EFTA01100849

To: Bradley 1 Edwards Subject: Please can is mall the dots Hi Brad, discussed. weekend. Please can you email the &cc we Hope you're reeling better and enjoying the Including all unsealed dots Many thanks, i miaua lacl(Beny from I -Mobile ll Sent via BlackBerry from 1 -Mobile Sent via BlackBerry from T-Mobile 02596 EFTA01100849 I torn: 10: Subject: NMI GOO 9140 RICOVERY!!!! 04 Date: Monday, august 31, 2009 10:5033 you forward Hi Brad, well on you r way to a God speed recovery! Please could Hope you are somehow deleted those emails!!!! the names of the girls in NY, I Mai' irks, m wrote: Aug 24, 2009 07:38:41 PM, link still does not allow . I actually forgot about it. If the orry it look me a couple days can get it from g you aN the information so that you ou to open il, then I am also givin . Let me know if you need Case number 00-80656 acer. It is Jane One 102 v. Epstein. that woul d be helpf ul. I am still you hear of anyt hing nything else from me and also it working on some things for you. in legtliacungswiaggyAgratifkall incerely, rad* J. Edwards artner Rothstein Rosenfeldt Adler! Attorneys at Law as Olas City Centre 01 East Los Olas Boulevard, Suite 1650 ort Lauderdale, FL 33301 facsimile 02895 EFTA01100850 from: Slibfa'atodelleotactI.LES Blflb To: Bradley J. icloueds Out Of Office Auto!Zen: FOS Subject: 1 AM Date: Tuesday. tub 28, 2009 8:59:4 ning Wednesday, July 29. I am currently out of the office, retur editor, Mary Hladky, at my absence, please contact my I! you need to speak to someone in time zone six hours behind Florida time. on my cell. I am in a Or if it is 100% urgent you can call me Thank you. 03070 EFTA01100851 Roan: waisr ae drat l To: Subject: PRIVATE 2. ONFICENTIA1 1:31:44 P.M Date: MonOay, SIP:OWe: ?I. 209 pieces of Hi grad, ing to pla ns. Jus t spo ke with Mike. Found a few Hope all is going accord info that might help you. Global Initiative e is registered at Clinton foundation under parent's nam thropic Fund ilan Elissa and Herbert Epstein Ph including a couple of family members working for that foundation are Mark Epstein Jill Epstein White (research) Debra Epstein (Dir of Finance) Bon voyage 03081 EFTA01100852 I Mori: to: atagyj Ediarcl Subject: Re: ? FM Vote: wediesnay, Otteber 1.1, 2OO19:01:0; Thanks Brad, good luck!!! Original Met;Sage Pr om Brad Edwards To: Sent: IA Oct :39 Subject: RE: ? not get it. I have a bunch of weeks ago, so I assume I did The last email I received from you was hom e. Take care. beach. I'll call you on my way Lpstein things today up in west palm From: . a c (mailtualipmal Sent: W. nee • y, . 4, 2009 S:. lo: Bradley J. Edwards Subject: ? lit Brad, previous email ? Hope you're feeling better. Did you nut receive my Best, Sent via BlackBerry from f -Mobile Sent via BlackBerry from T-Mobile 03189 EFTA01100853 Trot»: nr icaunatta To: Subject: RI: er 1.1, 2(P1 7:19:m Ni Date: Wetitte5417,1. Octob not get it. I have a bunch of was weeks ago, so I assume I did the last email I received from you home. Take Care. beach. I'll call you on my way Epstein things today up in west palm On inal Message From: (miltoggipal. Sent: %V ne ay„ 2009 5: To: Bradley J. Edwards Subject: ? Ili Brad, my previous email ? Mope you're feeling better. Did you not receive is at est Sent via Illackilerry from T-MobIle 03190 EFTA01100854 I rani: Edwrib ' OIL 2009 II:13:00 AM Date: TuctAay, 5rDtetrAter also be a problem I'm feelin g a little better, which you know can I haven't forgotten about anyth ing. e out this morning. That can do mere , and of course I busted a sutur number, the because you then think you ASAP. I found Evelyn's into work pers onall y, but I will get you things know s ever ythin g Marisa delayed me going very helpful. She that work ed for MC2 in NY. I think she will be dy told you this and that, then other lady on that Morisse alrea sketc hy. Also . ' knows but is much less number is she will give you more. Her and I heard it was Also. Epstein sent his is -I don't could n't risk In fact, I just calle d because he call you 4ncr. how to go abou t getti ng her, but know und telt a message for you. Brad -• Front: made AM Sent: Tuesday, September 0 I, 2009 10:47 To: Wadley 1 Edwa rds Subject: DOCS Ili Brad, the a reminder please not to forget to send me Hope you're feeling better this morning. Just does, thank you much as possible. even it' its on the floor! Don't sit down too long and try to lie down as place towel underneath you and lie down! :) 04015 EFTA01100855 Num: To: MEP Btace/Callos lisbaystn 3E Cc: TACTIC Roman pols-kski on0 Subject: IMPORTAK POTENTIAL MEDIA AM 8,09 .09 Date: Menlo, Scptenber 28, 2009 rges t for his arrest on cha iii Brad, ding pola nsk i's arre st in Zur ich based on a 7Os warran The media buzz surroun tein's case now!!!! old skid be leveraged in eps abuse children? that he bad sex with 13 year crea te a stir and a vigi l against men in power who bea ch can Maybe mother's in palm What are your thoughts? Warmly, e Sent via BlackBerry from T-Mobil 02913 EFTA01100856 From: eifteT-Lithatin To: Cirragfailaffna RE: hey Brad! 4, Mject: 10.00 PM Date: Tuesday, tune f19, )C09 Attachments: 1(0141: 0=21 een Epstein and the -pros ecuti on agreement (agreement betw FYI - The motion to unse al the non courtroom 11F. I know that Tim front of Judg e Colb ath tomorrow morning at 10.30 in government) is in Thanks and we would love that too. wanted to have you guys there Beadley..1. Edwards Partner rneys at Law Rothstein Roscnfeldt Adlert Atto Las Olas City Centre 1650 401 East Las Olas Boulevard, Suite Fort Lauderda le, EL 3330 1 facsimile From: Glasser, Eric (WPTV) [mato Sent: Tuesday, June 02, 2009 10:24 AM To: Bradley J. Edwards Subject: hey Brad! keep you posted. I .un working on getting you a copy. Peter OK'd it -- so I'll Email me the address you want it sent to, OK? lalk soon, Eric 06655 EFTA01100857 lam e; icax):33renairomeni Fr : Mike Fisten Sea • Se 3 28.2009 23:45:22 To: Cc: Bee: Subject: Note Ili posted as issues pleasant trip back North. keep you Just stopping by to say Hi, hope you had a d very you and your project this weekend. He seeme develop. Also I had a long talk with my agent about trafficking of children. The more I read the more interested. I have been reading a lot lately about ents ing dozens of girls on false immigration docum believe SE has been doing this for some time. Bring now? h the modeling agency. Where are all these girls from Eastern Europe, and Brazil to the US throug ago and no minutes caught on to this scheme 10 years Did they sell them? Someone in the news show 60 l, who's currently a partner in MC2, denied one stepped in to stop it "Karim Models founder Brune advantage of young models who were high on allegations in a 1997 ""60 Minutes"" segment that he look after complaints of night carousing, drugs. Bnmel also reportedly left his Trump Tower digs in 1999 d Marie is also involved with MC2, says which he also denied. Disgraced former Elite models exec Geral in a 1999 BBC documentary where our source. Marie was accused of having sex with underage models t in which the average age of he was filmed saying he hoped to seduce contestants in a modeling contes when she was "" participants was 15. He also dated Hope all is good, Mike Mike Fisten, Senior Intelligence Agent Rothstein Rosenfeld' Adler1 Attorneys at Law 401 East Las Ohs Boulevard, Suite 1260 Fort Lauderdale, Florida 33301 Telephone: Facsimile: Cellular: lik ll/CliDectanaills, 420und%20Sellinp/TrIalaksktupit ..teet loiVeDocskMad/MiteFiskne0233$^.2 MoilConleill.hien (1 of 2) RI/6O010 10.28:0$ PM) 19986 EFTA01100858 • 3.1S"chlmIConicni hint www.rra-law.com attachments hereto se note that the view s expressed herein or in any Plea IRS Circular 230 Disclosure: opin ion" " under applicable Treasury Regulations, and titute a ""re lian ce the purpose ate not intended to cons used , and may not be used or relied upon, for writ ten to be accordingly arc not intended or imposed by the Internal Revenue Service, or (ii) elat ed pen altie s that may be in. of (i) avoiding tax-r ther part y any tax-related matters addressed here reco mm end ing to ano promoting, marketing or IS ATTORNEY TIC E: ME INF OR MA TIO N CO NTAINED IN THIS TRANSMISSION THE NO D AND CO NFI DEN TIA L. IT IS INT ENDED ONLY FOR THE USE OF PRIVILEGE THE ITY NA ME D ABO VE. IF THE REA DER OF THIS MESSAGE IS NOT INDIVIDUAL OR ENT INATION, END ED REC IPIE NT, YOU ARE HER EBY NOTIFIED THAT ANY DISSEM INT IF YOU ION OR COP Y OF THI S CO MM UNI CATION IS STRICTLY PROHIBITED. DISTRIBUT EDIATELY ION IN ERROR, PLEASE NOTIFY US IMM [(AVE RECEIVED TITIS COMMUNICAT THANK MATERIAL FROM ANY COMPUTER. BY TELEPLIONE COLLECT AND DELETE THE YOU. Lk in(1/1krreunct:Is%2Oa.O%20Scilings/rtialfanklapilt ..utlian/CD0esiettagAtiktEisten002338^cMnile0tolt lam 12 of 2)111/V2010 0.2S,CIS 19987 EFTA01100859 From: WItraaafi To: Mad/ell Edwards Subject: Re: testae NAN Date: Wednesday, July 15, 2003 1:22:54 Pet worries. understand being short staffed. No No problem Brad. I totally complete as possib le and, of course , to have your voice in it since I just want to be the story as you propelled this whole process. Michele > wrote: Edwards" On 7/15/09 3:17 PM, "Bradley J. another lawyer in so I forwarded the instruction to I'm sorry Michele. My secretary is out, get it today, but like I said r secretary. I hope you the firm and it was delegated to anothe best to follow up and get you ise, so I will do my we are a person down right now staff-w the response. Bradley J Edwards Partner Law Rothstein Rosonfeldt Adlert Attorneys at Las Ohs City Centre 401 East Las Olas Boulevard. Suite 1650 rdale FL 33301 facsimile From: Michele Dorgan Sent: Wednesday, July 15, 2009 1 : To: Bradley J. Edwards Subject: Epstein filing Hi Brad, ow's paper and