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IN THE CIRCUIT COURT OF THE 
SEVENTEENTH JUDICIAL CIRCUIT, IN 
AND FOR BROWARD COUNTY, FLORIDA 
CASE NO.: CACE 15-000072 
BRADLEY J. EDWARDS and PAUL G. 
CASSELL, 
Plaintiff, 
vs. 
ALAN M. DERSHOWITZ, 
Defendant. 
DECLARATION OF 
1. My name is 
and I was born in August, 1983. 
2. I am currently 31 years old. 
3. I grew up in Palm Beach, Florida. When I was little, I loved animals and wanted 
to be a veterinarian. But my life took a very different turn when adults — including Jeffrey 
Epstein and his close friend Alan Dershowitz -- began to be interested in having sex with me. 
4. In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is 
the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked 
that I come with her to Jeffrey Epstein's mansion for the purposes of teaching me how to 
perform "massages" and to train me professionally in that area. Soon after that I went to 
Epstein's home in Palm Beach on El Brillo Way. 
5. From the first time 1 was taken to Epstein's mansion that day, his motivations and 
actions were sexual, as were Maxwell's. My father was not allowed inside. I was brought up 
some stairs. There was a naked guy, Epstein, on the table in the room. Epstein and Maxwell 
forced me into sexual activity with Epstein. I was 15 years old at the time. He seemed to be in 
his 40s or 50s. I was paid $200. I was driven home by one of Epstein's employees. 
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6. I came back for several days following and did the same sorts of sexual things for 
Epstein. 
7. After I did those things for Epstein, he and Maxwell said they were going to have me 
travel and were going to get an education for me. They were promising me the world, that I 
would travel with Epstein on his private jet and have a well-paid profession. Epstein said he 
would eventually match me up with a wealthy person so that I would be "set up" for life. 
8. So I started "working" exclusively for Epstein. He took me to New York on his big, 
private jet. We went to his mansion in New York City. I was shown to my room, a very 
luxurious room. The mansion was huge. I was very young and got scared because it was so big. 
Epstein brought me 
to a room with a massage parlor. Epstein made me engage in sexual activities with him there. 
9. You can see how young I looked in the photograph below. 
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10. Epstein took me on a ferry boat on one of the trips to New York City and there he 
took the picture above. I was approximately 15 or 16 years old at the time. 
11. Over the next few weeks, Jeffrey Epstein and Ghislaine Maxwell trained me to do 
what they wanted, including sexual activities. The training was in New York and Florida, at 
Epstein's mansions. It was basically every day and was like going to school. I also had to have 
sex with Epstein many times. 
12. I was trained to be "everything a man wanted me to be." It wasn't just sexual training 
- they wanted me to be able to cater to all the needs of the men they were going to send me to. 
They said that they loved that I was very compliant and knew how to keep my mouth shut about 
what they expected me to do. 
13. Epstein and Maxwell also told me that they wanted me to produce information for 
them in addition to performing sex on the men. They told to me to pay attention to the details 
about what the men wanted, so I could report back to them. 
14. While I had juvenile hopes of bettering my life, from very early on 1 was also afraid of 
Epstein. Epstein told me he was a billionaire. I told my mother that I was working for this rich 
guy, and she said "go, go far away." Epstein had promised me a lot, and 1 knew if I left I would 
be in big trouble. I was a witness to a lot of illegal and bad behavior by Epstein and his friends. If 
I left Epstein, he knew all kinds of powerful people. He could have had me killed or abducted, 
and I knew he was capable of that if 1 did not obey him. He let me know that he knew many 
people in high places. Speaking about himself, he said "I can get away" with things. Even as a 
teenager, I understood what this meant and it scared me, as I believe he intended. 
15. I visited and traveled with Jeffrey Epstein from 1999 through the summer of 
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2002, and during that time I stayed with him for sexual activities at each of his houses (or 
mansions) in locations including New York City, New York; the area of Santa Fe, New Mexico; 
Palm Beach, Florida; an island in the U.S. Virgin Islands; and Paris, France. I had sex with him 
often in these places and also with the various people he demanded that I have sex 
with. Epstein paid me for many of these sexual encounters. Looking back, I realize that my only 
purpose for Epstein, Maxwell and their friends was to be used for sex. 
