so disgusted, she did not say anything; Epstein told her she "had a really hot body." Id. at 14. In the report, S.G. admitted seeing Jeffrey Epstein's penis and stated she thought Epstein was on steroids because he was a "really built guy and his wee wee was very tiny." Id at 15. 4. The exact number of minor girls who Epstein assaulted is known only to Epstein. However, Edwards had a good faith basis to believe and did in fact believe that Epstein's victims were substantially more than forty (40) in number. In addition to the deposition excerpts from two of his many victims above about the number of underage girls brought to Epstein and the Palm Beach 2 In support of all assertions concerning the actions Edwards took, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit. For clarity, depositions attached to this memorandum will be identified numerically as attachments NI, #2, #3, etc., while exhibits attached to this memorandum will be identified alphabetically as exhibits A, 13, C, etc. 3 EFTA00188868

Case 9:08-cv-807.36-KA,.,. DowMeot 291-15 Entered on,FU- Docket 0JJ21/2015 Page 6 of se 09-34/9i -Now -Doc 16%3 raeo u4rott/li Fage ot incident report, there is overwhelming proof that the number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 J Epstein, (hereinafter Jane Doe 102 complaint) (Exhibit "B"); see also Deposition of Jeffrey Epstein, April 14, 2010, at 442, 443, and 444 (Epstein invoking the 5th on questions about his daily abuse and molestation of children) (Deposition Attachment #6). 5. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that Epstein and his attorneys knew of the seriousness of the criminal investigation against him and corresponded constantly with the United States Attorney's Office in an attempt to avoid the filing of numerous federal felony offenses, which effort was successful. See Correspondence from U.S. Attorney's Office to Epstein (hereinafter "U.S. Attorney's Correspondence") (Composite Exhibit "C) (provided in discovery during the Jane Doe. Epstein case). 6. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that, more specifically, Epstein's attorneys knew of Epstein's scheme to recruit minors for sex and also knew that these minors had civil actions that they could bring against him. In fact, there was much communication between Epstein's attorneys and the United States Prosecutors in a joint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter reads in pertinent part, "The undersigned, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide information relevant to your service as a Special Master in the selection of an attorney to represent several young women who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the "United States") have conducted an investigation of Jeffrey Epstein regarding his solicitation of minor females in Palm Beach County to engage in prostitution. Mr. Epstein, through his assistants, would recruit underage females to travel to his home in Palm Beach to 4 EFTA00188869

Case 9:08-cv-8072Mt. .-31/7tRiggt 2810.-ci 64flierVaLli wi yocntg21420y3815 Page 7 of engage in lewd conduct in exchange for money. Based upon the investigation, the United States has identified forty (40) young women who can be characterized as victims pursuant to 18 USC 2255. Some of those women went to home o once sin sent As part of the resolution of the case, Epstein has agreed that he would not contest jurisdiction in the Southern District of Florida for any victim who chose to sue him for damages pursuant to 18 USC 2255. Mr. Epstein agreed to provide an attorney for victims who elected to proceed exclusively pursuant to that section, and agreed to waive any challenge to liability under that section up to an amount agreed to by the parties. The parties have agreed to submit the selection of an attorney to a Special Master...." 7. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that fl was, in fact, a victim of Epstein's criminal abuse becausa. was one of the minor females that the United States Attorney's Office recognized as a victim. Ms sworn deposition testimony and the adverse inference drawn from Epstein's refusal to testify confirm that Epstein began sexually assaulting IN when she was 13 years old and continued to molest her on more than fifty (50) occasions over three (3) years. Epstein Depo., Attachment #1, at 17 ("Q: Did you . . . ever engage in any sexual conduct with gil?" A: [Invocation of the Fifth Amendment].); see also Epstein Depo., April 14, 2010, Attachment #6, at 456 ("Q: ,was an underage female that you first abused when she was 13 years old; is that correct?" A: (Invocation of Fifth Amendment].) 8. Epstein was also given ample opportunity to explain why he engaged in sexual activity with beginning when was 13 years old and why he has molested minors on an everyday basis for years, and he invoked his 5th amendment right rather than provide explanation. See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition Attachment # 7). 9. Epstein also sexually assaulted al, beginning when she was 14 years old and did so on numerous occasions. See.. Depo., Attachment #4 at 215-216. 10. Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse began 5 EFTA00188870

Case 9:08-cv-80721%.-3figsM 2Raltu i ygier iiicpa to8.1.Rocisstg2y2oV3815 Page 8 of when Jane Doc was 14 years old. Rather than incriminate himself, Epstein invoked the 5th amendment to questions about him ME Epstein Depo., April 14, 2010, Attachment #6, at 420, 464, 468. 11. When Edwards's clientsM.,IR., and Jane Doe were 13 or 14 years old, each was brought to Epstein's home multiple times by another underage victim. Epstein engaged in one or more of the following acts with each of the then-minor girls at his mansion: See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane Doe I. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice") (Exhibit "E"); Jane Doe Depo., Attachment #2, at 379-380; 5. Depo., Attachment #3, at 416;5. Depo, Attachment #4, at 205. 12. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that yet another of the minor girls Epstein sexually assaulted was C.L. When she was approximately 15 years old, C.L. was brought to Epstein's home by another underage victim. While a minor, she was at Epstein's home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - 6 See Rule 413 Notice, EFTA00188871

Case 9:08-cv-8072=S:349git4illfRt 28(lialfa rerftDdi cf4Ith,8KROSIsstalecy3915 Page 9 of Exhibit "E"; Incident Report, Exhibit "A." 13. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that yet another girl Epstein sexually assault we. When she was approximately 16 years old, she was brought to Epstein's home by another underage victim. While a minor, she was at Epstein's home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house a II MS IIMINIMMIMMIMIE". See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A", at 41 (specifically discussing the rape): 14. Without detailing each fact known about Epstein's abuse of the many underage girls, Edwards has had a good faith basis to believe and did in fact believe at all relevant times that Epstein also abused other victims in ways closely similar to those described in the preceding paragraphs. Epstein's additional victims include the following (among many other) young girls: F.E.; These girls were between the ages of 13 and 7 EFTA00188872

Case 9:08- cv-807n-sIM -3W.pmmt 2Viiji a rgereflagg 61.6ilocIfpgelq3.1W5 Page 10 of 17 when Epstein abused them. See Rule 413 Notice, RYbibit E; Deposition of.., Deposition Attachment #4. 15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodriguez was aware that "sex toys" and vibrators were found in Epstein's bedroom after the purported massages. Id. at 223-28. Rodriguez thought what Epstein was doing was wrong, given the extreme youth of the girls he saw. Id. at 230-31. 16. Alfredo Rodriguez took a journal from Epstein's computer that reflected many of the names of underage females Epstein abused across the country and the world, including locations such as Michigan, California, West Palm Beach, New York, New Mexico, and Paris, France. See Journal (hereinafter "The Journal" or "Holy Grail") (Exhibit "F") (identifying, among other Epstein acquaintances, females that Rodriguez believes were underage under the heading labeled "Massages"). 17. Rodriguez was later charged in a criminal complaint with obstruction of justice in connection with trying to obtain $50,000 from civil attorneys pursuing civil sexual assault cases against Epstein as payment for producing the book to the attorneys. See Criminal Complaint at 2, U.S. I. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez stated he needed money because the journal was his "property" and that he was afraid that Jeffrey Epstein would make him "disappear" unless he had an "insurance policy" (i.e., the journal). Id. at 3. Because of the importance of the information in the journal to the civil cases, Mr. Rodriguez called it "The Holy Grail." 18. In the "Holy Grail" or "The Journal," among the many names listed (along with the abused girls) are some of the people that Epstein alleges in his Complaint had "no connection whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00188873

