HOUSE_OVERSIGHT_010566

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IN THE CIRCUIT COURT OF THE 15TH 
JUDICIAL CIRCUIT IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
Case No. :50 2009 CA 040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff, 
SCOTT ROTHSTEIN, individually, and 
BRADLEY J. EDWARDS, individually, 
Defendants, 
STATEMENT OF UNDISPUTED FACTS  
Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed 
material facts in this case. Each of the following facts is numbered separately and individually to 
facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall 
identify . . . any summary judgment evidence on which the adverse party relies."). All 
referenced exhibits and attachments have previously been filed with the Court and provided to 
Epstein. 
Sexual Abuse of Children By Epstein  
1. Defendant Epstein has a sexual preference for young children. Deposition of 
Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment 
#1).1 
When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to 
remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the 
adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to 
him. "[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to 
2. Epstein repeatedly sexually assaulted more than forty (40) young girls on 
numerous occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These 
sexual assaults included vaginal penetration. Epstein abused many of the girls dozens if not 
hundreds of times. Epstein Depo. at 109 ("Q: How many times have you engaged in oral sex 
with females under the age of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane 
Doe, September 24, 2009 and continued March 11, 2010, at 527 (minor girl sexually abused at 
least 17 times by Epstein) (hereinafter "Jane Doe Depo") (Deposition

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