Filing i/ 36529442 E-Filed 01/13/2016 03:48:01 PM

Filing i/ 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 to the Federal Bureau of Investigation [Redacted] I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- Serve to all Counsel on the attached list, this 1-54%- day of , 2016. Jack Scarola Florida Bar No.: 169440 Attorney E-Mail(s): and mej)@searcylaw.com Primary E-Mail: rn Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach Florida 33409 Phone: Fax: Attorneys for Plaintiffs *** FILED: BROWARD COUNTY. FL HOWARD FORMAN. CLERK 1/13/2016 3:48:01 PM.**** EFTA00597076 Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072 Response to Fourth Set of Document Requests to Bradley J. Edwards COUNSEL LIST Sigrid Stone McCawle , Esquire Boles Schiller & Flexner, LLP 401 E Las Olas Boulevard., Suite 1200 Fort Lauderdal 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. Edward E_squire Farmer Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale FL 3301 Phone: Fax: Kenneth A. Sweder Es uire Sweder & Ross, LLP 131 Oliver Street Boston, MA 02110 Phone: Fax: Attorneys for Alan M. Dershowitz Ashle Eller. Esquire Mar E. Bo 'a, Esquire Richard A. Simpson, Esquire [email protected] Wiley Rein, LLP 1776 K Street NW Washington, DC 20006 Phone: Fax: Attorneys for Alan M. Dershowitz Joni J. Jones Es uire Assistant Utah Attorney General 160 E 300 S Salt Lake CttvjUT 84114 Phone: Fax: Attorneys for Paul Cassell EFTA00597077 1O-302 (Rev. 34-10) I -1 of 12- FEDERAL BUREAU OF INVESTIGATION — . OcraReartsoi Date of entry 07/05/2013 maiden name date 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. llllllllllllllllll, 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 land via telephone, Assistant United States Attorney' I provided the following information: was born in Sacramento, California to parents' 'date of birth' currently resides in and date of birth currently resides in 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' 'was training to be an escort' gave a life off of the streets which made her feel Inveitiptionon 03/17/2011 at Sydney, Australia (In Person) Filet 31S-MM-108062 by I MS 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 disuibuted outside your agency. Ea tined 07/05/2013 b6 b7C b6 b7C b6 b7C b6 b7C EFTA00597078 nNmnsateltas-mao 31E -MM inlla Continuation of FD-302 of , On03/17/2011 pmm 2 of 12 like she was locked into the relationship' gave IM pharmaceutical drugs toward the end of their relationship. relationship wi h ended while she was at a private ranch near Ocala, Florida. elephonically contacted a childhood friend,' from a telephone at the ranch. knew' 'from elementary school and called him at the home telephone of his parents GIUFFRE told' Ishe was very lonely, an sked her why she did not leave lephone conversation with the recreational vehicle V) as did not 'pack staying in at strike her' her belongings and the ranch' told her she was going to live with another man. Eli felt that specifics she was sent to of the arrangement. who was described as a whit ut did not know the sexual activity with tayed with approximately one or two weeks before the police located her and her to her parents. was interviewed by a male detective. parents were still married at the time and lived near Florida. believed there was an FBI investigation related to She never saw again after In approximately June 1998 or 1999, Trump's Mar-A-Lago be an working at Donald Club in Palm Beach, Florida. father was able to help her gain as a locker room attendant at the employment as club. therapist. In approached by a baby sitter and later started studying for her GED and wanted to become a massage August, as reading an anatomy/massage book and was land help her get her masseuse accreditation consulted her father about the opportunity and at a roximately 5:00 p.m. the same day, her father drove her to a residence at b6 b7C b6 b7C b6 b7C b6 b7C EFTA00597079 FD-302a (Rev. 05-08.10) 31E-MM-108062 Continuation of FD-302 of on 03/17/2011 pmn 3 of 12 Florida. spoke wither father and told him it was a wonderful oppirtunity for met also known as was led upstairs Once upstairs in instructed to wash her hands prior to beginning the massa e The massage begs !demonstrated massage techniques to b6 b7C b6 b7c 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. was given instruction and began kissing' At the conclusion,' 'instructed o obtain two warm wash clothes. One wash cloth was used to clean second wasl to help him relax. describe and hen moved to the steam room and shower where massaged kith soap and a loofah in the shower. At the conclusion of the shower, went downstairs and[ MS Arrangement e for to return to the house the following