haven't I hate to be a pain, but I'm bumping up on deadline fur tomorr yet and I definite ly want to include your position in my received your e-mall filing story. your position in my if you can e-mall me that pleading soon, I will be able to include story. Thanks in advance, Michele Michele Dorgan, staff writer ea h Dail News phone ax 04905 EFTA01100860 I ruin: [gailyjistayacit To: tlitheir pamae RE: Epstein ring PM Date: Wednesday, NV 15, 2:X9 1:17:00 another lawyer in the firm and secre tary is out. so I forwarded the instruction to person down I'm sorry Michele. My y, but like I said we are a deleg ated to anot her secre tary. I hope you get it toda resp onse . it was get you the do my best to follow up and right now staff-wise, so I will Blarney J. litvards Partner Attorneys at Law Rothstein Rnsonfeldt Adler' Las Olas City Centre 1650 401 East Las Olas Boulevard. Suite Fort Lauderda le, FL 3330 1 facsimile From: Michele Dorgan [rnailto Sent: Wednesday, July 15, 20 To: Bradley ). Ldwards Subject: I pstein filing Hi Brad, n't received deadline for tomorrow's paper and have I hate to be a pain, but I'm bumping up on include your position In my story. your e-mail filing yet and I definitely want to story. will be able to include your position in my If you can e-mail me that pleading soon, I Thanks in advance, Michele •- Michele Dargati, staff writer Palm Bea Ddii News phone fax 04906 EFTA01100861 fetid') I rom: keelStL,EandeURIIIIIIELD*2.0th To: Bradley]. Edwards Subject: RE: iinsren Pr'. Date: friday. May 22. 2009 )2:21:43 10.4, Thank you. Susan Spencer-Wendel Courts Reporter Beach Post 0) 0 Original Message From: Bradley Edwards (ma' Sent: Fri 5/22/2009 12:13 PM (CNI-Palm Beach) To: Spencer Wendel, Susan Sut)ect: Epstein ecution agreement was released to the The case in which the Non-pros v. United States of America, victims and victim's attorneys Jane Doe is to prote ctive order which is why 1 08-80/36. It was released pursuant on agreement. nts of the Non -Pros ecuti cannot discuss the conte Bradley J. Frtwards Partner Rothstein Rosenfeld) Adel Attorneys at taw Las Olas City Centre 401 East I as Olas Boulevard, Suite 1650 Fort I auderdale, Ft. 33301 direct line facsimile caladtaaning 05148 EFTA01100862 rrom: tiliallebilebaY 159F191 To: Bradley 1. &Weds Subject: RE. Epsom Date: tresday, May 26, 2009 5:31:30 PM Tint good tomorrow if you are Have called your olfice,we're ta From: Bradley ). Edwards (man PM Soot: Tuesday, May 26, 2009 4:58 To: Malloy, Timo thy (WPT V) Subject: Epstein lit dim, se would be able to arrange for an interview tomorrow. Plea I was able to reach my client, and we contact me at your earliest chance. Bradley .1. Edwards Partner s at Law Rothstein Rosenfoldt Adler] Attorney Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 direct line facsimile 05151 EFTA01100863 ikni0 From: 5PPICCLIårSk.)-~Lek.Ft lo: Wadley ). tdwards Subject: RE: Cusick PM Date: I bursday. May28. 2009 2:13:11 Czar Mr. Edwards: give me a call? Would ou have a moment to Eli. she/you touch on the sealing repre sent inter viewed by Channel 5? And tid Was the young wom an you he beat to the punch. with 5? Pleas e advise .. as we at the Post do not want to issues Many thanks, Susan Spencer-Wendel Courts Reporter Palm Beach Post 0) r(O Original Message From: Bradley I. Edwards [MILO Sent: Fri 5/22/2009 12:13 PM -Palm Death) To: Spencer Wendel, Susan (CNI Subject: Epstein agreement was released to the The case in which the Non-prosecution Jane Doe v. United States of America, victims and victim's attorneys is relea sed purs uant to prote ctive order which is why 08-80736. R was Non- Pros ecuti on agreement. cannot discuss the contents of the Bradley 3. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre .401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 direct line facsimile <ma 05161 EFTA01100864 From: ruattlernatectis To: ache Daman Subject: RE: ecutein Date: Tuesday, :oat 23,200 1:l6:00 PM those does today. secretary and she wilt send you I sent the request to my Bradley J. Edwards Partner Attorneys at Law Rothstein Roseatekit Adler] Las Olas City Centre Suite 1650 401 East Las Otas Boulevard. Fort Lauder dale, FL 33301 • facsimile ---• - • _ • From: Michele Dargan [mat° PM Sent: Tuesday, June 23, 2009 1:11 To: Bradley J. Edward s Subject: Re: epstein Brad, Thanks for the link. I appreciate It! l - and the we talked about - your motion to unsea Also, would you e-mall those documents that attorne y docum ent that was filed on the Epstein Posts' atty if she has a separate one and also Friday. Thanks so much! Michele wrote: On 6/23/09 12:52 PM, "Bradley 1 Edwards" eieffrenengeirdle-releacrd-nrisnn-early film /Mom radaronline comfexclusives/20091.25LeXclusiv Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 Mile Michele Dargan, staff writer Palm Beach Daily News phone fax 05203 EFTA01100865 from: etteray.J—EdraVnlå &ChetD.1100.0 L.00jett: RE: epstein Date: Tuesday, June 23, 2M9 2:31:03 PP Does that media anything similar to the Radar report anywhere. I nave not seen anyone else report Radar got the info... curious how channel not share with others? I am pretty Bradley J. Edwards Partner Rothstein Rosenfeld( Adler! Attornoys at Law Las Obs City Centre 401 East I as Glas Boulevard. Suite 1650 'on Lauderdale. FL 33301 - facsimile From: Michele Dargan !mantel Sent: Tuesday, June 23, 2009 1.27 PM To: Bradley J. Edwards Subject: Re: epstein Thanks! On 6/23/09 1: lb PM, "Bradley 3. Edwards" wrote: I sent the request to my secretary and she will send you those does today Bradley J. Edwards Partner Rothstein Rosenfeld( Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale. FL 33301 facsimile From: Michele Dargan [ragjita Sent: Tuesday, June 23, 2009 1:11 PM To: Bradley 3. Edwards Subject: Re: epstein Brad, Thanks for the link. 1 appreciate itl Also, would you e-mail those documents that we talked about - your motion to unseat - and the Posts atLy if she has a separate one and also the Epstein attorney document that was tiled on Friday. thanks so much! Michele On 6/23/09 12:S2 PM, "Bradley 3. Edwards" c wrote: hitoliwww radaronline com/exclusivest2009/0 11X 05207 EFTA01100866 Bradley I Edwards Partner Law Rothstein Resent°Icit Adler' Attorneys at Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale. FL 33301 - facsimile mai < Michele Darwin, staff writer P !In each Dail News hone ax 05208 EFTA01100867 noun: CfStkaith I o: tltchdestamae Stohject: RE: epstein Data: Tuesday, June 23, 2000 5:21:0t) rA not them out today. but it may time to send the does. I hope she gets desp ite bein ga Unfortunately she has not had comm ent on It doesn't surprise me at all that he. ing to really when he is relea sed happen. There is noth also won't be a surprise being released early, and it you the does you registered sex offender, is the cour se with this case. I will try to gel notifi ed. Par for without the victims being want. See you 1hursday. Bradley .1 Edwards Partner Attorneys at Law Rothstein Rosenfeld( Adler' Las Olas Cily Cent re Suite 1650 401 East las Olas Boulevard. I atderdale, FL 33301 - facsimile From: Michele Dargan [math° PM Sent: Tuesday, June 23, 2009 4:37 To: Bradley J. Edw ards Subject: Re: epstein Brad, to me today? yet. Will she be able to forward them I haven't received those documents July 22 and 1 am citing about his release date. Found out It's Also, I am filing a story to the web . in the Bear Stearns case Radaronline about his involvment that he's getting released on July 22? Do you want to comment on the fact M al wrote: On 6/23/09 1:16 PM, "Bradley J. Edwards" you those does today. I sent the request to my secretary and she will send Bradley J. Edwards Partner Rothstein Rusenfoldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Fl. 33301 facsimile From: Michele Dargan Sent: Tuesday, June 23, 2009 1:1 To: Bradley J. Edwards Subject: Re: epstein ()rad, 05220 EFTA01100868 Thanks for the link. I appreciate it! to unseal - and the that we talked about - your motion Also, would you e-mail those documents Epstei n attorne y docum ent that was filed on also the Posts any if she has a separate one and Friday. Thanks so much! Michele ds" wrote: On 6/23/09 12:52 PM, "Bradley 3. Edwar dsiealesurisgmsaty. rikettha veS/2O 249/Of g•xclisive:iellrey_lt • 11.1112:Thecaw radarentheSO Bradley .1. Edwards Panne' Rothstein Rosenfoicit Adler; Attorneys at Law Las Olas City Cantle 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale. FL 33301 - facsimile Michele Dargan, staff writer Palm Beach Dail/)News hone ax 05221 EFTA01100869 Dent: :luta I Edwards To: MireIto/Lean subject: erate.n am Date: Wednesday, Juni, 24, 2009 9:14410 M 20.02a 2Z001=043430311 blIPSWW,b.U.Sitle,SS.WegESengl2WdallaabalLCAPIIISSUI investor from a sauce other 2007 already naming Epstein as the mysterious This was a story from share. than Radar. Just thought rd Bradley J. Edwards Partner Attorneys at Law Rothstein Resent°Idt Adlert Las Olas City Centre 1650 401 East Las Olas Boulevard. Suite Fort Lauderdale, I-1 33301 - facsimile • --- From: MIchc4e Dargan (mailto Sent: Tuesday, June 23, 2009 4:37 PM To: Bradley 3. Edwards Subject: Re: epstein Brad, she be able to forward them to me today? I haven't received those documents yet. Will date. Found out it's July 22 and I am citing Also, I am tiling a story to Ow web about his release s case. Radarunime about his invelyntent in the Bear Stearn released on July 22? Do you want to comment on the fact that he's getting M wrote: On 6/23/09 1:16 PM, "Bradley J. Edwards" dues today. I sent the request to my secretary and she will send you those Bradley J. Edwards Partner Rothstein Rosenfoldt Adler' Attorneys at Law Las Oias City Centre 401 East Las Olus Boulevard, Suite 1650 Foil Lauderdale, FL 33301 facsimile <Jn011ea From: Michele Dargan (Ma Sent: Tuesday, June 23, 2009 1:11 PM To: Bradley J. Edwards Subject: Re: epstein Brad, Thanks for the link. I appreciate it! 05224 EFTA01100870 the your motion to unseal - and you e-m ail those docu men ts that we talked about - men t that was filed on Also, would attorney docu one and also the Epstein Posts' DUN if she has a separate friday. Thanks so much! Michele wrote: J. Edwards" On 6/23/09 12:S2 PM, "Bradley • :LeilealethWisotteallY anad a020 lilleS t2M& XCIU SIM. 020=6LeXCiuSilte:atiCe.V.: MULliVed Bradley .1. Edwards Panne: s at Law Rothstein Rosenfoldt Adler' Attorney Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale. FL 33301 facsimile Michele Dargan, staff writer nil News phone fax 05225 EFTA01100871 (sons: Micfrele_04tailfi To: Bradley S. Edwards Subject: Re: ensteln Date: Tuesday, June 73, 7(109 1:13:17 PM Brad, Thanks for the link. I appreciate it! unseal - and the that we talked about - your motion to Also, would you e-mail those documents attorne y docum ent that was filed on also the Epstein Posts' atty if she has a separate one and Friday. Thanks so much! Michele wrote: On 6/23/09 12:52 PM, "Bradley J. Edwards' eipapi karyedelfrey-enstoky be- released- htto.liwww.radaronline comlexclusiyeaMyt missal:tea. Bradley J. Edwards Partner Rothstein Rosenfeldt Adlerl Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile Michele Darwin, staff writer Palm Reach Daily News phone fax 05239 EFTA01100872 Flom: MeChi* Dargao To: Wadley 1. Ede/aids Subject: Re: (cute., Date: Tuesday. lone 73, 7009 I:29:20 eet Thanks! wrote: Edwards" •ca' On 6/23/09 1:16 PM, "Bradley J. today. and she will send you those does I sent the request to my secretary Bradley J. Fdwards Partner ys at Law Rothstein Rosenfeld( Adler' Attorne Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, VI. 33301 From: Michele Dargan prtaiitcl Sent: Tuesday, June 23, 2009 1:11 PM To: Bradley 3. Edwards Subject: Re: epstein Brad, Thanks for the link. I appreciate it! we talked about - your motion to Also, would you e-mall those documents that if she has a separa te one and also the Epstein attorney unseal and the Posts atty document that was filed on Friday. Thanks so much! Michele > wrote: On 6/23/09 12:52 PM, "Bradley J. Edwards" 09/.06/exclusive-j •m- • leasg.d.. Prison-early Bradley J. Edwards Partner Rothstein Rosenfeld( Adler' Attorneys al Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, Ft. 33301 facsimile ma„,„7- O5277 EFTA01100873 •- Michele Dargan, staff writer it News hone ax 05278 EFTA01100874 From: MILNICRablaa To: Wadley 1 Ectogetls Subject: Re: epstein Date: Tuesday, June 23,2009 2:4r.42 PM rd Newspapers have a higher standa noticed that Radar is the only one to report that info. have to confirm that the info I also generally, bloggers etc. and newspapers, I've been making than online publications and a s0urce ....Beli eve me, be able to cite Radar as is in fact true. However, we may calls trying to verify the Info. umpteen Edwards" ja , wrote: On 6/23/09 7:31 PM, "Bradley J. anywhere. Does anything similar to the Radar report I have not seen anyone else report curious how Radar got the into... others? I am pretty that media channel not share with Bradley J. Edwards Partner Law Rothstein Rosonteklt Adler' Attorneys at Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, FL 33301 - facsimile --•.-• •--• From: Michele Dargan [matt Sent: Tuesday, June 23, 2009 1:21 PM To: Bradley J. Edwards Subject: Re: epstein Thanks! On 6/23/09 1:16 PM, "Bradley J. Edwards" a> wrote: I sent the reques t to my secreta ry and she will send you those dots today. Bradley J. Edwards Partner Rothstein Rosenfoldt AcIlerl Attorneys at Law Las Otns City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile smaS From: Muchete Dar an lit smadt Sent: Tuesday, June 23, 2009 1:11 P To: Bradley J. Edwards Subject: Re: epstein 05324 EFTA01100875 Brad, thanks for the link. I appreciate it! we talked about - your motion to Also, would you e-mail those documents that n y separate one and also the Epstei attorne unseal - and the Posts' atty if she has a document that was filed on Friday . Thanks so much! Michele ds' MEIR. wrote: On 6/23/09 12:52 PM, "Bradley J. Edwar -released- ntizag amijat conye itclung sall09 106f ' ray-engem- htipavi prison-early Bradley J. Edwards Partner Rothstein Rosenfoldt Adler] Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 FL 33301 facsimile <tnai!t0' Michele Dargan, staff writer Palm Beach Dally News phone fax 05325 EFTA01100876 From: athejekty03 To: Wadley ;. Etheards subject: Re: epstein Date: Tuesday, Tune 73, 7009 4:39:33 PM lit ad, d them to me today' receive d those docum ents yet. Will she be able to forwar I haven 't am citing Found out it's July 22 and I web about his release date. Also, I am filing a story to the in the Clear Stearns case. Radaronline about his involvment July 22? fact that he's getting released on Do you want to comment on the M On 6/23/09 1:16 I'M, "Bradley J. Edward s- <I wrote: will send you those does today. sent lite request to my secretary and she Bradley .1. Edwards Partner Rothstein Rosenfehlt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 le FL 33301 facsimile Snail] --• From: Michele Dargan [maS Sent: I uesday, June 23, 2009 1:11 PM To: Bradkiy 1 Edwards Subject: Re: epstein Brad, Thanks for the link. I appreciate it! - your motion to Also, would you e-mail those documents that we talked about atty if she has a separa te one and also the Epstein attorney unseal - and the Posts' document that was filed on Friday. Thanks so much; Michele wrote: On 6/23/09 12:52 PM, "Bradley 1. Edwards" e e-lenfe Y-09.51 011-be -relnaS eLE BgplAvww radnionhneththyps 12009AlliekcIUSN orison-earl% Bradloy J. Edwards Partner Rothstein Rosonteldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fret Lauderdale FL 33301 facsimile 05368 EFTA01100877 berlwards@rra-law.com <mailisd Michele Dorgan, staff writer r• I with Dail News gione DX 05369 EFTA01100878 Front: laILLI4ltI2Z0a2 To: D:adley a. Edwal:15 Subject: 041 40cleln Elate: 'Tuesday, lune 23, ?MO S:28:53 FM two as for now, t will run Thanks so much. purs ue the Bear Stea rns angle tomorrow. But, at I am 000 to continue to the web within the hour source. It should be up on graphs citing Radar as the www.palmbeachdadynews.com a- wrote: dley 3. Edwards" On 6/23/09 5:22 PM, "Bra y. hope she gels than out toda lime to send the does. I Unfortunately she has not had on. It does n't surp rise me at is nothing to really comment but it may not happen. There relea sed early , and it also sex offender, is being all that he, despite being a registered ied. Par for the he is relea sed without the victims being notif won't be a surprise when , See you Thursday. to get you the dots you want course with this case. I wilt try Bradley J. Edwards Partner Attorneys at Law Rothstein Rosenfeldt Adler' Las Olas City Cent re 1650 401 East Las Olas Boulevard. Suite Fort Lauderda le, FL 3330 1 facsimile From: Michele Dargan Sent: Tuesday, June 23, 2009 : To: Bradley J. Edwards Subject: Re: epstein Brad, me Will she be able to forward them to I haven't received those documents yet. today? 22 and t his release date. Found out it's July Also, I am filing a story to the web abou Bear Stea rns case . lvme nt in the 1 am citing Radarontine about his invo getting released on July 22? Do you want to comment on the fact that he's wrote: On 6/23/09 I:16 PM, "Bradley J. Edwards" to ay. she will send you those does I sent the request to my secretary and Bradley J. Edwards Partner Rothstein Rosenfoldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 FL 33301 05387 EFTA01100879 - facsimile bedwardsetirra-law.com cjvjll •- •-- .•_ •-• -• •-. - • From: i cmailt0' PM Sent: Tuesday, June To: Bradley J. Edwards Subject: Re: epstein Brad, Thanks (or the link. I appreciate it! motion to ents that we talked about - your Also, would you e-mail those docum and also the Epstei n attorney a separate one unseal - and the Posts' atty if she has document that was filed on Friday. Thanks so much! Michele > wrote: On 6/23/09 t2:52 PM, "Bradley J. Edwards" e rev :nAmi ci. - released- lusives t7009/0 6/exclu sive li tplAvww rartmonlina.com/exc prisenready Wadley J. Edwards Partner Rothstein Rosenfeld) Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, Fl. 33301 - facsimile «nailtoS Michele Dargan, staff writer Palm Beach Daily News phone fax 05388 EFTA01100880 From: raft,/ I.:award& To: Michele clarao Subject: Epstein applicalk statutes Date: Friday, September 18, 2009 2:55:00 PM Attachments: ianciattli Imoc.922,a would add some amount of time. . and convictions of conspiracy I did not pull the conspiracy version helps. how much I don't know. I hope this I cut the statutes straight from Westtaw. 18 § 2422 thesa United States Cude Annotated Chhen Title 18. Crimes and Crimin al Proced ure (Refs & Annos1 Earl!. Crimes ads & Annos.1 f 'trig Sexual Activity and Related Crimes Chapter 117. Transportation for Illegal &MOS) § 2422. Coercion and enticement in s, entices, or coerces any individual to travel (a) Whoever knowingly persuades, induce ssion of the United State sitto ry or Posse interstate or foreign commerce, or in any Territo prosti tution , or in any sexua l activit y for which any person can be charged with engage in he fined under this title or imprisoned not a criminal offense, or attempts to do so, shall more than 20 years, or both. of Interstate or foreign commerce, (b) Whoever, using the mail or any facility or means of the United States knowingly or within the special maritime and territorial jurisdiction who has not attained the age of 18 persuades, induces, entices, or coerces any individual l activit y for which any person can be years, to engage In prostitution or any sexua shall be fined under this title and charged with a criminal offense, or attempts to do so, imprisoned not less than 10 years or for life 18 U.S.C.A. § 2423 United States Code Annotated Currentnects. Titre 18. Crimes and Criminal Procedure (Bets & Annoc) Part 1. Crimes :Ref% & tagup Related Crimes (Refs Pt Chanter 117. Transportation for Illegal Sexual Activity and ARCM) § 2423. Transportation of minors ty.