Edwards provided notice that he intended to depose Alan Dershowitz. Edwards
possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with
Epstein for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th
book... The only person outside of my immediate family that I send drafts to is Jeffrey" The
29
Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See
article attached as Exhibit "00"); (c) Epstein's housekeeper Alfredo Rodriguez testified that
Dershowitz stayed at Epstein's house during the years when Epstein was assaulting minor
females on a daily basis; (d) Rodriguez testified that Dershowitz was at Epstein's house at times
when underage females where there being molested by Epstein (see Alfredo Rodriguez
deposition at 278-280, 385, 426-427); (e) Dershowitz reportedly assisted in attempting to
persuade the Palm Beach State Attorney's Office that because the underage females alleged to
have been victims of Epstein's abuse lacked credibility and could not be believed that they were
at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house;
(f) Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not only
Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians,
businessmen, and/or other professional and personal acquaintances" " categories that Dershowitz
and acquaintances of Dershowitz fall into; (g) during the years 2002-2005 Alan Dershowitz was
on Epstein's plane on several occasions according to the flight logs produced by Epstein's pilot
and information (described above) suggested that sexual assaults may have taken place on the
plane; (h) Epstein donated $30 Million one year to the university at which Dershowitz teaches.
Based on this infoli__iation,

Take note of this

ershowitz reportedly assisted in attempting to
persuade the Palm Beach State Attorney's Office that because the underage females alleged to
have been victims of Epstein's abuse lacked credibility and could not be believed that they were
at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house;

That is fucking damning!!!!!!!!!!!
and diabolical

Bradley J. Edwards, Esq., provided notice that he intended to take the deposition
of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads
confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach
mansion on several occasions during the time period most relevant to my Edwards's clients'
complaints; (b) Trump was quoted in a Vanity Fair article about Epstein as saying "I've known
Jeff for fifteen years. Terrific guy," "He's a lot of fun to be with. It is even said that he likes
beautiful women as much as I do, and many of them are on the younger side. No doubt about it --
28
Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals
with a passel of Nobel Prize"winning scientists, CEOs like Leslie Wexner of the Limited,
socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, Kevin
Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder
who he is. By Landon Thomas Jr. (See article attached hereto as Exhibit "NN") (c) Trump
allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually
assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe
102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be
Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified
that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged
was used to have sex with underage girls); (f) Trump had been to Epstein's home in Palm Beach;
(g) Epstein's phone directory from his computer contains 14 phone numbers for Donald Trump,
including emergency numbers, car numbers, and numbers to Trump's security guard and
houseman. Based on this information,

all crap we knew alrady

Edwards notified Epstein's attorneys of his intent to take Bill Clinton's deposition.
Edwards possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine
Maxwell who was Epstein's longtime companion and helped to run Epstein's companies, kept
images of naked underage children on her computer, helped to recruit underage children for
Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and
photographed underage females in sexually explicit poses and kept child pornography on her
computer; (b) it was national news when Clinton traveled with Epstein aboard Epstein's private
plane to Africa and the news articles classified Clinton as Epstein's friend. (c) the complaint
filed on behalf of Jane Doe No. 102 stated generally that she was required by Epstein to be
sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty,
27
politicians, academicians, businessmen, and/or other professional and personal acquaintances" "
categories Clinton and acquaintances of Clinton fall into. The flight logs showed Clinton
traveling on Epstein's plane on numerous occasions between 2002 and 2005. See Flight logs
attached hereto as Exhibit "MM." Clinton traveled on many of those flights with Ghislaine
Maxwell, Sarah Kellen, and Adriana Mucinska, - all employees and/or co-conspirators of
Epstein's that were closely connected to Epstein's child exploitation and sexual abuse. The
documents clearly show that Clinton frequently flew with Epstein aboard his plane, then
suddenly stopped - raising the suspicion that the friendship abruptly ,ended, perhaps because of
events related to Epstein's sexual abuse of children. Epstein's personal phone directory from his
computer contains e-mail addresses for Clinton along with 21 phone numbers for him, including
those for his assistant (Doug Band), his schedulers, and what appear to be Clinton's personal
numbers. This information certainly leads one to believe that Clinton might well be a source of
relevant information and efforts to obtain discovery from him were reasonably calculated to lead
to admissible evidence.

ummm yeah clinton too, f him

Maxwell is not the only important witness to lie to avoid deposition by Edwards.
Upon review of the message pads that were taken from Epstein's home in the police trash pulls,
see Exhibit "J" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's
closest pals. He left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to
teach you how to speak Russian. She is 2x8 years old, not blonde. Lessons are free and you can
have your 1st today if you call." See Messages taken from Jean Luc Brunel are attached hereto as
Exhibit "EE." In light of these circumstances of the case, this message reasonably suggested to
24
Edwards that Brunel might have been procuring two eight-year-old girls for Epstein to sexually
abuse. According to widely circulated press reports reviewed by Edwards, Brunel is in his
sixties and has a reputation throughout the world (and especially in the modeling industry) as a
cocaine addict that has for years molested children through modeling agencies while acting as
their agent " conduct that has been the subject of critical reports, books, several news articles,
and a 60 Minutes documentary on Brunel's sexual exploitation of underage models.