day after work. cellular phone number was given tol Ib6 b7c b6 b7c b6 b7C b6 b7C EFTA00597080 and FD-302a (Rev. 05-0840) 31E-MM-108062 ComemaamofFD-302of L. .00 03/17/2011 pn, 4 of 12 The same routine and pattern of massages and sexual activity between land continued for between one and two weeks. At times, 'offered the option to quit her job at Mar-A-Lago and travel There was also discussion of receiving massage training. was to be paid $200.00 per day for travel and $200.00 per hour for massages. Early in her relationship with and was introduced asi !assistant. soon began traveling traveled around the including California, New York City( New tri s. During those trips,! ICJ Six to nine months after For the initial six months, United States and Caribbean, Mexico ) and various business began working for was introduced t4 ILNU4 in !Florida. lat the time. met the couple at a condominium next to the [The condominium was bought( land was a lIn the condominium, lill. provided a normal massage t LNU. Shortly thereafter,) LNU provided an erotic massage to IIIIII!II cleanedr paid cash paid advised She explained that Xanax helped still function normally. Xanax doing with( and others. eight pills per day. lIn addition, She was was 16 introduced her to the drug Xanax. her escape from reality but allowed her to helped her go forward with what she was Her habit went from two pills per day up to second client was an academic of some sort described as an older American male (sent from Miami International Airport to Iby commercial airline. was picked up at the airport byl land then taken to the island by boat. b6 b7C b6 b7C b6 b7C b6 b7C b6 b7C b6 b7C EFTA00597081 FD-302a (Rev. 05-0S-I0) 31E-MM-108062 Continuation of FD-302 of L. O, 03/17/2011 ipne 5 of 12 pointed out that' client to ride jet skis and participate in other with the client. assumes the client also traveled commercially. instructed to entertain the land wanted island activities' spent two days on island the During the following several months, traveled internationally I 'Prior to her traveling abroad ssisted in getting her pass ort. got passport photographs of herself and provided them t he remaining paperwork was taken care of by I I II traveled to Paris, France, the South of France, London, England, Africa, and Spain. While in Paris, recalled stayin at a hotel overlooking the Champs-Elysees. 1111911 traveling traveled on a black plane. During travel,( times, IIIIIII would'While the international (At 'Rarely a day would pass' 'contacted throu land wanted to talk to land offered a contract. agreed to the contract for her story and was paid $140,000 for the story, 810,000 when the article was printed, and another $10,000 to be wired into account in May 2011. The contract prevented from talking to any other press for a specified period. advised that she provided' 'with detailed informatio b6 b7C b6 b7C b6 b7C b6 b7C b6 b7C EFTA00597082 FD-30Ta (Rev 05-013-10) 31E—MM-108062 Continuation of FD-302 of 03/17/2011 int 6 of 12 At age 16, met 9 I believed she ands were approximately the same age. an.l WOU ci cite although GIUFFREexplained provided an An unknown individual described GIUFFRE sa hen she arrived at had' sai. that day was a low stage in ecause she could not believe relationship never b6 b7C b6 b7C b6 b7C b6 b7C b6 b7C b6 b7C EFTA00597083 FD-302a (Rev. 05-0840) 31E-14N-108062 Continuation of FD-302 saw of L. on 03/17/2011 pmo 7 of 12 I I. believed the girls may have been) b6 'but b7C b6 b7C was not certain off 'involvement. had a picture of herself she wanted to give( described some of the unique interior areas of b6 b7C 'which referred to which was where While in New York, also stayed at an apartment was aware of apartments in the same building. According to apartment building on 66th street was owned b advised that she had a photo raph of the interior of the apartment among other photos 66th on 66th street additional he IUFFRE Street advised that some of her photographs that were provided to her civil attorneys by her family were not returned. One of the missing photos depicted wearing a pink dress while seated on a quad bike. ILNU was' kemale that formerly lived inl b6 b7C b6 b7C EFTA00597084 FD-302a (Rev. 05-0840) 31E-MM-108062 Continuation of FD-302 of 0, 03/17/2011 p,40 8 of 12 LNU and went shopping together and purchased clothing and sex toys. „„„, explained that' used a cellular telephone She believed it was a New York City number but could not recall the number. and could only remember faces Inot their names. did not' but she did try unsuccessfully to get recalled' not recall the wording. iMINI advised'1,6 b7c b6 b7C 'but she could b6 'LNU. b7C traveled' Ito a self-help