Case 9:08-cv-807.36-KA6. Doc gmeOt 291-15 Egere.d oriSI Jocket 1/21/2M.5 Page 11 of t;ase OU-34/9-r<btrt uoc 1604 rueo 04/06/11 rage 'mot (Bill Clinton phone numbers listed under "Doug Bands"). federal Investigation and Plea Alinement With Epstein 19. In approximately 2005, the FBI and the U.S. Attorney's Office in the Southern District of Florida learned of Epstein's repeated sexual abuse of minor girls. They began a criminal investigation into federal offenses related to his crimes. See U.S. Attorney's Correspondence, Exhibit 20. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that to avoid the Government learning about his abuse of minor girls, Epstein threatened his employees and demanded that they not cooperate with the government. Epstein's aggressive witness tampering was so severe that the United States Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows: "UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER" On August 21, 2007, FBI icia.gents E. and traveled to the home of to serve her with a federal !mitagiljay subpoena with an investigation pending in the Sotaifrict of Florida. ME= works as the personal assistant of the defendant. began speaking with the agents then excused herself to go upstairs to check on her sleeping child. While upstairs, NE telephoned the defendant, Jeffrey Epii informed him that the FBI agents were at her home. Mr. Epstein instructed not to speak with the agents and IN lmanded her for allowing them into her home. Mr. Epstein applied pressure to keep M from complying with the grand j i iiikahenas that the agents had served upon her. In particular, Mr. Epstein warned ME= against tuning over documents and electronic evidence responsive to the subpoena and pressured her to delay her appearance before the grand jury in the Southern District of Florida. This conversation occurred when Mr. Epstein was aboard his privately owned civilian aircraft in Miami in the Southern District of Florida. His pilot had filed a flight plan showy66 arties were about to return to Teterboro, NJ. After the conversation with , Mr. M in became concerned that the FBI would try to serve his traveling companion, Marcinkova, with a similar grand jury subpoena. In fact, the agents were 9 EFTA00188874

Case 9:08-cv-807211/8la.13413gsS 2 BOACVeril giAla im)ocisstg21/pgna5 Page 12 of preparing to serve Ms. with a target letter when the flight landed in Teterboro. Mr. Epstein tila ilrected his airplane, making the pilot file a new flight plan to travel to the US Virgin Islands instead of the New York City area, thereby keeping the Special Agents from serving the target letter on During the flight, the defendant verbally harassed Ms. harassing an pressuring her not to cooperate with the grand jury's Investigation, thereby hindering and dissuading her from reporting the commission of a violation of federal law to a law enforcement officer namely, Special Agents of the FBI. Epstein also threatened and harassed against cooperating against him as well. 21. Edwards learned that the Palm Beach police department investigation ultimately led to the execution of a search warrant at Epstein's mansion in October 2005. See Police Incident Report, Exhibit "A". 22. Edwards learned that at around the same time, the Palm Beach Police Department also began investigating Epstein's sexual abuse of minor girls. They also collected evidence of Epstein's involvement with minor girls and his obsession with training sex slaves, including pulling information from Epstein's trash. Their investigation showed that Epstein ordered from Amazon.com on about September 4, 2005, such books as: SMI01: A Realistic Introduction, by Jay Wiseman; SlaveCraft: Roadmaps for Erotic Servitude - Principles, Skills, and Tools, by Guy Baldwin; and Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Receipt for Sex Slave Books (Exhibit "I"). 23. The Palm Beach incident reports provided Edwards with the names of numerous witnesses that participated in Epstein's child molestation criminal enterprise and also provided Edwards with some insight into how far-reaching Epstein's power was and how addicted Epstein was to sex with children. See Incident Report, Exhibit "A". 24. The Palm Beach Police Department also collected Epstein's message pads, which provided other names of people that also knew Epstein's scheme to molest children. See Message Pads (Exhibit "J") (note: the names of underage females have been redacted to protect the anonymity 10 Abernathy. See EFTA00188875

Case 9:08-cv-80736-KAAN 11Q4CUfflefit - ease 09-34 (91-KBY'Y 280Cl?EaerValCi4A71-? ocket 01z /21/2°15 Page 13 of Hag° ot 9 of the underage sex abuse victims). Those message pads show clear indication that Epstein's staff was frequently working to schedule multiple young girls between the ages of 12 and 16 years old literally every day, often two or three times per day. Id. 25. In light of all of the information of numerous crimes committed by Epstein, Edwards learned that the U.S. Attorney's Office began preparing the filing of federal criminal charges against Epstein. For example, in addition to the witness tampering and money laundering charges the U.S. Attorney's Office prepared an 82-page prosecution memo and a 53-page indictment of Epstein related to his sexual abuse of children. On September 19, 2007, at 12:14 PM, AUSA wrote to Epstein's counsel, Jay Lefkowitz, "Jay - I hate to have to be firm about this, but we need to wrap this up by Monday. I will not miss my indictment date when this has dragged on for several weeks already and then, if things fall apart, be left in a less advantageous position than before the negotiations. I have had an 82-page pros memo and 53-page indictment sitting on the shelf since May to engage in these negotiations. There has to be an ending date, and that date is Monday." These and other communications are within the correspondence attached as Composite Exhibit "C." 26. Edwards learned that rather than face the filing of federal felony criminal charges, Epstein (through his attorneys) engaged in plea bargain discussions. As a result of those discussions, on September 24, 2007, Epstein signed an agreement with the U.S. Attorney's Office for the Southern District of Florida. Under the agreement, Epstein agreed to plead guilty to an indictment pending against him in the 15th Judicial Circuit in and for Palm Beach County charging him with solicitation of prostitution and procurement of minors for prostitution. Epstein also agreed that he would receive a thirty month sentence, including 18 months of jail time and 12 months of community control. In exchange, the U.S. Attorney's Office agreed not to pursue any federal charges against Epstein. See Non-Prosecution Agreement (Exhibit "K"). 11 EFTA00188876

Case 9:08-cv-807aM349mrgt 283.z1/1 0Uterffleocita c§ 71 peociIgl ign5 Page 14 of 27. Part of the Non-Prosecution Agreement that Epstein negotiated was a provision in which the federal government agreed not to prosecute Epstein's co-conspirators. The co-conspirators procured minor females to be molested by Epstein. One of the co-conspirators - even participated in the sex acts with minors (including...) and Epstein. See Incident Report, Exhibit "A", at 40-42, 49-51; Deposition of April 13, 2010, (hereinafter Depo.") at 11 (Deposition attachment #9). 28. Under the Non-Prosecution Agreement, Epstein was to use his "best efforts" to enter into his guilty pleas by October 26, 2007. However, Edwards learned that Epstein violated his agreement with the U.S. Attorney's Office to do so and delayed entry of his plea. See Letter from U.S. Attorney R. Alexander Acosta to Lilly Ann Sanchez, Dec. 19, 2007 (Exhibit "L"). 29. On January 10, 2008 and again on May 30, 2008.. and.. received letters from the FBI advising them that "iglus case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." Letters attached at Composite Exhibit "M". This document is evidence that the FBI did not notify and that a plea agreement had already been reached that would block federal prosecution of Epstein. Nor did the FBI notify.. and.. of any of the parts of the plea agreement. Nor did the FBI or other federal authorities confer with. and. about the plea. See id. 30. In 2008, Edwards believed in good faith that criminal prosecution of Epstein was extremely important to his clients and.. and that they desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of Epstein. The letters that they had received around January 10, 2008, suggested that a criminal investigation of Epstein was on-going and that they would be contacted before the federal government reached any final resolution of that investigation. See id 12 EFTA00188877