- -A person who (a) Transportation with intent to engage in criminal sexual activi knowingly transports an individ ual who has not attaine d the age of 18 years in interstate or foreign commerce, or in any commonwealth, territory or possession of the United e in prosti tution , or in any sexua l activity for States, with intent that the individual engag title which any person can he charged with a criminal offense, shall be fined under this and imprisoned notJs than JO years or for life. (b) Travel with intent to engage in illicit sexual conduct.--A person who travels in citizen or an interstate commerce or travels into the United States, or a United States 01280 EFTA01100881 ign es who travels in fore for perm anen t residence in the United Stat with anot her person alien adm itted any illicit sexual cond uct ose of enga ging in . commerce, for the purp morg_than 3a mass, or both title or inionsttned not_ shall be lined under this States citizen or con duc t in fore ign places. --Any United in (c) Engaging in illicit sex ual commerce, and engages for perm anen t resid ence who travels in foreign title or impr ison ed alien admitted under this another person shall be fined any illicit sexual conduct with both. not more than 30 years, or ate mercial advantage or priv illar y offe nse s. --Wh oeve r. for the purpose of com pers on know ing (d) Anc the travel of a ces, procures, or facilitates iinanciat gain, arranges, indu mer ce or foreign commerce for the ling in interstate com that such a person is trave under this title, imprisoned not sexual conduct shall be fined purpose of engaging in illicit . more than 30 years, or both to violate subsection (a). hoever atteinatS or consoires (e) Attempt and conspiracy.--W d violation of that same manner as a complete (dl shall be punishable in the cut/SIX-OM al conduct" means (1) a this section, the term illicit sexu (f) Definition.--As used in r 18 years of age that would be act (as defin ed in sect ion 2246) with a person unde sexu al special maritime and the sexual act occurred in the in violation of chapter 109A if cial sex act (as defined in ed States; or (2) any commer territorial jurisdiction of the Unit r 18 years of age. section 1591) with a person unde al conduct as r this section based on illicit sexu (g) Defense.--In a prosecution unde defe ndan t mus t establish by a defense, which the defined in subsection (f)(2), it is a that the person defendant reasonably believed preponderance of the evidence, that the had atta ined the age of 18 the commercial sex act with whom the defendant engaged in years. 18 U.S.C.A. § 1591 ess United States Code Annotated C.Urtattn e fs8Arms) Title 18. Crimes and Criminal Procedur (ile Crimes (fief s 8i Anno 5.1 ns) and Trafficking in Persons fliefs_ection alaULer 71. Peonage, Slavery, coe rcio n or by force, fraud, or § 1591. Sex trafficking of children (a) Whoever knowingly -- ce, or within the special maritime and (1) in or affecting interstate or foreign commer provides, es, recruits, entices, harbors, transports, territorial jurisdiction of the United Stat on; or obtains, or maintains by any means a pers of value, from participation in a venture (2) benefits, financially or by receiving anything tion of paragraph (1), which has engaged in an act described in viola d, that means of force, threats of force, frau knowing, or in reckless disregard of the fact, be used to any combination of such means will coercion described in subsection (e)(2), or pers on has not attained sex act, or that the cause the person to engage in a commercial 18 year s and will be caus ed to enga ge in a commercial sex act, shall be the age of punished as provided in subsection (b). 01281 EFTA01100882 e under subsection (a) is-- (b) The punishment for an offens or coercion of force, threats of force, fraud, (1) ii the offense was effected by means combination of such means, or if the person any described in subsection (e)(2), or by ttainolthe ane provided, or obtained had not_a recruited, enticed, harbored, transported, fine under this title and anur janfl e, by a au 4 years at the time of such offens life; or any_term of years not Ipso than 15 or for harbored, the person recruited, enticed, (2) if the offense was not so effected, and ed attained the ace of 14 years butlat IBA attain transported, provided, or obtained bad fine under this title, and riffense_by e the ane of AS years at the time of such anorispnmen t for natie sstha allYe ariar for (a)(1) in which the defendant had a reasonable (c) In a prosecution under subsection enticed, harbored, transported, provided, opportunity to observe the person so recruited, the nment need not Drove that the defendant knew that obtained or maintained, the Gover . 'lesson had not attained the age of 18 years nts ct, or in any way interferes with or preve (d) Whoever obstructs, attempts to obstru title, impris oned for a term not fined under this the enforcement of this section, shall be to exceed 20 years, or both. (e) In this section: law or legal process" means the use or (1) The term "abuse or threatened abuse of in any whether administrative, civil, or criminal, threatened use of a law or legal process, design ed, In order to exert pressu re not manner or for any purpose for which the law was from taking some some action or refrain on another person to cause that person to take action. (2) The term "coercion" means-- t any person; (A) threats of serious harm to or physical restraint agains to believe that failure to (B) any scheme, plan, or pattern intended to cause a person int against any person; perform an act would result in serious harm to or physical restra or s. (C) the abuse or threatened abuse of law or the legal proces account of which anything of (3) The term "commercial sex act" means any sex act, on value is given to or received by any person. or nonphysical, including (4) The term "serious harm" means any harm, whether physical that is suffici ently seriou s, under all the psychological, financial, or reputational harm, s, to compe l a reason able person of the same background and in surrounding circumstance sexual activity perfor ming comm ercial the same circumstances to perform or to continue in order to avoid Incurring that harm. associated in fact, (5) The term "venture" means any group of two or more Individuals whether or not a legal entity. S r iscri to the list of offenses Twelfth, Section 206 of the Adam Walsh Act added 8 II lf71fAl. The for which a defendant is to be sentenced to life under 1.8.11..W-3552(e t offens es of convic tions that are amendment adds 18 U.S.C. 1591 to the list of instan 01282 EFTA01100883 r § 451.5. covered sex crimes unde & Annos, 18 U.S.C.A. USSG, Ch. TWO, Pt. A, Refs Currentness. United States Code Annotated eline s Federal Sentencing Guid Chapter Two. Offense Conduct the Person Part A. Offenses Against Offenses Related to Registra tion as a Sex Offender inal Sex ual Abus e and 3. Crim HISTORICAL NOTES 2007 Amendments ing by adding at the end Three, is amended In the head Chapter Two, Part A, Subpart OFF END ERTM. REGISTRATION AS A SEX "AND OFFENSES RELATED TO Child Protection ent: This ame ndm ent responds to the Adam Walsh Reason for Ame ndm -248, which contained a of 200 6 (the "Adam Walsh Act"), Pub.L. 109 and Safe ty Act enhanced penalties for ted new sexual offenses, and directive to the Commission, crea ent implements the dire ctive by creating two new ses. The ame ndm existing sexu al offen to Registration as a ual Abuse and Offenses Related guidelines, §§ 2A3.5 (Criminal Sex istra tion as a Sex ted Offenses Relating to Reg Sex Offender) and 2A3.6 (Aggrava the Ada m Wals h Act by making vant provisions in Offender). It further addresses rele and Part G (Offenses Subpart 3 (Criminal Sexual Abuse) changes to Chapter Two, Part A, rs, and Obs cenity), § 211.2 Sexual Exploitation of Mino Involving Commercial Sex Acts, ely Rela ted Cou nts), § 481.5 (Repeat and (Groups of Clos (Obstruction of Justice), § 301.2 ation ), § 501.2 Minors), § 551.3 (Conditions of Prob Dangerous Sex Offender Against ervis ed Rele ase) and Appendix (Conditions of Sup (Term of Supervised Release), § 501.3 A (Statutory Index). 