HOUSE_OVERSIGHT_013489.tif

aa a Doe any substantive testimony re lated her. allegations. 7 AFFIDAVIT OF BRADLEY JAMES EDWARDS L- 4 am. an n attorney in good standing with the Florida Bar and admitted to. practice i in the - Southern District of Florida. vd arm a partner i in the law firm of Farmer Jaffe Weissing Edwards Fistos and Lehrman. OT ae - !, -Lam the lead attorney currently representing “ane Doe” in the case of | jane Doe v. Jeffrey Epstei in, 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 Epstein sexually molested her humerous oceasions when she was a minor. ce oe re ; 3. Defendant Epstein has ‘entered into a “non-prosecution agreement” (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 p lead guilty to state law criminal charges - involving solicitation of prostitution and procuring a minor: for prostitution. The victim af the criminal charges to. which he has pled was not Jane Doe. . 4, Under. the NPA, Epstein has agreed not to ‘contest civil lability of any of 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, 00G-in. damages. Therefore, the terms. of the NPA purport to- prevent Jane Doe from oo using the NPA to prove liability. 2 5, - Epstein has fil ed an answer to. ‘Jane Doe’ s complaint, in “which he has invoked his Fifth a Amendment right to silence with respect to the allegations that he molested. her asachild. Epstein-has. ~ ; further’ argued that this Fifth Amendment invocation Is the functional equivatent_ of, and must ‘be. Se treated aS, a specific denial of the allegations. 6. . Defendant Epstein’ s deposition has been taken on several occasions, in ‘this and other. related cases,.and he has not provided any substantive discovery whatsoever. instead, he invoked his _ 5" amendment privilege against seltincrimination when. asked questions about hi is abuse of Jane Doe or. other girls. oe : Ss oA “Defendant: Epstein has: also heen served: with interrogatories and ‘requests. for oe - - production; all requests. have been met. with 5°. amendment assertions sand Epstein has not given Jane ed SB, "Jane Doe's: complaint. contains. a punitive. ‘damages claim, ‘aril Mr! _Epstei n has a Iso. - a co alected: te invoke the pth Amendment on. all questions ‘that would, relate to ‘punitive damages. issues, pepe such: as his. intent when committing the crimes, his Jack of remorse and his intent. to recidivate.” : nn 9. coe -Epsteir has taken Jane Doe’ $ deposition. During that deposition he has asked numerous’ Se te ; questions of Jane Doe that suggest that shel is: fabri icating her allegation of abuse by Epstein. mgd . “40, 7 qn addition to deposing Mr. Epstein, other attorneys and! have taken the’ de sasitions of. CoE “his various co- conspirators (as labeled by” the: federal I government in-the NPA}, | ra ;—ssg aid Each of those: individuals was employed, by Epstein to bring 0. “him underage girls for him to. molest and to ensure that-he: was. protected ‘from detection by: law Oe Lobe . enforcement, and thus those individuals could fi ikely provide. general testimony that wou id assist Plaintiff 0° in proving, liability and damages, including punitive damages. However, none of these individuals. were : a HOUSE_OVERSIGHT_013489