File 013463
Affidavit of Bradley Edwards - Jane Doe v. Jeffrey Epstein Civil Case (File 013463)
Attorney Bradley Edwards' affidavit in the Jane Doe v. Jeffrey Epstein civil case describing discovery obstacles, Epstein's Fifth Amendment assertions, and statements made to journalist George Rush regarding the abuse allegations and lack of remorse.
Summary
Bradley Edwards, lead attorney for Jane Doe, provides an affidavit detailing the civil case against Jeffrey Epstein for sexual molestation of a minor. The affidavit documents how Epstein's non-prosecution agreement limits Jane Doe's damages, how Epstein and his co-conspirators have invoked Fifth Amendment privileges to avoid providing discovery, and critically, how journalist George Rush reported that Epstein admitted to coming "too close to the line" and expressed minimal remorse for his conduct. Edwards argues these statements from Rush are crucial evidence of Epstein's admission of liability and lack of remorse for punitive damages purposes.
AFFIDAVIT OF BRADLEY JAMES EDWARDS1. I am an attorney in good standing with the Florida Bar and admitted to practice in theSouthern District of Florida. I am a partner in the law firm of Farmer Jaffe Weissing Edwards Fistos andLehrman.2. I am the lead attorney currently representing "Jane Doe" in the case of Jane Doe v.Jeffrey Epstein, case number 08-80893 in federal Court in the Southern District of Florida. I am the leadattorney representing Jane Doe, whose civil complaint alleges that Epstein sexually molested hernumerous occasions when she was a minor.3. Defendant Epstein has entered into a "non-prosecution agreement" (NPA) with thefederal government for sex crimes against minors. Under that agreement, the federal government hasagreed not to file criminal charges against Epstein for sex crimes committed against approximately thirtygirls, including Jane Doe. In exchange, Epstein agreed to plead guilty to state law criminal chargesinvolving solicitation of prostitution and procuring a minor for prostitution. The victim of the criminalcharges to which he has pled was not Jane Doe.4. Under the NPA, Epstein has agreed not to contest civil liability of any of hisapproximately thirty victims — provided that the victim agrees to limit themselves to the damagesprovided by 18 U.S.C. § 2255 (currently set at $150,000). Jane Doe has not agreed to limit herself topursuing only $150,000-in damages. Therefore, the terms of the NPA purport to prevent Jane Doe from.using the NPA to prove liability.5. Epstein has filed an answer to Jane Doe's complaint, in which he has invoked his FifthAmendment right to silence with respect to the allegations that he molested her as a child. Epstein hasfurther argued that this Fifth Amendment invocation is the functional equivalent of, and must betreated as, a specific denial of the allegations.6. Defendant Epstein 's deposition has been taken on several occasions, in this and otherrelated cases, and he has not provided any substantive discovery whatsoever. Instead, he invoked his5th amendment privilege against self-incrimination when asked questions about his abuse of Jane Doe orother girls.7. Defendant Epstein has also been served with Interrogatories and requests forproduction; all requests have been met with 5th amendment assertions and Epstein has not given JaneDoe any substantive testimony related her allegations.8. Jane Doe's complaint contains a punitive damages claim, and Mr. Epstein has alsoelected to invoke the 5th Amendment on all questions that would relate to punitive damages issues,such as his intent when committing the crimes, his lack of remorse and his intent to recidivate.9. Epstein has taken Jane Doe's deposition. During that deposition he has asked numerousquestions of Jane Doe that suggest that she is fabricating her allegation of abuse by Epstein.10. In addition to deposing Mr. Epstein, other attorneys and I have taken the depositions ofhis various co-conspirators (as labeled by the federal government in the NPA), includingand Each of those individuals was employed by Epstein to bringhim underage girls for him to molest and to ensure that he was protected from detection by lawenforcement, and thus those individuals could likely provide general testimony that would assist Plaintiffin proving liability and damages, including punitive damages. However, none of these individuals wereHOUSE OVERSIGHT 013463present during acts of sexual abuse by Epstein. In any event, ALL of those individuals have also invokedtheir 5th amendment rights against self-incrimination, and thus have left Plaintiff with no informationabout what Epstein or other conspirators inside his house were doing during the sexual abuse of JaneDoe and other minors girls. This creates a serious issue for Jane Doe in proving her sexual molestationclaim against Epstein. By its nature, sexual molestation takes place in private, with only the abuser andthe victim typically available to testify. In this case, Epstein's abuse of Jane Doe took place in private,with only Epstein and Jane Doe present during the abuse. Jane Doe has no other reasonable avenues ofdiscovery to provide direct proof of claim of sexual abuse by Epstein.11. Additionally, Mr. Epstein has recently filed a lawsuit against me personally that has nomerit whatsoever, a fact known to Mr. Epstein and his attorneys. He filed the lawsuit against BradEdwards, Scott Rothstein, and =another Epstein victim of his molestation). That lawsuit implies thatL.M.'s civil case against him (currently pending in Florida state court) is fabricated and that and Ihave conspired to commit fraud against him (presumably that she made up