EFTA00597076.pdf

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 Boston, MA 02110 Phone: Fax: Boles Schiller & Flexner, LLP Attorneys for Alan M. Dershowitz 401 E Las Olas Boulevard., Suite 1200 Fort Lauderdal FL 33301 Ashle Eller. Esquire Phone: Mar E. Bo 'a, Esquire Thomas Emerson Scott, Jr. Esquire Richard A. Simpson, Esquire [email protected] Wiley Rein, LLP 1776 K Street NW Cole Scott & Kissane P.A. Washington, DC 20006 9150 S Dadeland Boulevard, Suite 1400 Phone: Miami, FL 33156 Fax: Phone: Attorneys for Alan M. Dershowitz Fax: Attorneys for Alan M. Dershowitz Joni J. Jones Es uire Bradley J. Edward E_squire Assistant Utah Attorney General 160 E 300 S Salt Lake CttvjUT 84114 Phone: Farmer Jaffe Weissing Edwards Fistos & Fax: Lehrman, P.L. Attorneys for Paul Cassell 425 N Andrews Avenue, Suite 2 Fort Lauderdale FL 3301 Phone: Fax: Kenneth A. Sweder Es uire Sweder & Ross, LLP 131 Oliver Street EFTA00597077  -1 of 12 - OcraReartsoi 1O-302 (Rev. 34-10) —. FEDERAL BUREAU OF INVESTIGATION Date ofentry 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 b6 I land via telephone, Assistant I provided the b7C United States Attorney' following information: was born in Sacramento, California to parents' 'date of birth' b6 currently resides in and date of birth b7C 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' b6 b7C '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 Ea t i ned 07/05/2013 b6 b7C byI 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. EFTA00597078 nNmnsateltas-mao 31E-MM Continuation of FD-302 of inlla , On 03/17/2011 pmm 2 of 12 like she was locked into the relationship' gave IM pharmaceutical drugs toward the end of their relationship. b6 b7C 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. b6 knew' 'from elementary school and called him at the home telephone b7C 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 staying in at the ranch' did not strike her' 'pack her belongings and told her she was going to live with another man. Eli felt that she was sent to ut did not know the b6 b7C specifics of the arrangement. sexual activity with who was described as a whit 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, be an working at Donald Trump's Mar-A-Lago Club in Palm Beach, Florida. father was able to help her gain employment as a baby sitter and later as a locker room attendant at the club. started studying for her GED and wanted to become a massage therapist. In August, as reading an anatomy/massage book and was approached by b6 b7C 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 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 b6 also known as was led b7C upstairs Once upstairs in b6 b7c instructed to wash her hands prior to beginning the massa e The massage begs !demonstrated massage techniques to 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 b7c was given instruction and began kissing' b6 b7c At the conclusion,' 'instructed o obtain two warm wash clothes. One wash cloth was used to clean b6 second wasl to help him relax. b7C describe and hen moved to the steam room and shower where massaged k ith soap and a loofah in the shower. At the conclusion of the shower, went downstairs and[ b6 b7C Arrangement e for to return to the house the following day after work. MS cellular phone number was given tol I EFTA00597080 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 b6 times, b7C '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 b6 b7C and was introduced asi !assistant. soon began traveling For the initial six months, traveled around the United States and Caribbean, b6 including California, New York City( New Mexico) and various business b7C tri s. During those trips,! ICJ Six to nine months after began working for was introduced t4 ILNU4 in b6 !Florida. b7C lat the time. met the couple at a condominium next to the [The condominium was bought( land was a lIn the condominium, provided a normal massage t LNU. Shortly thereafter,) LNU lill. provided an erotic massage to IIIIII!II and cleanedr She was paid cash lIn addition, paid was 16 advised introduced 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 b7C doing with( and others. Her habit went from two pills per day up to eight pills per day. second client was an academic of some sort described as an older American male (sent from Miami International Airport to b6 I by commercial airline. was picked up at the b7C airport byl land then taken to the island by boat. EFTA00597081 FD-302a (Rev. 05-0S-I0) 31E-MM-108062 Continuation ofFD-302 of L. O, 03/17/2011 i pne 5 of 12 pointed out that' b6 instructed to entertain the b7C client land wanted to ride jet skis and participate in other island activities' spent two days on the island with the client. assumes the client also traveled commercially. During the following several months, traveled internationally I 'Prior to her traveling abroad getting her pass ort. ssisted got passport photographs of herself and