Latest / The Epstein Chronicles / Mega Edition: Brad Edwards And The Battle Over The CVRA (Part 2) (6/13/26)

Transcript

Mega Edition: Brad Edwards And The Battle Over The CVRA (Part 2) (6/13/26) · The Epstein Chronicles

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Speaker 1: What's up, everyone, and welcome to another episode of the
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Epstein Chronicles. In this episode, we're picking up where we
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left off with Brad Edwards and the CVRA. Affidavid the
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government's fiduciary duty to crime victims bars any privilege. I'm
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familiar with the case law recited in our pleading regarding
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a fiduciary exception also known as the Garner exception in
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some filings to privileges. In this case, the government had
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a fiduciary obligation to protect the CVRA rights a Jaine
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Do number one and Jaine Do number two, specifically, because
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they were recognized as victims under the CVRA, the government
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had obligations to provide them rights under the CVRA, including
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the right to confer, the right to notice, and the
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right to be treated with fairness. Because of this fiduciary duty,
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an exception applies to many of the government privilege claims
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regarding in our actions with the victims. The fiduciary duty
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of the government to the victims in this case is clear.
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In two thousand, the FBI determined that both Jane Do
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one and Jane Do two were victims of sexual assault
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by Epstein. While there were miners, beginning when they were
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approximately fourteen years of age and approximately thirteen years of age, respectively.
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These sexual assaults involve use of means of interstate commerce
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ie telephone and travel in interstate commerce. Both Jane does
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were initially identified through Palm Beach Police Department's investigation of Epstein,
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confirming the fact that the government had identified Jane do
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One as a victim in its case. On about June seventh,
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two thousand and seven, FBI agents had delivered to Jane
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Doe number one a standard CVRA victim notification letter. The
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notification promises that the Justice Department would make its best
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effort to protect Jane do One and her rights, including
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the reasonable right to confer with the attorney for the
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United States in the case, and to be reasonably heard
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at any public proceeding in the district court involving a plea.
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The notification further explain that at this time, your case
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is under investigation. Similarly, on or about August eleventh, two
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thousand and seven, FBI agents had delivered to Jane do
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number two a standard CVRA victim notification letter. The notification
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promises that Justice Department would make its best efforts to
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protect Jane Doe number two's rights, including the right to
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confer with the attorney of the US and to be
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reasonably heard at public proceedings. Early in the investigation, the
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FBI agents and the Assistant US Attorney had several meetings
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with Jane Do number one, and Jane Do number two
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was represented by council that was paid for by Epstein,
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accordingly all contact or contract that was made through that attorney.
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These meetings occurred because the FBI had obligations to protect
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victims' rights under the CVRA. In October of two thousand
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and seven, shortly after the initial non prosecution agreement was
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signed between Epstein and the US Attorney's Office for the
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Southern didstay strict to Florida, Jane Do number one was
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contacted to be advised regarding the investigation. On October twenty six,
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two thousand and seven, special agents E Nesbit, Kirkandaal and
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Jason Richards met in person with Jane Do number one
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because she was recognized as a victim of Epstein's crimes.
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In all of the dealings between the government and the victims,
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as well as other dealings of a similar nature, the
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government had a fiduciary obligation to protect the interests of
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the victims under the Crime Victim's Rights Act. Accordingly, the
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government is precluded from raising any privileged claim to which
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a fiduciary exception applies, or at the very least any
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privilege assertion would be outweighed by the victim's compelling need
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for the material. An illustration of a situation where the
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fiduciary duty exception applies is found on page one of
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the Supplemental Privilege Log with regard to Supplemental Box number three.
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The entry here reads seven eight eight Email from Marie
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Vilafauna to Alex Acosta, Jayson Lohmann, k Atkinson, and FBI
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reproposed response to Goldberger's letter Victim Notification. In responding to
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Defense Attorney Goldberger's letter about victim notification, the U. S.
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Attorney's Office had a statutory duty under the CVRA to
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protect the victim's interest. Accordingly, the office cannot assert privilege
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when questions about whether it fulfilled its obligations to the
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victims have arisen in this case, or at the very
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least any privileged assertion would be outweighed by the victim's
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compelling need for the material. Another illustration of a situation
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where the fiduciary duty exception applies is found on page
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sixteen of the first privileged log with regard to box two.