Case 9:08-ov- 80706- K iet1341:Mi t 1301c-11 ter ase 0 Wig 2 Nigel05111)01011110.42.B.5 Page 15 of Edwards Legal Counsel Victims o r E stein ¶s Sexual Assaults 31. In about April 2008, Bradley J. Edwards, Esq., was a licensed attorney in Florida, practicing as a sole practitioner. As a former prosecutor, he was well versed in civil cases that involved criminal acts, including sexual assaults. Three of the many girls Epstein had abused — M., and Jane Doe — all requested that Edwards represent them civilly and secure appropriate monetary damages against Epstein for repeated acts of sexual abuse while they were minor girls. Two of the girls ( . 1 . and..) also requested that Edwards represent them in connection with a concern that the Federal Bureau of Investigation (FBI) and U.S. Attorney's Office might be arranging a plea bargain for the criminal offenses committed by Epstein without providing them the legal rights to which they were entitled (including the right to be notified of plea discussions and the right to confer with prosecutors about any plea arrangement). See Affidavit of Bradley J. Edwards, Esq. at 11 - 2,14 (hereinafter "Edwards Affidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent..; on July 2, 2008, attorney Edwards agreed to represent Jane Doe; and, on July 7, 2008, attorney Edwards agreed to represent M. in connection with the sexual assaults committed by Epstein and to insure that their rights as victims of crimes were protected in the criminal process on-going against Epstein. Mr. Edwards and his three clients executed written retention agreements. See id at 12. 33. In mid June of 2008, Edwards contacted AUSA to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. AUSA Villafafia did not advise that a plea agreement had already been negotiated with Epstein's attorneys that would block federal prosecution. To the contrary, AUSA mentioned a possible indictment. AUSA did indicate that federal investigators had concrete evidence and information that Epstein had sexually molested many underage minor females, including.., M, and Jane Doe. See id at 14. 13 EFTA00188878

Case 9:O8-cv-8O7ekM.:3496,mwt 28m,koigergiec(poti6, yor3Agliql/f241315 Page 16 of 34. Edwards also requested from the U.S. Attorney's Office the information that they had collected regarding Epstein's sexual abuse of his clients. However, the U.S. Attorney's Office, declined to provide any such information to Edwards. It similarly declined to provide any such infommtion to the other attorneys who represented victims of Epstein's sexual assaults. At the very least, this includes the items that were confiscated in the search warrant of Epstein's home, including dildos, vibrators, massage table, oils, and additional message pads. See Property Receipt (Exhibit "O"). 35. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA called Edwards to provide notice to his clients regarding the hearing. AUSA did not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. See Edwards Affidavit, Exhibit "N", at ¶6. 36. Under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, victims of federal crimes — including.. and II. — are entitled to basic rights during any plea bargaining process, including the right to be treated with fairness, the right to confer with prosecutors regarding any plea, and the right to be heard regarding any plea. The process that was followed leading to the non- prosecution of Epstein violated these rights of.. and It . See Emergency Petn. for Victim's Enforcement of Crime Victim's Rights, No. 9:08-CV-80736-KAM (S.D. Fla. 2008) (Exhibit "P"). 37. Because of the violation of the CVRA, on July 7, 2008, Edwards filed an action in the U.S. District Court for the Southern District of Florida, Case No. 9:08-CV-80736, seeking to enforce the rights of . and.. That action alleged that the U.S. Attorney's Office bad failed to provide and In. the rights to which they were entitled under the Act, including the right to be notified 14 EFTA00188879

Case 9:08-ov-807agin 1349gige 2ag.-6110VeM eocriAlasiigocisstglaygn5 Page 17 of about a plea agreement and to confer with prosecutors regarding it. See id. 38. On July 11, 2008, Edwards took and with him to the hearing on the CVRA action. It was only at this hearing that both victims learned for the fast time that the plea deal was already done with Epstein and that the criminal case against Epstein had been effectively terminated by the U.S. Attorney's office. See Hearing Transcript, July 11, 2008 (Exhibit "Q"). 39. Edwards learned that Jane Doe felt so strongly that the plea bargain was inappropriate that she made her own determination to appear on a television program and exercise her First Amendment rights to criticize the unduly lenient plea bargain Epstein received in a criminal case. 40. The CVRA action that Edwards filed was recently administratively closed and Edwards filed a Motion to reopen that proceeding. See No. 9:08-CV-80736 (S.D. Fla.). Epstein's Entry of Guilty Pleas to Sex Offenses 41. Ultimately, on June 30, 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, defendant Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. See Plea Colloquy (Exhibit "R"). 42. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, Epstein additionally entered into an agreement with the Federal Government acknowledging that approximately thirty-four (34) other young girls could receive payments from him under the federal statute providing for compensation to victims of child sexual abuse, 18 U.S.C. § 2255. As had been agreed months before, the U.S. Attorney's Office did not prosecute Epstein federally for his sexual abuse of these minor girls. See Addendum to Non- Prosecution Agreement (Exhibit "5") (in redacted form to protect the identities of the minors involved). 15 EFTA00188880

Case 9:08-cv-807aileo.9:3ffis_ gt 2gl-c1. 60erV iesig4LAvigocisstgCjI,R1015 Page 18 of 43. Because Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-contact order applied to "all of the victims." Similar orders were entered by the federal court handling some of the civil cases against Epstein. The federal court stated that it "finds it necessary to state clearly that Defendant is under this court's order not to have direct or indirect contact with any plaintiffs . . . ." Order, Case No. 9:08-cv-80119 (S.D. Ha. 2008), [DE 238] at 4-5 (emphasis added); see also Order, Case No. 9:08-cv-80893, [DE 193] at 2 (emphasis added). Edwards Files Civil Suits Azainst Epstein 44. Edwards had a good faith belief that his clients felt angry and betrayed by the criminal system and wished to prosecute 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 Doc. See Edwards Affidavit, "N" at ¶7. Included in this complaint was a RICO count that explained how Epstein ran a criminal conspiracy to procure young girls for him to sexually abuse. See Complaint, Jane Doe'. Epstein (Exhibit "T"). 45. On September 11, 2008, at the request of his client Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of.. See Complaint,..'. Epstein (Exhibit "U"). 46. On September 11, 2008, at the request of his client..., Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of.. See Complaint, M. I. Epstein, (Exhibit 1"). 47. Jane Doe's federal complaint indicated that she sought damages of more than $50,000,000. 16 EFTA00188881

Case 9:08-cv-807dlin4:349mgit 283.64 0Wtergleoeb56-871 90clsOli/R.F.R.5 Page 19 of Listing the amount of damages sought in the complaint was in accord with other civil suits that were filed against Epstein (before any lawsuit filed by Edwards). See Complaint, Jane Doe #41. Epstein (Exhibit "W") (filed by Herman and Mermelstein, PA). 48. At about the same time as Edwards filed his three lawsuits against Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herman filed on behalf of his seven clients were similar in tenor and tone to the complaint that Edwards filed on behalf of his three clients. See id. 49. Over the next year and a half, more than 20 other similar civil actions were filed by various attorneys against Epstein alleging sexual assault of minor girls. These complaints were also similar in tenor and tone to the complaint that Edwards filed on behalf of his clients. These complaints are all public record and have not been attached, but are available in this Court's files and the files of the U.S. District Court for the Southern District of Florida. 50. In addition to the complaints filed against Epstein in Florida, a female in New York, Ave Cordero, filed a lawsuit against Epstein in New York making similar allegations - 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 a baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York Post, October 17, 2007, by Dareh Gregorian, link at: http://www.mmost.com/pinews/reirionaliitem 44zlWvLUFH7R1OUtICYGPbP;isessionid=6CA3EBF1 BEF68F5DEI4BFB2CAA5C37E0. See Article attached hereto as Exhibit "X". 17 EFTA00188882

