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negotiated a plea
bargain. Affidavit of Bradley James Edwards dated September 14,2010 ("Edwards Aff.")1 6.
Under the plea agreement, Epstein pled guilty to two state criminal charges related ... procuring a
minor for prostitution and soliciting prostitution. Edwards Aff. ¶ 6. These two charges to which
he pled pertained to girls other than Jane Doe. Edwards Mil 6. Epstein also ... federal government agreed not to
prosecute him for any other sex offenses. Edwards Aff. ¶¶ 6. As part of the NPA, Epstein
agreed to make restitution to any of the victims
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were commenced
against him by young women who had been his victims. See Balin Aff. Ex. G (Statement of
Undisputed Facts ("SUF") in Ponzi Scheme Action)¶¶ 48-49. Edwards ... Daily News journalist who covered the unfolding sex abuse scandal
surrounding Epstein. Balin Aff. Ex. J (Affidavit of George Rush, sworn to April 6, 2010 ("Rush
Aff ... including attorney Edwards — who could provide tips and
information to assist his reporting. Rush Aff. ¶¶ 3, 6-7.
In October 2009, Rush obtained a telephone interview with Epstein to talk
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soliciting a prostitute, a
third degree felony. That charge is still pending. Black Aff. 75.
In the fall of 2005, prior to being charged with any wrongdoing, Mr. Epstein
retained ... Black, Esq., to represent him in connection with the then ongoing
state investigation. Black Aff. ¶3. Mr. Black in turn hired William Riley of Riley
Kiraly, a private investigation firm ... assist him in his representation of Mr.
Epstein. Black Aff. 74.
During the course of the state investigation, law enforcement authorities
concluded that at some time, one or more computers
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Black, Esq., to represent him in connection with the then ongoing
state investigation. Black Aff. ¶3. Mr. Black in turn hired of
a a private investigation firm, to assist ... representation of Mr.
Epstein. Black Aff. 14.
During the course of the state investigation, law enforcement authorities
concluded that at some time, one or more computers had been removed from ... thereafter defense counsel were
provided with open disclosure of the state's evidence. Black Aff. 16. As a result,
all or virtually all of the evidence obtained by the state
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EFTA01207793Set 9
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also Search Warrant, Ex. B to
Defs.' Mot. [Dkt. # 35-2] ("Search Warrant"); Aff. in D. The December 5, 2012 Search of Kim
Supp. of Appl. for Search Warrant ... Defs.' Mot. Special Agent Hamako testified that while he understood
[Dkt. # 35-2] ("SW Aff."), at 7 n.1. that he had the authority to conduct a border search of
WestlawNext ... would be contained in the files on Kim's laptop. SW Aff.
search function in Outlook instead; given the 10. The affidavit states that the laptop was detained
investigators' search
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agreement it had reached with Epstein. See DE 361 at 31-39; Edwards Aff. of Aug.
11, 2017, at 11 11-19. All of the Government's arguments about what ... prosecution of Epstein, the Government concealed the
existence of the NPA. See generally Edwards Aff. of Aug. 11, 2017 at 1 1 11-25.
Clearly, at a minimum, the Government ... This was a
reasonable understanding of the letters. See Edwards Aff. of August II, 2017, at 9f 8.
D. The Government's Continuing Concealment of the NPA as Epstein Plead
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party." DE 290 at 8. This unsupported
allegation is simply false. See Aff. of Jane Doe No. 3 at 7, Exhibit 1 to Victims' Reply in
Support of Motion ... Joinder (hereinafter "Jane Doe No. 3 Aff.") (responding to Government's
claim of legal representation and attesting "Mills is completely untrue, and I think the
Government knows it is untrue ... Critically, Jane Doe No. 3 was hiding from Epstein.
See Jane Doe No. 3 Aff. at 3. Her decision to live away from family and friends was not
voluntary
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party." DE 290 at 8. This unsupported
allegation is simply false. See Aff. of Jane Doe No. 3 at 7, Exhibit 1 to Victims' Reply in
Support of Motion ... Critically, Jane Doe No. 3 was hiding from Epstein.
See Jane Doe No. 3 Aff. at 3. Her decision to live away from family and friends was not
voluntary ... Jane Doe No. 3 "did not know what that
meant." Jane Doe No. 3 Aff. at 5. Significantly with regard to this CVRA litigation, the
Government did not tell
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party." DE 290 at 8. This unsupported
allegation is simply false. See Aff. of Jane Doe No. 3 at 7, Exhibit 1 to Victims' Reply in
Support of Motion ... Critically, Jane Doe No. 3 was hiding from Epstein.
