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Court Records Edwards v. Maxwell, No. 11
==================== DOCUMENT: Court Records__Edwards v. Maxwell, No. 117-mc-00025 (S.D.N.Y. 2016)__001-01.txt ====================
METADATA_SOURCE: Court RecordsEdwards v. Maxwell, No. 117-mc-00025 (S.D.N.Y. 2016)
METADATA_FILENAME: 001-01.pdf
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Jack Scarola
Florida Bar No.: 169440
Attorney E-Mail(s): jsx@searcylaw.com and
mep@searcylaw.com
Primary E-Mail: _scarolateam@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax:
(561) 383-9451
Attorney for Bradley J. Edwards
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
In re: SUBPOENA TO BRADLEY J.
EDWARDS
Underlying case:
VIRGINIA L. GIUFFRE, Plaintiff
v.
GHISLAINE MAXWELL, Defendant
No. 15-cv-07433-RWS (S.D.N.Y.)
DECLARATION OF BRADLEY J.
EDWARDS IN SUPPORT OF MOTION
TO QUASH SUBPOENA OR, IN THE
ALTERNATIVE, FOR A PROTECTIVE
ORDER
Case No.
I, Bradley J. Edwards, declare as follows:
1.
I am an attorney at law duly licensed in the State of Florida and admitted to
practice in the U.S. District Court for the Southern District of Florida. I respectfully submit
Case 1:17-mc-00025-RWS Document 1-1 Filed 06/13/16 Page 1 of 7
this declaration in support of the Motion to Quash Subpoena or, in the Alternative, for a
Protective Order.
2.
Attached as Exhibit 1 is a true and correct copy of the complaint filed in the
Southern District of New York in the case of Virginia L. Giuffre v. Ghislaine Maxwell.
3.
Attached as Exhibit 2 is a true and correct copy of the subpoena received by
Bradley J. Edwards.
4.
Attached as Exhibit 3 is a composite exhibit, which are true and correct copies
of pages from the Deposition of Alan Dershowitz.
5.
Attached as Exhibit 4 is a true and correct copy of a composite document
containing Plaintiff’s Second Request for Production of Documents and Defendant
Maxwell’s Responses and Objections Thereto.
6.
Attached as Exhibit 5 is a true and correct copy of the complaint filed in the
case currently styled as Jane Doe 1 and Jane Doe v. United States (S.D. Fla.).
7.
Attached as Exhibit 6 is a true and correct copy a subpoena sent to a Florida
company, Victims Refuse Silence, Inc. (VRS).
8.
I maintain my law office in Fort Lauderdale, Florida.
9.
I am a counsel of record for plaintiff Virginia L. Giuffre in the case Giuffre v.
Maxwell, No. 15-cv-07433-RWS (S.D.N.Y.). Other counsel of record include: Sigrid S.
McCawley and Meredith Schulz of Boies, Schiller & Flexner, LLP (Ft. Lauderdale, Florida),
and Paul G. Cassell (who maintains his law office at the University of Utah in Salt Lake City,
Utah).
Case 1:17-mc-00025-RWS Document 1-1 Filed 06/13/16 Page 2 of 7
10.
I have received a subpoena to produce numerous documents in the Giuffre v.
Maxwell case. I am not a party to that case, but the attorney for the plaintiff, Ms. Giuffre.
11.
I was a party to a case styled Edwards and Cassell v. Dershowitz, 15-000072
(17th Judicial District, Broward County, Florida). The production at issue in that case
spanned several thousand pages of documents. Production from defendant Dershowitz came
in several different stages, and various productions involved assertions of privilege.
Production to defendant Dershowitz of documents and receipt of documents in that case was
handled by my attorney. While I have many of the documents that were produced or
received, I did not maintain a separate file as I was merely a party in the litigation and did not
keep records of the exact documents produced or received during that litigation. Id.
12.
I am party in the case Epstein v. Edwards et al., Case No. 50-2009 CA
040800XXXNMBAG (15th Judicial Circuit, West Palm Beach, Florida). The case has been
litigated for seven years. A substantial number of documents are involved in the case. Many
of the subjects in the case overlap with subjects in the on-going Jane Doe 1 and Jane Doe 2
v. United States case, as well as the now-closed Edwards and Cassell v. Dershowitz case.
Because of this overlap, and because I was merely a party and not the primary attorney
handling the Epstein v. Edwards case, I have not maintained a separate file for this matter nor
have I segregated any materials for the Epstein v. Edwards case. It would be an enormous
burden and would be impossible to try and identify which discovery materials relate only to
the Epstein v. Edwards case.
13.
Ghislaine Mawell is in a joint defense agreement with Jeffrey Epstein. See
Exhibit 5, answers to RFPs 6 and 7.
Case 1:17-mc-00025-RWS Document 1-1 Filed 06/13/16 Page 3 of 7
14.
I am a counsel of record in the case of Jane Doe 1 and Jane Doe 2 v. United
States, No. 9:08-cv-80736-MARRA (S.D. Fla.), along with co-counsel Paul G. Cassell. We
filed the case in July of 2008 and have been handling the matter ever since on a pro bono