fabricating cases of a sexual nature fleecing unsuspecting Florida investors and others out of millions of dollars for cases of a sexual nature with--I'd like to answer your questions; however if I--I'm told that if I do so, I risk losing my counsel's representation; therefore I must accept their advice." Epstein deposition, March 8, 2010, at 106 (Deposition attachment #10).
56. | When Edwards had the opportunity to take Epstein’s deposition, he only asked reasonable questions, all of which related to the merits of the cases against Epstein. All depositions of Epstein in which Mr. Edwards participated on behalf of his clients are attached to this motion. See Edwards Affidavit, Exhibit “N” at §11 and Deposition attachments #1, 6, 7, 10, 11, 12, and 13. Cf. with Deposition of Epstein taken by an attorney representing BB (one in
which Edwards was not participating), http://www.youtube.com/watch?v=V-dqoEyY Xx4; and
http://www.youtube.com/ watch?v=Y CNiYItW-10
57. Edwards's efforts to obtain information about Epstein’s organization for procuring young girls was also blocked because Epstein’s co-conspirators took the Fifth. Deposition of Sarah Kellen, March 24, 2010 (hereinafter “Kellen Depo.”) (Deposition attachment #14); Deposition of Nadia Marcinkova, April 13, 2010, (Deposition attachment #9); Deposition of Adriana Mucinska Ross, March 15, 2010 (hereinafter “Ross Depo.”) (Deposition attachment #15). Each of these co-conspirators invoked their respective rights against self- incrimination as to all relevant questions, and the depositions have been attached.
58. At all relevant times Edwards has had a good faith basis to believe and did in fact believe Sarah Kellen was an employee of Epstein’s and had been identified as a defendant in at least one of the complaints against Epstein for her role in bringing girls to Epstein’s mansion to
be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on 22
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