EFTA01093549

IN THE CIRCUIT COURT OF THE 15TH 
JUDICIAL CIRCUIT IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
Case No.:50 2009 CA 040800XXXXIMBAG 
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."). 
All 
referenced exhibits and attachments have previously been filed with the Court and provided to 
Epstein. 
Sexual Abuse of Children By Epstein 
I. 
Defendant Epstein has a sexual preference for young children. Deposition of 
Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment 
#1).' 
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. "Mt is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to 
EFTA01093549

2. 
Epstein repeatedly sexually assaulted more than forty (40) young girls on 
numerous 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 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane 
Doe, September 24, 2009 and continued March 11, 2010, at 527 (minor girl sexually abused at 
least 17 times by Epstein) (hereinafter "Jane Doe Depo") (Deposition Attachment #2); id. 564-67 
(vaginal penetration by Epstein with his finger), 568 (vaginal penetration by Epstein with a 
massager); Deposition of 
September 24, 2009, at 73 (hereinafter a 
Depo") 
(Deposition Attachment #3) (describing the manner in which Epstein abused her beginning when 
was 13 years old, touching her vagina with his fingers and vibrator) at 74, line 12-13 (she 
was personally molested by Epstein more than 50 times), at 164, line 19-23 and 141, line 12-13 
and 605, line 3-6 (describing that in addition to being personally molested by Epstein she was 
paid $200 per underage girl she brought Epstein and she brought him more than seventy (70) 
underage girls - she told him that she did not want to bring him any more girls and he insisted 
that she continue to bring him underage girls); Deposition of 
May 6, 2010 (hereinafter 
■ 
Depo") (Deposition Attachment #4) at 115-116, 131 and 255 (describing Epstein's abuse 
of her beginning at age 14 when he paid her for touching her vagina, inserting his fingers and 
civil actions when they refuse to testify in response to probative evidence offered against them." Baxter 
v. Paintigiatto, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 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 and then escape the consequences by invoking a constitutional privilege — at least not in a civil 
setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993). 
2 
EFTA01093550

using a vibrator and he also paid her $200 for each other underage female 
brought him to 
molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date 
(hereinafter "Jane Doe #4 Depo") (Deposition Attachment #5) at 32-34, and 136 (she describes 
first being taken to Epstein at 15 years old, "Being fingered by him, having him use a vibrator on 
(me], grabbing my nipples, smelling my butt, jerking off in front of me, licking my clit, several 
times."). 
3. 
At all relevant times Edwards has had a good faith basis to conclude and did 
conclude2 that Epstein was able to access a large number of underage girls through a pyramid 
abuse scheme in which he paid underage victims $200-$300 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 ■ 
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 
that Epstein would be up in a second. Epstein 
walked over to =tnd told her to take her clothes off in a stem voice= states in the report 
she did not know what to do, as she was the only one there... took off her shirt, leaving her 
bra on. Epstein, then in a towel told her to take off everything. • 
removed her pants leaving 
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. 
3 For clarity, depositions attached to this memorandum will be identified numerically as attachments #1, #2, #3, etc., 
while exhibits attached to this memorandum will be identified alphabetically as exhibits A, B, C, etc. 
3 
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on her thong panties. Epstein then instructed■ to give him a massage. As Mave Epstein a 
massage, Epstein turned around and masturbated 
was so disgusted, she did not say 
anything; Epstein told her she "had a really hot body." Id. at 14. In the report 
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 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 v. 
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 v. Epstein 
case). 
4 
EFTA01093552

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 
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 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 Mr. Epstein's home 
only once, some went there as much as 100 times or more. Some of the 
women's conduct was limited to performing a topless or nude massage while 
Mr. Epstein masturbated himself. For other women, the conduct escalated to 
full sexual intercourse. 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 tha■was, in fact, a victim of Epstein's criminal abuse because was 
one of the 
5 
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minor females that the United States Attorney's Office recognized as a victim. 
sworn 
deposition testimony and the adverse inference drawn from Epstein's refusal to testify confirm 
that Epstein began sexually assaulting.. 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 M.?" 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.., 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 when Jane Doe was 14 years old. Rather than incriminate himself, Epstein invoked the 
5th amendment to questions about him digitally penetrating Doe's vagina, using vibrators on her 
vagina and masturbating and ejaculating in her presence. 
Epstein Depo., April 14, 2010, 
Attachment #6, at 420, 464, 468. 
11. 
When Edwards's clients ■.,.., 
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 
6 
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one or more of the following acts with each of the then-minor girls at his mansion: receiving a 
topless or completely nude massage; using a vibrator on her vagina; masturbating in her 
presence; ejaculating in her presence; touching her breast or buttocks or vagina or the clothes 
covering her sexual organs; and demanding that she bring him other underage girls. Epstein and 
his co-conspirators used the telephone to contact these girls to entice or induce them into going 
to his mansion for sexual abuse. Epstein also made ■. 
perform oral sex on him and was to 
perform sex acts on 
Epstein's live-in sex slave) in Epstein's presence. See 
Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane 
Doe v. 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; ■. Depo., Attachment #3, at 416; 
M. 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 
approximately 15 years old, 
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 - topless or completely 
nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her 
presence; Epstein ejaculated in her presence; Epstein also demanded that she bring him other 
underage girls. See Rule 413 Notice, 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 wain 
When she was approximately 16 
years old, she was brought to Epstein's home by another underage victim. While a minor, she 
7 
When she was 
EFTA01093555

