EFTA00597076

Filing i/ 36529442 E-Filed 01/13/2016 03:48:01 PM 
IN THE CIRCUIT 
COURT 
OF 
THE 
SEVENTEENTH JUDICIAL CIRCUIT, IN 
AND FOR BROWARD COUNTY, FLORIDA 
CASE NO.: CACE 15-000072 
BRADLEY J. EDWARDS and PAUL G. 
CASSELL, 
Plaintiff(s), 
vs. 
ALAN M. DERSHOWITZ, 
Defendant(s). 
RESPONSE TO FOURTH SET OF DOCUMENT REQUESTS 
TO BRADLEY J. EDWARDS 
Plaintiff, Bradley J. Edwrds, by and through his undersigned attorneys and pursuant to Rule 
1.350, Florida Rules of Civil Procedure, hereby responds to Defendant, Alan M. Dershowitz's, 
Fourth Set of Document Requests to Bradley J. Edwards, dated December 11, 2015 as follows: 
1. Please see attached Statement by 
to the Federal Bureau of 
Investigation [Redacted] 
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-
Serve to all Counsel on the attached list, this  1-54%- day of 
, 2016. 
Jack Scarola 
Florida Bar No.: 169440 
Attorney E-Mail(s): 
and 
mej)@searcylaw.com 
Primary E-Mail: 
rn 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach Florida 33409 
Phone: 
Fax: 
Attorneys for Plaintiffs 
*** FILED: BROWARD COUNTY. FL HOWARD FORMAN. CLERK 1/13/2016 3:48:01 PM.**** 
EFTA00597076

Edwards, Bradley vs. Dershowitz 
Case No.: CACE 15-000072 
Response to Fourth Set of Document Requests to Bradley J. Edwards 
COUNSEL LIST 
Sigrid Stone McCawle , Esquire 
Boles Schiller & Flexner, LLP 
401 E Las Olas Boulevard., Suite 1200 
Fort Lauderdal FL 33301 
Phone: 
Thomas Emerson Scott, Jr. Esquire 
Cole Scott & Kissane P.A. 
9150 S Dadeland Boulevard, Suite 1400 
Miami, FL 33156 
Phone: 
Fax: 
Attorneys for Alan M. Dershowitz 
Bradley J. Edward E_squire 
Farmer Jaffe Weissing Edwards Fistos & 
Lehrman, P.L. 
425 N Andrews Avenue, Suite 2 
Fort Lauderdale FL 3301 
Phone: 
Fax: 
Kenneth A. Sweder Es uire 
Sweder & Ross, LLP 
131 Oliver Street 
Boston, MA 02110 
Phone: 
Fax: 
Attorneys for Alan M. Dershowitz 
Ashle Eller. Esquire 
Mar E. Bo 'a, Esquire 
Richard A. Simpson, Esquire 
[email protected] 
Wiley Rein, LLP 
1776 K Street NW 
Washington, DC 20006 
Phone: 
Fax: 
Attorneys for Alan M. Dershowitz 
Joni J. Jones Es uire 
Assistant Utah Attorney General 
160 E 300 S 
Salt Lake CttvjUT 84114 
Phone: 
Fax: 
Attorneys for Paul Cassell 
EFTA00597077

1O-302 (Rev. 34-10) 
I 
-1 of 12 -
FEDERAL BUREAU OF INVESTIGATION 
— . 
OcraReartsoi 
Date of entry  
07/05/2013
maiden name 
date of birth 
Social Security Account Number 
United States Citizen and 
Australian Permanent Resident, residence 
New South Wales, Australia, 2261 was interviewed at the United States 
Consulate in Sydney, Australia. 
llllllllllllllllll, was advised of the identity of the 
interviewing agents and purpose of the interview. Present during the 
interview was Federal Bureau of Investigation Special Agent 
land via telephone, Assistant 
United States Attorney' 
I 
provided the 
following information: 
was born in Sacramento, California to parents' 
'date of birth' 
currently resides in 
and 
date of birth 
 
 currently resides in 
 
moved to Palm 
Beach County, Florida with her parents when she was four years old and 
returned to California at age 11. She returned to Florida at age 13 and 
was placed in a rehabilitation or foster care facility in West Palm Beach, 
Florida. 
ran away from the rehabilitation facility when she was 
approximately 14 years old, and while living on the streets in Miami, 
Florida, she met' 
'was training 
to be an escort' 
gave 
a life off of the streets which made her feel 
Inveitiptionon 03/17/2011  at Sydney, Australia (In Person) 
Filet 31S-MM-108062 
by I 
MS document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency, it and its contents are not 
to be disuibuted outside your agency. 
Ea t ined 
07/05/2013 
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EFTA00597078

