(USAFLS)" </DI
From: (USAFLS)" </DI To: "Brad Edwards Subject: Confidential Settlement Negotiations Date: Sat, 25 Jun 2016 20:17:08 +0000 Importance: High Attachments: Proposed_Order_Approving_Stip_for_Dismissal.pdf; Proposed_Stipulation_for_Dismissal.pdf; USAO_Letter_to Jane_Doe_l_-_06-22- 2016_with_watermark.pdf; 20160625_Jane_Doe_Settlement_Agreement.pdf Ili Brad —I am sending you our complete packet, that is: (1) Proposed Settlement Agreement, including title of DOJ official for meeting (2) Proposed Stipulation of Dismissal and Order accepting it (this would be Appendix "B") (3) Proposed letter (this would be Appendix "C") Sealed Appendix A is the victim list from you with my one addition. I need from you: Appendix D (proposed amendments to the "Attorney General Guidelines for Victim and Witness Assistance" and to the procedures for filing complaints with the Justice Department's Crime Victims' Rights Ombudsman) Appendix E (proposed amendments to the U.S. Attorney's Manual) I am
Summary
From: (USAFLS)" </DI To: "Brad Edwards Subject: Confidential Settlement Negotiations Date: Sat, 25 Jun 2016 20:17:08 +0000 Importance: High Attachments: Proposed_Order_Approving_Stip_for_Dismissal.pdf; Proposed_Stipulation_for_Dismissal.pdf; USAO_Letter_to Jane_Doe_l_-_06-22- 2016_with_watermark.pdf; 20160625_Jane_Doe_Settlement_Agreement.pdf Ili Brad —I am sending you our complete packet, that is: (1) Proposed Settlement Agreement, including title of DOJ official for meeting (2) Proposed Stipulation of Dismissal and Order accepting it (this would be Appendix "B") (3) Proposed letter (this would be Appendix "C") Sealed Appendix A is the victim list from you with my one addition. I need from you: Appendix D (proposed amendments to the "Attorney General Guidelines for Victim and Witness Assistance" and to the procedures for filing complaints with the Justice Department's Crime Victims' Rights Ombudsman) Appendix E (proposed amendments to the U.S. Attorney's Manual) I am
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EFTA02726140
From: Brad Edwards
From: Brad Edwards To: Cc: Paul Cassell Subject: Re: Rescheduling Settlement Conference - bad date Date: Sat, 25 Jun 2016 20:39:34 +0000 Importance: Normal Inline-Images: image001.png; image002.png I will forward everything to Paul. is calling me Tuesday. I will use that time to relay everything to her and see where we are then. Sent from my iPhone On Jun 25, 2016, at 4:23 PM, wrote: Hi Paul — Thank you for your email. July 5th is bad for us, too, but I saw Judge Brannon to sign some search warrants yesterday and, although we didn't talk about this case, he mentioned how full his schedule was. I don't know that he is going to be inclined to move it, especially in light of Jane Doe #1's status. I am wondering if you think it is possible for us to finalize things without going back to court? Brad now has our complete packet and I think if we can get things resolved over the next week, then we can take the settlement conference off the calendar and move on to asking Judg
Subjec
Fr • < > Subjec :Deliberative t Process ec aratton rom am Justice - equest or wo ee xtension Date: Fri, 20 Sep 2013 17:59:47 +0000 Importance: Normal We have no objection, provided we get the following accommodation, which you already anticipated. We would request that your motion for extension of time give us an extension on our reply document, such that our reply would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much appreciated. Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2 Paul G Cassell CONFIDENTIAL: This electronic message along with any/all attachments is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message
Filing # 31897743 E-Filed 09/10/2015 12:44:35 PM
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen
Epstein Depositions
10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps
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