Case 9:08-cv-807ag;•It§;349Bm'nt 2lKialP60Uerglecn r46 c ?ocogpig iephis Page 20 of 51. EdwEuts's three complaints against Epstein contained less detail about sexual abuse than (as one example) a complaint filed by attorney Robert Josephsberg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 1021. Epstein (Exhibit "B"). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein's house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein were flying her all over the world. According to the Complaint, Jane Doe 102 was forced to live as one of Epstein's underage sex slaves for years and was forced to have sex with not only Maxwell and Epstein but also other politicians, businessmen, royalty, academicians, etc. She was even made to watch Epstein have sex with three 12-year-old French girls that were sent to him for his birthday by a French citizen that is a friend of Epstein's. Luckily, Jane Doe 102 escaped to Ella to get away from Epstein and Maxwell's sexual abuse. 52. Edwards learned that in addition to civil suits that were filed in court against Epstein, at around the same time other attorneys engaged in pre-filing settlement discussions with Epstein. Rather than face filed civil suits in these cases, Epstein paid money settlements to more than 15 other women who had sexually abused while they were minors. See articles regarding settlements attached hereto as Composite Exhibit "Y," gystein is Obstruction offormal Discovery and Attacks on His Victims 53. Once Edwards filed his civil complaints for his three clients, he began the normal process of discovery for cases such as these. He sent standard discovery requests to Epstein about his sexual abuse of the minor girls, including requests for admissions, request for production, and interrogatories. See Edwards Affidavit, Exhibit "N", at 9¶11 -19 and 25. Rather than answer any substantive questions about his sexual abuse and his conspiracy for procuring minor girls for him to abuse, Epstein invoked his 5th amendment right against self-incrimination. An 18 EFTA00188883

Case 9:08-cv-807ailt349mpt 20g.Aoigterglara citn yockypith/t2915 Page 21 of example of Epstein's refusal to answer is attached as Composite Exhibit "Z" (original discovery propounded to Epstein and his responses invoking 5th amendment). 54. During the discovery phase of the civil cases filed against Epstein, Epstein's deposition was taken at least five times. During all of those depositions, Epstein refused to answer any substantive questions about his sexual abuse of minor girls. See, e.g., Deposition Attachments 1, 6 and 7. 55. During these depositions, Epstein further attempted to obstruct legitimate questioning by inserting a variety of irrelevant information about his case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon advice of counsel, I cannot answer that question. They've advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse me, against--under the Constitution. And though your partner, Jeffrey Herman, was disbarred after filing this lawsuit [a statement that was untrue], Mr. Edwards' partner sits in jail for fabricating cases of a sexual nature fleecing unsuspecting Florida investors and others out of millions of dollars for cases of a sexual nature with--I'd like to answer your questions; however if I--I'm told that if I do so, I risk losing my counsel's representation; therefore I must accept their advice." Epstein deposition, March 8, 2010, at 106 (Deposition attachment #10). 56. When Edwards had the opportunity to take Epstein's deposition, he only asked reasonable questions, all of which related to the merits of the cases against Epstein. All depositions of Epstein in which Mr. Edwards participated on behalf of his clients are attached to this motion. See Edwards Affidavit, Exhibit "N" at 1111 and Deposition attachments #1, 6, 7, 10, 11, 12, and 13. a. with Deposition of Epstein taken by an attorney representing BB (one in which Edwards was not 19 EFTA00188884

Case 9:08-cv-80702i la n ayiwt 28?).elp60erWapAL/687.RocisstAl.g3ty915 Page 22 of participating), and 57. Edwards's efforts to obtain information about Epstein's organization for procuring young girls was also blocked because Epstein's co-conspirators took the Fifth. Deposition of- !, March 24, 2010 (hereinafter MB Depo.") (Deposition attachment #14); Deposition of , April 13, 2010, (Deposition attachment #9); Deposition of Ross, March 15, 2010 (hereinafter "Ross Depo.") (Deposition attachment #15). Each of these co- conspirators invoked their respective rights against self-incrimination as to all relevant questions, and the depositions have been attached. 58. At all relevant times Edwards has had a good faith basis to believe and did in fact believe was an employee of Epstein's and had been identified as a defendant in at least one of the complaints against Epstein for her role in bringing girls to Epstein's mansion to be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on all substantive questions regarding her role in arranging for minor girls to come to Epstein's mansion to be sexually abused. Reinhart had previously been an Assistant United States Attorney in the U.S. Attorney's Office for the Southern District of Florida when Epstein was being investigated criminally by Reinhart's office. Reinhart left the United States Attorney's Office and was immediately hired by Epstein to represent Epstein's pilots and certain co-conspirators during the civil cases against Epstein. See Edwards Affidavit, Exhibit "N" at 911. 59. Edwards also had other lines of legitimate discovery blocked through the efforts of Epstein and others. For example, Edwards learned through deposition that Ghislaine Maxwell was involved in managing Epstein's affairs and companies. See deposition of Epstein's house manager Janusz Banziak, February 16, 2010 at page 14, lines 20-23 (Deposition Attachment #16); See 20 EFTA00188885

Case 9:08- cv- 807agilaw-3ffistggt 281.-a6oWerTiimcfa ti.RocK,01R7945 Page 23 of deposition of Epstein's housekeeper October 20, 2009, page 9, lines 17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Attachment #8); See also Prince Andrew's Friend, Ginslaine Maxwell, Some Underage Girls and A Very Disturbing Story, September 23, 2007 by Wendy link at http://www.redicecreations.com/article.php7id=1895OHANNA SJOBERG. Exhibit "AA". 60. Alfredo Rodriguez testified that Maxwell took photos of girls without the girls' knowledge, kept the images on her computer, knew the names of the underage girls and their respective phone numbers and other underage victims were molested by Epstein and Maxwell together. See Deposition of Rodriguez, Deposition attachment # 8 at 64, 169-170 and 236. 61. In reasonable reliance on this and other information, Edwards served Maxwell for deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Greaser, and Edwards understood that her attorney was paid for (directly or indirectly) by Epstein. She was reluctant to give her deposition, and Edwards tried to work with her attorney to take her deposition on terms that would be acceptable to both sides. The result was the attached confidentiality agreement, under which Maxwell agreed to drop any objections to the deposition, attached hereto as Exhibit "CC." Maxwell, however, contrived to avoid the deposition. On June 29, 2010, one day before Edwards was to fly to NY to take Maxwell's deposition, her attorney informed Edwards that Maxwell's mother was deathly ill and Maxwell was consequently flying to England with no intention of returning to the United States. Despite that assertion, Ghislaine Maxwell was in fact in the country on July 31, 2010, as she attended the wedding of Chelsea Clinton (former President Clinton's daughter) and was captured in a photograph taken for OK magazine. Photos from Issue 809 of the publication See US Weekly dated August 16, 2010 are attached hereto as 21 EFTA00188886