nNmnsateltas-mao 
31E -MM 
inlla
Continuation of FD-302 of 
 
, On
03/17/2011 
pmm 2 of 12 
like she was locked into the relationship' 
gave IM 
pharmaceutical drugs toward the end of their relationship. 
relationship wi h 
ended while she was at a private 
ranch near Ocala, Florida. 
elephonically contacted a childhood 
friend,' 
 from a telephone at the ranch. 
knew' 
'from elementary school and called him at  the home  telephone 
of his parents 
GIUFFRE told' 
Ishe was 
very lonely, an 
sked her why she did not leave 
lephone conversation with 
the recreational vehicle 
V) 
as 
did not 
'pack 
staying in at 
strike her' 
her belongings and 
the ranch'
told her she was going to live with another man. 
Eli
 
felt that 
specifics 
she was sent to 
of the arrangement. 
who was described as a whit 
ut did not know the 
sexual activity with 
tayed with 
approximately one or two weeks before the police located her and 
her to her parents. 
was interviewed by a male detective. 
parents were still married at the time and lived near 
Florida. 
believed there was an FBI investigation related to 
She never saw 
again after 
In approximately June 1998 or 1999, 
Trump's Mar-A-Lago 
be an working at Donald 
Club in Palm Beach, Florida. 
father 
was able to help her gain 
as a locker room attendant at the 
employment as 
club. 
therapist. In 
approached by 
a baby sitter and later 
started studying for her GED and wanted to become a massage 
August, 
as reading an anatomy/massage book and was 
land help her get her masseuse accreditation 
consulted her father about the opportunity and at a roximately 
5:00 p.m. the same day, her father drove her to a residence at 
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EFTA00597079

FD-302a (Rev. 05-08.10) 
31E-MM-108062 
Continuation of FD-302 of 
o n 
03/17/2011 
pmn 3 of 12 
 
 Florida. 
spoke wither 
father and told him 
it was a wonderful oppirtunity for
met 
also known as 
 
was led 
upstairs 
Once upstairs in 
 
 instructed 
to wash her  hands prior to 
beginning the massa e The massage begs 
!demonstrated massage 
techniques to 
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ng the course of the massage,' 
uestioned 
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about her past, including her time as a runaway. 
was also 
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asked if she took birth control. 
was given instruction and began kissing' 
At the conclusion,' 
'instructed 
o obtain two warm wash
clothes. One wash cloth was used to clean 
second wasl 
to help him relax. 
describe 
and 
hen moved to the steam room and shower where massaged 
 
kith soap and a loofah in the shower. 
At the conclusion of the shower, 
went downstairs and[ 
MS 
Arrangement 
e for 
to return to the house the following day 
after work. 
cellular phone number was given tol 
I
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EFTA00597080

and 
FD-302a (Rev. 05-0840) 
31E-MM-108062 
ComemaamofFD-302of 
L. 
.00 03/17/2011 
pn, 4 of 12 
The same routine and pattern of massages and sexual activity between 
land 
continued for between one and two weeks. At 
times, 
'offered 
the option to quit her 
job at Mar-A-Lago and travel 
There 
was also discussion of 
receiving massage training. 
was to 
be paid $200.00 per day for travel and $200.00 per hour for massages. 
Early in her relationship with 
and was introduced asi 
!assistant. 
soon began traveling 
traveled 
around the 
including California, New York City( New 
tri s. During those trips,! 
ICJ 
Six to nine months after 
For the initial six months, 
United States and Caribbean, 
Mexico) and various business 
began working for 
was 
introduced t4 
ILNU4 
in 
 
!Florida. 
lat the time. 
met the couple at a condominium next to the 
[The condominium was bought( 
land was a 
 
lIn the condominium, 
lill. 
provided a normal massage  t 
LNU. Shortly thereafter,) 
LNU
provided an erotic massage to
 
IIIIII!II 
cleanedr
paid cash 
paid 
advised 
She explained that Xanax helped 
still function normally. Xanax 
doing with( 
and others. 
eight pills per day. 
lIn addition, 
She was 
was 16 
introduced her to the drug Xanax. 
her escape from reality but allowed her to 
helped her go forward with what she was 
Her habit went from two pills per day up to 
second client was an academic of some sort described as an 
older American male 
(sent 
from Miami International Airport to 
Iby commercial airline. 
was picked up at the 
airport byl 
land then taken to the island by boat. 
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EFTA00597081

