Epstein Files

Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 1 of 40 EXHIBIT 16 EFTA00081180

Case 9:08-cv-807m091349pept Z91-15 _EriterM ocp WERocisstifolf/E15 Page 2 of roio-< uoc 16q0,3 e 0 EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00081181

Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger phri N 7NRocieatgfe)10/§815 Page 3 of IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 50 2009 CA 040800XXXKMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY I ED...

Case 9:08.cv_807agg3498mot 2rKali564rgerNeocp0F4lapiyocisstggy aig15 Page 4 of orrasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assaults included vaginal penetration. Epstein abused many of the girls dozens if not hundreds of times. Epstein Depo. at 109 ("...

Case 9:08-cv-807mAdv34198 .1mt 28,?).-cdpa ggergleodi0F4layoc ilistali2y3.015 Page 5 of 3. At all relevant times Edwards has had a good faith basis to conclude and did conclude2 that Epstein was able to access a large number of underage girls through a pyramid abuse scheme in which he paid undera...

Case 9:08-cv-807aeKte349mwt 28,:li alpeirger leocpcf4WhyoliVig204915 Page 6 of incident report, there is overwhelming proof that the number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 v. Epstein, (hereinafter Jane Doe 102 complaint) (...

Case 9:08-cv-80736-KAM Document 291-15 Entered ailed Docket 01121/21015 Page 7 of Case 09-34791-RBR Doc 16*3 Filed u4iusitt Page b Ot engage in lewd conduct in exchange for money. Based upon the investigation, the United States has identified forty (40) young women who can be characterized as ...

Case 9:08-cv-807a= 31:3gst....mt 2gA gi jnierNapif 4La iyolstggy2O1f/N15 Page 8 of 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 ejacu...

Case 9:08-cv-807ael<V32,8m 3pt 2n.-cl i6ci irger%cisiper4LaRyocisspine15 Page 9 of Exhibit "E"; Incident Report, Exhibit "A." 13. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that yet another girl Epstein sexually assault was A.H. When she was appro...

Case 9:08-cv-807pa-sIM -3 9imgW 1.16 .I645ereMigg umtRocIgg0elqcin15 Page 10 of 17 when Epstein abused them. See Rule 413 Notice, Exhibit E; Deposition of E.W., Deposition Attachment #4. 15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous underage girls coming into...

Case 9:08-cv-807attotAme 2Niall ogerrl eocroFaCAyocitaWW015 Page 11 of (Bill Clinton phone numbers listed under "Doug Bands"). Federal Investigation and Plea Agreement With Epstein 19. In approximately 2005, the FBI and the U.S. Attorney's Office in the Southern District of Florida learned of...

Case 9:08-cv-80722s-It/1-349vivot 28(25-c1f6aertocrAIRE9RocisstgSaRlaya5 Page 12 of preparing to serve Ms. Marcinkova with a target letter when the flight landed in Teterboro. Mr. Epstein then redirected his airplane, making the pilot file a new flight plan to travel to the US Virgin Islands inst...

Case 9:08-cv-80736-KAM Document 291-15 Entere_d on FL,a0P Docket 01/21/2015 Page 13 of Case 09-34791-RBR Doc 160463 Foe° 04/us/11 rage of au of the underage sex abuse victims). Those message pads show clear indication that Epstein's staff was frequently working to schedule multiple young girls b...

Case 9:08-ov-807_36-KAM.. .Document 291-15. Wered orLFLSD Docket 01/21/2015 Page 14 of Case 09-34791-KBK Uoc MO u4iuorl rage of 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....

Case 9:08-cv-807e=g34198Aeliit 2aLli60igtergieccipoya i yocgaRWIef2.12cp Page 15 of Edwards Agrees to Serve as Legal Counsel for Three Victims of Eostein's Sexual Assaults 31. In about April 2008, Bradley J. Edwards, Esq., was a licensed attorney in Florida, practicing as a sole practitioner. A...

Case 9:08-cv-80736-KAM Document 291-15_ igtered on_FLSD Docket 01/21=5 Page 16 of ease 09-34 uoc m0 Hiea urttuoil rage ro or .39 34. Edwards also requested from the U.S. Attorney's Office the information that they had collected regarding Epstein's sexual abuse of his clients. However, the U.S...

Case 9:08-cv-80736- KAM_ Document 291-15 Entered ortELSID Docket 01/21/21015 Page 17 of ease 09-S4/91-K16R UOC 1601463 Hien u4rubill Fage to 01 about a plea agreement and to confer with prosecutors regarding it. See id. 38. On July 11, 2008, Edwards took E.W. and L.M. with him to the hearing...

Case 9:08-cv-807agilMastifot 2glo-cliCer rlesinahRocisst9C41,q1c/a.5 Page 18 of 43. Because Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo or...

Case 9:08-cv-807_36-KMA .DocuncLent 291-15.. Wered on_FLSD Docket 01/21/2M5 Page 19 of ease 0s-34/91-M3K UOC ib0 Hiea u4ruidel vage MOT .J9 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 Ed...

Case 9:08-cv-807avm.4-3498mee 2N.ailowern eocr oF4RA?ostbgiawsp Page 20 of 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...

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 am...

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 als...

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 (Depositi...

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 poli...

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 obta...

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 ...

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 e...

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...

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 E...

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 le...

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 feder...

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 in...

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 ti...

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 Fac...

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 inv...

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 pros...

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 ...

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 ans...

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...

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...