the case against him,implying that he does not knovM. While the present subpoena before the Court has been filed byJane Doe, the Court should be aware that attorneys representingMmay also file a subpoena for theGeorge Rush tape shortly.12. Despite Mr. Epstein and all of his co-conspirators, asserting a 5" amendment privilegeagainst self-incrimination, George Rush of the New York Daily news did contact me to inform me thatMr. Epstein spoke personally with him about issues related to the various charges of sex abuse againsthim.13. Paraphrasing from memory of my conversation with Mr. Rush, Mr. Epstein told him thathe may have come"too close to the line" but that he should not have been punished as severely as hewas and that his conduct was at most worthy of a $100 fine. This is a statement that shows two thingsof great importance to Jane Doe's pending civil action. First, it is in effect an admission by Epstein of hisliability to Jane Doe for sexually abusing her. Jane Doe does not have any other admission of Epstein ofhis sexual abuse of her and Epstein has filed an answer to Jane Does complaint that has the functionaleffect of denying abuse of her. Jane Doe has diligently pursued all possible ways of obtaining anadmission from Epstein of his molestation of Jane Doe without success. Second, the statement to Mr.Rush is a clear demonstration that Epstein lacks remorse for committing felony child molestation againstJane Doe. This will be a central issue in the punitive damages case against Epstein at trial. Here again,Jane Doe has diligently pursued all possible ways of obtaining a statement from Epstein about his lack ofremorse for abusing Jane Doe without success. There are no other reasonable means of obtaining astatement from Epstein on these subjects.14. Mr. Rush also told me that Mr. Epstein spoke specifically about one of my clients,and he made derogatory remarks about her.15. Additionally, Mr. Rush said that Epstein spoke directly about another civil case that wasfiled against him (Jane Doe 102 v. Epstein); that case alleges that Epstein repeatedly sexually abused a15 year old girl, forced her to have sex with his friends and flew her on his private plane nationally andinternationally for the purposes of sexually molesting and abusing her. Epstein flippantly told GeorgeRush that that case was dismissed, in a way to indicate that the allegations are ridiculous and untrue.Mr. Rush indicated that he taped the conversation between him and Mr. Epstein.17. Mr. Rush also spoke at length to Michael Fisten, an investigator with my firm that wasassisting with the investigation of the case. Mr. Fisten reported to me shortly after the conversationwith Mr. Rush that he had such a conversation.HOUSE OVERSIGHT 01346418. While research by other plaintiffs' attorneys and myself has uncovered other personsthat were acquaintances of Mr. Epstein, specifically Donald Trump, Alan Dershowitz, Bill Clinton,Tommy Mottola, and David Copperfield, we have no information that any of those people (other thanMr. Dershowitz) have spoken to Mr. Epstein about Jane Doe or any of the other specific victims of Mr.Epstein's molestation. Mr. Dershowitz is acting as an attorney for Mr. Epstein, and therefore it ispresumably unlikely to question him about any admissions that Epstein may have made regarding JaneDoe or other minors girls. Additionally, we have no information that any of those individuals or anyother individuals have any taped statements of Epstein's own voice relating to these matters. GeorgeRush's taped conversation with Mr. Epstein is the only known one in existence, making it very uniqueand it contains information not otherwise obtainable through other means or sources. Indeed, withoutthe Rush tape conversation, the jury that handles the case will not hear any words from Epstein himselfabout his abuse of Jane Doe and other young girls. I have been informed by Epstein's attorney thatEpstein intends to invoke his Fifth Amendment rights rather than answer any substantive questionsabout the abuse of Jane Doe and other girls at trial.19. The Rush interview is, in any event, unique and not otherwise obtainable from otherwitnesses because it can be used to prove perjury (a federal crime) on the part of Epstein. Epstein liedabout not knowing George Rush. See deposition of Jeffrey Epstein, taken in Jeffrey Epstein, case50-2008-CA-028051, page 154, line 4 through 155 line 9, wherein Jeffrey Epstein clearly impresses thathe does not recognize George Rush from the New York Daily News, despite the fact that he gave apersonal interview that we all now know to have been tape recorded. It is therefore evidence of acriminal event. If we receive the tape, we intend to alert the appropriate law enforcement authorities,both federal and state, so that they can pursue any appropriate criminal investigation perjury charges.20. The tape is also crucial for. to dismiss the frivolous complaint filed by Jeffrey Epsteinagainst her, as he clearly acknowledges knowing contrary to claims he makes in his complaintagainst her and also contradictory to other statements he has made in depositions related to knowingIn that regard, this tape provides evidence of other false statements Epstein has made under oath.21. During a telephone call with George Rush, he provided me more than a description ofthe tape, and in fact described the general tenor of the entire interview, so that nothing in the interviewcan be fairly regarded as confidential at this point.22. As George Rush admitted in his affidavit, he played the tape for at least two otherpersons who also confirmed Epstein's arrogance as he speaks about his actions with