Filing # 36529442 E-Filed 01/13/2016 03:48:01 PM IN .THE CIRCUIT COURT .OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiff(s), vs, ALAN M. DERSHOWITZ, Defendant(s). / RESPONSE TO FOURTH SET OF DOCUMENT REQUESTS TO BRADLEY J. EDWARDS Plaintiff, Bradley J. Edwrds, by and through his undersigned attorneys and pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby responds to Defendant, Alan M. Dershowitz’s, Fourth Set of Document Requests to Bradley J. Edwards, dated December 11, 2015 as follows: 1, Please see attached Statement by | (ad the Federal Bureau of Investigation [Redacted] I HEREBY CERTIFY that a true and correct. copy of the foregoing was sent via E- Ww Serve to all Counsel on the attached list, this 0 day of he ~*, 2016. Jack Scarola Florida Bar No.: 169440 Attorney E-Mail(s): mep@searcylaw.com Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys for Plaintiffs and *** FILED: BROWARD COUNTY, FL: HOWARD FORMAN, CLERK 1/13/2016 3:48:01 PM.**** EFTA00597076

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Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072 Response to Fourth Set of Document Requests to Bradley J, Edwards COUNSEL LIST Sigrid Stone McCawley, Esquire Boies Schiller & Flexner, LLP 401.E Las Olas Boulevard., Suite 1200 Fort Lauderdale, FL_33301 Phone: Thomas Emerson Scott, Jr., Esquire Cole Scott & Kissane P.A. 9150 S Dadeland Boulevard, Suite 1400 Miami, FL_ 33156 Phone: Fax: Attorneys for Alan M. Dershowitz Bradley J. Edwards, E Farmer Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL_33301 Phone: Fax: Kenneth A. Sweder, Esquire n Sweder & Ross, LLP 131 Oliver Street Boston, MA 02110 Phon Fax: Attorneys for Alan M. Dershowitz — Eiler, _ Mary E. Borja, Esquire Richard A. Simpson, Esquire RSimpson@wileyrein.com Wiley Rein, LLP 1776 K Street NW Washington, DC_ 20006 Attorneys for Alan M. Dershowitz Joni J. Jones i Assistant Utah Attorney General 160 E300S Salt Lake City, UT_84114 Phone: Fax: Attorneys for Paul Casse EFTA00597077

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FD-302 (Rev. $-8-10) -1 off2- FEDERAL BUREAU OF INVESTIGATION Date of entry 07/05/2013 ED «232-2. o2re MMMM. ate of birth Social Security Account Number United States Citizen and Australian Permanent Resident, residence New South Wales, Australia, 2261 was interviewed at the United States Consulate in Sydney, Australia. [RM was advised of the identity of the interviewing agents and purpose of the interview. Present during the interview was Federal Bureau of Investigation Special Agent and via telephone, Assistant ned United States Attorney WE) provided the < following information: | was born in Sacramento, California to parents date of birth currentl date of birth a currently resides in Hs moved to Palm Beach County, Florida with her parents when she was four years old.and returned to California at age 11. She returned to Florida at age 13 and was placed in a rehabilitation or foster. care facility in West Palm Beach, Florida. ran away from the rehabilitation facility when she was approximately 14 years old, and while living on the streets in Miami, Florida, she met b6 b7c was training to be an.escort a life off of the streets which made her feel Investigationon 03/17/2011 q Sydney, Australia’ (In Person) Filey 31E-MM-108062 Date drafted 07/05/2013 b6 SS SS SS S™ by This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency, it and its contents are not to be distributed outside your agency. EFTA00597078

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FD-302a (Rev. 05-08-10) 31E-MM= Continuation of FD-302 of ,On 93/17/2011 page 2 of 12 like she was locked into the relationship[ __] gave Ls pharmaceutical drugs toward the end of their relationship. b6 b7c FY relationship wi lended while she was at a private ranch near Ocala, Florida. elephonically contacted a childhood friend, from a telephone at the ranch. [x bé rom_elementary school and called him at the home telephone b7c of his parents GIUFFRE told very lonely, an sked her why she did not. leave lephone conversation wit the recreational vehicle staying in at the ranch didnot strike her her. belongings and told her she was going to live with another man. b6 felt that she was sent to ut did not know the b7c specifics of the arrangement. ngaged in sexual activity with stated tayed with for approximately one or two weeks before the police located her and returned her to her parents. a «2: interviewed by a male detective. Parents were still married at the time and lived near believed there was an FBI investigation related to She never saw[___Jagain after In approximately June 1998 or 1999, QMMbegan working at Donald Trump's Mar-A-Lago Club in Palm Beach, .Florida,. a ee was able to help her gain employment as a baby sitter and later as a locker room attendant at the club. [RRM started studying for her GED and wanted to become a massage therapist. approached b bé b7c 5:00 p.m. the same day, her father drove her to a residence at WN consulted her father about the opportunity and at ey EFTA00597079

