EFTA01098984

minor females that the United States Attorney's Office recognized as a victim. M.'s sworn 
deposition testimony and the adverse inference drawn from Epstein's refusal to testify confirm 
that Epstein began sexually assaulting 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 ■.T' A: [Invocation of the Fifth 
Amendment].); see also Epstein Depo., April 14, 2010, Attachment #6, at 456 ("Q: 
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 M. beginning when •. 
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 11-12, 30-31 (Deposition 
Attachment # 7). 
9. 
Epstein also sexually assaulted M., beginning when she was 14 years old and 
did so on numerous occasions. See M. Depo., Attachment #4 at 215-216. 
10. 
Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse 
began 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 •., M., 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 
6 
EFTA01099004

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 her 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 M. perform oral sex on him and was to 
perform sex acts onapstein'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; M. Depo., Attachment #3, at 416; 
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 
When she was 
approximately 15 years old, 
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, 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 
When she was approximately 16 
years old, she was brought to Epstein's home by another underage victim. While a minor, she 
7 
EFTA01099005

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 
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): 
remembered that she climaxed and was removing herself from the 
massage table. mi asked for a sheet of a r and drew the massage table in the 
master bathroo 
and where Epstein, 
and she were. Epstein turned 
on to her stomach on the massage bed and inserted his penis into her 
vagina. [=] 
stated Epstein began to pump his penis in her vagina. 
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 ...." 
"[M] advised there were times that she was so sore when she left Epstein's 
house. I
 advised she was ripped, torn, in her vagina area. 
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: 
• 
These girls were 
between the ages of 13 and 17 when Epstein abused them. See Rule 413 Notice, Exhibit E; 
Deposition ofM., Deposition Attachment #4. 
8 
EFTA01099006

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 230-31. . 
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 "O"). 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 bad 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 
9 
EFTA01099007

whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); 
at 9 (Bill Clinton phone numbers listed under "Doug Bands"). 
Federal Investigation and Plea ARreemeixt 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 bad 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 
o Le0cowitz (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 Au ust 21, 2007, FBI Special Agent
 and 
raveled to the home of Leslie Groff to serve her with a federal gr
. 
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 
10 
EFTA01099008

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. E stein became concerned that the FBI would 
try to serve his traveling companion 
with a similar and jury 
subpoena. In fact, the agents were preparing to serve Ms. 
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 
During the flight, the defendant 
verbally harassed Ms. 
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 
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: SM101: 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 
11 
EFTA01099009

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 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 53-
page indictment of Epstein related to his sexual abuse of children. On September 19, 2007, at 
12:14 PM, afrote 
to Epstein's counsel, Jay Leflcowitz, "Jay - I 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 53-
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 
12 
EFTA01099010

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"). 
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 - 
-even participated in the sex acts with minors (including M.) and Epstein. 
See Incident Report, Exhibit "A", at 40-42, 49-51; Deposition of 
April 13, 
2010, (hereinafter '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 M. and 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 M. and M. that a plea agreement had already been reached that would 
13 
EFTA01099011

block federal prosecution of Epstein. Nor did the FBI notify 
and 
of any of the parts of 
the plea agreement. Nor did the FBI or other federal authorities confer with 
and 
about the plea. See id. 
30. 
In 2008, Edwards believed in good faith that criminal prosecution of Epstein was 
extremely important to his clients 
and 
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. 
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 — 
M., M., 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 (M. and M.) 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 
14 
EFTA01099012

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 M.; on July 2, 2008, 
attorney Edwards agreed to represent Jane Doe; and, on July 7, 2008, attorney Edwards agreed to 
represent 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 ao 
inform her that he 
represented Jane Doe #1 and, later, Jane Doe #2. AUSA -= 
did not advise that a plea 
agreement had already been negotiated with Epstein's attorneys that would block federal 
prosecution. 
To the contrary, AUSA 
mentioned a possible indictment. 
AUSA 
did indicate that federal investigators had concrete evidence and information that 
Epstein had sexually molested many underage minor females, including M., M, and Jane 
Doe. See id. at ¶4. 
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"). 
15 
EFTA01099013