Case 9:08-cv-807MS:328imt 28d.ji5605wersleocpcfilowiyocisstaypc0,945 Page 24 of Exhibit "DD" and Edwards Affidavit, Exhibit "N" at 112. 62. Maxwell is not the only important witness to lie to avoid deposition by Edwards. Upon review of the message pads that were taken from Epstein's home in the police trash pulls, see Exhibit "J" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's closest pals. He left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to teach you how to speak Russian. She is 2x8 years old, not blonde. Lessons are free and you can have your 1st today if you call." See Messages taken from Jean Luc Brunel are attached hereto as Exhibit "BE." In light of these circumstances of the case, this message reasonably suggested to Edwards that Brunel might have been procuring two eight-year-old girls for Epstein to sexually abuse. According to widely circulated press reports reviewed by Edwards, Brunel is in his sixties and has a reputation throughout the world (and especially in the modeling industry) as a cocaine addict that has for years molested children through modeling agencies while acting as their agent — conduct that has been the subject of critical reports, books, several news articles, and a 60 Minutes documentary on Brunel's sexual exploitation of underage models. See http://bmdmillershero.bloaspot.coro/2010/08/wornen-are-objects.html, attached hereto as Exhibit "FF." 63. Edwards learned that Brunel is also someone that visited Epstein on approximately 67 occasions while Epstein was in jail. See Epstein's jail visitor log attached as Exhibit "GG." 64. Edwards learned that Brunel currently runs the modeling agency MC2, a company for which Epstein provides financial support. See Message Pad's attached as Exhibit "3" supra and Sworn Statement of MC2 employee =ME June 15, 2010, Sworn Statement" attached at Exhibit "HH" at 1-16. 65. Employees of MC2 told Edwards that Epstein's numerous condos at 301 East 66 Street in New York were used to house young models. Edwards was told that MC2 modeling agency, 22 EFTA00188887

Case 2 9:08-cv-8073K A G0 t 34 .4,M 283.A60V erNeocricrztli&viD ocket 01/21 O/01 eas 6-e Og: /9 1 vage Z4 f .595 Page 25 of affiliated with Epstein and Brunel brought underage girls from all over the world, promising them modeling contracts. Epstein and Brunel would then obtain a visa for these girls, then would charge the underage girls rent, presumably to live as underage prostitutes in the condos. See MENII. Sworn Statement, Exhibit "RH" at 7-10, 12-15, 29-30, 39-41, 59-60 and 62-67. 66. In view of this information suggesting Brunel could provide significant evidence of Epstein's trafficking in young girls for sexual abuse, Edwards had Brunel served in New York for deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit "II." Before the deposition took place, Brunt's attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brunel was actually staying with Epstein in West Palm Beach. See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidencing Jean Luc Brunel (JLB) staying at his house during that relevant period of time attached Exhibit "D". As a result, Edwards filed a Motion for Contempt, attached hereto as Exhibit "KK" (Because Epstein settled this case, the motion was never ruled upon.) 67. Edwards was also informed that Epstein paid for not only Brunel's representation during the civil process but also paid for legal representation for (Epstein's executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers (Epstein's personal pilot), Larry (Epstein's personal pilot), (Epstein's housekeeper), (Epstein's live-in sex slave), Ghislaine Maxwell (manager of Epstein's affairs and businesses), Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's house manager) It was nearly impossible to take a deposition of someone that would have helpful information that was not represented by an attorney paid for by Epstein. See Edwards Affidavit, 23 EFTA00188888

Case 9:08-cv-807=/a013498meiiit 2,1%.j,p6ogeri eodicri6087,Roskestg23,gla.5 Page 26 of Exhibit "N" at ¶11. 68. While Epstein and others were preventing any legitimate discovery into his sexual abuse of minor girls, at the same time he was engaging (through his attorneys) in brutal questioning of the girls who had filed civil suits against him, questioning so savage that it made local headlines. See Jane Musgrave, Victims Seeking Sex offender's Millions See Painful Pasts Used Against Them, Palm Beach Post News, Jan. 23, 2010, available at http://www.nalmbeachnost.com/news/crimeivictims- seekina-sex-offenders-millions-see-nainful-nasts-192988.html attached hereto as Exhibit "LL." Edwards Pursues Other Lines of Discovery 69. Because of Epstein's thwarting of discovery and attacks on Edwards's clients, Edwards was forced to pursue other avenues of discovery. Edwards only pursued legitimate discovery designed to fiuther the cases filed against Epstein. See Edwards Affidavit, Exhibit "N" at 70. Edwards notified Epstein's attorneys of his intent to take Bill Clinton's deposition. Edwards possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine Maxwell who was Epstein's longtime companion and helped to run Epstein's companies, kept images of naked underage children on her computer, helped to recruit underage children for Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and photographed underage females in sexually explicit poses and kept child pornography on her computer; (b) it was national news when Clinton traveled with Epstein aboard Epstein's private plane to Africa and the news articles classified Clinton as Epstein's friend. (c) the complaint filed on behalf of Jane Doe No. 102 stated generally that she was required by Epstein to be sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances" — categories Clinton and acquaintances of Clinton fall into. The flight logs showed Clinton traveling on Epstein's plane on numerous occasions between 2002 and 2005. See 24 EFTA00188889

Case 9:08-cv-80736-Km.,, Document 291-15 Entered on Docket 01J21/2D.15 Page 27 of Case 09-34791-RBR Doc 16040 Filed 04/08/11 P' age Zioi ot 39 Flight logs attached hereto as Exhibit "MM." Clinton traveled on many of those flights with Ghislaine Maxwell, MI, and - all employees and/or co-conspirators of Epstein's that were closely connected to Epstein's child exploitation and sexual abuse. The documents clearly show that Clinton frequently flew with Epstein aboard his plane, then suddenly stopped - raising the suspicion that the friendship abruptly ended, perhaps because of events related to Epstein's sexual abuse of children. Epstein's personal phone directory from his computer contains e-mail addresses for Clinton along with 21 phone numbers for him, including those for his assistant (Doug Band), his schedulers, and what appear to be Clinton's personal numbers. This information certainly leads one to believe that Clinton might well be a source of relevant information and efforts to obtain discovery from him were reasonably calculated to lead to admissible evidence. See Exhibits "B", "F" "AA", "OD", and "MM" and Edwards Affidavit, Exhibit "N" at 115. 71. Bradley J. Edwards, Esq., provided notice that he intended to take the deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several occasions during the time period most relevant to my Edwards's clients' complaints; (b) Trump was quoted in a Vanity Fair article about Epstein as saying "1've known Jeff for fifteen years. Terrific guy," "He's a lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it — Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, Kevin Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder who he is. By Landon Thomas Jr. (See article attached hereto as Exhibit "NN") (c) Trump allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein 25 EFTA00188890

Case 9:08-cv-807211159._313gsigpt 28Oalf605eriliclier41/0871c)(xlVg2ypoczyg.5 Page 28 of sexually assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe 102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged was used to have sex with underage girls); (f) Trump had been to Epstein's home in Palm Beach; (g) Epstein's phone directory from his computer contains 14 phone numbers for Donald Trump, including emergency numbers, car numbers, and numbers to Trump's security guard and houseman. Based on this information, Edwards reasonably believed that Trump might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. See deposition of Mark Epstein, September 21, 2009, at 48-50 (Deposition Attachment #19); See Jane Doe 102 1 Epstein, Exhibit "B"; Exhibit "F"; "Exhibit"J"; "N" and See Edwards Affidavit, Exhibit "N" at 113. 72. Edwards provided notice that he intended to depose Alan Dershowitz. Edwards possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with Epstein for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th book... The only person outside of my immediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See article attached as Exhibit "OO"); (c) Epstein's housekeeper Alfredo Rodriguez testified that Dershowitz stayed at Epstein's house during the years when Epstein was assaulting minor females on a daily basis; (d) Rodriguez testified that Dershowitz was at Epstein's house at times when underage females where there being molested by Epstein (see Alfredo Rodriguez deposition at 278-280, 385, 426-427); (e) Dershowitz reportedly assisted in attempting to persuade the Palm Beach State Attorney's Office that because the underage females alleged to have been victims of Epstein's abuse lacked credibility and could not be believed 26 EFTA00188891

