EFTA00597791

66. 
In view of this information suggesting Brunel could provide significant evidence 
of Epstein's trafficking in young girls for sexual abuse, Edwards had Brunel served in New York 
for deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit "II." 
Before the deposition took place, 
attorney (Tama Kudman of West Palm Beach) 
contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in 
January 2009 that Brunel had left the country and was back in France with no plans to return. 
This information was untrue; Brunel was actually staying with Epstein in West Palm Beach. See 
Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from 
Epstein's probation file evidencing Jean Luc Brunel (JLB) staying at his house during that 
relevant period of time attached Exhibit "JJ". As a result, Edwards filed a Motion for Contempt, 
attached hereto as Exhibit "KC" (Because Epstein settled this case, the motion was never ruled 
upon.) 
67. 
Edwards was also informed that Epstein paid for not only 
representation 
during the civil process but also paid for legal representation for 
(Epstein's 
executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal 
pilot), Dave Rogers (Epstein's personal pilot), Larry Harrison (Epstein's personal pilot), Louella 
Rabuyo (Epstein's housekeeper), 
(Epstein's live-in sex slave), Ghislaine 
Maxwell (manager of Epstein's affairs and businesses), Mark Epstein (Epstein's brother), and 
Janusz Banasiak (Epstein's house manager) It was nearly impossible to take a deposition of 
someone that would have helpful information that was not represented by an attorney paid for by 
Epstein. See Edwards Affidavit, Exhibit "N" at 911. 
26 
EFTA00597831

68. 
While Epstein and others were preventing any legitimate discovery into his sexual 
abuse of minor girls, at the same time be was engaging (through his attorneys) in brutal 
questioning of the girls who had filed civil suits against him, questioning so savage that it made 
local headlines. See Jane Musgrave, Victims Seeking Sex 
Millions See Painful Pasts 
Used 
Against 
Them, 
Palm 
Beach 
Post 
News, 
Jan. 
23, 
2010, 
available 
at 
http://www.nalmbeachnost.cominews/crime/victims-seeking-sex-offenders-millions-see-rainful-
pasts-192988.html attached hereto as Exhibit "LL." 
Edwards Pursues Other Lines of Discovery 
69. 
Because of Epstein's thwarting of discovery and attacks on 
clients, 
Edwards was forced to pursue other avenues of discovery. 
Edwards only pursued legitimate 
discovery designed to further the cases filed against Epstein. See Edwards Affidavit, Exhibit 
"N" at ¶11. 
70. 
Edwards notified Epstein's attorneys of his intent to take Bill 
deposition. 
Edwards possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine 
Maxwell who was Epstein's longtime companion and helped to run Epstein's companies, kept 
images of naked underage children on her computer, helped to recruit underage children for 
Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and 
photographed underage females in sexually explicit poses and kept child pornography on her 
computer; (b) it was national news when Clinton traveled with Epstein aboard Epstein's private 
plane to Africa and the news articles classified Clinton as Epstein's friend. (c) the complaint 
filed on behalf of Jane Doe No. 102 stated generally that she was required by Epstein to be 
sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty, 
27 
EFTA00597832

politicians, academicians, businessmen, and/or other professional and personal acquaintances" — 
categories Clinton and acquaintances of Clinton fall into. The flight logs showed Clinton 
traveling on Epstein's plane on numerous occasions between 2002 and 2005. See Flight logs 
attached hereto as Exhibit "MM." Clinton traveled on many of those flights with Ghislaine 
Maxwell, 
and Adriana a 
- all employees and/or co-conspirators of 
Epstein's that were closely connected to Epstein's child exploitation and sexual abuse. The 
documents clearly show that Clinton frequently flew with Epstein aboard his plane, then 
suddenly stopped - raising the suspicion that the friendship abruptly .ended, perhaps because of 
events related to Epstein's sexual abuse of children. Epstein's personal phone directory from his 
computer contains e-mail addresses for Clinton along with 21 phone numbers for him, including 
those for his assistant (Doug Band), his schedulers, and what appear to be 
personal 
numbers. This information certainly leads one to believe that Clinton might well be a source of 
relevant information and efforts to obtain discovery from him were reasonably calculated to lead 
to admissible evidence. See Exhibits "B", "F" "AK, "DD", and "MM" and Edwards Affidavit, 
Exhibit "N" at ¶15. 
71. 
Bradley J. Edwards, Esq., provided notice that he intended to take the deposition 
of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads 
confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach 
mansion on several occasions during the time period most relevant to my 
clients' 
complaints; (b) Trump was quoted in a Vanity Fair article about Epstein as saying "I've known 
Jeff for fifteen years. Terrific guy," 'M a lot of fun to be with. It is even said that he likes 
beautiful women as much as I do, and many of them are on the younger side. No doubt about it --
28 
EFTA00597833

Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; 
pals 
with a passel of Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, 
socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, Kevin 
Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder 
who he is. By Landon Thomas Jr. (See article attached hereto as Exhibit "NN") (c) Trump 
allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually 
assaulted an underage girl at the club; (d) Jane Doe No. 1021 complaint alleged that Jane Doe 
102 was initially approached at 
Maralago by Ghislaine Maxwell and recruited to be 
Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified 
that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged 
was used to have sex with underage girls); (f) Trump had been to Epstein's home in Palm Beach; 
(g) Epstein's phone directory from his computer contains 14 phone numbers for Donald Trump, 
including emergency numbers, car numbers, and numbers to 
security guard and 
houseman. Based on this information, Edwards reasonably believed that Trump might have 
relevant information to provide in the cases against Jeffrey Epstein and accordingly provided 
notice of a possible. deposition. See deposition of Mark Epstein, September 21, 2009, at 48-50 
(Deposition Attachment #19); See Jane Doe 102 v. Epstein, Exhibit "B"; Exhibit "F"; 
"Exhibit"J"; "N" and See Edwards Affidavit, Exhibit "N" at ¶13. 
72. 
Edwards provided notice that he intended to depose Alan Dershowitz. Edwards 
possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with 
Epstein for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th 
book... The only person outside of my immediate family that I send drafts to is Jeffrey" The 
29 
EFTA00597834

Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See 
article attached as Exhibit "OO"); (c) Epstein's housekeeper Alfredo Rodriguez testified that 
Dershowitz stayed at Epstein's house during the years when Epstein was assaulting minor 
females on a daily basis; (d) Rodriguez testified that Dershowitz was at Epstein's house at times 
when underage females where there being molested by Epstein (see Alfredo Rodriguez 
deposition at 278-280, 385, 426-427); (e) Dershowitz reportedly assisted in attempting to 
persuade the Palm Beach State 
Office that because the underage females alleged to 
have been victims of Epstein's abuse lacked credibility and could not be believed that they were 
at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house; 
(0 Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not only 
Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians, 
businessmen, and/or other professional and personal acquaintances" — categories that Dershowitz 
and acquaintances of Dershowitz fall into; (g) during the years 2002-2005 Alan Dershowitz was 
on Epstein's plane on several occasions according to the flight logs produced by Epstein's pilot 
and information (described above) suggested that sexual assaults may have taken place on the 
plane; (h) Epstein donated $30 Million one year to the university at which Dershowitz teaches. 
Based on this information, Edwards had a reasonable basis to believe that Dershowitz might 
have relevant information to provide in the cases against Jeffrey Epstein and accordingly 
provided notice of a possible deposition. See Dershowitz letters to the State 
office 
attached as Exhibit "PP"; Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit 
"MM"; Exhibits "B" and "OO"; and Edwards Affidavit, Exhibit "N" at ¶14. 
30 
EFTA00597835

73. 
Epstein's complaint alleges that Edwards provided notice that he wished to take 
the deposition of Tommy Mattola. That assertion is untrue. Mr. 
deposition was set by 
the law flrrn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" 
at 116. 
74. 
Edwards gave notice that be intended to take David 
deposition. 
Edwards possessed a legitimate basis for doing so. Epstein's housekeeper and one of the only 
witnesses who did not appear for deposition with an Epstein bought attorney, Alfredo Rodriguez, 
testified that David Copperfield was a guest at Epstein's house on several occasions. His name 
also appears frequently in the message pads confiscated from Epstein's house. It has been 
publicly reported that Copperfield himself has had allegations of sexual misconduct made against 
him by women claiming he sexually abused them, and one of Epstein's sexual assault victims 
also alleged that Copperfield had touched her in an improper sexual way while she was at 
Epstein's house. Mr. Copperfield likely has relevant information and deposition was reasonably 
calculated to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at 
117. 
75. 
Epstein also takes issue with Edwards identifying Bill Richardson as a possible 
witness. Richardson was properly identified as a possible witness because Epstein's personal 
pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was 
information indicating that Epstein had young girls at his ranch which, given the circumstances 
of the case, raised the reasonable inference he was sexually abusing these girls as he had abused 
girls in West Palm Beach and elsewhere. Richardson had also returned campaign donations that 
were given to him by Epstein, indicating that he believed that there was something about Epstein 
31 
EFTA00597836