16. To illustrate my connection to these places, I include four photographs taken of 
me in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. We 
had gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at the 
time, judging from the looks of it. At the end of the day we returned to Epstein's Zorro Ranch. 
The second picture is me on one of Epstein's horses on the ranch in New Mexico. The following 
two are from wintertime in New Mexico. 
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17. When I was with him, Epstein had sex with underage girls on a daily basis. His 
interest in this kind of sex was obvious to the people around him. The activities were so obvious 
and bold that anyone spending any significant time at one of Epstein's residences would have 
clearly been aware of what was going on. 
18. Epstein's code word for sexual encounters was that it was a "massage". At times 
the interaction between Epstein and the girls would start in a massage room setting, but it was 
always a sexual encounter and never just a massage. 
19. In addition to constantly finding underage girls to satisfy their personal desires, 
Epstein and Maxwell also got girls for Epstein's friends and acquaintances. Epstein specifically 
told me that the reason for him doing this was so that they would "owe him," they would "be in 
his pocket," and he would "have something on them." I understood that Epstein thought he 
could get leniency if he was ever caught doing anything illegal, or that he could escape 
trouble altogether. 
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20. Harvard law professor Alan Dershowitz was around Epstein frequently. Dershowitz 
was so comfortable with the sex that was going on that on one occasion he observed me in sexual 
activity with Epstein. 
21. I had sexual intercourse with Dershowitz at least six times. The first time was when I 
was about 16, early on in my servitude to Epstein, and it continued until I was 19. 
22. The first time we had sex took place in New York in Epstein's home. It was in 
Epstein's room (not the massage room). I was approximately 16 years old at the time. I called 
Dershowitz "Alan." I knew he was a famous professor. 
23. The second time that I had sex with Dershowitz was at Epstein's house in Palm 
Beach. 
24. I also had sex with Dershowitz at Epstein's Zorro Ranch in New Mexico in the 
massage room off of the indoor pool area, which was still being painted. 
25. We also had sex at Little Saint James Island in the U.S. Virgin Islands. 
26. Another sexual encounter between me and Dershowitz happened on Epstein's 
airplane. Another girl was present on the plane with us. 
27. I have recently seen Alan Dershowitz on television calling me a "liar." He is lying by 
denying that he had sex with me. The man I've seen on television, described as a former law 
professor, is the same man that I had sex with at least six times. Dershowitz also knows that 
Epstein had sex with other underage girls and lent me out to other people, but he is lying and 
denying that as well. 
28. After years of abuse and being lent out, I began to look for a way to escape. I had first 
gone into Epstein's household because I wanted to be a massage therapist. Epstein had taken me 
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into his clutches through promises and talk and for some time I believed him. But once he had 
me under his control, regardless of my doubts and fears, I felt trapped. 
29. I kept asking Epstein for my promised training and education. Epstein finally got me 
a plane ticket to Thailand to go to Chaing Mai to learn Thai massage. This sounded like my 
chance to escape. In September 2002,1 packed my bags for good. I knew this would be my only 
opportunity to break away. 
30. On September 27, 2002, I flew from JFK in New York to Chaing Mai, Thailand. I 
arrived around September 29 for my training. But Epstein was going to get something out of this 
trip as well. I was supposed to interview a girl there and bring her back to the United States for 
Epstein. 
31. 
32.1 did the massage training in Chiang Mai. While I was there, I met a great and special 
guy and told him honestly what I was being forced to do. He told me I should get out of it. I told 
him that the people 1 was working for were very powerful and that! could not walk away or 
disobey them without risking serious punishment, including my life. He told me he would protect 
me. I had confidence in him and I saw his love and help as my opportunity to 
escape and to be with someone who truly loved me and would protect me. I married him and 
flew to Australia. 
33.1 called Epstein and told him I was not coming back. He asked why? I said "I've 
fallen in love." Epstein basically said "good luck and have a good life." I could tell he was not 
happy. I was afraid of what he was going to do to me. I thought he or one of his powerful friends 
might send someone to hurt me or have me killed. 