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FD-302a (Rev. 05-08-10) 31E-MM-108062 ——— ls 03/17/2011 Page. 2 Of 12 ; hs Florida.[__]spoke i father and told him it was a wonderful opportunity for b6 was led bic upstairs b6 bic instructed beginning the massage. The massage bega techniques to a to wash her hands prior to emonstrated massage ng the course of the massage uestioned b6 about her past, including her time as a runaway. was also b7c asked if.she took birth control. b6 bic was given instruction and began kissing b6 bic At..the conclusion,| __ instructed o obtain two warm wash clothes. One wash cloth was used to clean b6 b7c hen moved to the steam room and shower where ith soap and a loofah in the shower. At the conclusion of the shower, went downstairs and b6 b7c Arrangement to return to the house. the following day after work. cellular phone number was given ce: | EFTA00597080

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FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of |. ‘on 03/17/2011 page 4 Of 12 The same routine and pattern of massages and sexual activity between continued for between one and two weeks. At b6. bic the option to quit her job at Mar-A-Lago and travel There was also discussion of ivi ing. was to b6 b7c and was introduced asj HM. soon _began traveling[ ——«dFor the initial six months, | traveled round the United States and Caribbean, b6é including California, New York Cit New Mexico, and various business b7Cc Six to nine months after began working for b6 b7c CE CCE provided a normal massage t as NU. Shortly theresfter, years old-at the time ; advisedf——SSS—~=sidintxodluced her to the drug Xanax. She explained that Xanax helped her escape from reality but allowed her to b6 still function normally. Xanax helped her go forward with what she was bic doing with _jand others. Her habit went from two pills per day up to eight pills per day. WS) s¢cond_client was an-academic of s older American male from Miami International Airport to b6 commercial airline. was picked up at the b7C airport by nd then taken to the island by boat. [xy EFTA00597081

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FD-302a (Rev. 05-08-10) 31E-MM=108062 Continuation of FD-302 of A -- On 03/17/2011 page 5 Of 12 pointed out that client and wanted jet skis and participate in other island activities MMMM Spent two days on the island with the client. assumes the client also traveled commercially. Duri the following several months, traveled internationally Prior to her traveling ir are SO Ea sin getting her passport. got passport photographs of herself. and bé he remaining paperwork was taken care of by bic traveled to Paris, France, the South of France, London, England, Africa, and Spain. While in Paris, WM. s ecalled staying at a hotel overlooking the Champs-Elysees. While . During the international b6 bic offered a contract. agreed to the contract for her story and was paid $140,000 for the story, $10,000 when the article was printed, and another $10,000 to be wired into [J account in May 2011. The contract prevented [MJ from talking to any other press for a specified period. advised that she ith detailed informatio b6 b7c b6 b7c EFTA00597082

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FD-302a (Rev, 05-08-10) 31E-MM=108062 ama SS SS 4 03/17/2011 page 6 of 12 b6 b7c pp at age 16, b6 bic b6 b7C would dress b6 b7C explained GIUFFRE provided an b6 bic described An unknown individual GIUFFRE saw when she arrived at b6 b7c ecause she could not believe EFTA00597083

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FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FO-302 of A <- (On 03/17/2011 | page 7 of 12 believed the girls may have been b6 but b7c was not certain of involvement. icture of herself she nted to S$ b7c described some of the unique interior areas of b6 b7c Po which referred tof which was where While in New York, (J also stayed at_an apartment on 66th street apartments in the same building. According to he b7c apartment building on 66th street was owned bi IUFFRE advised that she had a photograph of the interior of the 66th Street HE aivised that some of her photographs that were provided to her civil attorneys by her family were not returned. One of the missing photos depicted QINNNNJ wearing a pink dress while seated on a quad bike. NU wa emale that formerly lived in bé b7c EFTA00597084

