Teknosis

Teknosis - Join Robinhood with my link and we'll both get a free stock

1. Join Robinhood with my link and we'll both get a free stock 🤝 https://join.robinhood.com/juans4357

Teknosis Webull Referral - Get up to several free stocks upon signing up using our referral

Teknosis Webull Referral Link: https://a.webull.com/iq6chR5ouF6NuwpIBL

 

Full text of Exhibit C Epstein vs. Edwards Case 09-34791-RBR Filed 04/08/11 Undisputed Statement of Facts | Re: Jeffrey Epstein

Full text of Exhibit C Epstein vs. Edwards Case 09-34791-RBR Filed 04/08/11 Undisputed Statement of Facts | Re: Jeffrey Epstein

Case 09-34791-RBR Doc 1 603-3 Filed 04/08/11 Page 1 of 39

EXHIBIT C

Epstein vs. Edwards
Undisputed Statement of Facts

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 2 of 39

IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA

Case No.: 50 2009 CA 040800XXXXMBAG

JEFFREY EPSTEIN,
Plaintiff,

vs.

SCOTT ROTHSTEFN, individually, and
BRADLEY J. EDWARDS, individually,

Defendants,

. /

STATEMENT OF UNDISPUTED FACTS

Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify . . . any summary
judgment evidence on which the adverse party relies.").

Sexual Abuse of Children By Epstein

1 . Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.")

(Deposition Attachment #1). 1

2. Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous

___

1 When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to him. "[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 111 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A party may not trample upon the rights of others and then escape the consequences by invoking a constitutional privilege - at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993).

1

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 3 of 39

occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assaults included vaginal penetration. Epstein abused many of the girls dozens if not hundreds of times. Epstein Depo. at 109 ("Q: How many times
have you engaged in oral sex with females under the age of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane Doe, September 24, 2009 and continued March 11, 2010, at 527 (minor girl sexually abused at least 17 times by Epstein) (hereinafter "Jane Doe Depo")

(Deposition Attachment #2); id. 564-67 (vaginal penetration by Epstein with his finger), 568 (vagina penetration by Epstein with a massager); Deposition of L.M., September 24, 2009, at 73 (hereinafter "L.M. Depo")

(Deposition Attachment #3) (describing the manner in which Epstein abused her beginning when LM was 13 years old, touching her vagina with his fingers and vibrator) at 74, line 12-13 (she was personally molested by Epstein more than 50 times), at 164, line 19-23 and 141, line 12-13 and 605, line 3-6 (describing that in addition to being personally molested by Epstein, she was paid $200 per underage girl she brought Epstein and she brought him more than seventy (70) underage girls - she told him that she did not want to bring him any more girls and he insisted that she continue to bring him underage girls); Deposition of E.W., May 6, 2010 (hereinafter "E.W. Depo")

(Deposition Attachment #4) at 115-116, 131 and 255 (describing Epstein's abuse of her beginning at age 14 when he paid her for touching her vagina, inserting his fingers and using a vibrator and he also paid her $200 for each other underage female E.W. brought him to molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date (hereinafter "Jane Doe #4 Depo")
(Deposition Attachment #5) at 32-34, and 136 (she describes first being taken to Epstein at 15 years old, "Being fingered by him, having him use a vibrator on [me], grabbing my nipples, smelling my butt, jerking off in front of me, licking my clit, several times.").

2

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 4 of 39

3. At all relevant times Edwards has had a good faith basis to conclude and did conclude that Epstein was able to access a large number of underage girls through a pyramid abuse scheme in which he paid underage victims $200-$300 cash for each other underage victim that she brought to him. See Palm Beach Police
Incident Report at 87 (hereinafter "Incident Report") (Exhibit "A"). 3 The Palm Beach Police Incident Report details Epstein's scheme for molesting underage females. Among other things, the Incident Report outlines some of the experiences of other Epstein victims. When S.G, a 14 year old minor at the time, was brought to Epstein's home, she was taken upstairs by a woman she believed to be Epstein's assistant. The woman started to fix up the room, putting covers on the massage table and bringing lotions out. The "assistant" then left the room and told S.G. that Epstein would be up in a second. Epstein walked over to S.G.
and told her to take her clothes off in a stern voice. S.G. states in the report she did not know what to do, as she was the only one there. S.G. took off her shirt, leaving her bra on. Epstein, then in a towel told her to take off everything. S.G. removed her pants leaving on her thong panties. Epstein then instructed S.G to give him a massage. As S.G gave Epstein a massage, Epstein turned around and masturbated. S.G. was so disgusted, she did not say anything; Epstein told her she "had a really hot body." Id. at 14. In the report, S.G. admitted seeing Jeffrey Epstein's penis and stated she thought Epstein was on steroids because he was a "really built guy and his wee wee was very tiny." Id. at 15.

4. The exact number of minor girls who Epstein assaulted is known only to Epstein. However, Edwards had a good faith basis to believe and did in fact believe that Epstein's victims were substantially more than forty (40) in number. In addition to the deposition excerpts from two of his many victims above about the number of underage girls brought to Epstein and the Palm Beach

2 In support of all assertions concerning the actions Edwards took, what Edwards learned in the course of his representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards Affidavit and specifically paragraphs 25 and 25 of that Affidavit.

3 For clarity, depositions attached to this memorandum will be identified numerically as attachments #1, #2, #3, etc., while exhibits attached to this memorandum will be identified alphabetically as exhibits A, B, C, etc.

3

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 5 of 39

incident report, there is overwhelming proof that the number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 v. Epstein, (hereinafter Jane Doe 102 complaint) (Exhibit "B">; see also
Deposition of Jeffrey Epstein, April 14, 2010, at 442, 443, and 444 (Epstein invoking the 5th on questions about his daily abuse and molestation of children)

(Deposition Attachment #6).

5. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that Epstein and his attorneys knew of the seriousness of the criminal investigation against him and corresponded constantly with the United States Attorney's Office in an attempt to avoid the filing of numerous federal felony offenses, which effort was successful. See Correspondence from U.S. Attorney's Office to Epstein (hereinafter "U.S. Attorney's Correspondence")
(Composite Exhibit "C) (provided in discovery during the Jane Doe v. Epstein case).

6. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that, more specifically, Epstein's attorneys knew of Epstein's scheme to recruit minors for sex and also knew that these minors had civil actions that they could bring against him. In fact, there was much communication between Epstein's attorneys and the United States Prosecutors in a joint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafana sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special
master regarding handling numerous expected civil claims against Epstein. The letter reads in pertinent part,

"The undersigned, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide information relevant to your service as a Special Master in the selection of an attorney to represent several young women who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the
"United States") have conducted an investigation of Jeffrey Epstein regarding his solicitation of minor females in Palm Beach County to engage in prostitution. Mr. Epstein, through his assistants, would recruit underage females to travel to his home in Palm Beach to

4

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 6 of 39

engage in lewd conduct in exchange for money. Based upon the investigation, the United States has identified forty (40) young women who can be characterized as victims pursuant to 18 USC 2255. Some of those women went to Mr. Epstein's home only once, some went there as much as 100 times or more. Some of the women's conduct was limited to performing a topless or nude massage while Mr. Epstein masturbated himself. For other women, the conduct escalated to full sexual intercourse. As part of the resolution of the case, Epstein has agreed that he would not contest jurisdiction in the Southern District of Florida for any
victim who chose to sue him for damages pursuant to 18 USC 2255. Mr. Epstein agreed to provide an attorney for victims who elected to proceed exclusively pursuant to that section, and agreed to waive any challenge to liability under that section up to an amount agreed to by the parties. The parties have agreed
to submit the selection of an attorney to a Special Master...."

7. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that L.M. was, in fact, a victim of Epstein's criminal abuse because L.M. was one of the minor females that the United States Attorney's Office recognized as a victim. L.M.'s sworn deposition testimony and the adverse
inference drawn from Epstein's refusal to testify confirm that Epstein began sexually assaulting L.M. when she was 13 years old and continued to molest her on more than fifty (50) occasions over three (3) years. Epstein Depo., Attachment #1, at 17 ("Q: Did you . . . ever engage in any sexual conduct with L.M.?" A: [Invocation of the Fifth Amendment].); see also Epstein Depo., April 14, 2010, Attachment #6, at 456 ("Q: LM was an underage female that you first abused when she was 13 years old; is that correct?" A: [Invocation of Fifth Amendment].)

8. Epstein was also given ample opportunity to explain why he engaged in sexual activity with L.M. beginning when L.M. was 13 years old and why he has molested minors on an everyday basis for years, and he invoked his 5th amendment right rather than provide explanation. See Epstein Deposition, February 17, 2010, at 1 1-12, 30-31

(Deposition Attachment # 7).

9. Epstein also sexually assaulted E.W., beginning when she was 14 years old and did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216.

10. Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse began

5

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 7 of 39

when Jane Doe was 14 years old. Rather than incriminate himself, Epstein invoked the 5th amendment to questions about him digitally penetrating Doe's vagina, using vibrators on her vagina and masturbating and ejaculating in her presence.
Epstein Depo., April 14, 2010, Attachment #6, at 420, 464, 468.

11. When Edwards's clients L.M., E.W., and Jane Doe were 13 or 14 years old, each was brought to Epstein's home multiple times by another underage victim. Epstein engaged in one or more of the following acts with each of the then-minor girls at his mansion: receiving a topless or completely nude massage; using a vibrator on her vagina; masturbating in her presence; ejaculating in he presence; touching her breast or buttocks or vagina or the clothes covering her sexual organs; and demanding that she bring him other underage girls. Epstein and his co-conspirators used the telephone to contact these girls to entice or induce them into going to his mansion for sexual abuse. Epstein also made E.W. perform oral sex on him and was to perform sex acts on Nadia Marcinkova (Epstein's live-in sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice") (Exhibit "E"); Jane Doe Depo., Attachment #2, at 379-380; L.M. Depo., Attachment #3, at 416; E.W. Depo, Attachment #4, at 205.

12. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that yet another of the minor girls Epstein sexually assaulted was C.L. When she was approximately 15 years old, C.L. was brought to Epstein's
home by another underage victim. While a minor, she was at Epstein's home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein also demanded that she bring him other underage girls. See Rule 413 Notice,

6

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 8 of 39

Exhibit "E"; Incident Report, Exhibit "A."

13. At all relevant times Edwards has had a good faith basis to believe and did
in fact believe that yet another girl Epstein sexually assault was A.H. When she
was approximately 16 years old, she was brought to Epstein's home by another
underage victim. While a minor, she was at Epstein's home on multiple occasions.
Epstein engaged in one or more of the following acts with her while she was a
minor at his house - topless or completely nude massage on Epstein; Epstein used
a vibrator on her vagina; Epstein masturbated in her presence; Epstein
ejaculated in her presence; Epstein touched her breast or buttock or vagina or
the clothes covering her sexual organs; was made to perform sex acts on Epstein;
made to perform sex acts on Nadia Marcinkova in Epstein's presence.

Epstein also forcibly raped this underage victim, as he held her head down
against her will and pumped his penis inside her while she was screaming "No".
See Rule 413 Notice, Exhibit "E"; Incident Report,

Exhibit "A", at 41 (specifically discussing the rape):

"[A.H.] remembered that she climaxed and was removing herself from the massage
table. [A.H.] asked for a sheet of paper and drew the massage table in the
master bathroom and where Epstein, Marcinkova and she were. Epstein turned
[A.H.] on to her stomach on the massage bed and inserted his penis into her
vagina. [A.H.] stated Epstein began to pump his penis in her vagina. [A.H.]
became upset over this. She said her head was being held against the bed
forcibly, as he continued to pump inside her. She screamed no, and Epstein
stopped

"[A.H.] advised there were times that she was so sore when she left Epstein's
house. [A.H.] advised she was ripped, torn, in her vagina area. [A.H.] advised
she had difficulty walking to the car after leaving the house because she was so
sore."

14. Without detailing each fact known about Epstein's abuse of the many underage
girls, Edwards has had a good faith basis to believe and did in fact believe at
all relevant times that Epstein also abused other victims in ways closely
similar to those described in the preceding paragraphs. Epstein's additional
victims include the following (among many other) young girls: S.G.; A.D.; V.A.;
N.R.; J.S.; V.Z.; J.A.; F.E.; M.L.; M.D.; D.D.; and D.N. These girls were
between the ages of 13 and

7

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 9 of 39

17 when Epstein abused them. See Rule 413 Notice, Exhibit E; Deposition of E.W.,
Deposition Attachment #4.

15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw
numerous underage girls coming into Epstein's mansion for purported "massages."
See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodriguez was aware
that "sex toys" and vibrators were found in Epstein's bedroom after the
purported massages. Id. at 223-28. Rodriguez thought what Epstein was doing was
wrong, given the extreme youth of the girls he saw. Id. at 230-3 1.

16. Alfredo Rodriguez took a journal from Epstein's computer that reflected many
of the names of underage females Epstein abused across the country and the
world, including locations such as Michigan, California, West Palm Beach, New
York, New Mexico, and Paris, France. See Journal (hereinafter "The Journal" or
"Holy Grail") (Exhibit "F") (identifying, among other Epstein acquaintances,
females that Rodriguez believes were underage under the heading labeled
"Massages").

17. Rodriguez was later charged in a criminal complaint with obstruction of
justice in connection with trying to obtain $50,000 from civil attorneys
pursuing civil sexual assault cases against Epstein as payment for producing the
book to the attorneys. See Criminal Complaint at 2, U.S. v. Rodriguez, No. 9:10-
CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez stated he needed money
because the journal was his "property" and that he was afraid that Jeffrey
Epstein would make him "disappear" unless he had an "insurance policy" (i.e.,
the journal). Id. at 3. Because of the importance of the information in the
journal to the civil cases, Mr. Rodriguez called it "The Holy Grail."

18. In the "Holy Grail" or "The Journal," among the many names listed (along
with the abused girls) are some of the people that Epstein alleges in his
Complaint had "no connection whatsoever" with the litigation in this case. See,
e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9

8

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 10 of 39

(Bill Clinton phone numbers listed under "Doug Bands").

Federal Investigation and Plea Agreement With Epstein

19. In approximately 2005, the FBI and the U.S. Attorney's Office in the
Southern District of Florida learned of Epstein's repeated sexual abuse of minor
girls. They began a criminal investigation into federal offenses related to his
crimes. See U.S. Attorney's Correspondence, Exhibit "C".