with which he did not want to be associated. Richardson was not called to testify nor was he ever 
subpoenaed to testify. See Edwards Affidavit, Exhibit "N" at $18. 
76. 
Edwards learned of allegations that Epstein engaged in sexual abuse of minors on 
his private aircraft. See Jane Doe 102 Complaint, Exhibit "B." Accordingly, Edwards pursued 
discovery to confirm these allegations. 
77. 
Discovery of the pilot and flight logs was proper in the cases brought by Edwards 
against Epstein. Jane Doe filed a federal RICO claim against Epstein that was an active claim 
through much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal 
enterprise that involved and depended upon his plane travel. Although Judge Marra dismissed 
the RICO claim at some point in the federal litigation, the legal team representing 
Edwards' clients intended to pursue an appeal of that dismissal. Moreover, all of the subjects 
mentioned in the RICO claim remained relevant to other aspects of Jane 
claims against 
Epstein, including in particular her claim for punitive damages. See Edwards Affidavit, Exhibit 
"N" at $19. 
78. 
Discovery of the pilot and flight logs was also proper in the cases brought by 
Edwards against Epstein because of the need to obtain evidence of a federal nexus. 
client Jane Doe was proceeding to trial on a federal claim under 18 
§ 2255. Section 2255 
is a federal statute which (unlike relevant state statutes) established a minimum level of recovery 
for victims of the violation of its provisions. Proceeding under the statute, however, required a 
"federal nexus" to the sexual assaults. Jane Doe had two grounds on which to argue that such a 
nexus existed to her abuse by Epstein: first, his use of telephone to arrange for girls to be abused; 
and, second, his travel on planes in interstate commerce. During the course of the litigation, 
32 
EFTA00597837

Edwards anticipated that Epstein would argue that Jane 
proof of the federal nexus was 
inadequate. These fears were realized when Epstein filed a summary judgment motion raising 
this argument. In response, the other attorneys and Edwards representing Jane Doe used the 
flight log evidence to respond to Epstein's summary judgment motion, explaining that the flight 
logs demonstrated that Epstein had traveled in interstate commerce for the purpose of facilitating 
his sexual assaults.. Because Epstein chose to settle the case before trial, Judge Marra did not 
rule on the summary judgment motion. 
79. 
Edwards bad further reason to believe and did in fact believe that the pilot and 
flight logs might contain relevant evidence for the cases against Epstein. Jane Doe No. 1021 
complaint outlined Epstein's daily sexual exploitation and abuse of underage minors as young as 
12 years old and alleged that Epstein's plane was used to transport underage females to be 
sexually abused by him and his friends. The flight logs accordingly were a potential source of 
information about either additional girls who were victims of Epstein's abuse or friends of 
Epstein who may have witnessed or even participated in the abuse. 
Based on this 
information, Edwards reasonably pursued the flight logs in discovery. 
80. 
In the fall of 2009, Epstein gave a recorded interview to George Rush, a reporter 
with the New York Daily News about pending legal proceedings. In that interview, Epstein 
demonstrated an utter lack of remorse for his crimes (but indirectly admitted his crimes) by 
stating: 
• People do not like it when people make good and that was one reason he (Epstein) 
was being targeted by civil suits filed by young girls in Florida; 
• He (Epstein) had done nothing wrong; 
33 
EFTA00597838