6-). to add a new sh Act amended IR 11 S.0 2741 First, section 206 of the Adam Wal 30 year s for offen ses rela ted to the ment of mandatory minimum term of imprison child betw een 12 and 16 under 12 years old, or of a aggravated sexual abuse of a child resp onse to the new mandatory ns was used. In years old if force, threat, or other mea l at § 2A3.1 ent increases the base offense leve minimum for these offenses, the amendm leve l 30 to level mit Criminal Sexual Abuse) from (Criminal Sexual Abuse; Attempt to Com othe r offen ses. At leas t one been retained for all 38. The base offense level of 30 has ictio n und er .18 U S.C. 224 1(cI y conv specific offense characteristic applied to ever m 360 d unde r § 2A3 .1 in fisca l year 200 6. Accordingly, the mandatory minimu sentence ever y case with a base be reached or exceeded In months' imprisonment is expected to offense level of 38. specific on note that precludes application of the The amendment provides a new applicati ribed in JR U.S C. 224 1/al rding conduct desc offense characteristic at § 2A3.1(b)(1) rega ictio n und er 1,5 U.S. C.. 224 1(r). is that s for a conv or 011 if the conduct that forms the basi e, thre at, or ribed In 18 U.S.C. 2241fal or 04 (forc the defendant engaged in conduct desc offen se ludes application of the specific other means). The amendment also prec icted age of a victi m at § 2A3.1(b)(2) if the defendant was conv characteristic for the se leve l of 38 take s into acco unt the age offen under section 2241(c). The heightened base avoid unwarranted double counting. of the victim. These instructions, therefore, term of increased the statutory maximum Second, section 207 of the Adam Walsh Act years to 15 years for the sexual abuse of a 5 Imprisonment under 18 ll.Ss.C. 2243(b1 from alty, l ority. In response to increased pen person in official detention or under custodia auth 01283 EFTA01100884 in § 2A3.3 (Criminal ses the base offense level from 12 to 14 the amend ment increa amendment also adds a pt to Commit Such Acts). The elsewhere in the Sexual Abuse of a Ward or Attem define d tent with how this term is new definition of "minor" consis includ es an applic ation note precluding amendment guidelines manual. In addition, the for these of Trust or Use of Special Skill) application of § 3B1.3 (Abuse of Position in all such cases and, therefore, n of trust is assumed offenses because an abuse of positio is built into the base offense level. 18 U S.C. 7244. Act created a new subsection at Third, section 206 of the Adam Walsh l conduct would y of any term of years if the sexua Section 2244(a)(5) provides a penalt Sectio n 2241(c) the contact been a sexual act. have violated 1$__U„S.0 2241(c1 had under 12 years old or of a child abuse of a child conduct involves the aggravated sexual define d in 1./ threat, or other means was used, as between 12 and 16 years old if force, penalty for offens es involving U.S C 2241O1 and Prior to the Adam Walsh Act, the penalt y for otherwise provided," and the children under 12 years old was "twice that 18 LI S.C. 2241 was a statutory maximum ing behav ior descri bed in sexual contact involv term of imprisonment of 10 years. level in by increasing the minimum offense The amendment addresses this new offense or Attempt of § 2A3.4 (Abusive Sexual Contact the age enhancement In subsection (b)(1) level 20 to level 22. to Commit Abusive Sexual Contact) from created a new offense under 18 U.S C Fourth, section 141 of the Adam Walsh Act offend er. The basic offense carries a statutory 22Sffial for the failure to register as a sex Section 141 also included a directive to the maximum term of imprisonment of 10 years. the offense, to consider, among other Commission that when promulgating guidelines for conviction that gave rise to the requirement factors, the seriousness of the sex offender's during the period for which the defendant to register; relevant further offense conduct failed to register; and the offender's criminal history. e to Register as a Sex Offender), The amendment creates a new guideline, § 2A3.5 (Failur es three alternative base offense levels to address the directive. The new guideline provid if the defendant was required based on the tiered category of the sex offender: level 16 level 14 if the defend ant was required to register as a to register as a Tier III offender; ed to register as a Tier I Tier II offender; and level 12 If the defendant was requir offender. ics. First, subsection (b)(1) The amendment also provides two specific offense characterist t to addre ss crimin al condu ct comm itted while the defendant provides a tiered enhancemen provid es a six-level increase if, Is in a failure to register status. Specifically, § 2A3.5(b)(1) e against an the defend ant comm itted a sex offens while in a failure to register status, t a minor, e agains adult, a six -level Increase if the defendant committed a felony offens a minor. itted a sex offens e agains t and an eight•level increase If the defendant comm arily a three-leve l decrea se if the defen dant volunt Second, § 2A3.5(b)(2) provides nted er but was preve corrected the failure to register or voluntarily attempted to regist bute to and the defen dant did nut contri from registering by uncontrollable circumstances, stance s. The reduc tion covers cases in which (1) the the creation of those drcum the relevant registration period defendant either does not attempt to register until after has expired but subsequently successfully registers, thereb y correcting the failure to register status, or (2) the defendant, either before or after the registration period has to registe r but circum stance s beyon d the defendant's control expired, attempted prevented the defendant from successfully registering. An applic ation note specifies that or to correc t the failure to regist er must have occurred the voluntary attempt to register jurisdiction had prior to the time the defendant knew or reasonably should have known a es that the reduction does detected the failure to register. The application note also provid one of the enum erated offens es in § not apply if the enhancement for committing 2A3.5(b)(1) applies. 01284 EFTA01100885 that are considered 2A3.5 to the list of offenses Additionally, the amendment adds § is an ongoing and the failure to register offense groupable under § 3D1.2(d) because continuous offense. offenses relating to Act created two new aggravated Fifth, section 141 of the Adam Walsh S.c. ?250(r], n 141 of the Act created 18 u the registration as a sex offender. Sectio 5 years and a statutory term of imprisonment of which carries a mandatory minimum comm its a crime of violence years if a defendant maximum term of imprisonment of 30 to the the sentence to be consecutive while in a failure to register status, with n 702 of the Adam Walsh Act regist er. Sectio punishment provided for the failure to ission of various that prohibits the comm created a new offense at 1811 S C 2260A . 'I he penal ty for this offense is a register status enumerated offenses while in a failure to to be imposed consecutively to the mandatory term of imprisonment of 10 years underlying offense. to at § 2A3.6 (Aggravated Offenses Relating The amendment creates a new guideline new offenses. The new guidel ine Registration as a Sex Offender) to address these um under sectio n 2250( c), the guideline sentence is the minim provides that for offenses , the e, and for offenses under section 2260A term of imprisonment required by statut of impris onme nt required by statute. Chapters Three and guideline sentence Is the term that how the guidelines treat other offenses Four are not to apply. This is consistent with emen t that such term be nt and a requir carry both a specified term of imprisonme dure for Determining Offense Level on Imposed consecutively. See §§ 3D1.1 (Proce le Counts of Conviction). Multiple Counts) and 5G1.2 (Sentencing on Multip provides an upward departure stating that The guideline includes en application note that by section 2250(c) is an upward departure a sentence above the minimum term required be warranted, for example, in a from the guideline sentence. An upward departure may minor or if the offense resulted in case involving a sex offense committed against a serious bodily injury to a minor. mandatory minimum term of Sixth, section 208 of the Adam Walsh Act added a new 1591( 51(11 for sex trafficking of an adult by imprisonment of 15 years under 18 it S.C. se, the amend ment provid es a new base offense level force, fraud, or coercion. In respon Prohibited Sexual Conduct with an of 34 in § 2G1.1 (Promoting a Commercial Sex Act or of convic tion is 18 U.S.C. 1591.0)(1), but Individual Other than a Minor) if the offense for all other offens es. In addition, the amendment limits retains a base offense level of 14 2G1.1(b)(1) that applies if the application of the specific offense characteristic at § offense involved fraud or coercion only to those offens es receiving a base offense level of involve fraud and coercion and, 14. Offenses under 18 U S.C. 1591(b)(11 necessarily offense level of 34. This therefore, such conduct is built into the heightened base limitation thus avoids unwarranted double counting. atory minimum term of Seventh, section 208 of the Adam Walsh Act added a new mand sex traffic king of children under imprisonment of 15 years under J8 LI.S.0 15911b1(1) for minim um term of impris onment of 10 years 14 years of age and added a new mandatory ory maxim um term of impris onme nt from 40 years to life under and increased the statut ed the age of 14 years JS U S C. 1591161(21 for sex trafficking of children who had attain r, the Adam Walsh Act increa sed the but had not attained the age of 18 years. Furthe increa sed the term of impris onme nt from S years to 10 years and mandatory minimum 18 11.S C years to life under both statutory maximum term of imprisonment from 30 age of 18 years g any person who has not attain ed the 74771bl for persuading or enticin can be charg ed with person to engage in prostitution or any sexual activity for which any not attain ed transp orting a person who has a criminal offense, and IR U,SC 2473Cal, for person in interst ate or foreign comm erce, with the intent that the the age of 18 years can be charged with engage in prostitution, or in any sexual activity for which any person 01285 EFTA01100886 a criminal offense. levels in § 2G1.3 es alternative base offense in response, the amendment provid Condu ct with a Minor; Prohibited Sexual (Promoting a Commercial Sex Act or ercial Sex Act or Prohib ited Sexual Conduct; in a Comm Transportation of Minors to Engage Condu ct with a Minor; Sex Act or Prohibited Sexual Travel to Engage in Commercial Sex port Inform ation about a Minor) Facilities to Trans Trafficking of Children; Use of Interstate convic tion. For the conduct described in that based on the statute of conviction and 34. For convic tions the base offense level is convictions under j8 U S.C. 1591f tiff 11, offense level Is 30. under 1$ U.S.0 1591(h)(71, the base under la offense level of 28 for convictions The amendment further provides a base use of a comp uter at § enhancement for the U.S.C. 2427(b). and 2471(a1. The two-level ted under 1ILU.S .c,_24 22(b1 and offenders convic 261.3(b)(3) applied to 95 percent of enhan cemen t for 2006. In addition, the two-level sentenced under § 2G1.3 in fiscal year (b)(4) applie d to 95 perce nt sexual contact at § 2G1.3 the offense involving a sexual act or ced under this guidel ine In 2473/al and senten of offenders convicted under 18 U S.C. term of With applic ation of either enhancement, the mandatory minimum fiscal year 2006. tions under 111 in the majority of convic imprisonment of 120 months will be reached 24231 a) before applic ation of other guidelines adjustments. U.S C. 7472(h1. and ction of two specific offense characteristics Further, the amendment addresses the intera conviction under 18 U S.0 1591 with the alternative base offense levels. First, every the base offense levels being determined necessarily Involves a commercial sex act. With s that § 2G1.3(b)(4)(B), which ment clarifie based on the statute of conviction, the amend ed a commercial sex act, does not provides a two-level enhancement if the offense involv . 