20. At all relevant times Edwards has had a good faith basis to believe and did
in fact believe that to avoid the Government learning about his abuse of minor
girls, Epstein threatened his employees and demanded that they not cooperate
with the government. Epstein's aggressive witness tampering was so severe that
the United States Attorney's Office prepared negotiated plea agreements
containing these charges. For example, in a September 18, 2007, email from AUSA
Villafana to Lefkowitz (attached hereto as Exhibit "H"), she attached the
proposed plea agreement describing Epstein's witness tampering as follows:

"UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER"

On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards
traveled to the home of Leslie Groff to serve her with a federal grand jury
subpoena with an investigation pending in the Southern. District of Florida. Ms.
Groff works as the personal assistant of the defendant. Ms. Groff began speaking
with the agents and then excused herself to go upstairs to check on her sleeping
child. While upstairs, Ms. Groff telephoned the defendant, Jeffrey Epstein, and
informed him that the FBI agents were at her home. Mr. Epstein instructed Ms.
Groff not to speak with the agents and reprimanded her for allowing them into
her home. Mr. Epstein applied pressure to keep Ms. Groff from complying with the
grand jury subpoenas that the agents had served upon her. In particular, Mr.
Epstein warned Ms. Groff against turning over documents and electronic evidence
responsive to the subpoena and pressured her to delay her appearance before the
grand jury in the Southern District of Florida. This conversation occurred when
Mr. Epstein was aboard his privately owned civilian aircraft in Miami in the
Southern District of Florida. His pilot had filed a flight plan showing the
parties were about to return to Teterboro, NJ. After the conversation with Ms.
Groff, Mr. Epstein became concerned that the FBI would try to serve his
traveling companion, Nadia Marcinkova, with a similar grand jury subpoena. In
fact, the agents were

9

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 11 of 39

preparing to serve Ms. Marcinkova with a target letter when the flight landed in
Teterboro. Mr. Epstein then redirected his airplane, making the pilot file a new
flight plan to travel to the US Virgin Islands instead of the New York City
area, thereby keeping the Special Agents from serving the target letter on Nadia
Marcinkova. During the flight, the defendant verbally harassed Ms. Marcinkova,
harassing and pressuring her not to cooperate with the grand jury's
investigation, thereby hindering and dissuading her from reporting the
commission of a violation of federal law to a law enforcement officer, namely,
Special Agents of the FBI. Epstein also threatened and harassed Sarah Kellen
against cooperating against him as well.

21. Edwards learned that the Palm Beach police department investigation
ultimately led to the execution of a search warrant at Epstein's mansion in
October 2005. See Police Incident Report, Exhibit "A".

22. Edwards learned that at around the same time, the Palm Beach Police
Department also began investigating Epstein's sexual abuse of minor girls. They
also collected evidence of Epstein's involvement with minor girls and his
obsession with training sex slaves, including pulling information from Epstein's
trash. Their investigation showed that Epstein ordered from Amazon.com on about
September 4, 2005, such books as: SMI 01: A Realistic Introduction, by Jay
Wiseman; SlaveCraft: Roadmaps for Erotic Servitude - Principles, Skills, and
Tools, by Guy Baldwin; and Training with Miss Abernathy: A Workbook for Erotic
Slaves and Their Owners, by Christina Abernathy. See Receipt for Sex Slave Books
(Exhibit "I").

23. The Palm Beach incident reports provided Edwards with the names of numerous
witnesses that participated in Epstein's child molestation criminal enterprise
and also provided Edwards with some insight into how far-reaching Epstein's
power was and how addicted Epstein was to sex with children. See Incident
Report, Exhibit "A".

24. The Palm Beach Police Department also collected Epstein's message pads,
which provided other names of people that also knew Epstein's scheme to molest
children. See Message Pads (Exhibit "J") (note: the names of underage females
have been redacted to protect the anonymity

10

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 12 of 39

of the underage sex abuse victims). Those message pads show clear indication
that Epstein's staff was frequently working to schedule multiple young girls
between the ages of 12 and 16 years old literally every day, often two or three
times per day. Id.

25. In light of all of the information of numerous crimes committed by Epstein,
Edwards learned that the U.S. Attorney's Office began preparing the filing of
federal criminal charges against Epstein. For example, in addition to the
witness tampering and money laundering charges the U.S. Attorney's Office
prepared an 82-page prosecution memo and a 5 3 -page indictment of Epstein
related to his sexual abuse of children. On September 19, 2007, at 12:14 PM,
AUSA Villafana wrote to Epstein's counsel, Jay Lefkowitz, "Jay - 1 hate to have
to be firm about this, but we need to wrap this up by Monday. I will not miss my
indictment date when this has dragged on for several weeks already and then, if
things fall apart, be left in a less advantageous position than before the
negotiations. I have had an 82-page pros memo and 5 3 -page indictment sitting
on the shelf since May to engage in these negotiations. There has to be an
ending date, and that date is Monday." These and other communications are within
the correspondence attached as Composite Exhibit "C."

26. Edwards learned that rather than face the filing of federal felony criminal
charges, Epstein (through his attorneys) engaged in plea bargain discussions. As
a result of those discussions, on September 24, 2007, Epstein signed an
agreement with the U.S. Attorney's Office for the Southern District of Florida.
Under the agreement, Epstein agreed to plead guilty to an indictment pending
against him in the 15th Judicial Circuit in and for Palm Beach County charging
him with solicitation of prostitution and procurement of minors for
prostitution. Epstein also agreed that he would receive a thirty month sentence,
including 18 months of jail time and 12 months of community control. In
exchange, the U.S. Attorney's Office agreed not to pursue any federal charges
against Epstein. See Non-Prosecution Agreement (Exhibit "K").

11

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 13 of 39

27. Part of the Non-Prosecution Agreement that Epstein negotiated was a
provision in which the federal government agreed not to prosecute Epstein's co-
conspirators. The co-conspirators procured minor females to be molested by
Epstein. One of the co-conspirators - Nadia Marcinkova - even participated in
the sex acts with minors (including E. W.) and Epstein. See Incident Report,
Exhibit "A", at 40-42, 49-51; Deposition of Nadia Marcinkova, April 13, 2010,
(hereinafter "Marcinkova Depo.") at 11 (Deposition attachment #9).

28. Under the Non-Prosecution Agreement, Epstein was to use his "best efforts"
to enter into his guilty pleas by October 26, 2007. However, Edwards learned
that Epstein violated his agreement with the U.S. Attorney's Office to do so and
delayed entry of his plea. See Letter from U.S. Attorney R. Alexander Acosta to
Lilly Ann Sanchez, Dec. 19, 2007 (Exhibit "L").

29. On January 10, 2008 and again on May 30, 2008 E.W. and L.M. received letters
from the FBI advising them that "[t]his case is currently under investigation.
This can be a lengthy process and we request your continued patience while we
conduct a thorough investigation." Letters attached at Composite Exhibit "M".
This document is evidence that the FBI did not notify E.W. and L.M. that a plea
agreement had already been reached that would block federal prosecution of
Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of the plea
agreement. Nor did the FBI or other federal authorities confer with E.W. and
L.M. about the plea. See id.

30. In 2008, Edwards believed in good faith that criminal prosecution of Epstein
was extremely important to his clients E.W. and L.M. and that they desired to be
consulted by the FBI and/or other representatives of the federal government
about the prosecution of Epstein. The letters that they had received around
January 10, 2008, suggested that a criminal investigation of Epstein was on-
going and that they would be contacted before the federal government reached any
final resolution of that investigation. See id.

