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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 
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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 
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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 
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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, 
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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 
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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 
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(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 
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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 
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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"). 
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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 
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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. 
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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 
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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). 
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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. 
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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". 
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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 
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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 
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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 
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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 
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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, 
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