• He (Epstein) had gone to jail in Florida for soliciting prostitution for no reason; 
• if the same thing (i.e., sexual abuse of minor girls) had happened in New York, he 
(Epstein) would have received only a $200 fine; 
• Bradley J. Edwards was the one causing all of Epstein's problems (i.e., the civil 
suits brought by Jane Doe and other girls); 
• L.M. came to him as a prostitute and a drug user (i.e., came to Epstein for sex, 
rather than Epstein pursuing her); 
• All the girls suing him are only flying to get a meal ticket; 
• The only thing he might have done wrong was to maybe cross the line a little too 
closely; 
• He (Epstein) was very upset that Edwards had subpoenaed Ghisline Maxwell, that 
she was a good person that did nothing wrong (i.e., had done nothing wrong even 
though she helped procure young girls to satisfy Epstein's sexual desires); 
• 
With regard to Jane Doe 102 v. Epstein, which involved an allegation that Epstein 
had repeatedly sexually abused a 15-year-old girl, forced her to have sex with his 
friends, and flew her on his private plane nationally and internationally for the 
purposes of sexually molesting and abusing her, he (Epstein) flippantly said that 
the case was dismissed, indicating that the allegations were ridiculous and untrue. 
See Affidavit of Michael J. Fisten attached hereto as Exhibit "QQ." 
81. 
The Rush interview also demonstrated perjury (a federal crime) on the part of 
Epstein. Epstein lied about not knowing George Rush. See Epstein Deposition, February 17, 
2010, taken in L.M. v. Jeffrey Epstein, case 50-2008-CA-028051, page 154, line 4 through 155 
line 9, (Deposition attachment #7), wherein Jeffrey Epstein clearly impresses that he does not 
recognize George Rush from the New York Daily News. This impression was given despite the 
fact that he gave a lengthy personal interview about details of the case that was tape recorded 
with George Rush. 
34 
EFTA00597839

Epstein's Harassment of Witnesses Against Him 
82. 
At all relevant times Edwards has a good faith basis to believe and did in fact 
believe that Epstein engaged in threatening witnesses. See Incident Report, Exhibit "A" at p. 82, 
Correspondence, Exhibit "C" - Indictments drafted by Federal Government 
against Epstein; and Edwards Affidavit, Exhibit "N" at ¶11. 
83. 
Despite three no contact orders entered against Epstein (see Exhibit C, supra), 
Edwards learned that Epstein continued to harass his victims. For example, Jane Doe had a trial 
set for her civil case against him on July 19, 2010. As that trial date approached, defendant 
Epstein intimidated her in violation of the judicial no-contact orders. On July 1, 2010, he had a 
"private investigator" tail Jane Doe — following her every move, stopping when she stopped, 
driving when she drove, refusing to pass when she pulled over. When Jane Doe ultimately drove 
to her home, the "private investigator" then parked in his car approximately 25 feet from Jane 
Doe house and flashed his high beam lights intermittently into the home. 
Even more 
threateningly, at about 10:30 p.m., when Jane Doe fled her home in the company of a retired 
police officer employed by Jane 
counsel, the "private investigator" attempted to follow 
Jane Doe despite a request not to do so. The retired officer successfully took evasive action and 
placed Jane Doe in a secure, undisclosed location that night. Other harassing actions against 
Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein 
detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit "RR." 
Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 
84. 
The civil cases Edwards filed against Epstein on behalf of L.M., E.W., and Jane 
Doe were reasonably perceived by Edwards to be very strong cases. Because Epstein had 
35 
EFTA00597840