12

Case 09-34791-RBR Doc 1603-3 Filed 04/08/111 Page 14 of 39

Edwards Agrees to Serve as Legal Counsel for Three Victims of Epstein 's Sexual
Assaults

31. In about April 2008, Bradley J. Edwards, Esq., was a licensed attorney in
Florida, practicing as a sole practitioner. As a former prosecutor, he was well
versed in civil cases that involved criminal acts, including sexual assaults.
Three of the many girls Epstein had abused - L.M., E.W., and Jane Doe - all
requested that Edwards represent them civilly and secure appropriate monetary
damages against Epstein for repeated acts of sexual abuse while they were minor
girls. Two of the girls (L.M. and E.W.) also requested that Edwards represent
them in connection with a concern that the Federal Bureau of Investigation (FBI)
and U.S. Attorney's Office might be arranging a plea bargain for the criminal
offenses committed by Epstein without providing them the legal rights to which
they were entitled (including the right to be notified of plea discussions and
the right to confer with prosecutors about any plea arrangement). See Affidavit
of Bradley J. Edwards, Esq. at ¶1 - 2, ¶4 (hereinafter "Edwards Affidavit")
(Exhibit "N").

32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2,
2008, attorney Edwards agreed to represent Jane Doe; and, on July 7, 2008,
attorney Edwards agreed to represent L.M. in connection with the sexual assaults
committed by Epstein and to insure that their rights as victims of crimes were
protected in the criminal process on-going against Epstein. Mr. Edwards and his
three clients executed written retention agreements. See id. at ¶2.

33. In mid June of 2008, Edwards contacted AUSA Villafana to inform her that he
represented Jane Doe #1 and, later, Jane Doe #2. AUSA Villafana did not advise
that a plea agreement had already been negotiated with Epstein's attorneys that
would block federal prosecution. To the contrary, AUSA Villafana mentioned a
possible indictment. AUSA Villafana did indicate that federal investigators had
concrete evidence and information that Epstein had sexually molested many
underage minor females, including E.W., LM, and Jane Doe. See id. at ¶4.

13

Case 09-34791-RBR Doc 1603-3 Filed 04/08/11 Page 15 of 39

34. Edwards also requested from the U.S. Attorney's Office the information that
they had collected regarding Epstein's sexual abuse of his clients. However, the
U.S. Attorney's Office, declined to provide any such information to Edwards. It
similarly declined to provide any such information to the other attorneys who
represented victims of Epstein's sexual assaults. At the very least, this
includes the items that were confiscated in the search warrant of Epstein's
home, including dildos, vibrators, massage table, oils, and additional message
pads. See Property Receipt (Exhibit "O").

35. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafana
received a copy of Epstein's proposed state plea agreement and learned that the
plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafana called
Edwards to provide notice to his clients regarding the hearing. AUSA Villafana
did not tell Attorney Edwards that the guilty pleas in state court would bring
an end to the possibility of federal prosecution pursuant to the plea agreement.
See Edwards Affidavit, Exhibit "N", at ¶6.

36. Under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, victims of
federal crimes - including E.W. and L.M. - are entitled to basic rights during
any plea bargaining process, including the right to be treated with fairness,
the right to confer with prosecutors regarding any plea, and the right to be
heard regarding any plea. The process that was followed leading to the non-
prosecution of Epstein violated these rights of E.W. and L.M. See Emergency
Petn. for Victim's Enforcement of Crime Victim's Rights, No. 9:08-CV-80736-KAM
(S.D. Fla. 2008) (Exhibit "P").

37. Because of the violation of the CVRA, on July 7, 2008, Edwards filed an
action in the U.S. District Court for the Southern District of Florida, Case No.
9:08-CV-80736, seeking to enforce the rights of E.W. and L.M. That action
alleged that the U.S. Attorney's Office had failed to provide E.W. and L.M. the
rights to which they were entitled under the Act, including the right to be
notified

14

Case 09-34791 -RBR Doc 1 603-3 Filed 04/08/1 1 Page 1 6 of 39

about a plea agreement and to confer with prosecutors regarding it. See id.

38. On July 1 1, 2008, Edwards took E.W. and L.M. with him to the hearing on the
CVRA action. It was only at this hearing that both victims learned for the first
time that the plea deal was already done with Epstein and that the criminal case
against Epstein had been effectively terminated by the U.S. Attorney's office.
See Hearing Transcript, July 11, 2008 (Exhibit "Q").

39. Edwards learned that Jane Doe felt so strongly that the plea bargain was
inappropriate that she made her own determination to appear on a television
program and exercise her First Amendment rights to criticize the unduly lenient
plea bargain Epstein received in a criminal case.

40. The CVRA action that Edwards filed was recently administratively closed and
Edwards filed a Motion to reopen that proceeding. See No. 9:08-CV-80736 (S.D.
Fla.).

Epstein 's Entry of Guilty Pleas to Sex Offenses

41. Ultimately, on June 30, 2008, in the Fifteenth Judicial Circuit in Palm
Beach County, Florida, defendant Epstein, entered pleas of "guilty" to various
Florida state crimes involving the solicitation of minors for prostitution and
the procurement of minors for the purposes of prostitution. See Plea Colloquy
(Exhibit "R").

42. As a condition of that plea, and in exchange for the Federal Government not
prosecuting the Defendant, Epstein additionally entered into an agreement with
the Federal Government acknowledging that approximately thirty-four (34) other
young girls could receive payments from him under the federal statute providing
for compensation to victims of child sexual abuse, 18 U.S.C. § 2255. As had been
agreed months before, the U.S. Attorney's Office did not prosecute Epstein
federally for his sexual abuse of these minor girls. See Addendum to Non-
Prosecution Agreement (Exhibit "S") (in redacted form to protect the identities
of the minors involved).

15

Case 09-34791 -RBR Doc 1 603-3 Filed 04/08/1 1 Page 1 7 of 39

43. Because Epstein became a convicted sex offender, he was not to have contact
with any of his victims. During the course of his guilty pleas on June 30, 2008,
Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have
any contact, direct or indirect" with any victims. She also expressly stated
that her no-contact order applied to "all of the victims." Similar orders were
entered by the federal court handling some of the civil cases against Epstein.
The federal court stated that it "finds it necessary to state clearly that
Defendant is under this court's order not to have direct or indirect contact
with any plaintiffs . . . ." Order, Case No. 9:08-cv-801 19 (S.D. Fla. 2008),
[DE 238] at 4-5 (emphasis added); see also Order, Case No. 9:08-cv-80893, [DE
193] at 2 (emphasis added).

Edwards Files Civil Suits Aeainst Epstein

44. Edwards had a good faith belief that his clients felt angry and betrayed by
the criminal system and wished to prosecute and punish Epstein for his crimes
against them in whatever avenue remained open to them. On August 12, 2008, at
the request of his client Jane Doe, Brad Edwards filed a civil suit against
Jeffrey Epstein to recover damages for his sexual assault of Jane Doe. See
Edwards Affidavit, "N" at ¶7. Included in this complaint was a RICO count that
explained how Epstein ran a criminal conspiracy to procure young girls for him
to sexually abuse. See Complaint, Jane Doe v. Epstein (Exhibit "T").

45. On September 11, 2008, at the request of his client E.W., Brad Edwards filed
a civil suit against Jeffrey Epstein to recover damages for his sexual assault
of E.W. See Complaint, E.W. v. Epstein (Exhibit "U").