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34. From that point onward, out of concern for my safety and general well-being, I 
stayed in Australia with my husband. I was in Australia from late 2002 to October 2013. To be 
clear, I was never in the United States during these years, not even for a short trip to visit my 
mother. And my absence from the United States was not voluntary — I was hiding from Epstein 
out of fear of what he would do to me if I returned to the United States. 
35. In around 2007, after not hearing from anyone for years, out of the blue I was 
contacted by someone who identified himself with a plain sounding name and claimed he was 
with the FBI. It seemed very odd for someone doing an official criminal investigation to just call 
up on the phone like that. 1 hadn't heard Epstein's name for years. I didn't know who this person 
was and what it was really about. I couldn't tell what was going on. 
36. This man said he was looking into Jeffrey Epstein. The man asked if I had been 
involved with Epstein. My first instinct was to say nothing because 1 wasn't sure he was really 
with the FBI or any authorities. I answered a few basic questions, telling him that I knew Jeffrey 
Epstein and had met him at a young age. But the conversation didn't feel right. This man never 
offered to come and meet with me in person. Instead, he asked me right off the bat about 
Epstein's sexual practices. I thought it would be strange for a true law enforcement officer to 
behave that way, so I became increasingly uncomfortable and suspicious about who was actually 
calling me. 
37. I told the man nothing more about Epstein. The conversation probably didn't even 
last three minutes, but it immediately triggered all of the fears of Epstein and his powerful 
friends that had caused me to escape in the first place. If the call accomplished anything, it only 
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put me back into a state of fear and told me that I could be found quite easily and had nobody 
official protecting me. 
38. I suspected that the man who called me was working for Epstein or one of Epstein's 
powerful friends. I believed that if this was really an agent who was investigating Epstein, he 
would have known who I was and how I fit into Epstein's sexual crimes in many different 
places. He would have interviewed me in a way that would have established his credentials and 
would have shown how he could provide potential protection from Epstein. That never 
happened. 
39. Getting a call from this supposed FBI Agent made me scared all over again. I had left 
that old life of sexual slavery behind me and started a new life in a new country in hopes that the 
powerful people whose illegal activities I knew all about would never find me. 
40. Shortly after this purported FBI call, I was contacted by telephone by someone who 
appeared clearly to be working for Epstein. The caller told me about an investigation into Epstein 
and said that some of the girls being questioned were saying that Epstein had had sexual contact 
with them. After they made those allegations, the man said they were being discredited as drug 
addicts and prostitutes, but in my case, if I were to keep quiet, I would "be looked after." The 
fact that this call was made shortly after the supposed FBI call reinforced my concern that the 
man I had talked to earlier was not really working for the FBI but for Epstein. I didn't think that 
the FBI and Epstein would both be working together and would both get my phone number at 
almost exactly the same time. I played along and told this person that I had gotten a call from the 
"FBI" but that I didn't tell him anything. The person on the phone was pleased to hear that. 
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41. A short time later, one of Epstein lawyers (not Alan Dershowitz) called me, and then 
got Epstein on the line at the same time. Epstein and his lawyer basically asked again if I was 
going to say anything. The clear implication was that I should not. The way they were talking to 
me, I was afraid of what would happen if I didn't keep quiet. My thought was that if 1 didn't say 
what they wanted me to say, or not say, I might get hurt. 
42. I promised Epstein and his lawyer that I would keep quiet. They seemed happy with 
that and that seemed to me the way to keep me and my family safe. And I did what Epstein and 
his lawyer told me to do. I kept quiet. 
43.1 now understand that Epstein reached a non-prosecution agreement with the federal 
government in 2007 and pled guilty to two state crimes in June 2008. No one told me anything 
about those events until much later. In fact, nobody called or came to see me to explain what a 
non-prosecution agreement was, what crimes Epstein could have been charged with, why he was 
not being charged with the crimes he had committed, or anything whatsoever about the case. I 
was never offered a chance to meaningfully confer with the prosecutor for the Government, and I 
was never notified of any hearing that could affect me or my rights as a crime victim to ever 
bring charges. 
