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46. On September 11, 2008, at the request of his client L.M., Brad Edwards filed a civil
suit against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint,
L.M. v. Epstein, (Exhibit “V”).

47. Jane Doe’s federal complaint indicated that she sought damages of more than
$50,000,000. Listing the amount of damages sought in the complaint was in accord with other
civil suits that were filed against Epstein (before any lawsuit filed by Edwards). See Complaint,
Jane Doe #4 v. Epstein (Exhibit “W”) (filed by Herman and Mermelstein, PA).

48. At about the same time as Edwards filed his three lawsuits against Epstein, other
civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14,
2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on
behalf of one of its seven clients who were molested by Epstein. The complaints that attorney
Herman filed on behalf of his seven clients were similar in tenor and tone to the complaint that
Edwards filed on behalf of his three clients. See id.

49. Over the next year and a half, more than 20 other similar civil actions were filed by
various attorneys against Epstein alleging sexual assault of minor girls. These complaints were
also similar in tenor and tone to the complaint that Edwards filed on behalf of his clients. These
complaints are all public record and have not been attached, but are available in this Court’s files
and the files of the U.S. District Court for the Southern District of Florida.

50. In addition to the complaints filed against Epstein in Florida, a female in New York,
Ava Cordero, filed a lawsuit against Epstein in New York making similar allegations - that
Epstein paid her for a massage then forced her to give him oral sex and molested her in other
ways when she was only 16 years old. Cordero was born a male, and in her complaint she
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