46. On September 11, 2008, at the request of his client L.M.., Brad Edwards
filed a civil suit against Jeffrey Epstein to recover damages for his sexual
assault of L.M. See Complaint, L.M. v. Epstein, (Exhibit "V").

47. Jane Doe's federal complaint indicated that she sought damages of more than
$50,000,000.

16

Case 09-34791 -RBR Doc 1 603-3 Filed 04/08/1 1 Page 1 8 of 39

Listing the amount of damages sought in the complaint was in accord with other
civil suits that were filed against Epstein (before any lawsuit filed by
Edwards). See Complaint, Jane Doe #4 v. Epstein (Exhibit "W") (filed by Herman
and Mermelstein, PA).

48. At about the same time as Edwards filed his three lawsuits against Epstein,
other civil attorneys were filing similar lawsuits against Epstein. For example,
on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the
first civil action against Epstein on behalf of one of its seven clients who
were molested by Epstein. The complaints that attorney Herman filed on behalf of
his seven clients were similar in tenor and tone to the complaint that Edwards
filed on behalf of his three clients. See id.

49. Over the next year and a half, more than 20 other similar civil actions were
filed by various attorneys against Epstein alleging sexual assault of minor
girls. These complaints were also similar in tenor and tone to the complaint
that Edwards filed on behalf of his clients. These complaints are all public
record and have not been attached, but are available in this Court's files and
the files of the U.S. District Court for the Southern District of Florida.

50. In addition to the complaints filed against Epstein in Florida, a female in
New York, Ava Cordero, filed a lawsuit against Epstein in New York making
similar allegations - that Epstein paid her for a massage then forced her to
give him oral sex and molested her in other ways when she was only 16 years old.
Cordero was born a male, and in her complaint she alleges that Epstein told her
during the "massage", "I love how young you are. You have a tight butt like a
baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York
Post, October 17, 2007, by Dareh Gregorian, link at:

http://www.nvpost.eom/p/news/regional/item 44zlWvLUFH7Rl OUtKYGPbP:i
sessionid=6CA3EBF 1 BEF68F5DE14BFB2CAA5C37E0. See Article attached hereto as
Exhibit "X".

17

Case 09-34791 -RBR Doc 1 603-3 Filed 04/08/1 1 Page 1 9 of 39

51. Edwards's three complaints against Epstein contained less detail about
sexual abuse than (as one example) a complaint filed by attorney Robert
Josephsberg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 102 v.
Epstein (Exhibit "B"). As recounted in detail in this Complaint, Jane Doe 102
was 15 years old when Ghislaine Maxwell discovered her and lured her to
Epstein's house. Maxwell and Epstein forced her to have sex with both of them
and within weeks Maxwell and Epstein were flying her all over the world.
According to the Complaint, Jane Doe 102 was forced to live as one of Epstein's
underage sex slaves for years and was forced to have sex with not only Maxwell
and Epstein but also other politicians, businessmen, royally, academicians, etc.
She was even made to watch Epstein have sex with three 12-year-old French girls
that were sent to him for his birthday by a French citizen that is a friend of
Epstein's. Luckily, Jane Doe 102 escaped to Australia to get away from Epstein
and Maxwell's sexual abuse.

52. Edwards learned that in addition to civil suits that were filed in court
against Epstein, at around the same time other attorneys engaged in pre-filing
settlement discussions with Epstein. Rather than face filed civil suits in these
cases, Epstein paid money settlements to more than 15 other women who had
sexually abused while they were minors. See articles regarding settlements
attached hereto as Composite Exhibit "Y."

Epstein 's Obstruction of Normal Discovery 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-mcrimination. An

18

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 20 of 39

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 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

19

Case 09-34791 -RBR Doc 1 603-3 Filed 04/08/1 1 Page 21 of 39

participating), http://www.voutube.com/watch?v=V-dqoEyYXx4 ; and

http://www.youtube.coni/watch?v=YCNiYltW-rO

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 Sarah Kellen, March 24, 2010 (hereinafter "Kellen
Depo.") (Deposition attachment #14); Deposition of Nadia Marcinkova, April 13,
2010, (Deposition attachment #9); Deposition of Adriana Mucinska Ross, March 15,
2010 (hereinafter "Ross 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 Sarah Kellen 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 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

20

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 22 of 39

deposition of Epstein's housekeeper Louella Rabuyo, 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.com/article.php?id=18950HANNA 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 then- 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.

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

21

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 23 of 39

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 Brunei, 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 1st today if you call." See Messages taken from Jean Luc Brunei are
attached hereto as Exhibit "EE." In light of these circumstances of the case,
this message reasonably suggested to Edwards that Brunei might have been
procuring two eight-year-old girls for Epstein to sexually abuse. According to
widely circulated press reports reviewed by Edwards, Brunei 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 Brunei's sexual exploitation of underage models. See
http:/^radmillershero.blogspot.com/20 1 0/08/women-are-obiects.html, attached
hereto as Exhibit "FF."

63. Edwards learned that Brunei is also someone that visited Epstein on
approximately 67 occasions while Epstein was in jail. See Epstein's jail visitor
log attached as Exhibit "GG."

64. Edwards learned that Brunei 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 Maritza Vasquez, June
15, 2010, "Maritza Vasquez Sworn Statement" attached at Exhibit "HH" 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,

22

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 24 of 39

affiliated with Epstein and Brunei brought underage girls from all over the
world, promising them modeling contracts. Epstein and Brunei would then obtain a
visa for these girls, then would charge the underage girls rent, presumably to
live as underage prostitutes in the condos. See Maritza Vasquez Sworn Statement,
Exhibit "HH" at 7-10, 12-15, 29-30, 39-41, 59-60 and 62-67.

66. In view of this information suggesting Brunei could provide significant
evidence of Epstein's trafficking in young girls for sexual abuse, Edwards had
Brunei served in New York for deposition. See Notice of Deposition of Jean Luc
Brunei attached hereto as Exhibit "II." Before the deposition took place,
Brunei's attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay
the deposition date. Eventually Kudman informed Edwards in January 2009 that
Brunei had left the country and was back in France with no plans to return. This
information was untrue; Brunei 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 Brunei
(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 Brunei's
representation during the civil process but also paid for legal representation
for Sarah Kellen (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), Nadia Marcinkova (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,

23

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 25 of 39

Exhibit "N" at ¶11.

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
http://www.palmbeachpost.com/news/crime/victims- seeldng-sex-offenders-rmllions-
see-painful-pasts- 1 929 8 8 .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" at ¶11.

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, 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

24

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 26 of 39

Flight logs attached hereto as Exhibit "MM." Clinton traveled on many of those
flights with Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, - 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 ¶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 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 ~ 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

25

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 27 of 39

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 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

26

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 28 of 39

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 "PP";
Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit "MM"; Exhibits
"B" and "OO"; and Edwards Affidavit, Exhibit "N" at ¶14.

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 ¶16.

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

27

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 29 of 39

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 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.

28

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 30 of 39

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, 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
Marra 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

29

Case 09-34791 -RBR Doc 1 603-3 Filed 04/08/1 1 Page 31 of 39

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;

• 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 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 notrring wrong even
though she helped procure young girls to satisfy Epstein's sexual desires);

• With regard to Jane Doe 1 02 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

30

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 32 of 39

personal interview about details of the case that was tape recorded with George
Rush.