conference at a hotel in New Orleans, Louisiana. The hotel s near the Har Rock Café in New Orleans. traveled the world including the USVI, New York, Santa Fe, Palm Beach, France, Africa, Spain and the United Kingdom. recalled visiting Alhambra Castle in Spain. I 'GIUFFRE eventually traveled to the United Kingdom and b6 b7C 136 b7C EFTA00597085 FD-3023 (Rev. 05-08-10) 318-MM-108062 Colt-nation of FD-302 of 0n 03/17/2011 ft 9 of 12 while there' approached in a very excited manner and told her they had to go shopping to pick out a dress because would be dancing with' and' went shopping and purchased makeup, clothin , and a Burberry ba . The items were purchased withI an returned' I instructed to get read . When came down after getting ready, she was introduced to traveled to CLUB TRAM danced at CLUB TRAMP' Istayed at CLUB TRAMP for an hour or hour and a half and drank a couple of cocktails before returnin• to had not received an direction from After returning to( 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. proceeded with' Approximately two months later, met' lat recalled' ILNU, 'GIUFFRE recalled (joking about trading GIUFFRE in because she was getting too old. 1,6 b7C b6 b7C b6 b7C EFTA00597086 misarauLmosmwo Cs" -A\ 31E-MM-108062 Continuation of FD-302 of ,On 03/17/2011 ptio 10 of 12 cod <0' QA .)4 A recalled meeting" < b6 was using Xanax heavily at tfin lime' e?,t . NC" b A and her recollection was not clear. She remembered there were many models \ tja ..v.., o.on the island that did not speak English along with a modeling person who 4> .,:ss, had an unknown accent. id not have a problem with using prescription drugs. was described by as a a ranch employee )L ;TRUE NAME UNKNOWN) !but could not recall his name. She did have a photograph of the ranch employee. met numerous famous people ncluding &it a b6 QA b7C Sr ^4. Ce \,‘4 Ss'r b6 b7C b6 b7C academics politicians and celebrities. She me land 1b6 b7C b6 b7C andI received many gifts' 'including jewelry, watches, bags, shoes, make up, clot 'no. and home furnishingsfurnishings.'I 1 LAMMleft I all of the items behind when she traveled to Thailand to receive massage training. In August 2002, traveled by commercial airline to Bangkok, Thailand and began her massage training at International Training Massage School(ITM) where she received i massaae har certification. She stayed at the Princess Hotel in Thailand, but never did. met her future husband,I J during her visit to Thailand. contacted$ (telephonically and raid him she had fallen in love with someone. I I I 1,6 b7C EFTA00597087 Page 4, Page 4, Page 5, .<4" FD-302a (Rev. 05-08-10) _cam Continuation 31E-M4-108662 of FD-302 of ,on 03/17/2011 "ate 11 of 12 _4( esr b6 had not heard from received a telephone FBI agent. call fromr Inuring that call stated he was an.b7c 4t4. C5S He was trying to determine what she knew about I She did not tell' anything about her knowledge of IShe also received another telephone call from a c.)"- c.)"- 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 determine if she had 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' contacted Ia. telephonically.' 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. reviewed a series of photographs of individuals and identified the following: Page 1, Page 1, Page 2, Page 2, Page 3, number 1, number number 1, number 6, number 2, Page 4, number 3, number 7, number 8, number 1, 24 LNU, a.k.a LNU advised that the following were familiar to her, but she could not recall their names or her association to them: b6 b7C b6 b7c EFTA00597088 815.1028 (Rev. 05.08-10) 31E-MM-108062 Cool:tuition of FD-302 of .O, 03/17/2011 Jaw 12 of 12 Page 1, number 4 Page 2, numbers 7 and 8 Page 3, number B Page 4, number 1 Page 5, numbers 5 and 8 The images reviewed by were placed in a lA envelope of the case file. When questioned about United States Customs and Border (CBP) Patrol records of her entries into the United States, advised t h r January 2001 record was the return from her London, England tri IThe April 2001 CBP record was her return to the United Statesl could not recall her travel from March and May 2001 CPB records. Passport was turned over to the United States Consulate in Sydney, Australia. advised that her United States On March 18, 2011, writer, SAE andl traveled to residence where she provided 20 ITM massage school certification. FD-597 Receipts for executed for the items and a copy was provided to the receipts were dated based on the United States Eastern Standard Time Zone date. The photographs, certification and original FD-597s were placed in a 1A envelopes of case file. I photographs and her Property were . It is noted that b6 b7C b6 b7C EFTA00597089