FD-302a (Rev. 05-0S-I0) 
31E-MM-108062 
Continuation of FD-302 of 
L. 
O, 03/17/2011 i pne 5 of 12 
pointed out that' 
client 
to ride jet skis and participate in other 
with the client. 
assumes the client also traveled 
commercially. 
instructed 
to entertain the 
land wanted 
island activities' 
spent two days  on 
island 
the 
During the following several months, 
traveled internationally 
I
'Prior to her traveling abroad 
ssisted 
in 
getting her pass ort. 
got passport photographs of herself and 
provided them t 
he remaining paperwork was taken care of by 
I
I
II traveled to Paris, France, the 
South of France, London, England, Africa, and Spain. While in Paris, 
recalled stayin at a hotel overlooking the Champs-Elysees. 
1111911 
traveling 
traveled on 
a black plane. During 
travel,( 
times, IIIIIII would'
While 
the international 
(At 
'Rarely a day would pass' 
'contacted 
throu 
land wanted to talk to 
land 
offered 
a contract. 
agreed to the contract for her story 
and was paid $140,000 for the story, 810,000 when the article was printed, 
and another $10,000 to be wired into 
account in May 2011. The 
contract prevented 
from talking to  any other press for a specified 
period. 
advised that she provided' 
'with detailed
informatio 
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EFTA00597082

FD-30Ta (Rev 05-013-10) 
31E—MM-108062 
Continuation of FD-302 of 
03/17/2011 
i
nt  6 of 12 
At age 16, 
met 
9 
I 
believed she ands 
were 
approximately the same age. 
an.l 
WOU 
ci cite
 although 
GIUFFRE
explained 
provided an 
An unknown individual 
described 
GIUFFRE sa 
hen she arrived at 
had' 
sai. that day was a low stage in 
ecause she could not believe 
relationship 
never 
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EFTA00597083

FD-302a (Rev. 05-0840) 
31E-14N-108062 
Continuation of FD-302 
saw 
of 
L. 
on 
03/17/2011 
pmo 7 of 12 
I 
I. 
believed the girls may have been) 
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'but 
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was not certain off 
'involvement. 
had a picture of herself she wanted to give( 
described some of the unique interior areas of 
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'which 
referred to 
which was where 
While in New York, 
also stayed at an apartment 
was aware of 
apartments in the same building. According to 
apartment building on 66th street was owned b 
advised that she had a photo  raph of the interior of the 
apartment among other photos 
66th 
on 66th street 
additional 
he 
IUFFRE 
Street 
advised that some of her photographs that were provided to her 
civil attorneys by her family were not returned. One of the missing photos 
depicted 
wearing a pink dress while seated on a quad bike. 
ILNU was' 
kemale that formerly lived inl 
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EFTA00597084

FD-302a (Rev. 05-0840) 
31E-MM-108062 
Continuation of FD-302 of 
0, 
03/17/2011 
p,40 8 of 12 
LNU and 
went shopping  together and purchased clothing and sex 
toys. „„„, 
explained that' 
used a cellular telephone 
She believed it was 
a New York City number but could not recall the number. 
and 
could only remember faces 
Inot their names. 
did not' 
but she did try 
unsuccessfully to get 
recalled'
not recall the wording. 
iMINI
 advised'
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'but she could 
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'LNU. 
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traveled' 
Ito a self-help conference at a hotel in 
New Orleans, Louisiana. The hotel 
s near the Har Rock Café in New 
Orleans. 
traveled the world 
including the USVI, New 
York, Santa Fe, Palm Beach, France, Africa, Spain and the United 
Kingdom. 
recalled visiting 
Alhambra Castle in Spain. I 
'GIUFFRE eventually traveled to the United Kingdom and 
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EFTA00597085

FD-3023 (Rev. 05-08-10) 
318-MM-108062 
Colt-nation of FD-302 of 
0n 
03/17/2011 ft  9 of 12 
while there' 
approached 
in a very excited manner and told 
her they had  to go shopping to pick out a dress because 
would be 
dancing with' 
and' 
 went shopping and purchased makeup, clothin  , and a 
Burberry ba . The items were purchased withI 
an 
returned' 
I
instructed 
to get read . 
When 
came down after getting 
ready, she was introduced to 
traveled to CLUB TRAM 
danced 
at CLUB TRAMP' 
Istayed at CLUB TRAMP 
for an hour or hour and a half and drank a couple of cocktails before 
returnin• to 
had not received an direction 
from 
After returning to( 
requested' 
"to take a photograph of her' 
advised that she still had the original photograph in her possession  and 
would provide it to the interviewing agents. 
proceeded with' 
Approximately two months later, 
met' 
lat 
recalled' 
ILNU, 
'GIUFFRE recalled 
(joking about trading GIUFFRE in because 
she was getting too old. 
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EFTA00597086

misarauLmosmwo 
Cs" 
-A\
31E-MM-108062 
Continuation of FD-302 of 
,On 
03/17/2011 
ptio 10 of 12 
cod 
<0'
QA  
. )
4 
A 
recalled meeting" 
 