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 ¶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 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 L.M., E.W., and
Jane Doe were reasonably perceived by Edwards to be very strong cases. Because
Epstein had sexually

31

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 33 of 39

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 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 Edwards's settlement negotiations. See Edwards Affidavit,
Exhibit "N" at ¶21.

Edwards Non-Involvement in Fraud by Scott Rothstein

86. From in or about 2005, through in or about November 2009, Scott Rothstein
appears to

32

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 34 of 39

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-
603 31 -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).

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

33

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 35 of 39

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 "XT,"

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.

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

34

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 36 of 39

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 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.

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 1 8." 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

35

Case 09-34791 -RBR Doc 1603-3 Filed 04/08/1 1 Page 37 of 39

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.

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.

36

Case 09-34791-RBR Doc 1603-3 Filed 04/08/1 1 Page 38 of 39

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.'s Complaint that was filed against you in September
of 2008 which you contend to be false?" Id. at 128.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on September 2010 a copy of the foregoing has been served
via U.S. Mail and email transmittal to all those on the attached service list.

Jack Scarola

Searcy, Denney, Scarola, Barnhart & Shipley
2139 Palm Beach Lakes Blvd
West Palm Beach, FL 33409

By:

37

Case 09-34791-RBR Doc 1603-3 Filed 04/08/1 1 Page 39 of 39

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 S. Nurik, Esq.
Law Offices of Marc S. 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

38

<meta name="google-site-verification" content="TSjIGJNwDXIje2_kK8SaztI6GRxXdhpaiQ2ZkR-2eos" />

The Lost Light: An Interpretation of Ancient Scriptures | Leaflet re: Alvin Boyd Kuhn and The Lost Light

THE AUTHOR AND HIS BOOK

After years of language teaching in Pennsylvania schools, Alvin Boyd Kuhn took his Ph. D. degree in Philosophy at Columbia University in 1931, writing for his thesis a book of 351 pages under the title of THEOSOPHY: A Modern Revival of Ancient Wisdom, this being the only time this subject was permitted to be used for a degree thesis in the Western world. It was published by Henry Holt & Co., and now stands as the one accredited academic work on the Theosophical movement. THE LOST LIGHT is epochal in that, for once, a work of occult Bible interpretation does not rest on claims of interior mystical illumination, but is based impregnably upon the most authentic assemblage of scholarly data ever brought to bear on Scriptural exegesis. It is the first interpretation of the Bible in immediate relation to its sources. It renders obsolete at one stroke nearly every work written about the Bible!

JFK ASSASSINATION SYSTEM IDENTIFICATION | RECORD NUMBERS 124-10087-10143 & 124-10087-10144

https://www.archives.gov/files/research/jfk/releases/docid-32149267.pdf

ASSASSINATION OF PRESIDENT

JOHN FITZGERALD KENNEDY

Excerpt:

On March 14, 1977, Arlen L. Fuhlendorf, Group Manager, Internal Revenue Service, Intelligence, Dallas, Texas, telephonically contacted Special Agent Specht, FBI, Dallas, Texas, and advised that he was at a school all last week, and therefore, could not get in contact with Special Agent Specht. He was advised that Bob Vanderslice to date has not made himself available to be interviewed by the Dallas office of the FBI. Fuhlendorf advised that Vanderslice has been furnishing information to Internal Revenue Service in connection with a special enforcement program that Internal Revenue Service Intelligence has concerning the criminal element. Vanderslice has furnished information to Internal Revenue Service on local Dallas bookmakers. Fuhlendorf advised that as far as he knows, that the information that Vanderslice furnished has been reliable. Fuhlendorf advised that when he last talked to Vanderslice on March 4, 1977, that Vanderslice asked him that if he talked to the FBI, what use would be made of the information. Fuhlendorf told Vanderslice that he might get a free trip to Washington to testify before a Congressional Committee concerning his information. Fuhlendorf stated that Vanderslice might have had second thoughts after he told him that.

Fuhlendorf advised that several weeks ago, specific date unrecalled, he met
Vanderslice at the restaurant located on the twenty-fifth floor of the Manor House, Commerce Street, Dallas, Texas. Fuhlendorf stated that Vanderslice talked to him about Candy Barr, a former stripper in one of Jack Ruby’s nightclubs. This conversation led to Vanderslice discussing his knowledge of Ruby. Vanderslice told him that on the morning of the assassination, Jack Ruby called him on the telephone and asked him if he would like to go to the Presidential Parade with him, and if he would “like to watch the fireworks.” Vanderslice said that he was with Jack Ruby and standing at the corner of the Postal Annex Building facing the Texas School Book Depository Building, at the time of the shooting. Immediately after the shooting, Ruby left and headed toward the area of the Dallas Morning News Building, without saying anything to him.

https://www.archives.gov/files/research/jfk/releases/docid-32149268.pdf

NOTE: A review of Jack Ruby’s testimony before the Warren Commission on 6/7/64, indicates that Ruby testified that he was at the “Dallas Morning News” building at the time of Kennedy’s assassination on 11/22/63. Ruby advised he went to the News building at approximately 11:00 a.m. on the morning of 11/22/63, to arrange for advertising space for his night club. Ruby’s testimony was corroborated in part by the testimony of John William Newnam, an Advertising Department employee of the “Dallas Morning News.” Newnam testified before the Warren Commission on 6/26/64. No further attempts being made by our Dallas Division to interview Robert Murray Vanderslice at this time.

JFK ASSASSINATION SYSTEM IDENTIFICATION | RECORD NUMBER 104-10103-10057

EVERETTE HOWARD HUNT, JR.

1. Subject, a former GS-15 Operations Officer assigned to DDP/Europe, is 53 years of age and married. He served with the Office of Strategic Services during World War II, and was employed by this Agency from November 1949 until his voluntary retirement on 30 April 1970. In 1971, Subject served as an advisor to President Nixon in relation to his trip to China. Subject is of current interest to the Central Cover Staff.

2. Subject graduated from Brown University in 1940. He served with the United States Navy from early 1941 until late 1942. After a year with Time, Incorporated, he entered the Air Force, where he was detailed to the Office of Strategic Services. He served in the Far East until January 1946. Subject engaged in writing, and then from May 1948 until February 1949 was employed by the Economic Cooperation Administration, serving in Paris, France, as an aide to Avarell Harriman.

3. A background investigation conducted by the Federal Bureau of Investigation in July 1949 revealed no indication of instability on Subject’s part, but it was later learned that Subject had been refused an increase in salary with the Economic Cooperation Administration and had been permitted to resign. He was described as highly intelligent, but blindly selfish and egotistical.

4. Subject’s wife, Dorothy Louise Goutiere Hunt, was investigated for Agency employment in 1948. Her former husband was described as a habitual drunkard, and Subject’s wife was described as slightly unstable and not inclined to remain in one place for any length of time. She did not enter on duty, having accepted a position with the Economic Cooperation Administration in Paris. Our Paris sources later reported that Subject’s wife was formerly a mistress and was openly flouted as such for several months. She was then described as an amoral and dangerous individual who underhandedly attacked those persons who incurred her enmity.