1591 Second, the amendment apply if the defendant Is convicted under 18 U.S.C t in § 2G1.3(b)(5) if the base offense level is precludes application of the age enhancemen a conviction under louse- determined under subsection (a)(1) of § 2G1.3 for ction (a)(1) of § 2G1.3 takes into 1591(13)(1). The base offense level provided by subse ore, limitat ions on application of subsections account the age of the victim and, theref avoid unwar ranted double counting. (b)(4)(8) and (b)(5) of § 2G1.3 new section, 18 U.S.0 7S7A Eighth, section 503 of the Adam Walsh Act created a ction of any book, magazine, adopting new recordkeeping obligations for the produ that contai ns a visual depiction of simulated periodical, film, videotape, or digital Image sexually explicit condu ct. Sectio n 2257A has a statut ory maximum of one year g requirements and a imprisonment for the failure to comply with the recordkeepin nt of five years if the violation was to conceal a statutory maximum term of imprisonme e in sexually explicit substantive offense that involves either causing a minor to engag ion or traffic king in material involving conduct for the purpose of producing a visual depict S C 7757 which Is . The new offens e is simila r to 18 U the sexual exploitation of a minor of Sexually Produ ction referenced to § 2G2.5 (Recordkeeping Offenses Involving the Mail). in Comm ercial Electr onic Explicit Materials; Failure to Provide Required Marks Accordingly, the amendment refers the new offens e to § 2G2.5 . in 18 ll S.C. 2257A(01 Ninth, section 701 of the Adam Walsh Act created a new offense exploi tation enterp rises, define d as violating is ti s r that prohibits engaging in child ving a minor victim), chapter 1,591, 1701 (if the victim is a minor), chapter 109A (Invol ing a minor victim), as 110 (except forja 11 S C. 2257 and .7757A), or chapte 117 (involv r consti tuting three or more separa te incidents and part of a series of felony violations one victim , and comm itting those offens es in conce rt with three or Involving more than minim um term of imprisonment of more other people. The statute provides a mandatory 20 years. rises) to The amendment creates a new guideline at § 2G2.6 (Child Exploitation Enterp ine provid es a base offens e level of 35 and four specific cover this new offense. The guidel 01286 EFTA01100887 typically will involve charac teristic s. The Comm ission anticipates these offenses offens e s, resulting in an the specific offense characteristic conduct encompassing at least one of of imprisonment of the mandatory minimum term offense level of at least level 37. Thus, before applic ation of other reached or exceeded, 740 months typically is expected to be guideline adjustments. term of increased the statutory maximum Tenth, section 206 of the Adam Walsh Act for knowi ngly using a under 18 Q S.C. 2,528(b1 imprisonment from 4 years to 10 years minor into viewin g mater ial harmful to deceive a misleading domain name with the intent sectio n,11 n 703 of the Act created a new to minors on the Internet. In addition, sectio 10 years for um term of imprisonment of 7752C, that carries a statutory maxim code of a Web site with the s into the source knowingly embedding words or digital image tuting obsce nity. Sectio n 2252C (b) ial consti intent to deceive a person into viewing mater ngly embe dding nt of 20 years for knowi carries a statutory maximum term of imprisonme the source code of a Web site with the Intent to deceive a words or digital images into the Internet. minor Into viewing material harmful to minors on expands the scope of subsection (b)(2) In response to the new offense, the amendment ne Matter; Transferring Obscene el § 2G3.1 (Importing, Mailing, or Transporting Obsce to this enhancement "embedded in Name s) by adding Matter to a Minor; Misleading Doma Web site." words or digital images into the source code on a a new provision in JR USX. 1001 Eleventh, section 141 of the Adam Walsh Act added nt of 8 years for falsifying or that carries a statutory maximum term of imprisonme false or fraudulent statements or making covering up by any scheme or making materially ents that relate to offenses under chapters 109A, or using any false writings or docum r 77. The amendment adds a new 109B, 110, and 117, and under section 1591 of chapte specific offense characteristic at subsection (b)(1) (A) of § 211.2 (Obstruction of Justice) by four levels if the defend ant was convicted under HI enhancing the offense level onment applies because the 1001 and the statutory maximum term of 8 years' impris matter relates to sex offenses. The amendmen t also added language to Application Note 4 guideline in a case involving a stating an upward departure may be warranted under the particularly serious sex offense. tsLoffenses Twelfth vrtinn 70fLollheSdamWalabAstaddeLLSAISCalheis AI The 18 U 4 C. 3559 (001( for which a defenrivt Is to he sentenced to life under es of convictions that are amendment adds 18 11,1.C. 1591 to the list of instant offens covered sex crimes under 6 4B1 S U.S.0 3563. and 311,1. The Thirteenth, section 141 of the Adam Walsh Act amended 18 subdiv ision to (a)(9) of § SB1.3 and to (a)(7) of § 5D1.3 to amendment adds a new ts provided by the require a defendant to comply with the new registration requiremen es the langua ge In §§ SB1.3 (a)(9) and Adam Walsh Act. The amendment also modifi ants convic ted of a sexua l offens e descri bed in 18 II sr 5D1.3(a)(7) relating to defend ts, contin uing to register no4zfrusi. Not all states have implemented the new requiremen 27, 2006, the er regist ry in place prior to July sex offenders pursuant to the sex offend ge the Adam Walsh Act. Thus, It is neces sary to maint ain the langua date of enactment of those superv ised releas e for in the guidelines providing for conditions of probation and offenders. which provides that the Fourteenth, section 141 of the Act amended 18 11.4.0 35/33(k1 for any offens e under enum erated sex offenses Is authorized term of supervised release or life. In respon se, the amen dmen t adds offens es under chanter 10%1 any term of years sinrie or 1R U s r 1201 and 1511 and sections j2 01 and 1591 of title 111 United State under § 501.2 (b)(2) for which the length of the term of to the definition of sex offense specif ied for the supervised release shall be not less than the minimum term of years offense and may be up to life. 01287 EFTA01100888 ion of "minor" in relevant guidelines that is Finally, the amendment provides a definit round elsewhere in the guidelines. Outdated backg consistent with how this term is defined effect ive date of this amen dmen t t. The commentary also is deleted by this amendmen is November 1, 2007. Bradley .1. Edwards Partner Rothstein Rosonfoldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 r I FL 33301 facsimile 01288 EFTA01100889 cMailCoriem hun From: go. At: Sep 24, 200 . To: Bradley J. Edwa rds Cc: Bcc: Subject: T Visas and an incentive offer a trafficked victim protection, asylum Please read this important. I think you can foreign so they s if they know of any victims who were for coining forward on the case. Ask your client because This is a break through for some of the girls, can tell them about this and assuage their fears! on these visas. they'll be able to bring their families into the US -2000 annually and the last time he checked only 1500 According to Acosta some 7000 visas are issued out about the visas (on purpose may I add and apply annually. That means that the word is NOT g visa law enforcement to get it out, fear of havin furthermore, that there is ZERO effort on the part of abused!!!! healing quickly!!! More importantly,How are you feeling? Hope you're Congress passes Violence Against Women Act of 2000 2000 Immigrants' Rights Update, Vol. 14, No. 6, October 19, Trafficking and Violence Protection Act of 2000 Passed by Congress on Oct. I 1, 2000, the Victims of 2000 (VAWA 2000), which expands and (11.R. 3244) includes the Violence Against Women Act of en that were originally enacted in the improves on the protections for battered spouses and childr Violence Against Women Act of 1994 (VAWA 1994). hip"" requirement for self-petitioners and Most notably, VAWA 2000 eliminates the ""extreme hards States. The act also creates two new allows all self-petitioners to adjust their status in the United s of certain serious