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The entry reads file folder entitled rs RCCH Crime Victims'
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Rights containing attorney research, henwritten notes, draft victim notification letter,
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and draft correspondence to J. Lefkowitz. Here, again, the material
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at issue go to the heart of the case. What
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kind of notification were made to the victims and how
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did the defense attorney's shape and limit those notifications. Moreover,
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in evaluating victims' rights issues and determining what kind of
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letter descend, the government was fulfilling legal duties that it
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owed to the victims. Accordingly, the office cannot now assert
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privilege when questions about whether it fulfilled its obligations to
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the victims have arisen. In the case, communications facilitating crime
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fraud misconduct not covered, I'm familiar with the cases cited
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in our brief regarding an exception to various privileges when
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the communications concern crime, fraud or government misconduct, Many of
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the important documents about the treatment of the victims to
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which the government is asserting privilege would fall within that
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exception with regard to fraud the government misconduct. A number
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of the documents in the government's privilege log concerned concealment
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from the victims of the existence of the non prosecution
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agreement between the government and Epstein. Reviewed a copy of
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the non prosecution agreement signed on about September twenty fourth,
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two thousand and seven by Epstein and his attorneys and
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a representative of the US Attorney's Office. The text of
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that agreement bar's disclosure of the agreement to the victims.
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On about January tenth, two thousand and eight, my client's
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Jane Do number one and Jane Do number two received
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letters from the FBI advising them that this case is
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currently under investigation. This can be a lengthy process, and
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we request your continued patients while we conduct a thorough investigation.
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The statement in the notification letter was deceptive because it
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did not reveal that the case had previously been resolved
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by the non prosecution agreement entered into by Epstein and
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the US Attorney's Office discussed previously. Moreover, the FBI did
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not notify Jane Do number one or Jane Do number
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two that a plea agreement had been reached previously, and
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that part of the agreement was a non prosecution agreement
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with the US Attorney's Office for the Southern District of Florida,
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and that the non prosecution agreement would resolve the federal
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case completely. Whether the FBI itself had been properly informed
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of the non prosecution agreement is also unclear. Were not
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alleging misconduct by the FBI, but rather that the FBI
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was not properly informed about the case or in any event,
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was acting at the direction of the U s Attorney's Office.
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In about April of two thousand and eight, Jane Do
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number one contacted the FBI because Epstein's council was attempting
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to take her deposition and private investigators were harassing her.
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Assist in US Attorney Marie Villafauna secured pro bono council
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to represent Jane Do Number one and several other identified
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victims in connection with the criminal investigation. Pro Bono council
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was able to assist Change No. Number one in avoiding
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the improper deposition. Ausa. Vilafauna secured pro bono council by
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contacting Meg Garvin of the National Crime Victims Law Center
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in Portland, Oregon, which is based in the Lewis and
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Clark College of Law. During the call, Miss Garvin was
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not advised that a non prosecution agreement had been reached
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in the matter. On May thirtieth, two thousand and eight,
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another of my clients who was recognized as an Epstein
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victim by the US Attorney's Office, received letters from the
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FBI advising her that her case is currently under investigation.
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This can be a lengthy process, and we request your
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continued patients while we conduct a thorough investigation. The statement
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in the notification letter was deceptive because it did not
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reveal that the case had been resolved by the non
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prosecution agreement entered into by Epstein and the US Attorney's
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Office in September of two thousand and seven. In mid
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June two thousand and eight, I contacted a USA Vilafauna
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to inform her that I represented Jane Doe number one
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and later Jane Doe number two. I asked to meet
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to provide information about the federal crimes committed by Epstein,
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hoping to secure a significant federal indictment against Epstein. AUSA
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Vila Fauna and I discussed the possibility of federal charges
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being filed. At the end of the call, Ausa Vila
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Fauna asked me to send any information that I wanted
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considered by the US Attorney's Office in determining whether to
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file federal charges. I was not informed that previously, in
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September of two thousand and seven, the US Attorney's Office
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had reached an agreement not the file federal charges. I
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was also not informed that any resolution of the criminal
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matter was eminent at the time. Presumably the reason the
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US Attorney's Office withheld this information from me was because
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of the confidentiality provision that existed in the non prosecution agreement.