Case 9:08-cv-807ale% .:3498?..irt 21311560LTerNe111055-tfiRcei4SgVallef215 Page 29 of that they were at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house; (f) Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances" — categories that Dershowitz and acquaintances of Dershowitz fall into; (g) during the years 2002-2005 Alan Dershowitz was on Epstein's plane on several occasions according to the flight logs produced by Epstein's pilot and information (described above) suggested that sexual assaults may have taken place on the plane; (h) Epstein donated $30 Million one year to the university at which Dershowitz teaches. Based on this information, Edwards had a reasonable basis to believe that Dershowitz might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. See Dershowitz letters to the State Attorney's office attached as Exhibit "PP"; Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit "MM"; Exhibits "B" and "OO"; and Edwards Affidavit, Exhibit "N" at /14. 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 notice that he intended to take David Copperfield's deposition. Edwards possessed a legitimate basis for doing so. Epstein's housekeeper and one of the only witnesses who did not appear for deposition with an Epstein bought attorney, Alfredo Rodriguez, testified that David Copperfield was a guest at Epstein's house on several occasions. His name also appears frequently in the message pads confiscated from Epstein's house. It has been publicly reported that Copperfield himself has had allegations of sexual misconduct made against him by women claiming he sexually abused them, and one of Epstein's sexual assault victims also alleged that Copperfield had touched her 27 EFTA00188892

Case 9:08-cv-807ags-ItV-34t.i ggi BeNt 2N12.15605(4er_Vd0F4Igl if.{ iseatg0eliltig5 Page 30 of in an improper sexual way while she was at Epstein's house. Mr. Copperfield likely has relevant information and deposition was reasonably calculated to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at 117. 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 Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable inference he was sexually abusing these girls as he had abused girls in West Palm Beach and elsewhere. Richardson had also returned campaign donations that were given to him by Epstein, indicating that he believed that there was something about Epstein with which he did not want to be associated. Richardson was not called to testify nor was he ever subpoenaed to testify. See Edwards Affidavit, Exhibit "N" at 118. 76. Edwards learned of allegations that Epstein engaged in sexual abuse of minors on his private aircraft. See Jane Doe 102 Complaint, Exhibit "B." Accordingly, Edwards pursued discovery to confirm these allegations. 77. Discovery of the pilot and flight logs was proper in the cases brought by Edwards against Epstein. Jane Doe filed a federal RICO claim against Epstein that was an active claim through much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal enterprise that involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing Edwards' clients intended to pursue an appeal of that dismissal. Moreover, all of the subjects mentioned in the RICO claim remained relevant to other aspects of Jane Doe's claims against Epstein, including in particular her claim for punitive damages. See Edwards Affidavit, Exhibit "N" at 119. 28 EFTA00188893

Case 9:08-cv-80736-KAM L,,,cuFTBesit 291-15 Enter d Page 1/05 Page 31 of R Doc 16046 hi ecgi0F40S8?1 i :30 of 39 Case 09-34791- 78. Discovery of the pilot and flight logs was also proper in the cases brought by Edwards against Epstein because of the need to obtain evidence of a federal nexus. Edwards's client Jane Doe was proceeding to trial on a federal claim under 18 U.S.C. § 2255. Section 2255 is a federal statute which (unlike relevant state statutes) established a minimum level of recovery for victims of the violation of its provisions. Proceeding under the statute, however, required a "federal nexus" to the sexual assaults. Jane Doe had two grounds on which to argue that such a nexus existed to her abuse by Epstein: first, his use of telephone to arrange for girls to be abused; and, second, his travel on planes in interstate commerce. During the course of the litigation, Edwards anticipated that Epstein would argue that Jane Doe's proof of the federal nexus was inadequate. These fears were realized when Epstein filed a summary judgment motion raising this argument. In response, the other attorneys and Edwards representing Jane Doe used the flight log evidence to respond to Epstein's summary judgment motion, explaining that the flight logs demonstrated that Epstein had traveled in interstate commerce for the purpose of facilitating his sexual assaults. Because Epstein chose to settle the case before trial, Judge Marra did not rule on the summary judgment motion. 79. Edwards had further reason to believe and did in fact believe that the pilot and flight logs might contain relevant evidence for the cases against Epstein. Jane Doe No. 102's complaint outlined Epstein's daily sexual exploitation and abuse of underage minors as young as 12 years old and alleged that Epstein's plane was used to transport underage females to be sexually abused by him and his friends. The flight logs accordingly were a potential source of information about either additional girls who were victims of Epstein's abuse or friends of Epstein who may have witnessed or even participated in the abuse. Based on this information, Edwards reasonably pursued the flight logs in discovery. 80. In the fall of 2009, Epstein gave a recorded interview to George Rush, a reporter with 29 EFTA00188894

Case 9:08-cv-80736-KAM i.s4culnegt 291-15 Ent Case 09 34791 - Doc ° 160405er°Priledn0Fa1 figtgitlyMa5 Page 32 of the New York Daily News about pending legal proceedings. In that interview, Epstein demonstrated an utter lack of remorse for his crimes (but indirectly admitted his crimes) by stating: • People do not like it when people make good and that was one reason he (Epstein) was being targeted by civil suits filed by young girls in Florida; • He (Epstein) had done nothing wrong; • He (Epstein) had gone to jail in Florida for soliciting prostitution for no reason; • If the same thing (i.e., sexual abuse of minor girls) had happened in New York, he (Epstein) would have received only a S200 fine; • Bradley J. Edwards was the one causing all of Epstein's problems (i.e., the civil suits brought by Jane Doe and other girls); • came to him as a prostitute and a drug user (i.e., came to Epstein for sex, rather than Epstein pursuing her); • All the girls suing him are only tying to get a meal ticket; • The only thing he might have done wrong was to maybe cross the line a little too closely; • He (Epstein) was very upset that Edwards had subpoenaed Ghisline Maxwell, that she was a good person that did nothing wrong (i.e., had done nothing wrong even though she helped procure young girls to satisfy Epstein's sexual desires); • With regard to Jane Doe 102'. Epstein, which involved an allegation that Epstein had repeatedly sexually abused a 15-year-old girl, forced her to have sex with his friends, and flew her on his private plane nationally and internationally for the purposes of sexually molesting and abusing her, he (Epstein) flippantly said that the case was • dismissed, indicating that the allegations ware ridiculous and untrue. See Affidavit of Michael J. Fisten attached hereto as Fihibit "QQ." 81. The Rush interview also demonstrated perjury (a federal crime) on the part of Epstein. Epstein lied about not knowing George Rush. See Epstein Deposition, February 17, 2010, taken in ■. I. Jeffrey Epstein, case 50-2008-CA-028051, page 154, line 4 through 155 line 9, (Deposition attachment #7), wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News. This impression was given despite the fact that he gave a lengthy 30 EFTA00188895