sexually assaulted these girls, he had committed several serious torts against them and would be 
liable to them for appropriate damages. See Preceding Undisputed Facts. Because of the 
outrageousness of Epstein's sexual abuse of minor girls, Edwards reasonably expected that 
Epstein would also be liable for punitive damages to the girls. Because Edwards could show that 
Epstein bad molested children for years and designed a complex premeditated scheme to procure 
different minors everyday to satisfy his addiction to sex with minors, the punitive damages 
would have to be sufficient to deter him from this illegal conduct that he had engaged in daily for 
years. 
Epstein was and is a billionaire. 
See Complaint, ¶49 (referring to "Palm Beach 
Billionaire:), see also Epstein Deposition, February 17, 2010, at 172-176 (Deposition 
Attachment #7) (taking the Fifth when asked whether he is a billionaire). Accordingly, Edwards 
reasonably believed the punitive damages that would have to be awarded against Epstein would 
have been substantial enough to punish him severely enough for his past conduct as well as deter 
him from repeating his offenses in the future. See Edwards Affidavit, Exhibit "N" at 1119. 
85. 
On July 6, 2010, rather than face trial for the civil suits that had been filed against 
him by L.M., E.W., and Jane Doe, defendant Epstein settled the cases against him. The terms of 
the settlement are confidential. The settlement amounts are highly probative in the instant action 
as Epstein bases his claims that Edwards was involved in the Ponzi scheme on Epstein's inability 
to settle the L.M., E.W., and Jane Doe cases for "minimal value". His continued inability to 
settle the claims for "minimal value" after the Ponzi scheme was uncovered would be highly 
probative in discrediting any causal relationship between the Ponzi scheme and 
settlement negotiations. See Edwards Affidavit, Exhibit "N" at ¶21. 
Edwards Non-Involvement in Fraud by Scott Rothstein 
36 
EFTA00597841

86. 
From in or about 2005, through in or about November 2009, Scott Rothstein 
appears to have run a giant Ponzi scheme at his law firm of Rothstein, Rosenfeldt and Adler P.A. 
("RRA"). This Ponzi scheme involved Rothstein falsely informing investors that settlement 
agreements had been reached with putative defendants based upon claims of sexual harassment 
and/or whistle-blower actions. 
Rothstein falsely informed the investors that the potential 
settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott 
W. Rothstein, No. 9-60331-CR-COHN 
(
.
1
.
 
Fla. Jan. 27, 2010) attached hereto as Exhibit "SS." 
87. 
It has been alleged that among other cases that Rothstein used to lure investors 
into his Ponzi scheme were the cases against Epstein that were being handled by Bradley J. 
Edwards, Esq. Edwards had no knowledge of the fraud or any such use of the Epstein cases. See 
Edwards Affidavit, Exhibit "N" at ¶9. 
88. 
Bradley J. Edwards, Esq., joined RRA in about April 2009 and left RRA in 
November 2009 — a period of less than one year. Edwards would not have joined RRA had he 
been aware that Scott Rothstein was running a giant Ponzi scheme at the firm. Edwards left 
RRA shortly after learning of 
fraudulent scheme. Id. at ¶8. 
89. 
At no time prior to the public disclosure of 
Ponzi scheme did Edwards 
know or have reason to believe that Rothstein was using legitimate claims that Edwards was 
prosecuting against Epstein for any fraudulent or otherwise illegitimate purpose. Id. at ¶20. 
90. 
Edwards never substantively discussed the merits of any of his three cases against 
Epstein with Rothstein. See Deposition of Bradley J. Edwards taken March 23, 2010, at 110-16. 
(hereinafter "Edwards Depo") (Deposition Attachment #22). 
37 
EFTA00597842

91. 
On July 20, 2010, Bradley Edwards received a letter from the 
Office for the Southern District of Florida — the office responsible for prosecuting 
Ponzi scheme. The letter indicated that law enforcement agencies had determined that Edwards 
was "a victim (or potential victim)" of Scott 
federal crimes. The letter informed 
Edwards of his rights as a victim of 
fraud and promised to keep Edwards informed 
about subsequent developments in 
prosecution. See Letter attached hereto as Exhibit 
92. 
Jeffrey Epstein filed a complaint with the Florida Bar against Bradley Edwards, 
Esq., raising allegations that Edwards and others were involved in the wrongdoing of Scott 
Rothstein. After investigating the claim, the Florida Bar dismissed this complaint. See Edwards 
Affidavit, Exhibit "N" at ¶23. 
Epstein Takes the Fifth When Asked Substantive Questions About His Claims Against Edwards 
93. 
On March 17, 2010, defendant Epstein was deposed about his lawsuit against 
Edwards. 
Rather than answer substantive questions about his lawsuit, Epstein repeatedly 
invoked his Fifth Amendment privilege. 
See Epstein Depo. taken 3/17/10, Deposition 
Attachment #1. 
94. 
In his deposition, Epstein took the Fifth rather than answer the question: 
"Specifically what are the allegations against you which you contend Mr. Edwards ginned up?" 
Id. at 34. 
95. 
In his deposition, Epstein took the Fifth rather than name people in California that 
Edwards had tried to depose to increase the settlement value of the civil suit he was handling. Id. 
at 37. 
38 
EFTA00597843