35. 
On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA =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 
called Edwards to provide notice to his clients 
regarding the hearing. AUSA 
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 M. and 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 M. and 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 
.
 
and M. That action alleged that the U.S. Attorney's Office had 
failed to provide M. and M. the rights to which they were entitled under the Act, including 
the right to be notified about a plea agreement and to confer with prosecutors regarding it. See 
id. 
38. 
On July 11, 2008, Edwards took M. and 
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 
16 
EFTA01099014

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). 
17 
EFTA01099015

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 
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-80119 (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 Azainst 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 M., Brad Edwards filed a civil 
suit against Jeffrey Epstein to recover damages for his sexual assault of M. See Complaint, 
M. v. Epstein (Exhibit "U"). 
18 
EFTA01099016

46. On September 11, 2008, at the request of his client M.., Brad Edwards filed a civil 
suit against Jeffrey .Epstein to recover damages for his sexual assault of M. See Complaint, 
M. v. Epstein, (Exhibit "V"). 
47. Jane Doe's federal complaint indicated that she sought damages of more than 
$50,000,000. 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, 
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. 
was born a male, and in her complaint she 
19 
EFTA01099017

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: 
httn://vrww.nytiost.com/o/news/regional/item 44zIWyLUFH7R1OUtKYGPbP;isessionid=6CA3 
EBF1BEF68F5DE14BFB2CAA5C37E0. See Article attached hereto as Exhibit "X". 
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, royalty, 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." 
20 
EFTA01099018

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-
incrimination. An example of Epstein's refusal to answer is attached as Composite Exhibit "Z" 
(original discovery propounded to Epstein and his responses invoking 5th amendment). 
54. 
During the discovery phase of the civil cases filed against Epstein, Epstein's 
deposition was taken at least five times. During all of those depositions, Epstein refused to 
answer any substantive questions about his sexual abuse of minor girls. See, e.g., Deposition 
Attachments 1, 6 and 7. 
55. 
During these depositions, Epstein further attempted to obstruct legitimate 
questioning by inserting a variety of irrelevant information about his case. 
As one of 
innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 
2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that 
question, as I would like to answer mostly every question you've asked me here today; however, 
upon advice of counsel, I cannot answer that question. They've advised me I must assert my 
Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse 
me, against--under the Constitution. And though your partner, Jeffrey Herman, was disbarred 
after filing this lawsuit [a statement that was untrue), Mr. Edwards' partner sits in jail for 
21 
EFTA01099019

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. (one in 
which Edwards was not participating), http://www.youtube.comiwatch?v=V-dqoEyYXx4; and 
htto://www.voutube.com/watch?v=YCNiY1tW-r0 
57. 
Edwards's efforts to obtain information about Epstein's organization for 
procuring young girls was also blocked because Epstein's co-conspirators took the Fifth. 
Deposition of 
March 24, 2010 (hereinafter 
Depo.") (Deposition 
attachment #14); Deposition o 
April 13, 2010, (Deposition attachment #9); 
Deposition of 
March 15, 2010 (hereinafter `tepo.") 
(Deposition 
attachment #15). Each of these co-conspirators invoked their respective rights against self-
incrimination as to all relevant questions, and the depositions have been attached. 
58. 
At all relevant times Edwards has had a good faith basis to believe and did in fact 
believe 
was an employee of Epstein's and had been identified as a defendant in at 
least one of the complaints against Epstein for her role in bringing girls to Epstein's mansion to 
be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on 
22 
EFTA01099020