minors.23. The people for whom George Rush played the tape or told in detail of the informationon the tape were not "sources" in the tradition sense of the word — all individuals were simply chattingwith Mr. Rush about Mr. Epstein and his propensity to molest children. For example, when I discussedthe tape with Mr. Rush, I was not a "source" in the traditional sense of that term. At no point did Mr.Rush tell me that I was a "source" for his reporting.24. Because Epstein and all other co-conspirators have invoked the 5th amendment as to allrelevant questions, this tape is the only way that Jane Doe can put Epstein's own perceptions of whathe has done before the jury and the only way that Jane Doe can put Epstein's admissions and statements before the jury. As even a quick perusal of the more than 500 entries on the docket sheet for JaneDoe's (consolidated) case will confirm (see Case no. 9:08-80119 (S .D. Fla.) (case number for consolidatedcases on discovery), Jane Doe and other plaintiffs have made exhaustive attempts to obtain informationfrom Epstein about his abuse. These attempts have included repeated requests for admission, requestsfor production, interrogatories, and depositions — all the means that are listed in the Federal Rules ofCivil Procedure for obtaining discovery. These means have all been exhausted without success. NeitherHOUSE OVERSIGHT 013465Jane Doe nor any of the other plaintiffs have been able to obtain even a single word of information fromEpstein about his abuse of minor girls.25. I made a good faith, albeit unsuccessful, effort to resolve this matter with Anne B.Carroll, representing the Daily News in order to avoid any court intervention. I explained that weneeded this tape for several reasons, including those cited by her in her pleading. The tape isdetrimental to Epstein's personal complaint against = and me; the tape is evidence of perjurycommitted by Epstein; the tape is the Best Evidence of his lack of remorse for his actions and will bepresented in the punitive damages phase of the civil trials against him; and, perhaps most important,the tape is the only way that the jury considering Jane Doe's case will be able to hear Epstein's voice andown statements about his abuse of Jane Doe and other minor girls. Without the tape, the jury will nothave the opportunity to hear Epstein give any substantive information about Jane Doe's complaint.Indeed, they will not have the opportunity to even hear Epstein's voice utter any substantive wordsother than (in essence) "I take the Fifth." As part of our discussion, Ms. Carroll told me that it was a"stupid move" for Mr. Rush to play the tape or disclose the tape to other people as he likely waived anyprivilege and that, as a result of disclosing the tape, he was at risk of losing his job. I responded that itdid not seem fair that Mr. Rush lose his job or be punished in any way, but that I had an absolute duty torepresent my client and that I would be failing in that duty if I did not pursue this critical piece ofevidence.I declare under penalty of perjury that the foregoing is true and correct.FURTHER AFFIANT SAYETH NAUGHT.Dated this 23' day of April, 2010.The foregoing instrument was acknowledged before me this 23 day of April, 2010 by BRADEDWARDS, who is personally known to me.My Commission Expires:MARIAW.KELLICNIANte COMMISSION *00 813393- EXPIRES: August 1 1 , 20'125/070. Boodedibru Notary Pubic Undowiters 'HOUSE OVERSIGHT 013466DEFENDAIVT BRADLEY EDWARDS'S STATEMENT OF UNDISPUTED FACTSEpstein v. Edwards, et al.Case No.: 50 2009 CA 040800NOCCMBAGEXHIBIT NHOUSE OVERSIGHT 013467AFFIDAVIT OF BRADLEY JAMES EDWARDS1. I am an attorney in good standing with the Florida Bar and admitted to practice in theSouthern District of Florida. I am currently a partner in the law firm of Farmer, Jaffe,Weissing, Edwards, Fistos & Lehrman, P.L.2. In 2008, I was a sole practitioner running a personal injtntw firm in Hollywood, FL.While a sole practitioner I was retained by three clients, =, OM, and Jane Doe topursue civil litigation a. ainst Jeffrey Epstein for sexually abusing them while they wereminor girls. I agreed to represent these girls, along with attorney Jay Howell (anattorney in Jacksonville, Florida with Jay Howell & Associates) and Professor PaulCassell (a law professor at the University of Utah College Of Law). I filed state courtactions 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 U.S. Department of Justice regardingtheir rights as victims of Epstein's federal sex offenses. (True and accurate copies ofthe letters are attached to Statement of Undisputed Facts as Exhibit "M")4. In mid June 2008, I contacted Assistant United States Attorney Marie Villafafta toinform her that I represented Jane Doe #1=.) and, later, Jane Doe #2M). I askedto meet to provide information regarding Epstein. AUSA Villafarla did not advise methat a plea agreement had already been negotiated with Epstein's attorneys that wouldblock federal prosecution. AUSA Villafafia did indicate that federal investigators hadconcrete evidence and information that Epstein had sexually molested at least 40underage minor females, including=., Jane Doe and5. I also requested from the U.S. Attorney's Office the information and evidence that theyhad collected regarding Epstein's sexual abuse of his clients. However, the U.S.Attorney's Office declined to provide any such information to me. The U.S. Attorney'sOffice also declined to provide any such information to the other attorneys whorepresented victims of Epstein's sexual assaults.6. I was informed that on Friday, June 27, 2008, at approximately 4:15 p.m., AUSAVillafafia received a copy of Epstein's proposed state plea agreement and learned that theplea was scheduled for 8:30 a.m., Monday, June 30, 2008. She called me to providenotice to my clients regarding the hearing. She did not tell me that the guilty pleas instate court would bring an end to the possibility of federal prosecution pursuant to theplea agreement. My clients did not learn and understand this fact until July 11, 2008,when the agreement was described during a hearing held before Judge Marra on theCrime Victims' Rights Act action that I had filed.7. In the summer of 2008 •I filed complaints against Jeffrey Epstein on behalf o!