5. Subject entered on duty as an Intelligence Officer. GS-13, on 8 November 1949. In December 1950 he was assigned as Chief of Station, Mexico City, and then served as Chief of Mission there until August 1953. He served in Tokyo, Japan, from June 1954 until February 1957. He was then assigned as Chief of Station, Montevideo, Uruguay. Subject was Chief of Station in Montevideo until early 1960. There were indications that Subject attempted to use his personal influence with the President of Uruguay to have his assignment there extended, but he returned to the United States in June 1960 and was assigned to Mexico City on Project JMARC.

6. A cable from Montevideo, dated 6 November 1960, indicates that Subject had written former Uruguayan contacts commenting that he was working on the Cuban problem and publishing anti-Castro newspaper in Miami. It was recommended that Subject be warned about such indiscreet remarks, but apparently no action was taken.

7. In November 1961, subject was reassigned to the DDP/Covert Action Staff, and in January 1962 to the Office of the Chief of the same Staff. In July 1962 Subject was transferred to the DODS Research and Publications Section in Washington, and in July 1964 to the DODS Covert Action Staff. In February 1965 he moved to the Office of the DDP/Operations Group. From June 1965 to September 1966 Subject served as a Contract Agent in Madrid, Spain, after which he served in the DDP as Chief of European Covert Operations until his retirement on 30 April 1970.

8. On 26 January 1970 a source of the Office of Security learned that Subject was circulating through the publishing community “Give Us This Day,” a manuscript written under his former operational alias and dealing with the events of the Bay of Pigs. Investigation disclosed that the manuscript had been in the possession of Tom Wallace of Holt, Rinehart, and Winston, Inc. as early as 9 July 1968 and that it was sent on that date to William F. Buckley, Jr., of the National Review. The manuscript was sent to the Arlington House and Walker and Company as well. Both rejected it as too controversial, as had Holt, Rinehart, and Winston.

9. Subject was interviewed regarding the manuscript on 17 February 1970 by the DDP. He at first professed ignorance, but when told the title admitted he had written it for his own benefit as a historical record. Subject said he had shown the manuscript about two years ago to his agent, Max Wilkinson, and to William F. Buckley, Jr. He said he had only wanted an opinion from these gentlemen, and added that the manuscript had been returned to him. He had, he said, not wanted it published. Subject was instructed as to the danger of such a manuscript being published, and was to attempt to determine how many copies of it might be in circulation. He was not to contact Walker and Company, who were the source of the original information.

10. A reinvestigation of Subject was conducted by the Office of Security in July 1970. Subject and his wife were described by six neighbors acquainted with them for up to nine years, as excellent parents, good neighbors, and fine community citizens.

11. On 19 July 1971, Subject was reported by the Jersey City, New Jersey, Journal to have joined the White House Staff as a Consultant to President Nixon preparatory to the President’s visit to the Peoples Republic of China.

12. On 6 November 1970, Subject was granted a Covert Security Approval for use by Central Cover Staff with Robert R. Mullen and Company, a Public Relations firm with offices at 1729 H Street, Northwest, Washington, D.C. Inquiry of the Central Cover Staff on 19 June 1972 revealed that this is a current relationship. Subject, as principal officer of Robert R. Mullen and Company, is witting of cover arrangements for two Agency assets, [redacted] in [redacted] and [redacted] in [redacted]

13. Subject’s security file reflects that Subject has, in the past, been of operational interest to Mr. James Angleton, Chief, CI Staff/DDP, in connection with an operational matter. On 19 June 1972, Mr. Fred Hubbard, CI Staff, advised that he will provide information as to the nature of Mr. Angleton’s utilization of Subject.

 

JFK ASSASSINATION SYSTEM IDENTIFICATION | RECORD NUMBER 145-10001-10272

 

[Redacted

St. Petersburg, Fla.

October 5, 1961

Dear Bush:

Three weeks ago I finally left Cuba, fortunately with no trouble to speak of. I have been visiting my family in St. Pete, after having spent some time in Miami getting my bearings among the “active exiles”, and expect to head North in about a week. I plan to spend a few days in Washington and then go to New York. I would like very much to keep in touch with the Cuban situation and to remain as active as possible, within the limitations of whatever job I can get.

Although a lot of water has gone over the dam since last we spoke, about which the less said the better, I remember your comments about the feasibility of an arrangement along these lines. I would therefore like to encourage from you any suggestions you may be able to offer in this respect. I am naturally very interested in receiving the opportunity of discussing the situation and my possible contribution with qualified persons in Washington. What do you think? So far my only contacts are Senator Smathers, whom I hope to see here in St. Pete on the 9th, and a man named Raskin who answered a letter I wrote Bundy asking for an appointment. Raskin is on Bundy’s staff.

Bush, you may be out of touch with the Cuban problem, but in case you are not and have any ideas I will appreciate hearing from you. I expect to be here another week and then drive up in a little VW I bought in Miami. In Washington I will be staying at my cousin’s, Maria Teresa de Zaldo Meyer, 9710 Persimmon Tree Road,) Bethseda, Maryland. In any event I will look forward to seeing you soon. Best wishes.

[Redacted]

[Stamped RETURN TO CIA

Background Use Only

Do Not Reproduce]

 

___

Related:

http://tekgnosis.typepad.com/tekgnosis/2014/03/the-kennedy-assasination-the-nixon-bush-connection.html

http://tekgnosis.typepad.com/tekgnosis/2013/12/bill-lords-letter-to-president-jimmy-carter-re-jfk-assassination-and-lee-harvey-oswald-lho-plus-geor.html

JFK ASSASSINATION SYSTEM IDENTIFICATION | RECORD NUMBER 145-10001-10272

26 February 1962

MEMORANDUM FOR RECORD

SUBJECT: Minutes of Special Group Meeting on Cuba, 26 February

PRESENT: General Taylor and Mr. Bundy; Mr. Johnson; Mr. McNamara, Mr. Gilpatric and General Lemnitzer; Mr. McCone. General Lansdale and Mr. Harvey were also present.

 

The following decisions were reached:

1. The immediate tasks to be accomplished include:

a. The drafting of a paper for higher authority which will include two assumptions. These are (1) the United States will make maximum use of Cuban resources, but recognizes that final success will require decisive U.S. military intervention; and (2) that development of Cuban resources will be for the purpose of facilitating and supporting this intervention and to provide a preparation and a justification for it. Higher authority will not be asked by this paper to make a poilcy decision at this time, but simply to note the assumptions.

b. The plan presented by General Lansdale will be recast to put into one paper the short-range actions for the months of March, April and May, such as the acquisition of hard intelligence, and other actions drawn from answers to his study of 20 February 1962, which would have a low visibility and little likelihood of giving away the basic plan. Another paper will include those actions which would have the effect of committing the U.S. to greater or lesser degree to intervention. To the extent possible, the actions contemplated in functional annexes to the plan will be assigned to specific time phases. These papers will be circulated before the coming weekend.

The plan will contain more on intelligence, including a reference to the effort required in third countries.

The reference to a Presidential memorandum, in the first two lines of the Lansdale paper of 20 February, will be deleted.

The paper should include reference to the development of adequate Cuban leadership.

c. The Special Group will consider these papers, with the Attorney General present, before presentation to higher authority.

2. The cover plan for early actions will be that the U.S. in pursuing an anti-Castro policy is under the necessity of acquiring as much hard intelligence on Cuba as possible in a short time.

3. Each proposed sabotage operation will be decided on the basis of its individual merits, at the time.

4. Mr. McNamara undertook to provide the boats needed by CIA on presentation of a list of requirements, if they are available within the Defense establishment.