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At this point, it's clear that Ausa Villafana was restricted
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in what she was being permitted to tell me. On
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July third, two thousand and eight, I sent to Ausa
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Vilafauna a letter. In the letter, I indicated my client's
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desire that federal charges be filed against defendant Epstein. In particular,
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I wrote, on behalf of my clients, we urge the
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Attorney General and our United States Attorney to consider the
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fundamental import of the vigorous enforcement of our federal laws.
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We urge you to move forward with the traditional indictments
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and criminal prosecution commesurate with the crimes mister Epstein has committed,
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and we further urge you to take the steps necessary
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to protect our children from this very dangerous sexual predator.
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When I wrote this letter, I was still unaware that
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a non prosecution agreement had been reached with Epstein, in fact,
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that continued to be concealed from me and the victims
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by the US Attorney's Office. I only learned of this
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fact later on, as alleged in the preceding paragraphs and
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elsewhere in the affid David and in this case, delivery
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concealment from crime victims and their legal counsel of the
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existence of the non prosecution agreement would be fraud and
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government misconduct. Documents related to that fraud misconduct would then
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fall outside of many of the privileges being asserted. An
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illustration of a document to which the crime fraud misconduct
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exception applies on this basis is found on page three
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of the Supplemental privilege log. The entry reads file folder
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entitled twelve five oh seven STARTO Acosta, containing drafts of
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eleven thirty seven letters from Acosta to Ken Starr and
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from Jay Slowman to Jay Lefkowitz performance and victim notification
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with handwritten notes and edits by Marie Vilafauna. Again, these
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materials are central to the dispute in the case, as
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they involve discussions between the US Attorney's Office and defense
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attorneys about notification to crime victims, and given the dates
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and communications, in all likelihood they would be related to
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the deceptive notification that the government made to the victims
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a few weeks later. All Right, folks, we're going to
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wrap up right here, and in the next episode, we're
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going to pick up where we left off. All of
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the information that goes with this episode can be found
11:54
in the description box. What's up, everyone, and welcome to
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another episode of the Epstein Chronicles. In this episode, we're
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going to pick up where we left off with the
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Brad Edwards CVR a affat David. Another illustration of where
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the crime fraud misconduct exception could potentially apply is with
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regard to information that the government possesses that Matthew Minchell
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has a personal or business relationship with defending Jeffrey Epstein.
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This could potentially show misconduct by Menchell, and it also
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potentially a motive to violate the victim's rights has explained previously,
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the government's privileged log has numerous entries showing that Menchell
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was substantially and personally involved in making decisions related to
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the Epstein prosecution. Of the first privilege log with regard
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to box number three P zero one one nine two
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three two P zero one one nine sixty six, the
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victims have information suggesting that immediately after leaving the employment
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with the US Attorney's Office, Menchell was associated with Epstein
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controlled entities or had some business relationship with them. The
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documents that the government possessed showing a personal or business
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relationship between one of its prosecutors and the man who
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was charged with prosecuting should be produced. The government has
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admitted that its internal affairs component, the Office of Professional Responsibility,
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has collected information about possible improper behavior during the investigation
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of the Epstein matter. Government answers to RFA twenty two.
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The fact that the government's own investigating agencies have collected
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such information demonstrates that there is a prima fossee case
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of improper behavior which is enough to trigger the crime
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fraud misconduct exception to various privileges, factual materials not privileged.
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As noted in the accompanying legal memorandum, factual materials are
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generally not covered by the privileges at issue. In the case,
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many of the material to which the government is asserting
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privilege are factual materials. Assertion of the attorney client privilege.