96. 
In his deposition, Epstein took the Fifth rather than answer the question: "Do you 
know former President Clinton personally." Id. 
97. 
In his deposition, Epstein took the Fifth rather than answer the question: "Are you 
now telling us that there were claims against you that were fabricated by Mr. Edwards?" Id. at 
39. 
98. 
In his deposition, Epstein took the Fifth rather than answer the question, "Well, 
which of Mr. Edwards' cases do you contend were fabricated." Id. 
99. 
In his deposition, Epstein took the Fifth rather than answer the question: "What is 
the actual value that you contend the claim of E.W. against you has?" Id. at 45. 
100. 
In his deposition, Epstein took the Fifth rather than answer a question about the 
actual value of the claim of L.M. and Jane Doe against him. Id. 
101. 
In his deposition, taken prior to the settlement of 
clients claims against 
Epstein, Epstein took the Fifth rather than answer the question: "Is there any pending claim 
against you which you contend is fabricated?" Id. at 71. 
102. 
In his deposition, Epstein took the Fifth rather than answer the question: "Did you 
ever have damaging evidence in your garbage?" Id. at 74. 
103. 
In his deposition, Epstein took the Fifth rather than answer the question: "Did 
sexual assaults ever take place on a private airplane on which you were a passenger?" Id. at 88. 
104. 
In his deposition, Epstein took the Fifth rather than answer the question: "Does a 
flight log kept for a private jet used by you contain the names of celebrities, dignitaries or 
international figures?" Id. at 89. 
39 
EFTA00597844

105. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized.with Donald Trump in the presence of females under the age of I8?" Id. at 
89. 
106. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized with Alan Dershowitz in the presence of females under the age of 18." Id. at 
90. 
107. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized with Mr. Mottola in the presence of females under the age of 18?" Id. at 91-
92. 
108. 
In his deposition, Epstein took the Fifth rather than answer the question: "Did you 
ever socialize with David Copperfield in the presence of females under the age of 18?" Id. at 
109. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever socialized with Mr. Richardson [Governor of New Mexico and formerly 
Representative and Ambassador to the United Nations] in the presence of females under the age 
of 18." Id. at 94. 
110. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever sexually abused children?" Id. at 95. 
111. 
In hiS deposition, Epstein took the Fifth rather than answer the question: "Did you 
have staff members that assisted you in scheduling appointments with underage females; that is, 
females under the age of 18." Id. at 97-98. 
112. 
In his deposition, Epstein took the Fifth rather than answer the question: "On how 
many occasions did you solicit prostitution." Id. at 102. 
40 
EFTA00597845

113. 
In his deposition, Epstein took the Fifth rather than answer the question: "How 
many minors have you procured for prostitution?" Id. at 104. 
114. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have 
you ever coerced, induced or enticed any minor to engage in any sexual act with you?" Id. at 
107. 
115. 
In his deposition, Epstein took the Fifth rather than answer the question: "How 
many times have you engaged in fondling underage females?" Id. at 108. 
116. 
In his deposition, Epstein took the Fifth rather than answer the question: "How 
many times have you engaged in oral sex with females under the age of 18?" Id. at 110. 
117. 
In his deposition, Epstein took the Fifth rather than answer the question: "Do you 
have a personal sexual preference for children?" Id. at 111-12. 
118. 
In his deposition, Epstein took the Fifth rather than answer the question: "Your 
Complaint at page 27, paragraph 49, says that `RRA and the litigation team took an emotionally 
driven set of facts involving alleged innocent, unsuspecting, underage females and a Palm Beach 
billionaire, and sought to turn it into a goldmine,' end of quote. Who is the Palm Beach 
billionaire referred to in that sentence?" Id. at 112-13. 
119. 
In his deposition, Epstein took the Fifth rather than answer the question: "Who are 
the people who are authorized to make payment [to your lawyers] on your behalf?" Id. at 120. 
120. 
In his deposition, Epstein took the Fifth rather than answer the question: "Is there 
anything in L.M.1 Complaint that was filed against you in September of 2008 which you 
contend to be false?" Id. at 128. 
41 
EFTA00597846

