E_OVERSIGHT_013361 --- PAGE BREAK --- DEFENDANT BRADLEY J. EDWARDS'S STATEMENT OF UNDISPUTED FACTS Epstein v. Edwards,

to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F’ — Deposition of Bradley Edwards dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” — Order of HOUSE_OVERSIGHT_013305 --- PAGE BREAK

ent, Epstein declined to answer, purportedly on attorney-client privilege grounds: Q. I want to know whether you have any knowledge of evidence that Bradley Edwards personally ever participated in devising a plan through which were sold purported confidential assignments of a structured payout settlemen

t 0 Cn -2 ° ! C' (n • • rn ORDER ON DEFENDANT'S MOTION TO APPOINT COMMISSIONER r - THIS CAUSE, having come on before the Court upon Defendant Bradley J. Edwards's Motion to Appoint Commissioner, and the Court having heard argument of counsel, and being otherwise duly advised in the premises, it is, ORDERED an

y Edwards, et al. (Case NO. 502009CA040800XXXXMBAG); and upon reading the Affirmation of Robert Y. Lewis dated September 15, 2010, the Affidavits of Bradley James Edwards and Michael Fisten both dated September 14, 2010, the Memorandum of Law dated September 16, 2010, and all the exhibits attached thereto, and it appe

APPLICATION FOR CPLR 3102(E) ORDER Index No. TO PRODUCE TAPE RECORDING x NOTICE OF MOTION PLEASE TAKE NOTICE that upon the annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14, 2010, the Affirmation of Robert Y. Lewis dated September 15, 2010, the

Yes K No Title: Reference: (Conntsnicatios Encbsing Wisteria') 'Description: K Original notes re interview of 14 SR Of pho-l-ovraphs pr lot? Arad Edwards Pirom EFTA00004231 --- PAGE BREAK --- ITEM WAS NOT SCANNED DESCRIPTION EFTA00004232 --- PAGE BREAK --- EFTA00004233

Yes K No Title: Reference: (Conntsnicatios Encbsing Wisteria') 'Description: K Original notes re interview of 14 SR Of pho-l-ovraphs pr lot? Arad Edwards Pirom EFTA00004231 --- PAGE BREAK --- ITEM WAS NOT SCANNED DESCRIPTION EFTA00004232 --- PAGE BREAK --- EFTA00004233

Yes K No Title: Reference: (Conntsnicatios Encbsing Wisteria') 'Description: K Original notes re interview of 14 SR Of pho-l-ovraphs pr lot? Arad Edwards Pirom EFTA00004231 --- PAGE BREAK --- ITEM WAS NOT SCANNED DESCRIPTION EFTA00004232 --- PAGE BREAK --- EFTA00004233

to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by Jane Doe. (Attachments: # 1 Exhibit October 9, 2008 letter from Brad Edwards, Esquire to AUSA Dexter Lee, # 2 Exhibit October 15, 2008 Letter from Brad Edwards, Esquire to AUSA Dexter Lee)(Edwards, Bradley) (Entered: 10/16/20

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

JUDGE 14 Appearances: 15 FOR THE PETITIONER Bradley J. Edwards, ESQ., and 16 Paul G. Cassell, ESQ. 1? FOR THE RESP

nvestigating the-ease Epstein. See Declaration of Bradley J. Edwards, Esq. at ¶¶ 1-2 (hereinafter "Edwards Declaration").

ue lacl hither •"(psardrrerSoUng corn •-•"" Source : BARD WrIrerlog Cit/Town Fon La, deroale • SlouilA - Muted SLISIC 111OUSPt : Loser Tags : Brae Edwards. Jeffrey Epstein. Cruno V•ctrus Rights, Ulmer one urasono shortcut : prlog oriel 2313086 0111C111111111: 1$$ UOI1 011110 ;1101.. 101041.US are SI.

iem-at—II—Ph AUSA Villafafia strongly encouraged Attorney Edwards and his client to attend and address the Court a

cument. Signed by Judge Kenneth A. Marra on 2/12/2009. (ir) (Entered: 02/12/2009) 04/09/2009 37 NOTICE by Jane Doe of Change of Firm Affiliation (Edwards, Bradley) (Entered: 04/09/2009) 09/08/2010 38 Administrative Order Closing Case. Signed by Judge Kenneth A. Marra on 9/8/2010. (tb) (Entered: 09/

s due by 9/3/2013 (Attachments: # 1 Affidavit of Bradley J. Edwards, Esq.)(Edwards, Bradley) (Entered: 08/16/2013) 226 Re

to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by Jane Doe. (Attachments: # 1 Exhibit October 9, 2008 letter from Brad Edwards, Esquire to AUSA Dexter Lee, # 2 Exhibit October 15. 2008 Letter from Brad Edwards, Esquire to AUSA Dexter Lee)(Edwards. Bradley) (Entered: 10/16/20

spiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with

Rothstein crimes, is now demanding over $2 million in legal fees. As a lawsuit brought by some of the investors' claims, Rothstein and his partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media pronouncements, and investigatory initiatives of Rothstein and Edwards were calculated

of RRA. 5. Defendant, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida. At all times relevant he