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The government has asserted attorney client privilege regarding many documents,
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Yet with regard to most of these assertions, it's impossible
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to determine who is the attorney, who is the client,
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whether professional legal services are being rendered, and whether the
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communications were confidential to those involved in the delivery of
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legal services. Accordingly, it's very difficult for me to respond
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to many of the assertions of attorney client privilege, and
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in any event, the government has failed to carry its
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burden of showing that privilege applies. An illustration of documents
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at to which attorney client privilege appears to have been
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improperly asserted or inadequately described is found on page seven
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of the first privilege log with regard to supplemental box
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number three. The entry for these twenty two pages of
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documents reads file folder entitled information Package Drafts, containing several
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descriptions to see how the attorney client privilege applies to
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these documents. I could provide many other illustrations of the problem.
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The god government's attorney client privileged claim directly covers situations
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where it was in a fiduciary relationship with the victims
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and therefore is limited in now asserting privilege. For example,
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page three of the supplemental privilege log contains an entry
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concerning a costa containing drafts of eleven thirty seven letters
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from Acosta to ken Starr and from Jay Slowman to
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Jay Lefkowitz, performance and victim notification with handwritten notes and
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edits by Marie Villafauna. This information goes very directly to
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the issue involved in the case, as it goes directly
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to victim notification, Yet the government has asserted an attorney
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client privilege to prevent the victims from learning what's in
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these documents. The fiduciary exception to the attorney client privilege
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applies in this situation and limits the government's ability to
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invoke a privilege. This also appears to be shared communication
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between the government and Epstein's attorneys, and it's unclear how
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the attorney client privilege could but ethically apply to such documents.
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As one example of why the victims have established a
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compelling need for material described in the preceding paragraph is
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the fact that the Court has indicated that it will
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be considering an estoppel argument raised by the government as
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a defense in the case. The Court has noted that
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this argument implicates a fact sensitive, equitable defense which must
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be considered in the historical, factual context of the entire
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interface between EPSTEIN, the relevant prosecutorial authorities, and the offense victims,
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including an assessment of the allegation of a deliberate conspiracy
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between EPSTEIN and federal prosecutors to keep the victims in
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the dark on the pendency of negotiation between EPSTEIN and
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federal authorities until well after the fact and presentation of
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the non prosecution agreement to them was completed. The materials
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to which the government is asserting attorney client privilege go
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directly to that interface between the victims, the government, and EPSTEIN.
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The victims have a compelling need for the information, and
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the fiduciary exception to the attorney client privilege applies to
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permit the Court to provide these documents to the victims.
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The government has not explained any harm that would come
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from releasing the documents covered by attorney client privilege to
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the victims. If the government raises any such harm, I
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respectfully request an opportunity to provide additional information on that
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alleged arm deliberative process privilege. Some of the correspondents that
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is being withheld by the government under the deliberative process
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privilege concerns an investigation that the Justice Department's Office of
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Professional Responsibility opened with regard to the Epstein case. This
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investigation was undertaken at the request of the victims in
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the case. On December tenth, twenty ten, CO Council Professor
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Paul Cassel of the University of Utah College of Law
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and I met with US Attorney for the Southern District
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of Florida regarding this case in the U s Attorney's
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Office in Miami, Florida. On that date, Professor Cassel presented
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a letter to the US Attorney, Mister Ferrer, asking him
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to personally investigate what happened during the Epstein prosecution and
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how the victims were treated during that investigation based on
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the privileged log that has been provided as well as
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subsequent correspondence sent to Professor Cassell. That request for investigation
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was turned over to OPR in Washington. The ultimate outcome
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of the OPR investigation is unclear. What is clear is
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that many documents are being withheld about that investigation, documents
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that would go to the central issue in the case.
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Approximately three hoole pages of privileged log Pages twelve through
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fourteen of the supplemental Log relate to the OPR investigation
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of how the Epstein case was handled and how the
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victims were treated. A deliberative process privilege can only be
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asserted with regard to the process of reaching a decision,
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not the ultimate decision itself. The government here has apparently
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asserted a deliberate process claim over not only the OPR process,
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but also over the OPR decision. It's not clear which
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document embodies the final OPR decision, or, given the inadequacies
19:11
of the government's log, whether that final decision has been produced.
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Given the limited description of the document that have been provided,
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it appears that the OPR decision may be reflected in
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a document found on page thirteen of the supplemental Log.
