<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Thursday, September 22, 2016 9:36 PM</td></tr><tr><td>To:</td><td>Darren Indyke</td></tr><tr><td>Subject:</td><td>Re: Privileged and Confidential</td></tr></table>

I think we should start with not 20 girls but two charges

On Thursday, 22 September 2016, Darren Indyke > wrote:

THIS IS PART OF THE PRE-TR=AL STIP THAT TONJA WILL PROPOSE TO JACK SCAROLA. I GIVE YOU EDWARDS<=span>' PROPOSED STATEMENT AND YOURS, BUT WE CANNOT EDIT EDWARDS=/span>' PROPOSED STATEMENT. =I HAVE BEEN TOLD BY ALL THAT WE MUST KEEP THE STATEMENT OF THE CASE TONED =OWN. PLEASE ADVISE. THANKS.

## 9. =C2 Short, Plain Statement of the Case Which Will Be Read to the Jury:

Edwards' Proposed Statem=nt:

Jeffrey Epstein =as criminally accused of engaging in illicit sexual activity with multiple under-aged females. More than 20 persons alleging to be victims of Epstein's crimes brought civil suits against Epstein. Several=of those persons were represented by Attorney Bradley Edwards. While the claims on behalf of those persons were being prosecuted by Edwards, it was publicly disclosed that the senior partner in the law firm that employed Edwards, Sc=tt Rothstein, had conducted a fraudulent scheme which, in part, had used the claims against Epstein to induce investors to buy interests in non-existent settlements. Rothstein's scheme raised hundreds of millions o= dollars and was one of the largest frauds in U.S. history.

After the Rothstein scheme unraveled and the fraud was publicly disclosed, Epstein went to his attorneys and arranged for a lawsuit to be filed against Edwards. Epstein's attorneys then filed suit against Edwards a=leging that he was a knowing participant in Rothstein's fraud. Epstein la=er settled the claims being prosecuted by Edwards on his client's behalf, but =dwards continued to pursue an action challenging the plea deal Epstein struck with the Feder=l government.

Bradley Edwar=s defended against Epstein's lawsuit, challenging it on the grounds t=at it had no legal or factual support. Shortly before the Court was scheduled to rule=on Mr. Edwards' challenge, Epstein dropped all of his claims against E=wards. Bradley Edwards has now sued Jeffrey Epstein alleging that the sole reason =or Epstein's lawsuit was an attempt to intimidate Edwards into abandon=ng or compromising his clients' interests.

## Epstein's Proposed Statement:=u>

Jeffrey Epstein was a Defendant in three civil suits brought by Bradley Edwards as Plaintiffs' attorney. During the time that the litigation was=pending, Edwards became a partner at the law firm of Rothstein Rosenfeldt Adler (RRA=, which was a front for the largest Ponzi scheme in South Florida history. =AO The cases against Epstein that were being prosecuted by Edwards while he wa= a partner at RRA were used to further the Ponzi scheme and defraud investors =f millions of dollars. Edwards's partner at RRA and the Co-Defe=dant in this case, Scott Rothstein, plead guilty to this scheme and is serving fift= (50) years in federal prison. Several other attorneys and co-conspira=ors have plead guilty or have been convicted in connection with this Ponzi sche=e and are serving time, or did serve time, in federal prison. <=p>

## Epstein's Proposed Statement:=u> (cont.)

Epstein learned of the use in the Ponzi scheme of the cases Edwards was prosecuting against Epstein while Edwards was a partner at RRA. From detailed ple=dings in lawsuits filed against RRA, Epstein learned how Edwards's actual Epstein case file= were shown to investors in the Ponzi scheme to persuade them of the substantial value =f the Epstein cases and of investments in fictitious settlements of similar c=ses against Epstein. These facts, together with Edwards's actions in the Epstein cases, and the pleadings and =iscovery filed by Edwards, specifically during the timeframe that Edwards was a part=er at RRA, supported Epstein's reasonable belief that Epstein'= claims against Edwards were supported by existing facts, and Epstein, through counsel, fil=d suit against Edwards and his partner Rothstein. Edwards immediately filed hi= Counterclaim for Abuse of Process and Malicious Prosecution. Only the Malicious Prosecution claim remains. Epstein dismissed his case against Edwards, with=ut prejudice, because of the difficulty he was having gathering discovery and other information to prove his case due to adverse rulings from the Court regarding discovery, the inability to get documents from the Trustee for RR=, and the ongoing federal investigation into RRA and the Ponzi scheme. =u>

=C2 please note

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