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6. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that, more specifically, Epstein's attorneys knew of Epstein's scheme to recruit minors for
sex and also knew that these minors had civil actions that they could bring against him. In fact,
there was much communication between Epstein's attorneys and the United States Prosecutors in
a joint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant
U.S. Attorney Marie Villafaña sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz,
counsel for Epstein, with attached proposed letter to special master regarding handling numerous
expected civil claims against Epstein. The letter reads in pertinent part,

"The undersigned, as counsel for the United States of America and
Jeffrey Epstein, jointly write to you to provide information relevant to your
service as a Special Master in the selection of an attorney to represent several
young women who may have civil damages claims against Mr. Epstein. The
U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred
to as the "United States") have conducted an investigation of Jeffrey Epstein
regarding his solicitation of minor females in Palm Beach County to engage in
prostitution. Mr. Epstein, through his assistants, would recruit underage
females to travel to his home in Palm Beach to engage in lewd conduct in
exchange for money. Based upon the investigation, the United States has
identified forty (40) young women who can be characterized as victims
pursuant to 18 USC 2255. Some of those women went to Mr. Epstein's home
only once, some went there as much as 100 times or more. Some of the
women's conduct was limited to performing a topless or nude massage while
Mr. Epstein masturbated himself. For other women, the conduct escalated to
full sexual intercourse. As part of the resolution of the case, Epstein has
agreed that he would not contest jurisdiction in the Southern District of Florida
for any victim who chose to sue him for damages pursuant to 18 USC 2255.
Mr. Epstein agreed to provide an attorney for victims who elected to proceed
exclusively pursuant to that section, and agreed to waive any challenge to
liability under that section up to an amount agreed to by the parties. The parties
have agreed to submit the selection of an attorney to a Special Master...."

7. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that L.M. was, in fact, a victim of Epstein’s criminal abuse because L.M. was one of the

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