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The description there reads draft letter marked confidential to be
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opened by addresses only Robin c Ashton to a Fredo Ferrar,
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with a handwritten correction. No dates provided regarding the letter,
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nor is there any indication as to whether the letter
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was or was not circulated to other persons. It is
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also noteworthy that this letter is described as a draft letter.
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Nowhere in the privileged log is the final version of
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that letter indicated, raising questions about what was draft and
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what was final. If this is the final embodiment of
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the opr's conclusions, then this letter would not be protected
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by process of privilege because the deliberations would have come
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to an end. It's also worth noting that because OPR
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is an agency that investigates misconduct by federal prosecutors, it
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would not be providing attorney client advice to prosecutors, and
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its documents would not be attorney client privileged with regard to,
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for example, the US Attorney's Office for the Southern District
20:25
of Florida. The fact that OPR has investigated many of
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the exact claims raised by Jane do one and two
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and were able to gather documents unobstructed by the government
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in order to reach its conclusion likely means that production
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of the OPR file to the victims in this case
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could significantly shortcut this discovery process and the litigation. Additionally,
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if OPR needed the documents to investigate and make findings
20:50
regarding the victim's claims, then logically the victims share that
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need and have no other means through which to obtain
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the documents. The government has not explained any harm that
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would come from releasing the documents covered by the process
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of privilege to the victims. If the government raises any
21:08
such harm, I respectfully request an opportunity to provide additional
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information on that alleged harm. Investigative privilege. The investigative privilege
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is a qualified privilege which balances the need of a
21:21
particular litigate for access to information against any public interest
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in non disclosure. That balancing process is ordinarily made with
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reference to factors discussed and Frankhauser vers Rizzo on the
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facts of this case favor way in favor of disclosing
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the information the victims have requested with regard to factor one,
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the extent to which disclosure will thwart governmental process by
21:46
discouraging citizens from giving the government information I presented for
21:50
victims of Epstein's sex offenses in federal court. Change No
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Number one, change do No. Number two, and a victim
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I will refer to as SR and MJ and other
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victims of Jeffrey Epstein's abuse as well. If further information
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is disclosed about the case, that will not discourage them
22:09
from providing information, but rather will encourage them. I have
22:12
also talked personally the attorneys for a number of other
22:15
victims in the case. I have been told that many
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of these victims hope that Jang Do one and Jane
22:20
Do two are successful in their case. With regard to
22:24
factor number two, the impact upon persons who have given
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information of having their identities disclosed, Jang Do one and
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Jane Do two are not asking for information that would
22:34
identify any particular victim. Accordingly, there will be no effect
22:38
on other victims. Additionally, I'm aware of the true names
22:41
of many of Epstein's victims, and that information has not
22:44
been disseminated to the public, where those individual victims did
22:48
not wish for their identities to be disseminated. All right,
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We're going to wrap up this episode right here, and
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in the next episode dealing with the topic, We're going
22:56
to pick up where we left off. All of the
22:58
information that goes with if this episode can be found
23:01
in the description box. What's up everyone, and Welcome to
23:04
another episode of the Epstein Chronicles. In this episode, we're
23:08
going to pick up where we left off with Brad
23:10
Edwards and the CVRA Affid David. With regard to factor three,
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the degree to which governmental self evaluation and consequent program
23:20
improvement will be chilled by disclosure, this is a lawsuit
23:24
to force the compliance by the government with its CVRA obligation. Accordingly,
23:29
the government's program of providing victims' rights will be directly
23:32
improved if the victims are able to enforce their rights
23:35
in this lawsuit. With regard to factor four, whether the
23:39
information sought as factual data or a summary, many of
23:43
the items that the victims seek are factual summaries. An
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example of this is found at page eighteen of the
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first Privilege log with regard to box number three P
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zero one one seven seven eight to P zero one
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one seven eight eight. The entry reads file four entitled
24:00
six twelve nine Victim Notification Log containing chart with victim
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contact information and attorney notes regarding dates and types of contacts.