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on November 
, 2010 a copy of the foregoing has been 
served via Fax and.. Mail to all those on the attached service list. 
By: 
Jack Scarola 
Searcy, Denney, Scarola, Barnhart & Shipley 
2139 Palm Beach Lakes Blvd 
West Palm Beach, FL 33409 
(561) 686- 
•0 
(561 
(fax) 
42 
AROLA 
ar No.: 169440 
EFTA00597847

SERVICE LIST 
Christopher E. Knight, Esq. 
Joseph L. Ackerman, Esq. 
FOWLER WHITE BURNETT P.A. 
901 Phillips Point West 
777 South Flagler Drive 
West Palm Beach, FL 33401 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger et al. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401 
Marc I. Nurik, Esq. 
Law Offices of Marc I. Nurik 
One E. Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Gary M. Farmer, Jr. 
Farmer, Jaffe, Weissing, 
Edwards, Fistos & Lehrman, P.L. 
425 N. Andrews Ave., Suite 2 
Fort Lauderdale, FL 33301 
43 
EFTA00597848

DEFENDANTBRADLEYJ.
STATEMENT OF UNDISPUTED FACTS 
Epstein v. Edwards, et al. 
Case No.: 50 2009 CA 040800,OCCA'MBAG 
EXHIBIT N 
e;4 
EFTA00597849

(-3 
AFFIDAVIT OF BRADLEY JAMES EDWARDS 
1. 
I am an attorney in good standing with the Florida Bar and admitted to practice in the 
Southern District of Florida. I am currently a partner in the law firm of Fanner, Jaffe, 
Weissing, Edwards, Fistos & Lehrman, P.L. 
2. 
In 2008, I was a sole practitioner running a personal injury law firm in Hollywood, FL. 
While a sole practitioner I was retained by three clients, L.M., E.W., and Jane Doe to 
pursue civil litigation against Jeffrey Epstein for sexually abusing them while they were 
minor girls. I agreed to represent these girls, along with attorney Jay Howell (an 
attorney in Jacksonville, Florida with Jay Howell & Associates) and Professor Paul 
Cassell (a law professor at the University of Utah College Of Law). I filed fate court 
actions on behalf of L.M. and E.W. and a federal court action on behalf of Jane Doe. 
All of the cases were filed in the summer of 2008. 
3. 
My clients received correspondence from the M. Department of Justice regarding 
their rights as victims of Epstein's federal sex offenses. (True and accurate copies of 
the letters are attached to Statement of Undisputed Facts as Exhibit "M") 
4. 
In mid June 2008, I contacted Assistant United States Attorney Marie Villafaha to 
inform her that I represented Jane Doe #1(E.W.) and, later, Jane Doe #2(L.M.). I asked 
to meet to provide information regarding Epstein. AUSA ViLlafatta did not advise me 
that a plea agreement had already been negotiated with Epstein's attorneys that would 
block federal prosecution. AUSA Villafafia did indicate that federal investigators had 
concrete evidence and information that Epstein had sexually molested at least 40 
underage minor females, including E.W., Jane Doe and L.M. 
5. 
I also requested from the M. 
Office the information and evidence that th 
had collected regarding Epstein's sexual abuse of his clients. However the 
Office declined to provide any such information to me. The 
a
 
Office also declined to provide any such information to the other attorneys who 
represented victims of Epstein's sexual assaults. 
6. 
I was informed that on Friday, June 27, 2008, at approximately 4:15 p.m., AUSA 
Villafaz3a received a copy of Epstein's proposed state plea agreement and learned that the 
plea was scheduled for 8:30 am., Monday, June 30, 2008. She called me to provide 
notice to my clients regarding the hearing. She did not tell me that the guilty pleas in 
state court would bring an end to the possibility of federal prosecution pursuant to the 
plea agreement. My clients did not team and understand this fact until July 11, 2008, 
when the agreement was described during a hearing held before Judge Marra on the 
Crime Victims' Rights Act action that I had filed. 
7. 
In the summer of 2008 I filed complaints against Jeffrey Epstein on behalf of L.M., 
E.W., and Jane Doe. 
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