5. Arrangements will be made to have available a facility for radio broadcasts from a submarine, but the decision as to the actual beginning of broadcasting will be deferred until a later date. An internal land-based radio facility will not be considered at this time.

6. General Lansdale is to prepare a list of the individuals who know about this plan, with an estimate of their degree of knowledgeability. A control list will be kept of those having knowledge of the basic document.

7. General Taylor undertook to prepare the paper referred to in paragraph 1a above, which would set forth the guidelines for the further development of the project and would outline the channels of responsibility.

 

 

Thomas A. Parrott

 

No distribution

JFK ASSASSINATION SYSTEM IDENTIFICATION | RECORD NUMBER 145-10001-10273

SECRET

OFFICE OF THE SECRETARY OF DEFENSE
WASHINGTON 25, D.C.

30 October 1962

SENSITIVE
FOR THE RECORD

By Brig. Gen. Lansdale

Subject: Operation Mongoose

John McCone asked me to call him on the gray telephone this morning. I did so. He stated that he didn't know exactly how I was supposed to get word on this, so he was informing me to help out: at the Executive Council meeting this morning, the President had decided to hold back Operation Mongoose for the time being. Also, during the negotiations re Soviet missle bases in Cuba, there were to be no Mongoose sabotage or similar militant operations. McCone said that he had informed General Carter of this, but was letting me know, as Chief of Operations, to let the operations team know; he mentioned that Alpha 66 and the approved sabotage of Cuban shipping were to be held, specifically.

I commented that I had just received a copy of a memorandum from him to the Attorney General, the Sec/Def., etc., dated today, saying that CIA was still awaiting word from me on sending in 20 teams by submarine for intelligence collection, after I'd determined JCS and State requirements. I said that I had been told by McGeorge Bundy on Sunday, 28 October, to hold up action on this for 24 hours and had promptly notified CIA, and that yesterday, upon receipt of a memorandum from Bruce Cheever on this same subject, I had taken it up again with Bundy -- and Bundy had told me that he would tell McCone to have CIA hold everything. I presumed that Bundy had so informed McCone. Also, Harvey had called me Sunday night, asking my persmission to discuss CIA assets with CINCLANT and JUWTF for contigency planning; I had given Harvey permission to assist in this planning, if he felt that the U.S. military needed more planning help from the CIA.

After the talk with McCone, I talked with Bruce Cheever who assured me that he had similar orders from Carter and that all militant actions under CIA were being held at a stop. I gave similar orders to General Johnson for Defense/JCS. Lt-Col Patchell concurrently informed State and USIA along the same lines.

SENSITIVE
SECRET

EXCLUDED FROM AUTOMATIC REGRADING; DOD DIR 5200.10 DOES NOT APPLY

J D Tippit assassination witness Acquilla Clemons talks to JFK assassination researcher Mark Lane (Full Transcript)

Mark Lane: Mrs. Clemmons, where were you on November 22^nd, 1963?

 

Aquila Clemmons: I was workin for Ms. <unintelligible>, um 3 <sounds like cent> 27 East 10^th

 

Mark Lane: <as Aquila Clemmons was continuing to speak you can hear Mark Lane say “From where”..>

 

Aquila Clemmons: just down the block from where Tippit was killed.

 

Mark Lane: Did you know officer Tippit?

 

Aquila Clemmons: Yes, I saw him… men.. pretty many times.

 

Mark Lane: And, did you hear the shots?

 

Aquila Clemmons: Yes, I heard the shots.

 

Mark Lane: And what did you do?

 

Aquila Clemmons: I ran out into the street and, looked down the street, and, I ran back down the street where he was lyin and I looked at him.

 

Mark Lane: Now, when you heard the shots, and you went out of the house, did you see a man with a gun?

 

Aquila Clemmons: Yes I did.

 

Mark Lane: What was he doing?

 

Aquila Clemmons: Oh he was reloading. When I see.. he was reloading his gun.

 

Mark Lane: And, how would you describe that man?

 

Aquila Clemmons: Well he was kinda chunky, he’s kinda heavy, wadn’t a very big man.

 

Mark Lane: Was he tall or short?

 

Aquila Clemmons: He was a kinda short guy.

 

Mark Lane: Short and heavy..

 

Aquila Clemmons: Yes.

 

Mark Lane: Was there any other man there?

 

Aquila Clemmons: Yes, the one on the other side of the street. All I know he told him to go. <motions with her hand and arm a gesture to go>

 

Mark Lane: Mrs. Clemmons, aah, the man who had thee gun, ah, did he make any motion at all to the other man across the street?

 

Aquilla Clemons: No.. no one.. told him to go. <motions with her hand and arm a go gesture>

 

Mark Lane: So he waved his hand..

 

Aquilla Clemons: Yes

 

Mark Lane: And said go on..

 

Aquilla Clemons: said go.. <motions with her hand and arm a go gesture>

 

Mark Lane: And then what happened with the man with the gun?

 

Aquilla Clemons: ah, he unloaded and reloaded.

 

Mark Lane: And what did the other man do?

 

Aquilla Clemons: Man kept goin, straight down the street.

 

Mark Lane: And then did they go in opposite directions.

 

Aquilla Clemons: Yes, they was, they wadn’t together, they went this way <motioning in opposite directions with her arms> from each other. One down the street and went this way <motions with one arm in a certain direction>, other went straight down past street <motions with other arm in another direction> that way.

 

Mark Lane:  What was thee, ah, the man who did not do the shooting, but the man who went in the other direction from the man with the gun, what was he wearing? If you remember.

 

Aquilla Clemons: Well, I, from that memory now it looked like, like khakis and a white shirt.

 

Mark Lane: And was he tall or short?

 

Aquilla Clemons: He was tall.

 

Mark Lane: And was he heavy or thin?

 

Aquilla Clemons: He was thin.

 

Mark Lane: But the one who did, the one with the gun, seconds after Tippit was shot, he was short

 

Aquilla Clemons: Yes, he was..

 

Mark Lane:  He was heavy?

 

Aquilla Clemons:  ..short and kinda heavy.

 

Mark Lane: Now, did you testify before the Warren Commission about this <unintelligible>?

 

Aquilla Clemons: I haven’t said anything to anyone.

 

Mark Lane: Did anyone come to see you after the murder of officer Tippit?

 

Aquilla Clemons: Yes, he was a man came. I don’t know what he was. He came to my house, and talked to me. But I don’t know what he’s.. looked like a policeman to me.

 

Mark Lane: He did. Did he have a gun?

 

Aquilla Clemons: Yes, he wore a gun.

 

Mark Lane: Mrs. Clemons. How long after Tippit was shot did this man with a gun come to visit you?

 

Aquilla Clemons: Bout two, bout two days. He’s bout two days. Said that I might get hurt, ah, someone might hurt me, if I would talk.

 

Mark Lane: About what you saw.

 

Aquilla Clemons: What I saw. He just told me ta, be best if I didn’t say anything because I might get hurt.

 

1. 652, Warren Commission Report:

“Commission finding. – The only woman among the witnesses to the slaying of Tippit known to the Commission is Helen Markham. The FBI never interviewed any other woman who claimed to have seen the shooting, and never received any information concerning the existence of such a witness.”

 

J D Tippit Assassination witness Acquilla Clemons Talks To JFK Assassination Researcher Mark Lane