crimes, including victims nonimmigrant visas for victims of trafficking and for victim and ""U"" Visas for Victims of of crimes against women (see ""Congress Creates New ""T"" ly adjust to permanent resident status. Exploitation ""). Individuals granted these visas may subsequent the House and 95-0 in the Senate), and The bill passed both houses by enormous margins (371-1 in President Bill Clinton has promised to swiftly sign it. ular problems faced by VA WA 1994. The original VAWA included provisions to address the partic ration law, immigrant spouses and battered immigrant women and children. Under pre-VAWA immig dependent on the citizen or LPR to children of U.S. citizens or lawful permanent residents (LPRs) were ularly subject to abuse on the part of petition to immigrate them, and this dependency left them partic spouses and their children or abused that relative. The VAWA created a procedure whereby abused without the cooperation of the children and their parents can ""self-petition"" to obtain LPR status en to obtain suspension of abusing relative. The VAWA also enabled battered spouses and childr for at least three years rather than deportation or cancellation of removal if they were present in the U.S. csieMaileMailetinicnt.hon (I of 4)(1I/6/201010:10.01 PM) 0k MCVOnc tatleA20and%20Seliinpftrial/Dcskuop/li onitIN 10586 EFTA01100890 S hbailcontemilhil ired for susp ension or ten years for cancella tion. the seven years normally requ that s rem oved . VAW A 200 0 removes a number of obstacles l statu the VAWA intended Obstacles based on family/marita red in attempting to use provisions of ren have enco unte failed to battered spouses and child who se mar riag e is defective because her husband batt ered spou se to help them. For example, a to immigrate under VAWA 1994. VAWA 2000 ady mar ried is not elig ible . citizen or tell her that he was alre als who belie ved that they were married to a U.S win g indi vidu corrects this problem by allo though they have been 200 0 also allo ws individuals to self-petition even ! PR to self-pet ition . VAW A two years and a , prov ided that the mar riag e terminated within the past divorced from the citizen or LPR nt can be shown. These een the term inat ion of the mar riage and the abuse of the immigra connection betw Moreover, A susp ensi on of dep orta tion and cancellation of removal. changes also apply to VAW petition within two years self- peti tion eve n if the citiz en relative has died, provided they individuals may of the death. self-petitioncrs to apply leav e U.S . to app ly for VAW A visa. The new law allows all VAWA No need to e inspected when they States, regardless of whether they wer for adjustment of status in the United subsequently maintained lawful status. entered the country or whether they eliminates the and othe r requ irem ents for VAW A self-petitioners. The act also ""Extreme Hardship" requirements not applied nt of self-pet ition ers who , under prior law, had to meet certain disp arat e trea tme er need to show ily imm igra nt visa app lican ts. Mos t significantly, self-petitioners no long to regular fam hurdle wou ld caus e "ex trem e hard ship ."" This eliminates an enormous evidentiary that their deportation . employees ws abused spouses and children of U.S from the self-petition procedure. The law also allo petition. and military personnel living abroad to self- s for reasons new law, if the U.S . citiz en or LPR pare nt or spouse subsequently loses that statu Under the ty to immigrate affect the abused immigrant's eligibili related to their abusive conduct, the loss does not s may immigrants with approved self-petition if they petition within two years. Moreover, abused ked. remarry without causing the petition to he revo od moral new law still must show that they have ""go Good moral character. Self-petitioners under the ing goo d moral pts them from the bar on establish character." However, the new law partially exem d moral provision, immigrants cannot establish goo character outlined in 1NA section 101(0. Under that oves the d of certain criminal acts. The new law rem character if they have committed or been convicte act was &portability that is waivable, and the bar if the act constitutes a ground of admissibility or suspension rule also applies to applicants for VAWA connected to the abuse the applicant suffered. This or cancellation. vative who have filed a self-petition or are deri Children who ""age out."" Under the act, children rules, "" or become subject to normal fam visa ily beneficiaries of a parent's petition 110 longer ""age out, ted as self-petitioners under the appropriate when they become 21 years old. instead, they are trea ens or LPRs, or married sons or daughters of category (as unmarried sons or daughters ofU.S. citiz citizens), with the parent's priority date. eMaileomtnl Inin (2 of O(11/6/2010 I'M) 10.10:01 rlialA7akloNG. on/Woes/O.1:i hlr//MUD.Kmncros%20sd%20Se11ingv7 10587 EFTA01100891 A cancellation of contin uous physic al presen ce requir ement. The act allows applicants for VAW Relaxed despite a single continuous physical presence in the U.S., removal to show that they have three years' connection longe r than 90 clays or cumu lative absences exceeding 180 days, if there is a absence ates application against the applicant. The act also elimin between the absence and the abuse perpetrated al continuous of ""stop -time role"" (unde r which servic e of a Notice to Appear stops the accru of the al to ce) in VAW A cance llation and suspe nsion cases. And it requires the attorney gener physical presen cancellation. who are granted VAWA suspension or parole the children or parents of individuals become eligible for VAWA suspension or Motions to reopen. The act allows individuals who s. It also new law to move to reopen their proceeding cancellation because of the changes made by the e a motio n to reopen to reopen, allowing individuals to fil amends the INA's time limitations on motions al may apply for VAW A cance llation within one year of the entry of a final order. The attorney gener to rdinary circumstances or extreme hardship to a also waive the one-year limitation in cases of extrao child. deportability. The act establishes waivers of certain New waivers of grounds of inadmissibility and for There is a waiver of the ground of inadmissibility grounds of inadmissibility for abused immigrants. havin g ear period of unlawful presence or after reentering the U.S. without inspection following a one-y duals who can establish a connection between been ordered removed. This waiver is available to indivi the abuse they suffered and their departure or reentry. g a conviction for a crime of domestic There is also a waiver of the ground of deportability for havin immigrant can show that she was not the violence or for violation of a protective order, if the abused also show that she was acting in self- primary perpetrator of violence in the relationship. She must and was connected to the abuse that the defense or that the crime did not result in serious bodily injury immigrant suffered. rs for certain criminal grounds (§ 212(h)), The act makes available to abused immigrants the INA's waive nding the availability of these fraud or misrepresentation (§ 212(0), and health grounds (§ 212(g)). Expa of U.S. citizens or LPRs. waivers was considered necessary because they had been limited to spouses Abused immigrants may no longer have such a relationship. provide that cash or other Public charge. The act amends the public charge ground of exclusion to VAW A beneficiaries to obtain benefits received pursuant to 8 U.S.C. section 1641(c) (which permits domestic violence) may not cash and other government assistance in connection with their escape from be considered in public charge determinations. ds the Cuban Adjustment Changes to Cuban Adjustment Act, NACARA, and }IRIFA. The act also amen Central American Relief Act Act, the adjustment of status provisions of the Nicaraguan Adjustment and amendments allow (NACARA), and the Haitian Refugee Immigration Fairness Act (HRIFA). These under these laws to abused spouses or children who are dependents of individuals eligible for relief nship. Under the act, adjust their status, without having to reside with the principal or maintain the relatio they have resided in persons who become LPRs through VAWA may also apply for naturalization after the U.S. in LPR status for three years. kMsi eMailCorticm Mon (1M (11/6/2010 1010:01 PM) Me://KilDoctimam%20nnd%20SolinisITtigaDesktop/E.. oc*Doa 10588 EFTA01100892 .MailfromothIm wrote: Sep 24, 2009 08:34:02 PM, h hell today. Long day. I will call you tomorrow. Client went throug Ori inal Message Front imaillo Sent: Thursday, September 24, 2009 10:39 AM To: Bradley J. Edwards iew Subject: Not a mention of the name atter a 2 1/2 hour interv Sent via BlackBerry from T-Mobile sleMoi Mailepment Wm hl of 4) I 11/(/201010:10.01 PMI //f(14)actimenh%20:mird4ZOSepiotgs/ProaltneAtop/P_ .onielMe 10589 EFTA01100893 Maileont ai From: Michele Darwin Sent: Jul 29, 2009 13:47:51 To: Bradley J. Edwards Cc: lice: Subject: Re: Epstein Brad, banned members lists. We have no way of getting the members or the g like getting it from the horse's mouth! However, I spoke to Donald Trump today - nothin er. He would not confirm or deny that he ever was a memb Anyway, he said Epstein is not a member and d from the on whether or not Epstein got boote would not comment at all (which is very rare for him) club or if he had recruited girls from Mar-A-Lago. he would say something. He usually does comment Sorry I couldn't be more help. I really thought that al. for all of our stories. That's why this was quite unusu s out during tiepin of anything related to If you get any info, please