=,E.W., and Jane Doe.HOUSE OVERSIGHT 0134688. In the Spring of 2009 (approximately April), I joined the law firm of Rothstein,Rosenfeldt and Adler, P.i."RRA"). I brought my existing clients with me when Ijoined RRA, including M., and Jane Doe. When I joined the finn, I was notaware that Scott Rothstein was running a Ponzi scheme at RRA. Had I known such aPonzi scheme was in place, I would never have joined RRA.9. I am now aware that it has been alleged that Scott Rothstein made fraudulentpresentations to investors about the lawsuits that I had filed on behalf of my clientsagainst Epstein and that it has been alleged that these lawsuits were used to fraudulentlylure investors into Rothstein's Ponzi scheme. I never met a single investor, had no partin any such presentations and had no knowledge any such fraud was occurring. If theseallegations are true, I had no knowledge that any such fraudulent presentations wereoccurring and no knowledge of any such improper use of the case files.10. Epstein's Complaint against me alleges that Rothstein made false statements aboutcases filed against Epstein, i.e., that RRA had 50 anonymous females who had filed suitagainst Epstein; that Rothstein sold an interest in personal injury lawsuits, reachedagreements to share attorneys fees with non-lawyers, paid clients "up front" money; andthat he used the judicial process to further his Ponzi scheme. If Rothstein did any ofthese things, I had no knowledge of his actions. Because I maintained close contactwith my clients, and Jane Doe, and Scott Rothstein never met any of them, Iknow for certain that none of my clients were paid "up front" money by anyone.11. Epstein alleges that I attempted to take the depositions of his "high profile friends andacquaintances" for no legitimate litigation purpose. This is untrue, as all of my actionsin representing M., M, and Jane Doe were aimed at providing them effectiverepresentation in their civil suits. With regard to Epstein's friends, through documentsand information obtained in discovery and other means of investigation, I learned thatEpstein was sexually molesting minor girls on a daily basis and had been for manyyears. I also learned the unsurprising fact that he was molesting the girls in the privacyof his mansion in West Palm Beach, meaning that locating witnesses to corroboratetheir testimony would be difficult to find. I also learned, from the course of thelitigation, that Epstein and his lawyers were constantly attacking the credibility of thegirls, that Epstein's employees were all represented by lawyers who apparently werepaid for (directly or indirectly) by Epstein, that co-conspirators whose representationwas also apparently paid for by Epstein were all taking the Fifth (like Epstein) ratherthan provide information in discovery. For example, I was given reason to believe thatLarry Visoski, Larry Harrison, David Rogers, Louella Rabuyo,Ghislaine Maxwell, Mark Epstein, and Janusz Banasiak all had lawyerspaid for by Epstein. Because Epstein and the co-conspirators in his child molestationcriminal enterprise blocked normal discovery avenues, I needed to search for otherordinary approaches to strengthen the cases of my clients. Consistent with my trainingand experience, these other ordinary approaches included finding other witnesses whocould corroborate allegations of sexual abuse of my clients or other girls. Some of thesewitnesses were friends of Epstein. Given his social status, it also turned out that someof his friends were high-profile. individuals.HOUSE OVERSIGHT 01346912. In light of information I received suggesting that British socialite Ghislaine Maxwell,former girlfriend and long-time friend of Epstein's, was involved in managing Epstein'saffairs and companies I had her served for deposition for August 17, 2009. (DepositionNotice attached to Statement of Undisputed Facts as Exhibit BB). Maxwell wasrepresented by Brett Jaffe of the New York firm of Cohen and Gresser, and Iunderstood that her attorney was paid for (directly or indirectly) by Epstein. She wasreluctant to give her deposition, and I tried to work with her attorney to take herdeposition on terms that would be acceptable to both sides. Her attorney and Inegotiated a confidentiality agreement, under which Maxwell agreed to drop anyobjections to the deposition. Maxwell, however, still avoided the deposition. On June29, 2010, one day before I was to fly to NY to take Maxwell's deposition, her attorneyinformed me that Maxwell's mother was deathly ill and Maxwell was consequentlyflying to England with no intention of returning and certainly would not return to theUnited States before the conclusion of Jane Doe's trial period (August 6, 2010).Despite that assertion, I later learned that Ghislaine Maxwell was in fact in the countryon approximately July 31, 2010, as she attended the wedding of Chelsea Clinton(former President Clinton's daughter) and was captured in a photograph taken for USWeekly magazine.13. Epstein alleges that there was something improper in the fact that I notified him that Iintended to take Donald Trump's deposition in the civil suits against him. Trump wasproperly noticed because: (a) after review of the message pads confiscated fromEpstein's home, the legal and investigative team assisting my clients learned that Trumpcalled Epstein's West Palm Beach mansion on several occasions during the time periodmost relevant to my clients' complaints; (b) Trump was quoted in a Vanity Fair articleabout Epstein as saying "I've known Jeff for fifteen years. Terrific guy." "He's a lotof fun to be with. It is even said that he likes beautiful women as much as I do, andmany of them are on the younger side. No doubt about it — Jeffrey enjoys his sociallife." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel ofNobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, socialiteGhislaine 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 worldbegan to wonder who he is. By Landon Thomas Jr.; (c) I learned through a sourcethat Trump banned Epstein from his Maralago Club in West Palm Beach becauseEpstein sexually assaulted an underage girl at the club; (d) Jane Doe No. 102'scomplaint alleged that Jane Doe 102 was initially approached at Trump's Maralago byGhislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e)Mark Epstein (Jeffrey Epstein's brother) testified that Trump flew on Jeffrey Epstein'splane with him (the same plane that Jane Doe 102 alleged was used to have sex withunderage girls) deposition of Mark Epstein, September 21, 2009 at 48-50; (f) Trumpvisited Epstein at his home in Palm Beach — the same home where Epstein abusedminor girls daily; (g) Epstein's phone directory from his computer contains 14 phonenumbers for Donald Trump, including emergency numbers, car numbers, and numbersto Trump's security guard and houseman. Based on this information, I believed thatHOUSE OVERSIGHT 013470Trump might have relevant information to provide in the cases against Jeffrey Epsteinand accordingly provided notice of a possible deposition.14. Epstein alleges that there was something improper in the fact that I notified him that Iintended to take Alan Dershowitz's deposition in the civil suits against him. Dershowitzwas properly noticed because: (a) Dershowitz has been friends with Epstein for manyyears; (b) in one news article Dershowitz comments that, "I'm on my 20th book... Theonly person outside of my immediate family that I send drafts to is Jeffrey" TheTalented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, VanityFair; (c) Epstein's housekeeper Alfredo Rodriguez testified that Dershowitz stayed atEpstein's house during the years most relevant to my clients; (d) Rodriguez testifiedthat Dershowitz was at Epstein's house at times when underage females where therebeing molested by Epstein (see Alfredo Rodriguez deposition at 278-280, 385, 426-427); (e) Dershowitz was reportedly involved in persuading the Palm Beach StateAttorney's office not to file felony criminal charges against Epstein because theunderage females lacked credibility and thus could not be believed that they were atEpstein's house, despite him being an eyewitness that the underage girls were actuallythere; (f) Jane Doe No. 102 stated generally that Epstein forced her to be sexuallyexploited by not only Epstein but also Epstein's "adult male peers, including royalty,politicians, academicians, businessmen, and/or other professional and personalacquaintances" — categories that Dershowitz and acquaintances of Dershowitz fall into;(g) during the years 2002-2005 Alan Dershowitz was on Epstein's plane on severaloccasions 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 Harvard $30 Million dollars one year, and Harvard was one of the onlyinstitutions that did not return Epstein's donation after he was charged with sex offensesagainst children. Based on this information, I believed that Dershowitz might haverelevant information to provide in the cases against Jeffrey Epstein and accordinglyprovided notice of a possible deposition.15. Epstein alleges that there was something improper in the fact that I notified him that Iintended to take Bill Clinton's deposition. Clinton was properly noticed because: (a) itwas well known that Clinton was friends with Ghislaine Maxwell, and several witnesseshad provided information that Maxwell helped to run Epstein's companies, kept imagesof naked underage children on her computer, helped to recruit underage children forEpstein, engaged in lesbian sex with underage females that she procured for Epstein,and photographed underage females in sexually explicit poses and kept childpornography on her computer; (b) newpaper articles stated that Clinton had an affairwith Ghislaine Maxwell, who was thought to be second in charge of Epstein's childmolestation ring. The Cleveland Leader newspaper, April 10, 2009; (c) it was nationalnews when Clinton traveled with Epstein (and Maxwell) aboard Epstein's private planeto Africa and the news articles classified Clinton as Epstein's friend; (d) the flight logsfor the relevant years 2002 - 2005 showed Clinton traveling on Epstein's plane on morethan 10 occasions and his assistant, Doug Band, traveled on many more occasions; (e)Jane Doe No. 102 stated generally that she was required by Epstein to be sexuallyHOUSE OVERSIGHT 013471exploited by not only Epstein but also Epstein's "adult male peers, including royalty,politicians, academicians, businessmen, and/or other professional and personalacquaintances" — categories Clinton and acquaintances of Clinton fall into; (f) flightlogs showed that Clinton took many flights with Epstein, Ghislaine Maxwell,md -- all employees and/or co-conspirators