EFTA00081180

Case 9:08-cv-80736-KAM Document 291-15 Entered on Fl 5f) Docket 01/21/2a15 Page 21 of 
ease 09-34 /91 -KIJK 
UOC 1604b3 
Fitea 04/ubul 
yage zu OT 
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 
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 ql l 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 
EFTA00081200

Case 9:08-cv-807attV3agiiimt 2aliall oVeryLocra&Mocieateeaplc(7935 Page 22 of 
participating), 
http://www.voutube.com/watch?v=V-dooEvYXx4; 
and 
http://wwvv.youtube.cotnAvatch7v=YCNiY1tW-r0 
57. 
Edwards's efforts to obtain information about Epstein's organization for procuring 
young girls was also blocked because Epstein's co-conspirators took the Fifth. Deposition of 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 
EFTA00081201

Case 9:08-cv-8078gn3asiw 
2a-c1.?60Verv iiecilif 4qp iRocistal..21c/M5 Page 23 of 
deposition of Epstein's housekeeper Louella Rabuyo, October 20, 2009, page 9, lines 17-25 
(Deposition Attachment #I7); 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.php7id=1895OHANNA SJOBERG. Exhibit "AA". 
60. 
Alfredo Rodriguez testified that Maxwell took photos of girls without the girls' 
knowledge, kept the images on her computer, knew the names of the underage girls and their 
respective phone numbers and other underage victims were molested by Epstein and Maxwell together. 
See Deposition of Rodriguez, Deposition attachment # 8 at 64, 169-170 and 236. 
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 
EFTA00081202

Case 9:08-cv-807algt13498mee 
&1p6ogerSo croF4yeSocIsstayilo/R15 Page 24 of 
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 
"3" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's closest pals. He 
left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to teach you how to speak 
Russian. She is 2x8 years old, not blonde. Lessons are free and you can have your In today if you 
call." See Messages taken from Jean Luc Brunel are attached hereto as Exhibit "EE." In light of these 
circumstances of the case, this message reasonably suggested to Edwards that Brunel might have been 
procuring two eight-year-old girls for Epstein to sexually abuse. According to widely circulated press 
reports reviewed by Edwards, Brunel is in his sixties and has a reputation throughout the world (and 
especially in the modeling industry) as a cocaine addict that has for years molested children through 
modeling agencies while acting as their agent — conduct that has been the subject of critical reports, 
books, several news articles, and a 60 Minutes documentary on Brunel's sexual exploitation of 
underage models. See httn://bradmillershero.blogspot.com/2010/08/women-are-obiects.html attached 
hereto as Exhibit "FF." 
63. 
Edwards learned that Brunel is also someone that visited Epstein on approximately 67 
occasions while Epstein was in jail. See Epstein's jail visitor log attached as Exhibit "GG." 
64. 
Edwards learned that Brunel currently runs the modeling agency MC2, a company for 
which Epstein provides financial support. See Message Pad's attached as Exhibit "J" supra and Sworn 
Statement of MC2 employee Maritza Vasquez, June 15, 2010, "Maritza Vasquez Sworn Statement" 
attached at Exhibit "RH" 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 
EFTA00081203

Case 9:08-cv-80736-KAM ,Qocum.ent 291-1,5 Enlered on_FUSD Docket 01/21/21015 Page 25 of 
ease 09-34tvi-Kuo-‹ uoc 160401 rued u4/uarl 
i-sage 24 OT 
affiliated with Epstein and Brunel brought underage girls from all over the world, promising them 
modeling contracts. Epstein and Bnmel 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 Brunel could provide significant evidence of 
Epstein's trafficking in young girls for sexual abuse, Edwards had Brunel served in New York for 
deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit "IL" Before the 
deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach) contacted Edwards to 
delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left 
the country and was back in France with no plans to return. This information was untrue; Brunel was 
actually staying with Epstein in West Palm Beach. See Banasiak deposition, deposition attachment 
#16 at 154-160 and 172-175; see also pages from Epstein's probation file evidencing Jean Luc Brunel 
(JLB) staying at his house during that relevant period of time attached Exhibit "JJ". As a result, 
Edwards filed a Motion for Contempt, attached hereto as Exhibit "KK" (Because Epstein settled this 
case, the motion was never ruled upon.) 
67. 
Edwards was also informed that Epstein paid for not only Brunel's representation 
during the civil process but also paid for legal representation for 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 
EFTA00081204

Case 9:08-cv-807ags- ,t8.13498me ria 28sti2f6owergleocivaiiyocSstggiglgy15 Page 26 of 
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 httn://www.palmbeachtiost.com/news/crime/victims-
seeking-sex-offenders-millions-see-painful-pasts-192988.html attached hereto as Exhibit "LL." 
Edwards Pursues Other Lines ofDiscovery 
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 
EFTA00081205

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/20,15 Page 27 of 
Case 09-34791-RBR Doc 1604O 
Filed 04/08/11 Page 26 ot 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 
EFTA00081206