LD NOT BE HELD IN CONTEMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), through counsel, hereby moves this honorable Court for an Order to Show Cause Why Fowler White and Jeffre

's files." Letter of transmittal attached hereto as Exhibit A. The subject flash drive contained three separate PDF files respectively titled: (I) "Bradley Edwards.pdf' containing 8,507 pages of emails; (2) "Epstein Searches.pdf' containing 17,348 pages of emails; and (3) "Scott Rothstein.pdf" containing 1,687 page

from the Trustee, which included documents from attorney Edwards related to Edwards' representation of the sex ab

une Does, L.N. and 10 • c: 524-2820 20 BY: BRADLEY J. EDWARDS, ESQ. 21 MERMELSTEIN & HOROWITZ, P.A. 22 Attorneys

llows: 16 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL. 17 Attorneys for PinintilTs June Does, L.N. and 10 • c: 524-2820 20 BY: BRADLEY J. EDWARDS, ESQ. 21 MERMELSTEIN & HOROWITZ, P.A. 22 Attorneys for Plaintiffs Jane Does, numbers 2 throu I 21 Tel: (305)931-2200 25 BY: ADAM D. HOROWITZ

23 24 25 EXHIBITS 1 Message pad 2 Documents INDEX OF EXAMINATION WITNESS DIRECT CROSS ALFREDO RODRIGUEZ (By Mr. Mermelstein) 12 (By Mr. Edwards) 157 (By Mr. Langino) 260 INDEX OF EXHIBITS PAGE 72 115 Page 6 Page 8 1 Doe right here on the copy you gave me. I'm 2 missing which Jane

l., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM, OR, IN THE ALTERNATIVE, MOTION FOR RECONSIDERATION OF ORAL SUMMARY JUDGMENT RULING, REOUEST FOR ORAL ARGUMENT AND SUPP

tence of probable 2 EFTA00799340 United States of America v. Scott W. Rothstein, 09-6033 I-CR-COHN; Epstein's Answer and Affirmative Defenses to Edwards's Fourth Amended Counterclaim; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Fu

se is encapsulated by the following paragraph from Edward's Opposition: Epstein knew that he had in fact molested each of the minors represented by Brad Edwards. He also knew that each litigation decision by Brad Edwards was grounded in proper litigation judgment about the need to pursue effective discovery

is case arises from Plainfiffitounter-Defendant Jeffery Epstein's lawsuit against Defendants/Counter-Plaintiffs Bradley Edwards and Scott Rothstein. Edwards then countersued Epstein for malicious prosecution. Epstein voluntarily dismissed his initial suit On Augustin 2011, Epstein served an Offer of Jud

roward Blvd., Ste. 700 Ft. Lauderdale, FL 33301 Bradley J. Edwards, Esq. 425 N. Andrews Ave., Ste. 2 Ft. Lauderdale, FL

N, against Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, and are not part of the legal claims brought by Defendant/Counte•-Plaintiff, BRADLEY EDWARDS, individually, against Plaintiff/Counter-Defendant, JEFFREY EPSTEIN. However, this Proposal is intended to resolve all such claims if available.

spiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with

Rothstein crimes, is now demanding over $2 million in legal fees. As a lawsuit brought by some of the investors' claims, Rothstein and his partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media pronouncements, and investigatory initiatives of Rothstein and Edwards were calculated

FLORIDA &WHEYSett* Plaintiff; v. Complex Litigation, Fla: k cht Pro. 1201 CASE NO. pn 50 2009CAO' -1Oe)"4B SCOTT ROTHSTEIN, indliricluallYt BRADLEY J. EDWARDS, Individually, and L;,M;,. Individually, Defendants. COPY RECEIVED FOR FPLING DEC Ti itgag orfArt6N M. POCK COMPLAINT 0Ingfil% ciPMPTROIVIR

r and the Palm Beach Police Department attempted to provide notice to all the victims. D.E. 14, 1 11; Ex. S 1 38. The prosecutor contacted attorney Edwards by phone to advise him of the state court plea hearing. (a) At that time, Edwards represented Jane Doe No. 1 and Jane Doe No. 2. (Id.) This placed b

:15 p.m., that Epstein's plea to state charges had been scheduled by state officials for 8:30 a.m., AUSA Villafafia specifically called and informed Brad Edwards, the attorney for petitioners, of the date and time of Epstein's state court plea hearing. Ex. S I 38. Attorney Edwards informed AUSA Villafafia tha

sistant United States Attorney 31 EFTA00799855 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 32 of 32 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro H

MBER: FROM: DATE: FACSIMILE COVER SHEET Esq. Bradley J. Edwards, Esq. and William J. Berger, Esq. June 4, 2009 RE: S

ger, Esq. Robert D. Critton, Esq. Bradley James Edwards Isidro Manuel Garcia Jack Patrick Hill Katheri