pass it on....like if any info come recruiting girls from there. You know I will run with Epstein getting booted from the club or about him it! Michele On 7/28/09 9:28 AM, ""Bradley J. Edwards"" wrote: Hi Michele, ago, and even more importantly if I was wondering if you were able to get a members list at the Maral Rumor has it that he was banned for you were able to get a list of banned members from the Maralago? we already know of certain having sex with and attempting to have sex with minors at the club, and of someone there if we need to do minors that he took from the dub to his house. I will take a deposition itions to take in this case (and we are that to get the true information on this, but there are so many depos this one if we could get the info setting them right now around the country) that I would like to avoid another way. Thanks Bradley J. Edwards Partner file ///C/Documents542nantrAMSeitinD41) ial/l)cskAopc. oakI haft/Au ttmodcomou him (s 00)(1I/61:010 10 10.54 Mg 11075 EFTA01100894 UlaJlry lidwaidh017032^i:MailConleni him Rothstein Rosenfeld' Adieu Attorneys at Law Las Olas City Centre 401 Past Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile Michele Dorgan, staff writer Palm Beach Daily News phone fax .nnicl)ricah:Mai MoilConteot.liten (2 of 2) II 1/N2010 1010.54 PMI illell/CYDociinicals%200m0420Sciiiiirltrial/Desktop/0 11076 EFTA01100895 From: Michele Dargan Sent: Jul 31, 2009 11:20:03 To: Bradley J. Edwards Cc: Bee: Subject: Re: Epstein • •••••.- . ..,•••••-•••••.• -.. I• • • Brad, mean it took place morning (Friday) so it was too late....you did 1 didn't get your e-mail until I got in this this morning, right? Anything interesting? : On 7/30/09 6:06 PM, ""Bmdley J. Edwards"" wrote e's courtroom (1113 1 think) at 8:30 on our Michele, I forgot to tell you that I have a hearing in Hafel sting things said for you. Things that have not motion to add punitive damages. Should be some intere been said before. Bradley J. Edwards Partner Rothstein Rosenfeld( Adler] Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dargan [mailto Sent: Wednesday, July 29, 2009 1:48 PM To: Bradley J. Edwards Subject: Re: Epstein Brad, We have no way of getting the members or the banned members lists. MnilComcm him ( ; orD( II:6/2010 le.10.9 PM) relc 1/ICK)ncemenIt524MCQUStiI ingsfriialInnk10". ..ndenntsiebAnill~e 11080 EFTA01100896 Maileontoithitn it from the horse's mouth! However, I spoke to Donald Trump today — nothing like getting or deny that he ever was a member. He Anyway, he said Epstein is not a member and would not confirm not Epstein got booted from the would not comment at all (which is very rare for him) on whether or club or if he had recruited girls from Mar-A-Lago. something. Ile usually does comment Sony 1 couldn't be more help. 1 really thought that he would say for all of our stories. That's why this was quite unusual. of anything related to If you get any info, please pass it on....like if any info comes out during depos You know 1 will nm with Epstein getting booted from the club or about him recruiting girls from there. it! Michele On 7/28/09 9:28 AM, ""Bradley J. Edwards" wrote: Hi Michele, I was wondering if you were able to get a members list at the Maralago, and even more importantly if you were able to get a list of banned members from the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house. I will take a deposition of someone there if we need to do that to get the true information on this, but there are so many depositions to take in this case (and we arc setting them right now around the country) that I would like to avoid this one if we could get the info another way. Thanks Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 Zile MelMocuments%20and%20Secitogs/12ial/Desktooff... ooknocsichloiliendley_tdo-ards012129^eMoileolocni.hint (2 of 3)111/6/2010 10:10:54 PM] 11081 EFTA01100897 L.Iwaids1)I I I 29AeMa i:Coolcoit Michele Dugan, stair writer Palm Reach Daily News phone fax MailConleal.lnm (3 of 3)11i/6/20(0 10.10:54 PM) Gk /dCVDocmncnti%20atd%2ptclliup/ftiolpkxknµJE. xinkeisltMail 11082 EFTA01100898 MaalConleio Mm From: Bradley J. Edwards Sent: Jul 30, 2009 14:36:23 'fo: Michele Dargan Cc: Bcc: Subject: RE: Epstein are public record - Complaint riled by Josephsberg Thank you. We have our answer then. All the pieces him, a ding Epste in being at the club with Ghisla ine Maxwell and taking a 15 year old home with regar but similar conduct (don't remember who published it newspaper article that indicated he was banned for will get the from Trump. Ile's banned. Don't worry, we I read it a few months back), and a no comment and certain people that will be set will know that official word. We are setting many depositions soon be in touch. information. 1 will keep you informed. Good work. I'll Bradley J. Edwards Partner Rothstein Rosenfeldt Adled Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dargan [mato- Sent: Wednesday, July 29, 2009 1:48 PM To: Bradley J. Edwards Subject: Re: Epstein Brad, eeMal chluilComot him (1of 3) (11/6/2010 11:30 filc./IICYDocoottnts%2(laoi%20Scoingsftrial/Desktop/13. .00lcIlocS 11320 EFTA01100899 cMailiConictu Mot lists. members or the banned members We have no way of getting the the horse's mouth! y - nothing like getting it from However, I spoke to Donald Trump toda ber. blc mem ber and wou ld not con firm or deny that he ever was a mem a Anyway, he said Epstein is not for him ) on whether or not Epstein got boo ted from the all (wh ich is very rare would not comment at Mar-A-Lago. club or if he had recruited girls from does comment help . I real ly thou ght that he would say something. He usually Sorry I couldn't be more was quite unusual. for all of our stories. That's why this related to se pass it °IL. ..lik e if any info com es out during depos of anything If you get any info, plea know I will run with ing boo ted from the club or abo ut him recruiting girls from there. You Epstein gett it! Michele ards"" wrote: On 7/28/09 9:28 AM, ""Bradley J. Edw Ili Michele, e importantly if bers list at the Maratago, and even mor I was wondering if you were able to get a mem was banned for able to get a list of bann ed mem bers fron t the Maralago? Rumor has it that he you were know of certain with minors at the club, and we already having sex with and attempting to have sex e if we need to do e. 1 will take a deposition of someone ther minors that he took from the club to his hous (and we arc the true info rma tion on this, but ther e are so many depositions to take in this case that to get could get the info ) that I would like to avoid this one if we setting them right now around the country another way. Thanks Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile 30 PM) eMoilemticm Iran (2 of 3) tl I/6(2010 10.11: We ..0NeDocileMat role INCYDocunicans%20and%20Sellielpf relating:SW(1 11321 EFTA01100900 fNiileo.Rcnt Son Mieltele Dugan, stair writer palm Beach Daily News phone fax Moilewonu.lion ()of]) I/6M/I0 IO I I .30 PM) file tifC1/13octonents9Q0on51420ScoingsffroliOcskloy/P. on/cOocaleMai 11322 EFTA01100901 Igmadenroothei. From: Bradley J. Edwards Sett: Jul 30, 2009 18:06:49 To: Michele Dugan Cc: Bee: Subject: RE: Epstein on our g in Hatele's courtroom (1113 I think) at 8:30 Michele,1 forgot to tell you that I have a hearin that have not interesting things said for you. Things motion to add punitive damages. Should be some been said before. Bradley J. Edwards Partner Rothstein Rosenfeldt Adlerl Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dargan imailto: Sent: Wednesday, July 29, 2009 1:48 PM To: Bradley J. Edwards Subject: Re: Epstein Brad, We have no way of getting the members or the banned members lists. the horse's mouth! However, I spoke to Donald Trump today - nothing like getting it from omoothiso( 1 of 3)1111612010 tat 1:30 PMt IlleVCl/Documents%20mKrA2USdiiisgsntialitesktup/E oni cDocsieMageMW/C 11323 EFTA01100902 MadeOigcol !who member. He Epste in is not a memb er and would not confirm or deny that he ever was a Anyway, he said got booted from the rare for him) on whether or not Epstein would not comment at all (which is very -tag°. club or if he had recruited girls from Mar-A comment be more help. I really thoug ht that he would say something. He usually does Sorry I couldn't quite unusual. for all of our stories. That's why this was related to if any info comes out during delves of anything If you get any info, please pass it on....Iike with recruiting girls from there. You know will run I Epstein getting booted from the club or about him it. Michele On 7/23/09 9:28 AM, ""Bradley J. Edwards"" wrote: Hi Michele, Maralago, and even more importantly if I was wondering if you were able to get a members list at the Rumor has it that he was banned for you were able to get n list of banned members front the Maralago? and we already know of certain having sex with and attempting to have sex with minors at the club, of someone there if we need to do minors that he took from the club to his house. I will take a deposition itions to take in this case (and we are that to get the true information on this, but there are so many depos this one if we could get the info setting them right now around the country) that I would like to avoid another way. Thanks Bradley J. Edwards Partner Rothstein Rosenteldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, PL 33301 facsimile Michele Dugan, staff writer hluilConcenthun (2 or 3) (I 1/6/201010:11:30 pmi rac ///e1/1)ocuntoust420n1%2(Xtiellingilitialifksklop/E .oiVeLhx://cMail 11324 EFTA01100903 .44,6colity,u.m., a - .11Daily New s phone fax PMJ I0 ID I I.30 10 (3 of 3)111/6/20 chlittlettotent 1,1 i 11325 Stitingsflitalt(ksilopit iatlfallil s%20sodK2O nokflooktv Ida a l/Doc tunceit EFTA01100904