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all substantive questions regarding her role in arranging for minor girls to come to Epstein’s mansion to be sexually abused. Reinhart had previously been an Assistant United States Attorney in the U.S. Attorney’s Office for the Southern District of Florida when Epstein was being investigated criminally by Reinhart’s office. Reinhart left the United States Attorney’s Office and was immediately hired by Epstein to represent Epstein’s pilots and certain co-conspirators during the civil cases against Epstein. See Edwards Affidavit, Exhibit “N” at ¶11.

59. Edwards also had other lines of legitimate discovery blocked through the efforts of Epstein and others. For example, Edwards learned through deposition that Ghislaine Maxwell was involved in managing Epstein’s affairs and companies. See deposition of Epstein's house manager Janusz Banziak, February 16, 2010 at page 14, lines 20-23 (Deposition Attachment #16); See deposition of Epstein's housekeeper Louella Rabuyo, October 20, 2009, page 9, lines 17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Attachment #8); See also Prince Andrew's Friend, Ghislaine Maxwell, Some Underage Girls and A Very Disturbing Story, September 23, 2007 by Wendy Leigh, link at http://www.redicecreations.com/article.php?id=1895OHANNA SJOBERG. Exhibit “AA”.

60. Alfredo Rodriguez testified that Maxwell took photos of girls without the girls' knowledge, kept the images on her computer, knew the names of the underage girls and their respective phone numbers and other underage victims were molested by Epstein and Maxwell together. See Deposition of Rodriguez, Deposition attachment # 8 at 64, 169-170 and 236.

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