44. On September 3, 2008, the FBI sent a victim notification letter to me. This was the 
first written communication I had received from the FBI. The letter was attached as Exhibit 1 to 
my earlier statement. This kind of written communication, on official FBI stationary, is the way 
that I thought the FBI really communicated with people that they wanted to talk to. The fact that 
I got this official letter from them made me wonder even more whether the call I had received 
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earlier was really from the FBI. The letter that I got did not mention that anyone from the FBI 
had ever called me before. 
45. The letter started off with the sentence: "By virtue of this letter, the United States 
Attorney's Office for the Southern District of Florida provides you with the following notice 
because you are an identified victim of a federal offense." That sentence (among others) made it 
seem like this was the first time the FBI was officially contacting me. That was the first time I 
was told about my rights as a crime victim. 
46. I did not know what was happening about any criminal prosecution of Epstein at this 
time. I wanted him prosecuted. And given his constant illegal sexual behavior, I thought it was 
obvious that he should be prosecuted. But after reading the letter, I was confused. The letter did 
not explain what was actually happening or what role, if any, I could play. In fact, the letter 
thanked me for my assistance during the investigations, yet made no reference to what this 
supposed "assistance" consisted of. 
47. Also, the letter did not directly say that Epstein's crimes against me were not going to 
be prosecuted. It just said that "the United States has agreed to defer federal prosecution in favor 
of this state plea and sentence . ..." I did not know what that meant. The letter did not inform me 
how it applied to me. The letter also said that there was "litigation between the United States and 
two other victims regarding the disclosure of the entire agreement between the United States and 
Mr. Epstein." Understanding more about that case now, I realize that the letter did not explain 
that the real purpose of that litigation was not to get "disclosure of the entire agreement" but 
instead to get criminal charges filed against Epstein and to seemingly uphold the rights of 
Epstein's victims. I wish that the Government had told me what was really going on. 
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48. I saw on the letter that I could call a lawyer. The letter also mentioned Jack 
Goldberger, who I knew to be Epstein's attorney, which scared me. I first got in touch with the 
attorneys at the Podhurst Orseck firm. My lawyers filed a lawsuit against Epstein for me, which 
mentioned that I was abused by Epstein and other powerful people. 1 was hoping that the 
information I gave as part of my lawsuit might help to put Epstein in prison, but the lawsuit 
ended up just being about money, which Epstein paid to settle. 
49.1 continued living in Australia and, in 2011, was contacted by a journalist, who told 
me she was working for a British newspaper. She asked me if I had information about Prince 
Andrew. When I said that I did, she came out to Australia to meet with me. 
SO. At this point, since nothing else seemed to be working to get Epstein and his 
associates held accountable, I wanted to try by myself to get a message out to the public about 
what Epstein and his friends had done to me and other girls. I was very disturbed that no one was 
prosecuting Epstein for these crimes. I was also very scared. It seemed that law enforcement was 
not doing anything with the information they knew about me, which left me and my family 
vulnerable and fearful. 
51. The journalist printed an article using some of the information I told her. Shortly after 
the article was published, I talked on the phone to Marie Villafacia, a federal prosecutor from 
Florida. I had seen her name on the official letter from the FBI, so she seemed legitimate. 
Villafafia seemed very interested in my case and seemed as if she wanted to do something. 
52. Within a few weeks of the newspaper article being published, two FBI agents also 
called me in Australia and then came to meet me. In around March 2011, they met me at the 
U.S. Consulate in Sidney. They seemed to be very professional and hard working. 1 thought that 
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I had finally gotten the attention of the people that I wanted and that these people would do the 
right things against Epstein and the others. I also thought that they could protect me. 
53. When I met with the agents, they mainly focused on Epstein. But while I was at the 
Consulate, I provided them some information about some of the others who were involved in 
illegal acts as well. I was aware that a false statement to these law enforcement officers was a 
crime and I told the truth, giving them information I could recall about the individuals they 
inquired about. 