The Palm Beach Post's (the "Post") Motion to Intervene and Petition for Access to certain court records in this case. It is our understanding that Bradley Edwards and William Berger ofa in Rosenfeldt Adler have filed a similar motion on behalf of a non-party known " and that S motion is set for hearing on J

. 25 Have you seen this document before? EFTA00656466 17 1 A Not to the best of my recollection, no. 2 Q Do you recall having been sued by Bradley 3 Edwards on behalf of an individual who was 4 identified by the initials LM? 5 A Yes, sir. 6 Q And is this one of the cases that you 7 contend was a

IRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III., individually, Defendant(s). VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN January 25, 2012 9:34 =I. - 10:03 III. SEARCY, DE

Reporting. 13 And will the counsel please announce 14 appearances for the record. 15 MR. SCAROLA: My name is Jack Scarola. 16 III counsel for Brad Edwards. Brad is also 17 present. 18 MR. KNIGHT: Christopher Knight on behalf 19 of Jeffrey Epstein. 20 MR. GOLDBERGER: Jack Goldberger on behalf 21

. (Witness complies.) 23 Q. — same paragraph, paragraph three. It says: 24 Attached hereto are copies of letters provided to 25 Mister — or to Bradley Edwards, three el lects,.., Page 145 1 Third sentence says: "All three of those 2 clients were victims of Jeffrey Epstein's while they 3 were minors,

o say — but go down to 10 Footnote 1. It says: "Attorney Edwards filed this 11 motion on behalf of lane Doe, wit

84-6022-4050-b036-0423518c2lb5 EFTA00723105 15 14 17 18 19 20 21 22 23 24 25 APPEARANCES! 6 On behalf of the Plaintiff, /env Doe: 3 BRAD J. ED WARDS. ESQ1.7IRE ROTHSTEIN ROSIDIPELDT ADLER Las Oles City Cant, Stitt 1650 401 East Las Clef Soignee:I Fan Lsoladde, Florida 33301 11 12 13 Onel,a

, FLORIDA JEFFREY EPSTEIN, ) ) ) Petitioner/Counter-Defendant, ) ) vs. No. 50-2009CA040800XXXXMBAG ) SCOTT ROTHSTEIN, individually, ) and BRADLEY J. EDWARDS, ) individually, ) ) Defendants/Counter-Plaintiff. ) ) West Palm Beach, Florida November 2nd, 2018 10:25 a.m. - 1:06 p.m. Plaintiff/Counte

al, whether it's admissible or not, whether it's really relevant or not, based upon the allegations included within the original complaint against Brad Edwards and the malicious prosecution claim that is currently being prosecuted in front of this Court. There is no way to excuse this nondisclosure, eith

o you want to also be involved and set it up some other time? Bradley Edwards." MR. SCAROLA: Right. And the suggestion is made that this impeaches Brad Edwards' testimony that he only met with Mr. Rothstein and spoke about the Epstein cases on two occasions. Well, first of all, it doesn't do that. Palm B

lawyers and others close to the case — including attorney Edwards — who could provide tips and information to assi

E. The Present Motion to Compel I0 ARGUMENT 11 I. EDWARDS MAY NOT RELY ON THE VACATED DISTRICT COURT ORDER FROM THE JANE DOE ACTION 12 II. EDWARDS FAILS TO MEET THE REQUIREMENTS FOR DISCOVERY OF A NON-PARTY UNDER CPLR 3101(a) 14 A. The Epstein Interview Does Not Have Heightened Relevance to

a deposition in one of the now-settled suits by implying that "he did not recognize" reporter Rush. Moving Br. at 17; see also Moving Affidavit of Bradley James Edwards, sworn to Sept. 14, 2010 ("Edwards Aft"), ¶ 22. Besides being farfetched and factually unsupported, Edwards' apparent desire to attack Epstein's cr

you read in fact, I should 21 probably have you just — why don't you read to yourself 22 paragraph three, because there's a reference to 23 Mr. Edwards and three of his clients,.., M. and 24 Jane Doe. Do you see that? 25 A. Yes, I do. Page 137 1 Do you see that? 2 A. Yes. 3 Q. And then it

o say — but go down to 10 Footnote 1. It says: "Attorney Edwards filed this 11 motion on behalf of Jane Doe, wit

. (Witness complies.) 23 Q. — same paragraph, paragraph three. It says: 24 Attached hereto are copies of letters provided to 25 Mister — or to Bradley Edwards, three clients,.., Page 145 1 Third sentence says: "All three of those 2 clients were victims of Jeffrey Epstein's while they 3 were minors, b

1 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwar

cum for Deposition, dated November 5, 2009, upon Bradley J. Edwards, Esq.; Rothstein Rosenfeldt Adler, PA; Stuart Rosenfel

which were entered into by an investor relating to any plaintiff's case with Jeffrey Epstein and any of the following: a. Scott W. Rothstein b. Bradley J. Edwards C. RRA e. any entity formed by RRA or Bradley J. Edwards or Scott W. Rothstein to create investment opportunities for third party investors to inv