< 
b6 
was using Xanax heavily at tfinlime' 
e
?,t 
. 
NC" 
b 
A 
and her recollection was not clear. She remembered there were many models \ 
 
tj
a 
..v.., 
o.
on the island that did not speak English along with a modeling person who 
4> 
.,:ss, 
had an unknown accent. 
id not have a problem with 
using prescription drugs. 
was described by 
as a 
a ranch employee )L 
;TRUE NAME UNKNOWN) 
!but 
could not recall his name. She did have a photograph of the ranch 
employee. 
met numerous famous people 
ncluding 
& it
a 
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^4.
Ce 
\,
‘4 
Ss'r 
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academics politicians and celebrities. She me 
land 
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andI 
received many gifts' 
'including jewelry, watches, 
bags, shoes, make up, clot
 'no. and home furnishings
furnishings.'
I 
1
LAMM left 
I 
all of the items behind when she traveled to Thailand to 
receive massage training. 
In August 2002, 
traveled by commercial airline to Bangkok, 
Thailand and began her massage training at International Training Massage 
School(ITM) where she received  
i 
massaae 
har
certification. She stayed at 
the Princess Hotel in Thailand, 
but never did. 
met her future husband,I 
J 
during her visit to Thailand. 
contacted$ 
(telephonically and 
raid him she had fallen in love with someone. I 
I 
 
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EFTA00597087

Page 4, 
Page 4, 
Page 5, 
.< 4" 
FD-302a (Rev. 05-08-10) 
_cam 
Continuation 
31E-M4-108662 
of FD-302 of 
 
,on 
03/17/2011 " ate 11 of 12 
_4(
e sr
b6 
had not heard from 
received a 
telephone 
FBI agent. 
call fromr 
Inuring that call 
stated he was an.
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4t4.
C5S 
He was trying to determine what she knew about 
I 
She did not tell' 
anything about her knowledge of 
I She also received another telephone call from a 
c.)"-
c.)"-
person that indicated he was an FBI agent. She did not tell that 
individual anything either. She also received a call from an attorney that 
was trying to determine if she had spoken with anyone or was willing to 
speak to anyone' 
(She 
explained that she was receiving telephone calls from people whom she did 
not know and that she was uncomfortable telling them anything over the 
telephone. 
One or two weeks later, an unknown attorney and' 
contacted 
Ia.
 telephonically.' 
was using a cellular telephone belonging to her husband. She 
nor her husband could recall the telephone number but advised that the 
carrier was OPTUS telephone company. 
reviewed a series of photographs of individuals and identified 
the following: 
Page 1, 
Page 1, 
Page 2, 
Page 2, 
Page 3, 
number 1, 
number 
number 1, 
number 6, 
number 2, 
Page 4, number 3, 
number 7, 
number 8, 
number 1, 
24 
LNU, a.k.a 
LNU 
advised that the following were familiar to her, but she could not 
recall their names or her association to them: 
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EFTA00597088

815.1028 (Rev. 05.08-10) 
31E-MM-108062 
Cool:tuition of FD-302 of 
.O, 03/17/2011 Jaw  12 of 12 
Page 1, number 4 
Page 2, numbers 7 and 8 
Page 3, number B 
Page 4, number 1 
Page 5, numbers 5 and 8 
The images reviewed by 
were placed in a lA envelope of the case 
file. 
When questioned about United States Customs and Border (CBP) Patrol 
records of her entries into the United States, 
advised t 
h r 
January 2001 record was the return from her London,  England tri 
IThe April 2001 CBP 
record was her return to the United Statesl 
could not recall her travel from 
March and May 2001 CPB records. 
Passport was turned over to the United States Consulate in Sydney, 
Australia. 
advised that her United States 
On March 18, 2011, writer, SAE 
 andl 
traveled to 
residence where she provided 20 
ITM massage school certification. FD-597 Receipts for 
executed for the items and a copy was provided to 
the receipts were dated based on the United States Eastern Standard Time 
Zone date. The photographs, certification and original FD-597s were placed 
in a 1A envelopes of case file. 
I 
photographs and her 
Property were 
. It is noted that 
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EFTA00597089