EFTA01093549

Epstein's Obstruction of Normal Discover), 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 ¶¶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 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 
21 
EFTA01093569

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 ¶11 and Deposition attachments #1, 6, 7, 10, 
11, 12, and 13. Cf. with Deposition of Epstein taken by an attorney representing BB (one in 
which Edwards was not participating), httn://www.voutube.com/watch?v=V-dqoEyYXx4; and 
http://www.youtube.corn/watch?v=YCNiY1tW-r0 
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 
attachment #14); Deposition of 
Deposition of 
March 24, 2010 (hereinafter 
) (Deposition 
April 13, 2010, (Deposition attachment #9); 
March 15, 2010 (hereinafter 
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 
22 
EFTA01093570

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 ¶11. 
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 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, Ghislaine Maxwell, Some Underage Girls and A Very Disturbing Story, 
September 
23, 
2007 
by 
Wendy 
Leigh, 
link 
at 
http://www.redicecreations.comiarticle.php?id=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. 
23 
EFTA01093571

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 Gresser, 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 
Exhibit "DD" and Edwards Affidavit, Exhibit "N" at ¶12. 
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 1" today if you call." See Messages taken from Jean Luc Brunel are attached hereto as 
Exhibit "EE." In light of these circumstances of the case, this message reasonably suggested to 
24 
EFTA01093572

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://bradmillershero.blogsoot.com/2010/08/women-are-obiects.html, attached hereto as Exhibit 
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 "GO." 
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 "J" supra 
and Sworn Statement of MC2 employee 
June 15, 2010,
Sworn Statement" attached at Exhibit "HI-I" 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, affiliated with Epstein and Brunel brought underage girls from all over the world, 
promising them modeling contracts. Epstein and Brunel would then obtain a visa for these girls, 
then would charge the underage girls rent, presumably to live as underage prostitutes in the 
condos. Se 
worn Statement, Exhibit "HH" at 7-10, 12-15, 29-30, 39-41, 59-
60 and 62-67. 
25 
EFTA01093573

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, Brunel's 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 "KK" (Because Epstein settled this case, the motion was never ruled 
upon.) 
67. 
Edwards was also informed that Epstein paid for not only Brunel's 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), 
(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 ¶11. 
26 
EFTA01093574

68. 
While Epstein and others were preventing any legitimate discovery into his sexual 
abuse of minor girls, at the same time he 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 offender's Millions See Painful Pasts 
Used 
Against 
Them, 
Palm 
Beach 
Post 
News, 
Jan. 
23, 
2010, 
available 
at 
htto://www.palmbeachvost.corninews/crime/victims-seeking-sex-offenders-millions-see-painful-
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 Edwards's 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" 
70. 
Edwards notified Epstein's attorneys of his intent to take Bill Clinton's 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 
EFTA01093575

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 
- 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 Clinton's 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" "AA", "DD", and "MM" and Edwards Affidavit, 
Exhibit "N" at 115. 
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 Edwards's clients' 
complaints; (b) Trump was quoted in a Vanity Fair article about Epstein as saying "I've known 
Jeff for fifteen years. Terrific guy," "He's 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 
EFTA01093576

Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's 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. 102's complaint alleged that Jane Doe 
102 was initially approached at Trump's 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 Trump's 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 113. 
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 
EFTA01093577

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 Attorney's 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; 
(f) 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 Attorney's office 
attached as Exhibit "Pr; Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit 
"MM"; Exhibits "B" and "OO"; and Edwards Affidavit, Exhibit "N" at ¶14. 
30 
EFTA01093578

73. 
Epstein's complaint alleges that Edwards provided notice that he wished to take 
the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by 
the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" 
at 1116. 
74. 
Edwards gave notice that he intended to take David Copperfield's 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 
¶17. 
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 
EFTA01093579

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 Doe's 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. Edwards's 
client Jane Doe was proceeding to trial on a federal claim under 18 U.S.C. § 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 
EFTA01093580

Edwards anticipated that Epstein would argue that Jane Doe's 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 Malta did not 
rule on the summary judgment motion. 
79. 
Edwards had 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. 102's 
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 
EFTA01093581

• 
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); 
• 
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 trying 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 
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 
EFTA01093582

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, 
U.S. Attorney's Correspondence, Exhibit "C" - Indictments drafted by Federal Government 
against Epstein; and Edwards Affidavit, Exhibit "N" at 111. 
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 Doe's 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 ■., M., and Jane 
Doe were reasonably perceived by Edwards to be very strong cases. Because Epstein had 
35 
EFTA01093583

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 had 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 ¶19. 
85. 
On July 6, 2010, rather than face trial for the civil suits that had been filed against 
him by M.,.., 
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..,.., 
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 Edwards's 
settlement negotiations. See Edwards Affidavit, Exhibit "N" at ¶21. 
Edwards Non-Involvement in Fraud by Scott Rothstein 
36 
EFTA01093584

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 (S.D. 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 Rothstein's fraudulent scheme. Id. at ¶8. 
89. 
At no time prior to the public disclosure of Rothstein's 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 
EFTA01093585

91. 
On July 20, 2010, Bradley Edwards received a letter from the U.S. Attorney's 
Office for the Southern District of Florida — the office responsible for prosecuting Rothstein's 
Ponzi scheme. The letter indicated that law enforcement agencies had determined that Edwards 
was "a victim (or potential victim)" of Scott Rothstein's federal crimes. The letter informed 
Edwards of his rights as a victim of Rothstein's fraud and promised to keep Edwards informed 
about subsequent developments in Rothstein's 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. 
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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 ■. 
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.. 
and Jane Doe against him. Id. 
101. 
In his deposition, taken prior to the settlement of Edwards's 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. 
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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 18?" 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 U.S. 
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 
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