Case 9:08-cv-80736-KAM L...1cument 291-15 Entered on F1,382 Page .5 Page 33 of Case 09-34791-RBR Doc 1604O Filed 04/08/11 32 of 39 personal interview about details of the case that was tape recorded with George Rush. Epstein's Harassment of Witnesses Against Him 82. At all relevant times Edwards has a good faith basis to believe and did in fact believe that Epstein engaged in threatening witnesses. See Incident Report, Exhibit "A" at p. 82, U.S. Attorney's Correspondence, Exhibit "C" - Indictments drafted by Federal Government against Epstein; and Edwards Affidavit, Exhibit "N" at ill. 83. Despite three no contact orders entered against Epstein (see Exhibit C, supra), Edwards learned that Epstein continued to harass his victims. For example, Jane Doe had a trial set for her civil case against him on July 19, 2010. As that trial date approached, defendant Epstein intimidated her in violation of the judicial no-contact orders. On July 1, 2010, he had a "private investigator" tail Jane Doe — following her every move, stopping when she stopped, driving when she drove, refusing to pass when she pulled over. When Jane Doe ultimately drove to her home, the "private investigator" then parked in his car approximately 25 feet from Jane Doe house and flashed his high beam lights intermittently into the home. Even more threateningly, at about 10:30 p.m., when Jane Doe fled her home in the company of a retired police officer employed by Jane Doe's counsel, the "private investigator" attempted to follow Jane Doe despite a request not to do so. The retired officer successfully took evasive action and placed Jane Doe in a secure, undisclosed location that night. Other harassing actions against Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe', Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit "RR." Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 84. The civil cases Edwards filed against Epstein on behalf of III., and Jane Doe were reasonably perceived by Edwards to be very strong cases. Because Epstein had sexually 31 EFTA00188896

Case 9:08-cv-80736-KAM ,cument 291-15 Entered on Firsap Page1/21/205 Page 34 of Case 09-34791-RBR Doc 16046 Filed 04/08/11 33 ot 39 assaulted these girls, he had committed several serious torts against them and would be liable to them for appropriate damages. See Preceding Undisputed Facts. Because of the outrageousness of Epstein's sexual abuse of minor girls, Edwards reasonably expected that Epstein would also be liable for punitive damages to the girls. Because Edwards could show that Epstein had molested children for years and designed a complex premeditated scheme to procure different minors everyday to satisfy his addiction to sex with minors, the punitive damages would have to be sufficient to deter him from this illegal conduct that he had engaged in daily for years. Epstein was and is a billionaire. See Complaint, 149 (referring to "Palm Beach Billionaire"); see also Epstein Deposition, February 17, 2010, at 172- 176 (Deposition Attachment #7) (taking the Fifth when asked whether he is a billionaire). Accordingly, Edwards reasonably believed the punitive damages that would have to be awarded against Epstein would have been substantial enough to punish him severely enough for his past conduct as well as deter him from repeating his offenses in the future. See Edwards Affidavit, Exhibit "N" at 119. 85. On July 6, 2010, rather than face trial for the civil suits that had been filed against him by NI, and Jane Doe, defendant Epstein settled the cases against him. The terms of the settlement are confidential. The settlement amounts are highly probative in the instant action as Epstein bases his claims that Edwards was involved in the Ponzi scheme on Epstein's inability to settle the II. II., and Jane Doe cases for "minimal value". His continued inability to settle the claims for "minimal value" after the Ponzi scheme was uncovered would be highly probative in discrediting any causal relationship between the Ponzi scheme and Edwards's settlement negotiations. See Edwards Affidavit, Exhibit "N" at 121. Edwards Non-Involvement in Fraud by Scott Rothstein 86. From in or about 2005, through in or about November 2009, Scott Rothstein appears to 32 EFTA00188897

Case 9:08-cv-80C6st gsi-1346tuRrgwit 2en ofatergieocroF40 c. osa l'e)W 0,15 Page 35 of have run a giant Ponzi scheme at his law finn of Rothstein, Rosenfeldt and Adler P.A. ("RRA"). This Ponzi scheme involved Rothstein falsely informing investors that settlement agreements had been reached with putative defendants based upon claims of sexual harassment and/or whistle-blower actions. Rothstein falsely informed the investors that the potential settlement agreements were available for purchase. Plea Agreement at 2, United States I Scott W. Rothstein, No. 9-60331-CR- COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit "SS." 87. It has been alleged that among other cases that Rothstein used to lure investors into his Ponzi scheme were the cases against Epstein that were being handled by Bradley J. Edwards, Esq. Edwards had no knowledge of the fraud or any such use of the Epstein cases. See Edwards Affidavit, Exhibit "N" at ¶9. 88. Bradley J. Edwards, Esq., joined RRA in about April 2009 and left RRA in November 2009 — a period of less than one year. Edwards would not have joined RRA had be been aware that Scott Rothstein was running a giant Ponzi scheme at the feint. Edwards left RRA shortly after learning of Rothstein's fraudulent scheme. Id. at ¶8. 89. At no time prior to the public disclosure of Rothstein's Ponzi scheme did Edwards know or have reason to believe that Rothstein was using legitimate claims that Edwards was prosecuting against Epstein for any fraudulent or otherwise illegitimate purpose. Id at ¶20. 90. Edwards never substantively discussed the merits of any of his three cases against Epstein with Rothstein. See Deposition of Bradley J. Edwards taken March 23, 2010, at 110-16. (hereinafter "Edwards Depo") (Deposition Attachment #22). 91. On July 20, 2010, Bradley Edwards received a letter from the U.S. Attorney's Office for the Southern District of Florida — the office responsible for prosecuting Rothstein's Ponzi scheme. The letter indicated that law enforcement agencies had determined that Edwards was "a victim (or potential 33 EFTA00188898

Case 9:08-cv-80736-KARA • t 9011- ief Case 06'23417OW striocIAOW6 Ne°c110P,4A51 14age o ) et °W1/2M5 Page 36 of r 39 victim)" of Scott Rothstein's federal crimes. The letter informed Edwards of his rights as a victim of Rothstein's fraud and promised to keep Edwards informed about subsequent developments in Rothstein's prosecution. See Letter attached hereto as Exhibit "It" 92. Jeffrey Epstein filed a complaint with the Florida Bar against Bradley Edwards, Esq., raising allegations that Edwards and others were involved in the wrongdoing of Scott Rothstein. After investigating the claim, the Florida Bar dismissed this complaint See Edwards Affidavit, Exhibit "N" at ¶23. Epstein Takes the Filth When Asked Substantive Questions About His Claims Against Edwards 93. On March 17, 2010, defendant Epstein was deposed about his lawsuit against Edwards. Rather than answer substantive questions about his lawsuit, Epstein repeatedly invoked his Fifth Amendment privilege. See Epstein Depo. taken 3/17/10, Deposition Attachment #1. 94. In his deposition, Epstein took the Fifth rather than answer the question: "Specifically what are the allegations against you which you contend Mr. Edwards ginned up?" Id at 34. 95. In his deposition, Epstein took the Fifth rather than name people in California that Edwards had tried to depose to increase the settlement value of the civil suit he was handling. Id. at 37. 96. In his deposition, Epstein took the Fifth rather than answer the question: "Do you know former President Clinton personally." Id. 97. In his deposition, Epstein took the Fifth rather than answer the question: "Are you now telling us that there were claims against you that were fabricated by Mr. Edwards?" Id at 39. 98. In his deposition, Epstein took the Fifth rather than answer the question, "Well, which of Mr. Edwards' cases do you contend were fabricated." Id 99. In his deposition, Epstein took the Fifth rather than answer the question: "What is the 34 EFTA00188899