in b6 provided them t he remaining paperwork was taken care of by b7C 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. While traveling 1111911 traveled on a black plane. During the international travel,( (At times, IIIIIII would' 'Rarely a day would pass' 'contacted throu b6 land wanted to talk to b7C 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 EFTA00597082 FD-30Ta(Rev 05-013-10) 31E—MM-108062 03/17/2011 i nt 6 of 12 Continuation of FD-302 of b6 b7C At age 16, met b6 9 b7C I believed she ands were approximately the same age. an.l b6 b7C WOU ci cite b6 b7C al though explained GIUFFRE provided an b6 b7C described An unknown individual GIUFFRE sa hen she arrived at b6 b7C had' sai. that day was a low stage in relationship ecause she could not believe never EFTA00597083 FD-302a (Rev. 05-0840) 31E-14N-108062 Continuation of FD-302 of L. on 03/17/2011 pmo 7 of 12 saw I I. believed the girls may have been) 'but b6 b7C was not certain off 'involvement. had a picture of herself she wanted to give( b6 b7C 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 on 66th street was aware of additional b6 apartments in the same building. According to he b7C apartment building on 66th street was owned b IUFFRE advised that she had a photo raph of the interior of the 66th Street apartment among other photos 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 EFTA00597084 FD-302a (Rev. 05-0840) 31E-MM-108062 Continuation ofFD-302 of 0, 03/17/2011 p,40 8 of 12 LNU and toys. „„„, went shopping together and purchased clothing and sex explained that' 1,6 b7c b6 b7C 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' 'but she could b6 not recall the wording. 'LNU. b7C iMINI advised' traveled' Ito a self-help conference at a hotel in b6 New Orleans, Louisiana. The hotel s near the Har Rock Café in New b7C Orleans. traveled the world including the USVI, New York, Santa Fe, Palm Beach, France, Africa, Spain and the United Kingdom. 136 recalled visiting b7C Alhambra Castle in Spain. I 'GIUFFRE eventually traveled to the United Kingdom and 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 1,6 b7C dancing with' and' went shopping and purchased makeup, clothin , and a Burberry ba . The items were purchased withI b6 an returned' I b7C 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 b6 b7C recalled' ILNU, 'GIUFFRE recalled (joking about trading GIUFFRE in because she was getting too old. EFTA00597086  Cs" cod misarauLmosmwo -A\ <0' 31E-MM-108062 Continuation of FD-302 of ,On 03/17/2011 ptio 10 of 12 A recalled meeting" QA .4 <?,t b6 NC") was using Xanax heavily at tfinlime' e b A and her recollection was not clear. She remembered there were many models .\ tj a ..v.., o. on the island that did not speak English along with a modeling person who 4> .,:ss, had an unknown accent. & it a b6 QA b7C Sr ^4. Ce ‘4 \, Ss 'r id not have a problem with using prescription drugs. was described by as a b6 b7C ;TRUE NAME UNKNOWN) a ranch employee )L !but b6 b7C could not recall his name. She did have a photograph of the ranch employee. met numerous famous people ncluding academics politicians and celebrities. She me land b6 andI 1 b7C received many gifts' 'including jewelry, watches, bags, shoes, make up, clot 'no. and home furnishings furnishings.' b6 I b7C 1 I LAMM left 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 receivedi har massaae certification. She stayed at the Princess Hotel in Thailand, but never did. during her visit to Thailand. met her future husband,I contacted$ (telephonically and J 1,6 b7C raid him she had fallen in love with someone. I I I EFTA00597087  .< 4" c.)"- c.)"- FD-302a (Rev. 05-08-10) _cam 31E-M4-108662 Continuation of FD-302 of , on 03/17/2011 " ate 11 of 12 _4( had not heard from e sr received a b6 4t4. telephone call fromr Inuring that call stated he was an. b7c C5S FBI agent. He was trying to determine what she knew about She did not tell' anything about her knowledge of I I 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 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.' b6 b7C 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, number 1, Page 1, number 24 LNU, a.k.a b6 b7c Page 2, number 1, Page 2, number 6, Page 3, number 2, Page 4, number 3, LNU Page 4, number 7, Page 4, number 8, Page 5, number 1, advised that the following were familiar to her, but she could not recall their names or her association to them: EFTA00597088 815.1028 (Rev. 05.08-10) 31E-MM-108062 Cool:tuition ofFD-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 b6 record was her return to the United Statesl I b7C could not recall her travel from March and May 2001 CPB records. advised that her United States Passport was turned over to the United States Consulate in Sydney, Australia. On March 18, 2011, writer, SAE andl b6 traveled to 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 . It is noted that 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. EFTA00597089