of Epstein's thatwere closely .connected to Epstein's child exploitation and sexual abuse; (g) Clintonfrequently flew with Epstein aboard his plane, then suddenly stopped — raising thesuspicion that the friendship abruptly ended, perhaps because of events related toEpstein's sexual abuse of children; (h) Epstein's personal phone directory from hiscomputer 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 beClinton's personal numbers. Based on this information, I believed that Clinton mighthave relevant information to provide in the cases against Jeffrey Epstein andaccordingly provided notice of a possible deposition.16. Epstein alleges that Tommy Mottola was improperly noticed with a deposition. I didnot notice Mattola for deposition. He was noticed for deposition by a law firmrepresenting another one of Epstein's victims — not by me.17. Epstein alleges that there was something improper in the fact that I notified him that Iintended to take the illusionist David Copperfield's deposition. Copperfield wasproperly noticed because: (a) Epstein's housekeeper Alfredo Rodriguez testified thatDavid Copperfield was a guest on several occasions at Epstein's house; (b) according tothe message pads confiscated from Epstein's house, Copperfield called Epstein quitefrequently and left messages that indicated they socialized together; (c) Copperfieldhimself has had similar allegations made against him by women claiming he sexuallyabused them; (d) one of Epstein's sexual assault victims also alleged that Copperfieldhad touched her in an improper sexual way while she was at Epstein's house. Based onthis information, I believed that Copperfield might have relevant information to providein the cases against Jeffrey Epstein and accordingly provided notice of a possibledeposition.18. Epstein alleges that there was something improper in the fact that I identified BillRichardson as a possible witness against him in the civil cases. Richardson wasproperly identified as a possible witness because Epstein's personal pilot testified toRichardson joining Epstein at Epstein's New Mexico Ranch. See deposition of LarryMorrison, October 6, 2009, at 167-169. There was information indicating that Epsteinhad young girls at his ranch which, given the circumstances of the case, raised thereasonable inference he was sexually abusing these girls since he had regularly andfrequently abused girls in West Palm Beach and elsewhere. Richardson had alsoreturned campaign donations that were given to him by Epstein, indicating that hebelieved that there was something about Epstein that he did not want to be associatedwith. Richardson was not called to testify nor was he ever subpoenaed to testify.19. Epstein alleges that discovery of plane and pilot logs was improper during discovery inthe civil cases against him. Discovery of these subjects was clearly proper andHOUSE OVERSIGHT 013472necessary because: (a) Jane Doe filed a federal RICO claim against Epstein that was anactive claim through much of the litigation. The RICO claim alleged that Epstein ran anexpansive 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 my clients intended to pursue an appeal of that dismissal.Moreover, all of the subjects mentioned in the RICO claim remained relevant to otheraspects of Jane Doe's claims against Epstein, including in particular her claim forpunitive damages; (b) Jane Doe also filed and was proceeding to trial on a federal claimunder 18 U.S.C. § 2255. Section 2255 is a federal statute which (unlike other statestatutes) guaranteed a minimum level of recovery for Jane Doe. Proceeding under thestatute, however, required a "federal nexus" to the sexual assaults. Jane Doe had twogrounds on which to argue that such a nexus existed to her abuse by Epstein: first, hisuse of the telephone to arrange for girls to be abused; and, second, his travel on planesin interstate commerce. During the course of the litigation, I anticipated that Epsteinwould argue that Jane Doe's proof of the federal nexus was inadequate. These fearswere realized when Epstein filed a summary judgment motion raising this argument. Inrespo-nse, the other attorneys and I representing Jane Doe used the flight log evidenceto respond to Epstein's summary judgment motion, explaining that the flight logsdemonstrated that Epstein had traveled in interstate commerce for the purpose offacilitating his sexual assaults. Because Epstein chose to settle the case before trial,Judge Marra did not rule on the summary judgment motion. (c) Jane Doe No. 102'scomplaint outlined Epstein's daily sexual exploitation and abuse of underage minors asyoung as 12 years old and alleged that he used his plane to transport underage femalesto be sexually abused by him and his friends. The flight logs accordingly might haveinformation about either additional girls who were victims of Epstein's abuse or friendsof Epstein who may have witnessed or even participated in the abuse. Based on thisinformation, I believed that the flight logs and related information was relevantinformation to prove the cases against Jeffrey Epstein and accordingly I pursued themin discovery.20. In approximately November 2009, the existence of Scott Rothstein's Ponzi schemebecame public knowledge. It was at that time that I, along with many other reputableattorneys at RRA, first became aware of Rothstein criminal scheme. At that time, I leftRRA with several other RRA attorneys to form the law firm of Farmer Jaffe WeissingEdwards Fistos and Lehrman ("Farmer Jaffe"). I was thus with RRA for less than oneyear.21. In July 2010, along with other attorneys at Farmer Jaffe and Professor Cassell, I reachedfavorable