Case 9:08-cv-80736-KAM L acument 291-15 Entered on F LSD L _ _.ket 01/21/2015 Page 37 of Case 09-34791-RBR Doc 1603K, Filed 04/08/11 Page 36 of 39 actual value that you contend the claim of E.W. against you has?" Id. at 45. 100. In his deposition, Epstein took the Fifth rather than answer a question about the actual value of the claim of and Jane Doe against him. Id. 101. In his deposition, taken prior to the settlement of Edwards's clients claims against Epstein, Epstein took the Fifth rather than answer the question: "Is there any pending claim against you which you contend is fabricated?" Id. at 71. 102. In his deposition, Epstein took the Fifth rather than answer the question: "Did you ever have damaging evidence in your garbage?" Id. at 74. 103. In his deposition, Epstein took the Fifth rather than answer the question: "Did sexual assaults ever take place on a private airplane on which you were a passenger?" Id. at 88. 104. In his deposition, Epstein took the Fifth rather than answer the question: "Does a flight log kept for a private jet used by you contain the names of celebrities, dignitaries or international figures?" Id. at 89. 105. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Donald Trump in the presence of females under the age of 18?" Id. at 89. 106. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Alan Dershowitz in the presence of females under the age of 18." Id at 90. 107. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Mr. Mottola in the presence of females under the age of 18?" Id. at 91-92. 108. In his deposition, Epstein took the Fifth rather than answer the question: "Did you ever socialize with David Copperfield in the presence of females under the age of 18?" Id. at 109. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Mr. Richardson [Governor of New Mexico and formerly U.S. Representative and 35 EFTA00188900

Case 9:08-cv-807_36-KAM ,,cument 291-15 Entered on FLSD L.. aPge1/21/2015 Page 38 of Case 09-34791-RBR Doc Mat, Filed 04/08/11 37 of 39 Ambassador to the United Nations] in the presence of females under the age of 18." Id at 94. 110. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever sexually abused children?" Id. at 95. 111. In his deposition, Epstein took the Fifth rather than answer the question: "Did you have staff members that assisted you in scheduling appointments with underage females; that is, females under the age of 18." Id at 97-98. 112. In his deposition, Epstein took the Fifth rather than answer the question: "On how many occasions did you solicit prostitution." Id. at 102. 113. In his deposition, Epstein took the Fifth rather than answer the question: "How many minors have you procured for prostitution?" Id at 104. 114. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever coerced, induced or enticed any minor to engage in any sexual act with you?" Id. at 107. 115. In his deposition, Epstein took the Fifth rather than answer the question: "How many times have you engaged in fondling underage females?" Id at 108. 116. In his deposition, Epstein took the Fifth rather than answer the question: "How many times have you engaged in oral sex with females under the age of 18?" Id. at 110. 117. In his deposition, Epstein took the Fifth rather than answer the question: "Do you have a personal sexual preference for children?" Id at 111-12. 118. In his deposition, Epstein took the Fifth rather than answer the question: "Your Complaint at page 27, paragraph 49, says that 'REA and the litigation team took an emotionally driven set of facts involving alleged innocent, unsuspecting, underage females and a Palm Beach billionaire, and sought to turn it into a goldmine,' end of quote. Who is the Palm Beach billionaire referred to in that sentence?" Id at 112-13. 36 EFTA00188901

Case 9:08-cv-80736-KAM _.cument 291-15 Entered on FL$D L_ Page 21 15 Page 39 of Case 09-34791-RBR Doc 16030 Filed 04/08111 38 ot 39 119. In his deposition, Epstein took the Fifth rather than answer the question: "Who arc the people who are authorized to make payment [to your lawyers] on your behalf?" Id at 120. 120. In his deposition, Epstein took the Fifth rather than answer the question: "Is there anything in.'s Complaint that was filed against you in September of 2008 which you contend to be false?" Id. at 128. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September old i,2010 a copy of the foregoing has been served via U.S. Mail and email transmittal to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Bamhart & Shipley By: 37 OL No.: 169440 EFTA00188902

Case 9:08-cv-80736-KAM ,current 291-15 Entered on FLSD L_ Ket 01/21/2015 Page 40 of Case 09-34791-RBR Doc 16048 Filed 04/08/11 Page 39 of 39 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. P.A. FOWLER WHITE ETJRNE'IT Jack Alan Goldberger, Esq. A b Goldber er et al. Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman. P.L. 38 EFTA00188903

EFTA00188904

Case 9:08-cv-80736-KAivi Document 291-16 Entered on PLS.. Jocket 01/21/2015 Page 1 of 3 EXHIBIT 17 EFTA00188905

Case 9:08-cv-80736-KAiv, Document 291-16 Entered on FLS Jacket 01/21/2015 Page 2 of 3 Elvaznuuetateen January 14, 2015 SEARCY DENNEY SCAROLA BARNHART Fr-SHIPLEY, His Royal Highness The Duke of York ATTORNEYS AT LAW. ROIALOS SA IMEIWAIILS Y.O.ROOITISIAIIHART T. KAPOK BAER LAURIE A BRIDGE ISMS A. SONO FNMA S. MO WARVJO GARCIA JAMS W.GOIRARCOLLR NAM RP.. liATNIA0 ADAM S. HECHT JAM ...ILL KELLY MOM. IMMO IC ICELLEI.AL CAMERON N PENNED:I VIIITAU S. MO' WEILL Los' MtINYAYMIgI gat OIANLANT SA1111tW K. SCHWAN= INIMIANO. MACY VON A. INPUTS CHNITORRA SPO• MTN B. SUWVAN 2.4 KABUL IThlY DONALD J. WARD 'C. CALM MAMMA le 0112:21RIGEL 'EARL LOOPIET.P.. SPRIOIOLOENS 'BOARD COLTER° Nirc AOMRDLO NN Y UNNE hM/NW.0 'ImssAcHustrts onsassen •ritroweentiz • • WASHNOION DC PARALEGALS: viNANAYARTIAEDA RN40y IA DUFRESNE DAVI> Vt GILMORE J01411 C. ROPERS DEBORAH/A KNAPP VINCENT L. MONAFIO. AFL AWES PETER LAW ROBERT W. PITGNER MILO PlAulACS KATHLEEN MON STEW IA SUM, BONNIE S. STARA WALTER A. STEIN Your Royal Highness: 0 ysi tANAWF nut/. 1111 I represent attorneys Paul G. Cassell and Bradley J. Edwards. They in turn represent a young woman pictured below who is being referred to as Jane Doe No. 3. That representation is in pending legal proceedings in the United States Federal District Court for the Southern District of Florida. This letter is a formal request on behalf of Mr. Edwards and Professor Cassell to interview you, under oath, regarding interactions that you had with Jane Doe No. 3 beginning in approximately early 2001. Jane Doe No. 3 was then 17 years old. Among other things, I would like to discuss events that occurred at the time that the photograph below was taken - and short! thereafter. WWW.SEARCYLAW.COM EFTA00188906

Case 9:08-cv-80736-Ktuv, Document 291-16 Entered on FLS_ Docket 01/21/2015 Page 3 of 3 January 14, 2015 His Royal Highness The Duke of York Re: Edwards and Cassell I would also like to discuss Jane Doe #3's claims of your subsequent interactions with her in New York City, New York later that year. Details of those claims have been widely reported in the British press (with varying degrees of accuracy) as have your denials of the claims , so 1 assume that it is unnecessary for me to be any more specific about the proposed areas of our inquiry. The interview could be conducted at a time and place of your choosing, and with your cooperation, I believe the interview could be completed in two hours or less. New court pleadings regarding relationships between you and Jane Doe #3 are currently being prepared but their £ling will be delayed if you are willing and able to commit to accepting this invitation. Accordingly, the favor of a prompt reply by no later than January 19, 2015, would be greatly appreciated. SCAROLA mep cc: Bradley J. Edwards, Esq. Professor Paul Cassell EFTA00188907