2 eight year olds

so, yeah, epstein was a pedophile

The Palm Beach Police Department also collected Epstein's message pads, which
provided other names of people that also knew Epstein's scheme to molest children. See
Message Pads (Exhibit "J") (note: the names of underage females have been redacted to protect
the anonymity of the underage sex abuse victims). Those message pads show clear indication
that Epstein's staff was frequently working to schedule multiple young girls between the ages of
12 and 16 years old literally every day, often two or three times per day.

t all relevant times Edwards has had a good faith basis to believe and did in fact
believe that yet another of the minor girls Epstein sexually assaulted was C.L. When she was
approximately 15 years old, C.L. was brought to Epstein's home by another underage victim.
While a minor, she was at Epstein's home on multiple occasions. Epstein engaged in one or
more of the following acts with her while she was a minor at his house - topless or completely
nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her
presence; Epstein ejaculated in her presence; Epstein also demanded that she bring him other
underage girls. See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A."
13. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that yet another girl Epstein sexually assault was A.H. When she was approximately 16
years old, she was brought to Epstein's home by another underage victim. While a minor, she
7
was at Epstein's home on multiple occasions. Epstein engaged in one or more of the following
acts with her while she was a minor at his house - topless or completely nude massage on
Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein
ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes
covering her sexual organs; was made to perform sex acts on Epstein; made to perfoim sex acts
on Nadia Marcinkova in Epstein's presence. Epstein also forcibly raped this underage victim, as
he held her head down against her will and pumped his penis inside her while she was screaming
"No". S

Nadia Marcinkova

For those doubting that Epstein was a monster- looking at you megyn kelly

IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No. :50 2009 CA 040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants,
STATEMENT OF UNDISPUTED FACTS
Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed
material facts in this case. Each of the following facts is numbered separately and individually to
facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall
identify . . . any summary judgment evidence on which the adverse party relies."). All
referenced exhibits and attachments have previously been filed with the Court and provided to
Epstein.
Sexual Abuse of Children By Epstein
1. Defendant Epstein has a sexual preference for young children. Deposition of
Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment
#1).1
When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to
remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the
adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to
him. "[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to
2. Epstein repeatedly sexually assaulted more than forty (40) young girls on
numerous occasions 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 ("Q: How many times have you engaged in oral sex
with females under the age of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane
Doe, September 24, 2009 and continued March 11, 2010, at 527 (minor girl sexually abused at
least 17 times by Epstein) (hereinafter "Jane Doe Depo") (Deposition Attachment #2); id. 564-67
(vaginal penetration by Epstein with his finger), 568 (vaginal penetration by Epstein with a
massager); Deposition of L.M., September 24, 2009, at 73 (hereinafter "L.M. Depo")
(Deposition Attachment #3) (describing the manner in which Epstein abused her beginning when
LM was 13 years old, touching her vagina with his fingers and vibrator) at 74, line 12-13 (she
was personally molested by Epstein more than 50 times), at 164, line 19-23 and 141, line 12-13
and 605, line 3-6 (describing that in addition to being personally molested by Epstein she was
paid $200 per underage girl she brought Epstein and she brought him more than seventy (70)
underage girls - she told him that she did not want to bring him any more girls and he insisted
that she continue to bring him underage girls); Deposition of E.W., May 6, 2010 (hereinafter
"E.W. Depo") (Deposition Attachment #4) at 115-116, 131 and 255 (describing Epstein's abuse
of her beginning at age 14 when he paid her for touching her vagina, inserting his fingers and
civil actions when they refuse to testify in response to probative evidence offered against them." Baxter
v. Paltnigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App.
2001). The reason for this rule "is both logical and utilitarian. A party may not trample upon the rights of
others and then escape the consequences by invoking a constitutional privilege " at least not in a civil
setting." Fraser v. Security and II1V. Corp., 615 So.2d 841, 842 (Fla. App. 1993).
2

From the emails