settlement terms for my three clients M., M., and Jane Doe in theirlawsuits against Epstein.22. On July 20, 2010, I received a letter from the U.S. Attorney's Office for the SouthernDistrict of Florida — the office responsible for prosecuting Rothstein's Ponzi scheme.The letter indicated that law enforcement agencies had determined that I was "a victim(or potential victim)" of Scott Rothstein's federal crimes. The letter informed me of myrights as a victim of Rothstein's federal crimes and promised to keep me informed aboutHOUSE OVERSIGHT 013473subsequent developments in his prosecution. A copy of this letter is attached to thisAffidavit. (A copy of the letter is attached to Statement of Undisputed Facts as ExhibitUU)23. Jeffrey Epstein also filed a complaint with the Florida Bar against me. His complaintalleged that I had been involved in Rothstein's scheme and had thereby violated variousrules of professional responsibility. The Florida Bar investigated and dismissed thecomplaint.24. I have reviewed the Statement of Undisputed Facts filed contemporaneously with thisAffidavit. Each of the assertions concerning what I learned, what I did, and the goodfaith beliefs formed by me in the course of my prosecutions of claims against JeffreyEpstein as contained in the Statement of Undisputed Facts is true, and the foundationsset out as support for my beliefs are true and correct to the best of my knowledge.25. All actions taken by me in the course of my prosecution of claims against JeffreyEpstein were based upon a good faith belief that they were reasonable, necessary, andethically proper to fulfill my obligation to zealously represent the interests of myclients.I declare under penalty of perjury that the foregoing is true and correct.Dated: 112.i , 2010Bradley J. Edwards, Esq.HOUSE OVERSIGHT 013474DEFENDA1VT BRADLEY J. EDWARDS'S MOTION FOR FINAL SUMMARY JUDGMENTEpstein v. Edwards, et al.Case No.: 50 2009 CA 040800=XMBAGEXHIBIT AHOUSE OVERSIGHT 013475Case 9:08-cv-80893-KAM Document 168 Entered on FLSD Docket 06/28/2010 Page 1 of 4UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACASE NO.: 08-C1V-80893-MARRA/JOHNSONJANE DOE,Plaintiff,vs.JEFFREY EPSTEIN,Defendant.DEFENDANT EPSTEIN'S MOTION FOR SETTLEMENT CONFERENCE, OR /N1 HE ALTERNATIVE, MOTION TO DIRECT PARTIES' BACK TO MEDIATIONDefendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,pursuant to the Federal Rules of Civil Procedure and the Local Rules for the SouthernDistrict of Florida, moves this Court for an order requiring the parties to attend aSettlement Conference before Magistrate Judge Linnea R. Johnson, or in the alternative,for an Order directing the parties to reconvene at a second mediation on or before July 1,2010, and as grounds set forth would state:1. The above-styled matter is currently scheduled on the Court's trial docketbeginning July 19, 2010. (D.E. #119, Order Re-Setting Trial Date and Pretrial Deadlines).The Court's Mandatory Pretrial Stipulation and Motions in Liraine deadlines are set forJuly 1, 2010. In this regard, if the parties could reach an agreement at a settlementconference or a mediation before these pre-trial deadlines, it would result in substantialconservation of judicial resources and preparation time.2. The parties attended mediation on April 5, 2010, at Matrix Mediation,LLC, with Rodney Romano serving as mediator, but were unable to reach an agreement.(See D.E. #139).HOUSE OVERSIGHT 013476Case 9:08-cv-80893-KAM Document 168 Entered on FLSD Docket 06/28/2010 Page 2 of 4Doe v. EpsteinCASE NO.: 08-CIV-80893-MARRALTOENSONPage 23. Since the April 5, 2010 mediation, additional discovery has been completedand exchanged, including each parties' psychological (Plaintiff) and psychiatric(Defendant) expert depositions. As well, Defendant filed his Motion for SummaryJudgment and Motion for Bifurcation. Both parties have exchanged witness and exhibitlists. Each party will be filing extensive Motions in Limine. Plaintiff's Trial WitnessList has identified over 170 potential witnesses, and further, Plaintiff identifies over 140trial exhibits, including composite exhibits that are hundreds of pages in length. It isconceivable this case could last 12- 20 trial days.4. Additionally, since the parties attended mediation on April 5, 2010, Defendanthas resolved all pending lawsuits, including Plaintiff, C.L. (Case No.: 10-80447) andJANE DOES Nos. 2-8 (Case Nos.: 08-80119, 08-80232, 08-08380, 08-80381, 08-80994,08-80993, 08-80802), C.M.A. (Case No.08-80811), Jane Does Nos. 101, 102 and 103(Case Nos. 09-80591, 09-80656, 10-80309), another Jane Doe (Case No. 08-80804),Jane Doe II (Case No. 09-80469), as well as other non-filed claims. Furthermore,Defendant has also resolved three state court claims. The only cases not resolved are thiscase and. two (2) cases in state court (all three plaintiffs are represented by Plaintiffscounsel, Brad Edwards, Esq. and his firm). 