Text extracted via OCR from the original document. May contain errors from the scanning process.
a - ‘Doe any substantive testimony related. her. allegations.
— enforcement, and thus those individuals could likely provide. general testimony that would assist Plaintiff. °
__ AFFIDAVIT OF BRADLEYJAMESEDWARDS == i (ssw |
1. - od ainan attorney in good standing with the Florida Bar and admitted to: practice in the
- Southern District of Fieri, Jam a PARee in ee law firm of Farmer Jaffe Weissing Edwards Fistos Hd .
Lehrman. ee ohm <n
“2. ‘Tam the lead attorney currently representing — Doe” in the case f J Inv Doe v.
Jeffrey Epstein, case number 08-80893 in: federal Court in the Southern District of Florida. | am the lead
attorney representing ° Jane Doe, whose civil complaint alleges that Egsela sexually molested her
numerous occasions when she was a minor. ee” . -
sects
Bi. vee Defendant: Epstein has ‘entered into a’ “non- prosecution adreentanr® (NPA) with the.
federal government for sex crimes against minors. Under that agreément, the federal government. has ©
agreed not to file criminal charges against Epstein for sex crimes committed against.approximately thirty
girls, including Jane Doe. In. exchange, Epstein agreed to plead guilty to state law criminal charges -
‘involving solicitation of prostitution and procuring a minor for r prostitution. The victim i tat the criminal
charges to: which he has pled was not Jane Doe. ai E
4. a Under. the’ NPA, Epstein has _agreed not to ‘contest - adult liability” if. any: ef his
_ approximately thirty: victims — provided. that the victim agrees to limit themselves to the damages
provided by 18'U.S.C.§'2255 (currently set at $150, 000). Jane. Doe has not agreed, to limit herself. to
pursuing only $150, 000-in: BANBEES Therefore, ‘the terms. of the NPA ad to pei Jane Doe from
using the NPA to prove liability. .
5. - Epstein has filed an answer to. ‘Jane Doe’ s complaint, in witch he has invoked his Fifth
Amendment right to silence with respect to the allegations that he molested. her asa child. Epstein has.
further ‘ argued that this Fifth. Amendment invocation is the functional equivalent of, and must ‘be.
oeatea as, a specific denial of the allegations. : :
6. “ Defendant: Epstein’ s deposition rs been taken on several occasions, .in ‘this. and other.
related cases,.and he has not provided any substantive discovery whatsoever. Instead, he invoked his
5th amendment privilege aealinS seit nerminaian wien: asked questions about his abuse of Jane Doe or.
a other girls. ae 7 Te
: . om * Detendant Epstein hee ‘also ‘Heei sanvedl: “with: nterrogatories ‘ad ‘requests. “for .
7 » production; all requests. have been met: with 5th amendment assertions Pane Epstein’ has not given Tan Ween
oe By: ' Jane, Doe's: complaint: contains. a punitive ‘damages: clainn, and Mr Tistein: he “also. . a
elected: to tiivoke the 5h Amendment on. all questions ‘that would, relate to ‘punitive damages: issues, ep Son
‘such: as. his. intent when committing the crimes, his Jack of | remorse and his intent to recidivate.~ we
Soe, 9. ae Epstein’ ‘has taken Jane. Doe’ S deposition. ‘During! that deposition he has asked numerous’ PTT
: ‘questions of Jane Doe that suggest that shei is: fabricating her allegation, of. abuse. by Epstein. teas
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Ds “10. - In addition to deposing Mr. Epstein, other attorneys and I have taken the depositions: of. gow!
a his various cé-conspirators (as labeled-b ‘the-federal government in-the NPA), inciudin 2s
Sor and’ _— ‘Each. of. those: individuals was employed: by Epstein. to ‘bring - oa ed
. him underage girls for him to. molest and to. ensure that-he: was- protected from detection by law ..- :-. Ben: be
in pension, liability and. damages, including punitive’ RBINaEES, However, none of these individuals, were ; i
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