See Jane Doe No. 3 Aff. at 3. Her decision to live away from family and friends was not
voluntary ... Jane Doe No. 3 "did not know what that
meant." Jane Doe No. 3 Aff. at 5. Significantly with regard to this CVRA litigation, the
Government did not tell
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Mail
Counselfor Bradley James Edwards
2
EFTA00728442
LEWIS AFF.
EFTA00728443
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
IN RE APPLICATION FOR CPLR 3102(E) Index ... follow criminal and civil legal proceedings in Florida relating to
Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010,
Ex. G] II 1-2), and that ... corrected the date of the interview to "prior to
October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply
Decl
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nature of the calls that he had with the line
prosecutor. See Edwards Aff. of Aug. II, 2017, at IN 11.25. If the Government fails to dispute that affidavit ... victims also adopt the information provided in the contemporaneously-filed Edwards Aff. of August 11, 2017,
to the extent that the Government does not contest the information provided there ... line prosecutor and the circumstances leading up to him drafting his letter. See Edwards Aff. of Aug. II,
2017. at Ti 11-25. If the Government fails to dispute that
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tell what
Epstein did to her behind closed doors in his mansion." Id.; Edwards Aff tl 10 ("Epstein's
abuse of took place in private, with only Epstein and present ... phraseology posited by plaintiff's counsel and investigator was spoken by Epstein. Supp. Rush
Aff't 1 4. Of course,. simply does not know what Epstein said• an in camera ... Development. LLC, 652 F. Supp. 2d 1252. 1260 (M.D. Ha. 2009), aff'd, No. 09-
15066, 2010 WL 1006661 (11th Cir. Mar. 19,2010): Bellefonte Re Ins. Co. v. Argonaut
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discuss the untrue and harmful allegations made by
out Dershowitz. Dershowitz Aff., ill 3-4. Dershowitz had those communications with
Boies - someone he has known professionally for many years ... that Boies might assist in getti to
publicly recant her false statements. Dershowitz Aff.,11 2, 5.
2. Boies repeatedly disavowed any ability to settle anything because he does ... represent the Plaintiffs in this case, Edwards and Cassell. Dershowitz Aff., I 5. Neither
Edwards nor Cassell, nor their counsel, Jack Scarola, participated in the communications
between Dershowitz and Boies
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allegations, in which Mr. Epstein is represented by Jack A. Goldberger, Esq. See Herman Aff.,
Exhibit "A" hereto 3-5). The Defendant's receipt of notice of this lawsuit ... service of process
at his New York residence. (See Herman Aff., Exhibit "A" hereto, 11 3, 4).
7. Under Fed.R.Civ.P. 4(e)(2)(B), service of process ... until Plaintiff reasonably believed that service had been effectuated on May 7, 2008.
(Golub Aff., Exhibit "B" hereto (attempts at service made in February and March, 2008); Affidavit
of Service
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EFTA00102999Set 9
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Various Grand Amy Subpoenas,
924 F. Supp. 2d 549 (S.D.N.Y. 2013), aff'd, 579 F. App'x 37 (2d Cir. 2014) 140
Intl Equity !nvs., Inc. v. Opportunity Equity Partners ... United States v. Annabi,
771 F.2d 670 (2d Cir. 1985), aff'd, 867 F.2d 1425 (2d Cir. 1988) 5
United States v. Arid,
12 Cr. 24 (LAP) 286
United States ... E.D.N.Y. 2010) 300
United States v. Barlow,
732 F. Supp. 2d 1 (E.D.N.Y. 2010), aff'd, 479 F. App'x 372 (2d Cir. 2012) 300, 302
United States v. Barnes
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sexual abuse." Daily News Memo. of
Law at 6 (citing Rush Supp. Aff. 7 4-5) (emphasis in original). This conclusory assertion is
flatly inaccurate, as others who have listened ... recorded interview by describing how he came from Brooklyn
and became wealthy (Fisten Aff. at & 8);
• Epstein said that people do not like it when people make good and that ... problems (i.e., the civil suits brought by Jane Doe, and other girls). Fisten Aff. at & 8.
This is obviously critical evidence for Edwards, particularly with regard to his effort
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