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a i ‘Doe any substantive testimony related. her. allegations. _ enforcement, and thus those individuals could likely provide. general testimony that would assist Plaintiff.” _ AFFIDAVIT OF BRADLEYJAMES EDWARDS qe Bee ot “| le _ tam. an 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 Hb . Lehrman. eet ohm oo “2. -T-am the lead attorney currently representing — Doe” in the case of 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 Epsieia sexually molested her numerous occasions when she was a minor. we” . sees Bi. vee Defendant: Epstein has ‘entered into a’ “non- prosecution adreentane® (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 iat the criminal charges to: which he has pled was not Jane Doe. a E 4. Under. the’ NPA, Epstein has agreed not to ‘contest - suit 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: BaMBRES: Therefore, ‘the terms. of the NPA Rupee to peat Jane Doe from using the NPA to prove liability. . 5 - Epstein has filed an answer to. Jane Doe’ s complaint, in wiftich 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, nd must ‘be. seated 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 Salis cell: nerfminaian wie: asked questions about his abuse of Jane Doe or. - other girls. oo o Te ‘ . oA * Detendant: Epstein hee’ ‘also ‘esi sanvedl: “with - Interrogatories ‘aiid ‘requests. for . 7 » production; all requests. have been met: with 5th amendment assertions iad Epstein has not given Tan heen oe Be: Jane. Doe's: complaint: contains. a punitive ‘damages: clainn, ‘and Mr. Tistein: he ‘also. . a elected: to tivoke 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.” ue ae 9. a Epstein’ has taken Jane. Doe’ S deposition. ‘During! that deposition he has asked numerous’ RATT : ‘questions of Jane Doe that suggest that she is: fabricating her allegation, of: abuse. by Epstein. ae t Sal i vad of i “4 Sed hae | j ay os “10. - In’ addition to deposing Mr. Epstein, other attorneys and I have taken the defposttions: of. gigs a his: various cé-conspirators (as labeled-b ‘the-federal government in-the NPA), incudin 2s Sar and’ _— ‘Each. of. those: individuals was ‘employed. by Epstein. to ‘bring. oy ead him underage girls for him to. molest and to. ensure that-he:was- protected from detection by law ..- :- Beta: be in peowdg, liability and. damages, including punitive’ RBINTaEES. However, none of these individuals. were : a HOUSE_OVERSIGHT_013463