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).
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