all substantive questions regarding her role in arranging for minor girls to come to Epstein's 
mansion to be sexually abused. Reinhart had previously been an Assistant United States 
Attorney in the U.S. Attorney's Office for the Southern District of Florida when Epstein was 
being investigated criminally by Reinhart's office. Reinhart left the United States Attorney's 
Office and was immediately hired by Epstein to represent Epstein's pilots and certain co-
conspirators during the civil cases against Epstein. See Edwards Affidavit, Exhibit "N" at ¶11. 
59. 
Edwards also had other lines of legitimate discovery blocked through the efforts 
of Epstein and others. For example, Edwards learned through deposition that Ghislaine Maxwell 
was involved in managing Epstein's affairs and companies. See deposition of Epstein's house 
manager Janusz Banziak, February 16, 2010 at page 14, lines 20-23 (Deposition Attachment 
#16); See deposition of Epstein's housekeeper
, October 20, 2009, page 9, lines 
17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison, 
October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo 
Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Attachment #8); See also Prince 
Andrew's Friend, Ghislaine Maxwell, Some Underage Girls and A Very Disturbing Story, 
September 
23, 
2007 
by 
Wendy 
Leigh, 
link 
at 
http://www.redicecreations.com/article.php?id=1895OHANNA SJOBERG. Exhibit "AA". 
60. 
Alfredo Rodriguez testified that Maxwell took photos of girls without the girls' 
knowledge, kept the images on her computer, knew the names of the underage girls and their 
respective phone numbers and other underage victims were molested by Epstein and Maxwell 
together. See Deposition of Rodriguez, Deposition attachment # 8 at 64, 169-170 and 236. 
23 
EFTA01099021

61. 
In reasonable reliance on this and other information, Edwards served Maxwell for 
deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented 
by Brett Jaffe of the New York firm of Cohen and Gresser, and Edwards understood that her 
attorney was paid for (directly or indirectly) by Epstein. 
She was reluctant to give her 
deposition, and Edwards tried to work with her attorney to take her deposition on terms that 
would be acceptable to both sides. The result was the attached confidentiality agreement, under 
which Maxwell agreed to drop any objections to the deposition, attached hereto as Exhibit "CC." 
Maxwell, however, contrived to avoid the deposition. On June 29, 2010, one day before 
Edwards was to fly to NY to take Maxwell's deposition, her attorney informed Edwards that 
Maxwell's mother was deathly ill and Maxwell was consequently flying to England with no 
intention of returning to the United States. Despite that assertion, Ghislaine Maxwell was in fact 
in the country on July 31, 2010, as she attended the wedding of Chelsea Clinton (former 
President Clinton's daughter) and was captured in a photograph taken for OK magazine. Photos 
from Issue 809 of the publication See US Weekly dated August 16, 2010 are attached hereto as 
Exhibit "DD" and Edwards Affidavit, Exhibit "N" at ¶12. 
62. 
Maxwell is not the only important witness to lie to avoid deposition by Edwards. 
Upon review of the.message pads that were taken from Epstein's home in the police trash pulls, 
see Exhibit "J" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's 
closest pals. He left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to 
teach you how to speak Russian. She is 2x8 years old, not blonde. Lessons are free and you can 
have your lm 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 
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EFTA01099022

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-objects.html. attached hereto as Exhibit 
63. 
Edwards learned that Brunel is also someone that visited Epstein on 
approximately 67 occasions while Epstein was in jail. See Epstein's jail visitor log attached as 
Exhibit "GO." 
64. 
Edwards learned that Brunel currently runs the modeling agency MC2, a company 
for which Epstein provides financial support. See Message Pad's attached as Exhibit "J" supra 
and Sworn Statement of MC employee 
June 15, 2010, 
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, affiliated with Epstein and Brunel brought underage girls from all over the world, 
promising them modeling contracts. Epstein and Brunel would then obtain a visa for these girls, 
then would charge the underage girls rent, presumably to live as underage prostitutes in the 
condos. See 
60 and 62-67. 
Sworn Statement, Exhibit "HH" at 7-10, 12-15, 29-30, 39-41, 59-
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