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This would include, for example, dates of contacts with Jane
24:13
Do number one and Jane Do number two, which would
24:16
be purely factual information with regard to factor five, whether
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the party seeking the discovery is an actual or potential
24:24
defendant in any criminal proceeding, either pending or reasonably likely
24:27
to follow from the incident. In the question, Jane one
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and Jane do two are plainly victims of a crime,
24:34
not criminal defendants. Indeed, as the court is aware, it's
24:37
the criminal defendant, Jeffrey Epstein who has undertaken several limited
24:41
intervention efforts to try and block disclosure of information to
24:45
the victims. With regard to the factor six, whether the
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police investigation has been completed, the investigation at Epstein was
24:53
completed years ago, and the government has not produced in
24:56
its privileged log any information indicating recent and vas activity.
25:02
With regard to factor seven, whether any inter department disciplinary
25:06
proceedings have arisen or may arise from the investigation, it
25:10
appears that OPR investigation has arisen as a direct result
25:14
of the victim's efforts in the case. However, it does
25:17
not appear that release of any information to the victims
25:20
would hamper any disciplinary proceedings. Indeed, to the extent that
25:24
the victims are able to obtain information about the case
25:28
and find information about misconduct, they can provide the information
25:32
to the government and other disciplinary entities as appropriate. With
25:37
regard to factor eight, whether the plaintiff suit is non
25:40
frivolous and broaden good faith. It should be clear at
25:43
this juncture of a five year long case that the
25:45
victims have substantial claim that has brought in good faith.
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With regard to factor nine, whether the information sought is
25:52
available through other discovery or from other sources. As recounted
25:57
throughout this Avia David, the victims have no other way
25:59
to obtain the information at issue in this privileged debate,
26:03
as it involves information internal to the Justice Department. With
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regard to factor ten, the importance of information saw to
26:11
the plaintiff's case, the information that the victims are seeking
26:15
is highly important to their case. Indeed, without adequate proof,
26:19
the court is indicated that it may have to deny
26:21
the victim's petition. Throughout this Avid David I have provided
26:25
numerous examples and explanations of why the victims need the
26:28
information that they're requesting. The documents to which the government
26:33
is asserting investigative privilege, for example, bear directly on the
26:37
government's alleged estoppel defense, which victims need to complete evidentiary
26:41
record to dispute work product doctrine. A work product claim
26:46
can be defeated by showing of substantial need and undue
26:49
hardship to obtain the material in other ways. In this Avid, David,
26:54
I have tried to articulate the specific and compelling need
26:57
for all the materials that victims are seeking. Will not
27:00
repeat all of those assertions here, but simply note that
27:03
I stand ready to provide any additional information that the
27:06
court may require to determine the compelling need that the
27:09
victims have for the materials they have requested, as well
27:13
as the undue hardship, if not actual impossibility of obtaining
27:17
the materials. In other ways, any balancing of considerations tips
27:22
decisively in the victim's favor. As one example, the victims
27:26
have a compelling need for the materials that OPR collected
27:29
as part of its investigation. Because Justice Department attorneys are
27:34
generally required to talk to OPR investigators, OPR was apparently
27:38
able to investigate the claim of misconduct related to the
27:41
Epstein case by getting statements from the attorneys involved. These
27:45
interviews appear to be recorded in materials found at page
27:49
fourteen of the Supplemental Privilege Log d two sixteen one
27:53
with regard to supplemental box number three p DASH zero
27:57
one three nine five six two p D DASH zero
28:00
one three eight four six a total of fourteen pages.