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 - topless or completely nude massage on 
Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein 
ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes 
covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts 
on 
in Epstein's presence. Epstein also forcibly raped this underage victim, as 
he held her head down against her will and pumped his penis inside her while she was screaming 
"No". See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A", at 41 (specifically 
discussing the rape): 
"ni 
remem 
d that she climaxed and was removing herself from the 
massage table. 
.] asked for a sheet of a er and drew the massage table in the 
Ai
r bathroom and where Epstein, 
and she were. Epstein turned 
] o
 her stomach on the massage bed and inserted his penis into her 
vagina. [M.] stated Epstein began to pump his penis in her vagina. [ 
.] 
became upset over this. She said her head was being held against the bed forcibly, 
as he continued to pump inside her. She screamed no, and Epstein stopped ...." 
a
"EN., 
ised there were times that she was so sore when she left Epstein's 
house. 
.] advised she was ripped, torn, in her vagina area. S.] advised she 
had difficulty walking to the car after leaving the house because she was so sore." 
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: 
These girls were 
between the ages of 13 and 17 when Epstein abused them. See Rule 413 Notice, Exhibit E; 
Deposition of 
Deposition Attachment #4. 
8 
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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. v. 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 
9 
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whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); 
at 9 (Bill Clinton phone numbers listed under "Doug Bands"). 
Federal Investigation and Plea Azreenzent 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 "C". 
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 
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 
and .M 
traveled to the home of Leslie Groff to serve her with a federal grand 
jury subpoena with an investigation pending in the Southern District of Florida. 
Ms. Groff works as the personal assistant of the defendant. Ms. Groff began 
speaking with the agents and then excused herself to go upstairs to check on her 
sleeping child. 
While upstairs, Ms. Groff telephoned the defendant, Jeffrey 
Epstein, and informed him that the FBI agents were at her home. Mr. Epstein 
instructed Ms. Groff not to speak with the agents and reprimanded her for 
allowing them into her home. Mr. Epstein applied pressure to keep Ms. Groff 
from complying with the grand jury subpoenas that the agents had served upon 
her. In particular, Mr. Epstein warned Ms. Groff against turning over documents 
and electronic evidence responsive to the subpoena and pressured her to delay her 
10 
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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 showing the parties were about to return to Teterboro, NJ. 
After the 
conversation with Ms. Groff, Mr. Epstein became concerned that the FBI would 
try to serve his traveling companion,
, with a similar =rand jury 
subpoena. In fact, the agents were preparing to serve 
with a 
target letter when the flight landed in Teterboro. Mr. Epstein then redirected his 
airplane, making the pilot file a new flight plan to travel to the US Virgin Islands 
instead of the New York City area thereb keeping the Special Agents from 
serving the target letter on 
During the flight, the defendant 
verbally harassed 
harassing and 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: SM101: 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 Christina Abernathy. See 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 
11 
EFTA01093559

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 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, 
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 
12 
EFTA01093560

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"). 
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 M. and M. received letters 
from the FBI advising them that "[t]his 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 
13 
EFTA01093561

block federal prosecution of Epstein. Nor did the FBI notify ■. and 
of any of the pans 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. 
Edwards Azrees to Serve as Legal Counsel for Three Victims of Epstein'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 — 
, ■., 
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 (E. 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 
14 
EFTA01093562

Affidavit of Bradley J. Edwards, Esq. at ¶1 - 2, ¶4 (hereinafter "Edwards Affidavit") (Exhibit 
"N"). 
32. 
On June 13, 2008, attorney Edwards agreed to represent M.; 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 ¶2. 
33. 
In mid June of 2008, Edwards contacted 
to inform her that he 
represented Jane Doe #1 and, later, Jane Doe #2. 
did not advise that a plea 
agreement had already been negotiated with Epstein's attorneys that would block federal 
prosecution. To the contrary, 
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 ¶4. 
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 information 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"). 
15 
EFTA01093563

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 M. — 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 ■. 
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 had 
failed to provide ■. 
and ■. 
the rights to which they were entitled under the Act, including 
the right to be notified 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 first time that the plea 
deal was already done with Epstein and that the criminal case against Epstein had been 
16 
EFTA01093564

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 "S") (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 
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 Against 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 Doe. 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 v. 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, 
v. Epstein (Exhibit "U"). 
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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, 
v. Epstein, (Exhibit "V"). 
47. 
Jane Doe's federal complaint indicated that she sought damages of more than 
$50,000,000. 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 #4 v. 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, 
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. MI 
was born a male, and in her complaint she 
19 
EFTA01093567

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: 
htto://www.nvoost.com/p/news/regional/item 44z1WyLUFH7R1OUtKYGPbPjsessionid=6CA3 
EBF1BEF68F5DE14BFB2CAA5C37E0. See Article attached hereto as Exhibit "X". 
51. 
Edwards'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 102 v. 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 Australia 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." 
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