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FD-302a (Rev. 05-08-10) 31E-MM=108062 Continanion ota ot [I (On 03/17/2011 pyge 8 Of 12 LNU and QJ went. shopping together and purchased clothing and sex b6 b7c b6 b7c WM sesed a cellular telephone She believed it was a New York City number but could not recall the number. Gs could only remember face not their names. [x did not unsuccessfully to get recalled b6 not recall the wording. . b7c | traveled to a-self-help conference.at a hotel in New Orleans, Louisiana. The hotel w d Rock Café in New wae Orleans. [RRRRBMMJ traveled the worl including the USVI, New York, Santa Fe, Palm Beach, France, Africa, Spain and the United Kingdom. ets b6 recalled visiting b7c Alhambra Castile in Spain. a eventually traveled to the United Kingdom and EFTA00597085

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FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of FD-302 of os ee ,On .93/17/2011 Page 9 of 12 while there] ___ipproached WMMMMMMsin a very excited manner and told her they had to go shopping to pick out a dress because would be b6 dancing with Sc FY and[__ vent shopping and purchased makeu Burberr ag. The items were purchased with an returned instructed JJ to get ready. came down after getting ready, she was introduced to clothing, and a az bé b7c traveled to CLUB TRAMP] = Bk st copaerramet SS returnin had not received any direction After returning t requested to take a photograph of her advised that she still had the original photograph in her possession and would provide it to the interviewing agents. roceeded with Approximately two months later, GIUFFRE recalled joking about trading GIUFFRE in because she.was getting too old. EFTA00597086

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FD-302a (Rev. 05-08-10) 31E-MM-108062 Continuation of F302 of ,On 03/17/2011 page 10 of 12 WM «was using Xanax heavily at the time, b7c and-her recollection was not clear.. She remembered there were many models on the island that did not speak English along with a modeling person who had an unknown accent. b6 b7c id not have a problem with JJ using prescription drugs. b6 bic (TROE NAME UNKNOWN). __] a ranch employee ee | TY b6 She did have a photograph of the ranch bic Gs et numerous famous people politicians, and celebrities. could not recall his name. employee, including b6 b7c HEM s<eceived many gifts jewelry, watches, bags, shoes, make up, clothj bé b7c receive massage training. In August 2002, QM traveled by commercial airline to Bangkok, Thailand and began her massage training at International Training Massage School (ITM) where she received fication. She stayed at the Princess Hotel in Thailand but never did. [I met her future husband during her visit to Thailand. [9 contacte elephonically and et llen in love with someone, EFTA00597087

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PD-302a (Rev. 05-08-10) 31E-MM=108062 Continuation oc FD-302 of [A On 03/17/2011 page 11 Of 12 had not heard from received a tated he was an b6é b7c telephone call from FBI agent. He was trying to determine what she knew about! She di ot tel anything about her knowledge of She-also received another telephone call from a person that indicated he was an FBI agent. She did not tell that individual anything either. She also received a.call from an attorney that was trying to dete ne if she spoken with anyone or was willing to speak to anyone She explained that she was receiving telephone calls from people whom she did not know and that she was uncomfortable telling them anything over the telephone. One or two weeks later, an_unknown attorney and telephonically. b6 b7c WM «was using a cellular telephone belonging to her husband. She nor her husband could recall the telephone number but. advised that the carrier was OPTUS telephone company. WE sceviewed a series of photographs of individuals and identified the following: Page 1, number 2f__junv, arkaf | b6é Page 3, number Se Page 4, number af __ kuna 7L___ Page 2, number 1, Page 2, number 6 Page 4, number HM) aivised that the following were familiar to her, but she could not recall their names or her association to them: EFTA00597088

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FD-302a (Rev. 05-08-10) 31E-MM-108062 Contimaion of £0302 of On 03/17/2011 page 12 of 12 Page 1, number 4 Page 2, numbers 7 and 6 Page 3, number 8 Page 4, number 1 Page 5, numbers 5 and 8 The images reviewed by JBN) were placed in a 1A envelope of the case file. When questioned about United States Customs and Border (CBP) Patrol records of her entries into the United States, JNJ advised t January 2001 record was-the return from her London, England tri The April 2001 CBP record was her return to the United States on | could not recall her travel from March and May 2001 CPB records. (9M) advised that her United States Passport was turned over to the United States Consulate in Sydney, Australia. On March 18, 2011, writer, sa{__._Jand b6 traveled to [MJ residence where she provided 20 photographs and her b7C ITM massage school certification, FD-597 Receipts. for Property. were executed for the items and a copy was provided to QM. it is noted that the receipts were dated based on the United States Bastern Standard Time Zone date. The photographs, certification and original FD-597s were placed in-a 1A envelopes of case file. EFTA00597089