28:06
Judging from the entry, these notes would be factual statements
28:09
from Justice Department prosecutors about how the Epstein case was
28:12
handled and whether any misconduct occurred during the handling of
28:16
the case. Those are central issues in the case. There's
28:20
no other way for the victims to obtain information about
28:23
these subjects because the Justice Department has declined to provide
28:27
information on the subject. The victims have established a substantial
28:32
need for the material there are requesting in the previous
28:34
paragraphs of this Avid David that review requests by request
28:38
their document production Request numbers one through twenty five and
28:42
supplemental Requests number one as Another example of why the
28:46
victims have established a compelling need for the materials is
28:50
the fact that the Court has indicated that it will
28:53
be considering an estoppel argument raised by the government as
28:56
a defense in the case. The Court has noted that
28:59
this argument implicates a fact sensitive equitable defense which must
29:03
be considered in the historical, factual context of the entire
29:07
interface between EPSTEIN, the relevant prosecutorial authorities, and the federal
29:12
offense victims, including an assessment of the allegation of a
29:16
deliberate conspiracy between EPSTEIN and federal prosecutors to keep the
29:21
victims in the dark on the pendency of negotiation between
29:24
EPSTEIN and federal authorities until after the fact and presentation
29:29
of the non prosecution agreement. The materials to which the
29:33
government is asserting work product protection go directly to that
29:36
interface between the victims, the government, and EPSTEIN. The victims
29:40
have no other way of showing what that interface is.
29:43
The government will not be harmed if the materials are
29:46
provided to the victims grand jury information. The victims legal
29:50
pleading has explained why the government has not properly asserted
29:54
any grand jury secrecy to the documents at issue. In addition,
29:58
many of the government's grand jury privilege desertions appear to
30:01
broadly cover both grand jury and non grand jury information.
30:06
Even if the court allows the government to assert some
30:08
form of grand jury privilege, it should require the government
30:11
to sever grand jury material from non grand jury material.
30:15
An illustration of this problem comes from page twelve of
30:18
the first Privilege log with regard to box number two
30:22
p DASH zero zero eight six one six to P
30:25
DASH zero zero eight six eighty six. The entry reads
30:29
file folder entitled FBI Summary Charts containing chart prepared at
30:33
direction of AUSA, containing victim names, identifying information, summary of activity,
30:40
and other information relevant to the indictment. This does not
30:43
appear to be a document that was ever presented to
30:46
the grand jury or that directly discloses grand jury preceding. Moreover,
30:51
to the extent that it involves some kind of limited
30:53
disclosure of grand jury proceedings, that limited disclosure could be redacted,
30:58
and the other information provided to the victims, it does
31:01
not appear that any of the alleged grand jury materials
31:04
that the government is asserting privilege involve ongoing grand jury issues. Moreover,
31:09
it does not appear that disclosing any of the materials
31:12
would tip off a potential target to a government investigation.
31:16
Of course, Jeffrey Epstein and his associates are well aware
31:19
of the government's investigation into their crimes against young girls
31:23
for sexual purposes. The government has not explained any harm
31:28
that would come from releasing the documents to the victims.
31:31
If the government raises any such harm, I respectfully request
31:34
an opportunity to provide additional information on that alleged harm
31:39
privacy rights of other victims. Jaine Do number one and
31:44
Jaine Do number two do not seek confidential or identifying
31:47
information about any other victim. To clarify that fact, on
31:51
July thirty first, twenty thirteen, I sent a letter to
31:54
the government stating in part that to avoid any interference
31:58
with any privacy rights of victim who are not parties
32:01
to this litigation, Chaine Do number one and Jane Do
32:04
number two are not seeking any identifying information about other
32:08
victims in any of the documents that Jane Do number
32:12
one or Jane Do number two have requested from the
32:14
government that they produce. The government should not produce the
32:17
names of other victims or other identifying information eg. Address
32:22
or a telephone number, but should instead redact that information.
32:27
I declare, under penalty of perjury, pursuant to US Code
32:30
twenty eight, Section seventeen forty six, that the foregoing is
32:35
true and correct to the best of my knowledge and belief,
32:38
executed this sixteenth day of August twenty thirteen, and this
32:43
document was signed by Brad Edwards all right, So that
32:47
finishes up the affid David of Brad Edwards when it
32:50
comes to the CVRA, and now with this new dump,
32:54
we have a lot of court records to dive into
32:56
and the grand jury material, especially because we've never seen
32:59
that right, so I want to make sure that we
33:01
get a handle on that as well. So over the
33:04
next couple of days, we're going to be diving deep
33:06
into that grand jury material, and that way everybody gets
33:09
to see for themselves what we've been saying for all
33:12
these years that the fix was in and this has
33:14
been a cover up since the start. All of the
33:18
information that goes with this episode can be found in
33:21
the description box.