15. Plaintiffs in other filed cases were represented by various law firms as thecourt is aware.6. With the additional discovery completed to date and with the motions, -Halpreparation and judicial rulings necessary to try this ease, all yet to be done, DefendantThere is also a case styled L.M. v. Jeffrey Epstein, CASE NO.: 09-CIV-81092 —MARRA/JOHNSON, which was never servedon the Defendant. Defendant has filed a Motion to Dismiss.HOUSE OVERSIGHT 013477Case 9:08-cv-80893-KAM Document 168 Entered on FLSD Docket 06/28/2010 Page 3 of 4Doe v. EpsteinCASE NO.: 08-CIV-808934MARRA/JOHNSONPage 3believes that a settlement conference or mediation is in the best interest of both parties toattempt resolution. There is no prejudice to either party.7. Therefore, Defendant requests the Court issue an order directing the parties toattend a Settlement Conference before Magistrate Judge Johnson or that the Court directthe parties to attend a further mediation before 'July 1, 2010. Both Magistrate JudgeJohnson and Rodney Romano (as the mediator in this case) are very familiar with theparticular case and other claims that were asserted.8. Defendant's Counsel has spoken with the secretary for the mediator, RodneyRomano, and she believes that he would be able to schedule a 2-3 hour mediation onshort notice this week.WHEREFORE, Defendant, JEFFREY EPSTEIN respectfully requests the Courtto enter an Order directing the parties to attend a Settlement Conference beforeMagistrate Judge Linnea R. Johnson, or in the alternative, a mediation on or before July1, 2010.Rule 7.1 CertificationI hereby certify that counsel has communicated by telephone with Plaintiffscounsel in a good faith effort to resolve the issues set forth herein. Plaintiffs position isthat the parties have already complied with the mediation requirements.By: s/Robert D. Critton, Jr.Robert D. Criiton, Jr.Michael I PikeAttorneys for Defendant EpsteinHOUSE OVERSIGHT 013478Case 9:08-cv-80893-KAM Document 168 Entered on FLSD Docket 06/28/2010 Page 4 of 4Doe v. EpsteinCASE NO.: 08-CIV-80893-MARRA/JOHNSONPage 4Certificate of ServiceI HEREBY CERTIFY that a true copy of the foregoing was electronically filedwith the Clerk of the Court using CM/ECF. I also certify that the foregoing document isbeing served this day on all counsel of record identified on the following service list inthe manner specified via transmission of Notices of Electronic Filing generated byCM/ECF on this 28th day of June, 2010:Brad Edwards, Esq.Farmer, Jaffe, Weissing, Edwards, Fistos& Lehrman, PL425 N. Andrews Ave.Suite #2Paul G. Cassell, Esq.Pro Hac Vice332 South 1400 E, Room 101Salt Lake City, UT 84112Co-counsel for PlaintiffJack Alan Goldberger, Esq.Atterbury Goldberger & Weiss, P.A.250 Australian Avenue SouthSuite 1400West Palm Beach, FL 33401-5012Co-Counsel for Defendant Jeffrey EpsteinRespectfully submitted,By: Is/ Robert D. Critton, Jr.ROBERT D. CRITTON, JR., ESQ.Florida Bar No. 224162rcrit@bcklaw.comMICHAEL I. PIKE, ESQ.Florida Bar #617296mpike@belclaw.comBURMAN, CRITTON, LU111.b,R &COLEMAN, LLP303 Banyan Boulevard, Suite 400West Palm Beach, FL 33401561/842-2820 Phone561/243-0164 Fax(Co-Counsel far Defendant Jeffivy Epstein)HOUSE OVERSIGHT 013479IN THE CIRCUIT COURT OF THEFIFTEENTH JUDICIAL CIRCUIT INAND FOR PALM BEACH COUNTY, FLORIDAGENERAL JURISDICTION DIVISIONJEFFREY EPSTEIN,Plaintiff,vs. No. 502009CA040800XXXXMBAGSCOTT ROTHSTEIN, individually,and BRADLEY J. EDWARDS,individually,Defendants.500 East Broward Boulevard,Ft. Lauderdale, FloridaThursday, June 14, 20129:14 a.m. - 12:37 p.m.DEPOSITIONOfSCOTT ROTHSTEIN(Via Video Conference)Taken on behalf of the Trusteepursuant to a notice of taking depositionFRIEDMAN, LOMBARDI & OLSON305-371-6677/aSHOUSE OVERSIGHT 013480Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800)000CMB AG • Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, -vs-VOLUME I OF II SCOTT ROTHSTEIN, individually, 1 2 3 4 5 6 7 Page 3 INDEX EXAMINATION DIRECT CROSS REDIRECT BRADLEY J. EDWARDS, ESQUIRE BY MR. CRITTON 5BRADLEY J. EDWARDS, 8individually, and L.M. individually, 910Defendants. 11 ERITIfI3ITS12VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE 1314 EXHIBIT DESCRIPTION PAGETuesday, March 23, 20010 1510:00 - 5:07 p.m. PLAINTIFF'S EX. 1 ALFREDO RODRIGUEZ 21116 CRIMINAL COMPLAINT2139 Palm Beach Lakes, Boulevard PLAINTIFF'S EX. 2 COMPLAINT 239West Palm Beach, Florida 33401 17 PLAINTIFF'S EX. 3 JULY 22, 2009 276FACSMILE18Reported By: 19Cynthia Hopkins, RPR, FPRNotary Public, State of Florida 20Prose Court Reporting 21Job No.: 1333 22232425Page 2 Page 41 APPEARANCES: 1 PROCEEDINGS2 3 On behalf of the Plaintiff ROBERT D. CRITTON, JR., ESQUIRE 2BURMAN, CRITTON, LUT1ThR & COLEMAN, LLP 3 Deposition taken before Cynthia Hopkins,4 303 Banyan Boulevard .Suite 400 4 Registered Professional Reporter and Florida5 West Palm Beach, Florida 33401 5 Professional Reporter, and Notary Public in and for6 Phone: 561.842.2820 6 the State of Florida at Large, in the above cause.7 and 7 - - -8 JACK ALAN GOLDBERGER, ESQUIRE Al 1ERBURY, GOLDBERGER & WEISS, P.A. 8 THE VBDEOGRAPHER: We are now on video9 250 Australian Avenue South 9 record. This is Media Number One in the10 Suite 1400 West Palm Beach, Florida 33401-5012 10 videotaped deposition of Bradley Edwards in thePhone: 561.659.8300 11 matter of Jeffi___ey Epstein versus Scott11 12 and 12 Rothstein, Bradley J. Edwards, and L.M.13 On behalf of the Plaintiff 13 Today is Tuesday, March 23rd, 2010 at14 ALAN M. DERSHOWITZ, ESQUIRE HARVARD LAW SCHOOL 14 10:00 a.m. We're here in the law offices15 Hauser 520 15 of Searcy, Denney, Scarola, Barnhart &16 Cambridge, Massachusetts 02138 Phone: 617.496.2020 16 Shipley, 2139 Palm Beach Lakes Boulevard,17 On behalf of the Defendant: 17 West Palm Beach, Florida.18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 18 My name is Joe Kozak. I am the19 BARNHART & SHIPLEY, PA. 19 videographer. The court reporter is Cindy20 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 20 Hopkins from Prose, Prose Court ReportingPhone: 561.686.6300 21 Agency.21 22 ALSO PRESENT: 22 Will counsel please introduce23 Jeffrey Epstein 23 yourselves, and then the court reporter24 Joseph Kozak, Videographer 24 will swear in the witnesses.Prose Reporting Services25 25 MR. CRITTON: Bob Critton on behalf of the1 (Pages 1 to 4)(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506`2rHOUSE OVERSIGHT 013481