Case 9:08-cv-807algg343gmeg 28L1F6ogertoikray
i yocntaypep215 Page 28 of 
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 "17"; "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 
EFTA00081207

Case 9:08-cv-80736-KAM Document 291-15 Entered on FirSD Docket 01/21/2D15 Page 29 of 
Case 09-34791-RBR Doc 1604@ Filed 04/08/11 
Vage 2t3 ot 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 "M14"; 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 
finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at 116. 
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 
EFTA00081208

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 30 of 
Case 09-34791-RBR Doc 160403 Filed 04/08/11 
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 118. 
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 
EFTA00081209

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 31 of 
Case 09-34791-RBR Doc 1604 Filed 04/08/11 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 
EFTA00081210

Case 9:08-cv-80736-KAM Document 291-15 Entered on Fl.,SD? Docket 01/21/2
5 Page 32 of 
Case 09-34791-RBR 
Doc 160403 
Filed 04/08/11 
Page 31
10.1 
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 nothing wrong even though 
she helped procure young girls to satisfy Epstein's sexual desires); 
• With regard to Jane Doe 102 v. Epstein, which involved an allegation that Epstein had 
repeatedly sexually abused a 15-year-old girl, forced her to have sex with his friends, 
and flew her on his private plane nationally and internationally for the purposes of 
sexually molesting and abusing her, he (Epstein) flippantly said that the case was 
dismissed, indicating that the allegations were ridiculous and untrue. 
See Affidavit of Michael J. Fisten attached hereto as Exhibit "QQ." 
81. 
The Rush interview also demonstrated perjury (a federal crime) on the part of Epstein. 
Epstein lied about not knowing George Rush. See Epstein Deposition, February 17, 2010, taken in 
L.M. v. Jeffrey Epstein, case 50-2008-CA-028051, page 154, line 4 through 155 line 9, (Deposition 
attachment #7), wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush 
from the New York Daily News. This impression was given despite the fact that he gave a lengthy 
30 
EFTA00081211

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 33 of 
Case 09-34791-RBR Doc 16046 Filed 04/08/11 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 
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 
EFTA00081212

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 34 of 
Case 09-34791-RBR Doc 1604§ Filed 04/08/11 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, 
149 (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 119. 
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 121. 
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 
EFTA00081213

Case 9:08-cv-80736-KAM Document 291-15 Entered on FI_SD Docket 01/1/2.215 Page 35 of 
Case 09-34791-RBR Doc 1603b§ Filed 04/u44/11 
Page 34 Ot 3V 
have run a giant Pont scheme at his law firm of Rothstein, Rosenfeldt and Adler P.A. ("RRA"). This 
Ponzi scheme involved Rothstein falsely informing investors that settlement agreements had been 
reached with putative defendants based upon claims of sexual harassment and/or whistle-blower 
actions. 
Rothstein falsely informed the investors that the potential settlement agreements were 
available for purchase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR-
00HN (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 
Pont 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 Pont 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 1122). 
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 Pont scheme. The 
letter indicated that law enforcement agencies had determined that Edwards was "a victim (or potential 
33 
EFTA00081214

Case 9:08-cv-807C3a6=1 3496iumpt t? -lacaterpVeodioF40 35) pocgayp o/f24131.5 Page 36 of 
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 "Ti'." 
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 123. 
Epstein Takes the Fifth When Asked Substantive Ouestions 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 
EFTA00081215

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 37 of 
Case 09-34791-RBR Doc 1603$0 Filed 04/08/11 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 18." Id. at 90. 
107. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have you 
ever socialized with Mr. Mottola in the presence of females under the age of 18?" Id at 91-92. 
108. 
In his deposition, Epstein took the Fifth rather than answer the question: "Did you ever 
socialize with David Copperfield in the presence of females under the age of 18?" Id. at 
109. 
In his deposition, Epstein took the Fifth rather than answer the question: "Have you 
ever socialized with Mr. Richardson [Governor of New Mexico and formerly U.S. Representative and 
35 
EFTA00081216

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 38 of 
Case 09-34791-RBR Doc 16044 Filed 04/08/11 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 I8?" 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 `12_RA 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 
EFTA00081217

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 39 of 
Case 09-34791-RBR Doc 16030 Filed 04/08/11 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 
0D 
I HEREBY CERTIFY that on September a 
 , 2010 a copy of the foregoing has been served 
via U.S. Mail and email transmittal to all those on the attached service list. 
By: 
Jack Scarola 
Searcy, Denney, Scarola, Barnhart & Shipley 
2139 Palm Beach Lakes Blvd 
West Palm Beach, FL 33409 
(561) 68 
(561 
(fax) 
OL 
Flon 
No.: 169440 
37 
EFTA00081218

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 40 of 
Case 09-34791-RBR Doc 1604E8 
Filed 04/08/11 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 
EFTA00081219