54. The agents were clearly prepared to meet me and already knew a lot about Epstein's 
crimes. The agents appeared to be very good at investigating and seemed like they really knew 
how to piece together the whole story. But at the same time, they seemed like they were being 
blocked from doing what they wanted to do — which I thought was to arrest Epstein and his 
powerful friends for all of their illegal sexual crimes. 
55. Shortly after the FBI interview in 2011, I spoke to attorney Brad Edwards. He told 
me he had been sued by Jeffrey Epstein and wanted to know what I knew about Epstein and his 
associates' involvement with sexually abusing underage girls. 1 told him about my abuse and 
trafficking by Epstein. I also told him at that time that I had been sexually abused by Ghislaine 
Maxwell, Alan Dershowitz, and other powerful people. 
56. In around April 2011, as a follow-up to my earlier call with Brad Edwards, I got a 
telephone call from him and another attorney, Jack Scarola. He and his firm wanted general 
information about whether various people had information relevant to the lawsuit. They told me 
that they were taping the conversation, and I had no problem with that. I cooperated with them 
and gave them information about which people had information relevant about Epstein's crimes. 
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57. Because it was over the phone and we did not know each other, they were polite and 
did not ask me a lot of details about specifically who I had sex with and what explicit sexual 
activities I was forced to participate in. It was a general, background interview. 
58. As the months following the FBI meeting in Sydney passed, I was trying to be patient 
but I began wondering what was going on with regard to prosecuting Epstein. 1 continued to be 
confused about what was happening. I was hoping that some kind of prosecution would come out 
of these events, but when nothing came of them, I got upset. I wanted to do something to stop 
Epstein and the other people he associates with from continuing to sexually abuse girls. Law 
enforcement had taken my detailed statements, but nothing seemed to be happening. I wasn't 
sure what to do. 
59. While I wanted to do what I could to get justice for what had happened to me, it was 
very hard for me to figure out how to get something done in the United States while living in a 
foreign country, especially after 1 had already gave information to the FBI that I believed they 
were using to investigate and eventually arrest Epstein. 
60. To further my effort to Prevent Sexual Abuse and Sex Trafficking I founded the non-profit 
organization "Victims Refuse Silence"— www.victimsrefusesilence.org. I know that I can't stop 
abuse everywhere, but if I help save even a few victims from the kind of degradation I 
experienced I will have made a positive difference. 
61. I asked two attorneys — Brad Edwards and Paul Cassell — to see if they could help me 
bring Epstein and his friends to justice. They agreed to try to add me to the existing CVRA case. 
They explained to me that the lawsuit was not asking to get money from Epstein or others. I 
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understand and have always understood that the goal of the case is to enforce my rights as a 
crime victim, rights that were unfairly taken away from me. 
62. Epstein and his friends sexually and physically abused many other girls. They did this 
in many places around the world. I personally observed this. There are also many people who 
could confirm what I am saying. I hope that these people will come forward and tell the truth. 
63. The trafficking of underage girls is a major problem in the United States and 
elsewhere. I will continue to cooperate fully in the investigation and prosecution of Epstein, 
Maxwell, or any of their friends who participated in the sexual abuse of minors. I also hope that 
this information is treated in a way that will keep me safe from Epstein and others identified here 
so as to encourage more victims of similar crimes to come forward. If these crimes are not 
prosecuted, despite my volunteering this information and cooperation, other victims will be 
deterred from coming forward. 
64. In this affidavit, I have tried to focus on how I was trafficked for sexual purposes. 
I have not described all of the details of the sexual activities Epstein forced me to have. Also, I 
have not described all of the details of the other events discussed here. If a judge wants me to 
present my information in more detail, including specific descriptions of the sexual behaviors, 
likes and dislikes of the men Epstein sent me to, I could do so. 
65. I have directed my attorneys, including Bradley J. Edwards and Paul G. Cassell, to 
pursue all reasonable and legitimate means to have criminal charges brought against these 
powerful people for the crimes they have committed against me and other girls. They are 
presenting me in Jane Doe I and Jane Doe 2 v. United States (S.D. Ha.) pro bono. 
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