← The Epstein Chronicles
The Epstein Chronicles
Mega Edition: Brad Edwards And The Battle Over The CVRA (Part 2) (6/13/26)
00:33:23
The affidavit submitted by attorney Bradley J. Edwards in the Southern District of Florida lays out a detailed argument for why the U.S. government should be compelled to produce documents related to the federal handling of the Jeffrey Epstein case....
Loading summary
Transcript8 lines
- [00:01]
Bluff / Bretzky / Lady Luck
What's going on everyone? It's Bluff here and we're driving through the states in the Bluff Mobile and the best thing that we can do is play our favorite casino style games. On Spin Quest. They have over a thousand games including live dealer, blackjack and craps. With tons of slots and unlimited options, you can get a 30 coin pack for just $10. For new users sign up today. Go to spinquest.com right now Spinquest is
- [00:24]
Spin Quest Announcer
a free to play social casino void where prohibited. Visit spinquest.com for more details.
- [00:30]
Brad Edwards
My name is Shannon Maldonado. I'm the founder of Yaoi, a gift shop from the lens of artists and handmade objects. I chose Shopify because when I was testing other platforms it was definitely one of the most user friendly. It was important to me to think about where we would be in the future. All of the tools for reading your sales, like planning inventory, they're just right there on your dashboard. For anyone starting a small business, the biggest thing I can tell you is it doesn't have to be perfect. Shopify can help you build upon it. Start your free trial on shopify.com what's
- [00:59]
Spin Quest Announcer
up everyone and welcome to another episode of the Epstein Chronicles. In this episode, we're picking up where we left off with Brad Edwards and the CVRA Affidavit the Government's Fiduciary duty to crime Victims bars any Privilege I'm familiar with the case law recited in our pleading regarding a fiduciary exception, also known as the Garner exception in some filings to privileges. In this case, the government had a fiduciary obligation to protect the CVRA rights a Jane Doe no. 1 and Jane Doe no. 2 specifically, because they were recognized as victims under the CVRA, the government had obligations to provide them rights under the cvra, including the right to confer, the right to notice and the right to be treated with fairness. Because of this fiduciary duty, it an exception applies to many of the government privilege claims regarding interactions with the victims. The fiduciary duty of the government to the victims in this case is clear. In 2007, the FBI determined that both Jane Doe 1 and Jane Doe 2 were victims of sexual assault by Epstein while there were minors beginning when they were approximately 14 years of age and approximately 13 years of age, respectively. These sexual assaults involve use of means of interstate commerce, I. E. Telephone and travel in interstate commerce. Both Jane does were initially identified through Palm Beach Police Department's investigation of Epstein, confirming the fact that the government had identified Jane Doe 1 as a victim in its case on about June 7, 2007, FBI agents hand delivered to Jane Doe number one a standard CVRA victim notification letter. The notification promises that the Justice Department would make its best effort to protect Jane Doe 1 and her rights, including the reasonable right to confer with the Attorney for the United States in the case and to be reasonably heard at any public proceeding in the District Court involving a plea. The notification further explained that at this time your case is under investigation. Similarly, or about August 11, 2007, FBI agents hand delivered to Jane Doe number two a standard CVRA victim notification letter. The notification promises that Justice Department would make its best efforts to protect Jane Doe no. 2's rights, including the right to confer with the attorney of the US and to be reasonably heard at public proceedings. Early in the investigation, the FBI agents and and the Assistant U.S. attorney had several meetings with Jane Doe number one and Jane Doe number two was represented by counsel that was paid for by Epstein. Accordingly all contact or contract that was made through that attorney. These meetings occurred because the FBI had obligations to protect victims rights under the CV. In October of 2007, shortly after the initial non prosecution agreement was signed between Epstein and the U.S. attorney's Office for the Southern District of Florida, Jane Doe Number one was contacted to be advised regarding the investigation. On October 26, 2007, Special Agents E. Nesbitt, Kuykendall and Jason Richards met in person with Jane Doe Number one because she was recognized as a victim of Epstein's crimes. In all of the dealings between the government and the victims, as well as other dealings of a similar nature, the government had a fiduciary obligation to protect the interests of of the victims under the Crime Victims Rights Act. Accordingly, the government is precluded from raising any privileged claim to which a fiduciary exception applies, or at the very least, any privilege assertion would be outweighed by the victim's compelling need for the material. An illustration of a situation where the fiduciary duty exception applies is found on page one of the Supplemental Privilege Log. With regard to Supplemental Box 3, the entry here reads 7808 Email from Maria Vilafana to Alex Acosta, Jay Sloman, Kay Atkinson, and FBI Re Proposed Response to Goldberger's Letter Victim Notification in responding to defense attorney Goldberger's letter about victim notification, the U.S. attorney's office had a statutory duty under the CVRA to protect the victim's interest. Accordingly, the office cannot assert privilege when questions about whether it fulfilled its obligations to the victims have arisen in this case, or at the very least, any privilege assertion would be outweighed by the victim's compelling need for the material. Another illustration of a situation where the fiduciary duty exception applies is found on page 16 of the first privilege log. With regard to box two, the entry reads file folder entitled RSRCH Crime Victims Rights Containing Attorney Research, Handwritten Notes, Draft Victim Notification Letter, and draft correspondence to Jay Lefkowitz. Here again, the material at issue go to the heart of the case. What kind of notification were made to the victims and how did the defense attorney shape and limit those notifications? Moreover, in evaluating victims rights issues and determining what kind of letter to send, the government was fulfilling legal duties that it owed to the victims. Accordingly, the office cannot now assert privilege when when questions about whether it fulfilled its obligations to the victims have arisen in the case. Communications Facilitating Crime Fraud, Misconduct Not Covered I'm familiar with the cases cited in our brief regarding an exception to various privileges when the communications concern crime fraud or government misconduct. Many of the important documents about the treatment of the victims to which the government is asserting privilege which would fall within that exception with regard to fraud, the government misconduct. A number of the documents in the government's privilege log concern concealment from the victims of the existence of the non prosecution agreement between the government and Epstein. I have reviewed a copy of the non prosecution agreement signed on about September 24, 2007 by Epstein and his attorneys and a representative of the U S Attorney's Office. The text of that agreement bars disclosure of the agreement to the victims. On about January 10, 2008, my clients Jane Doe number one and Jane Doe number two received letters from the FBI advising them that this case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation. The statement in the notification letter was deceptive because it did not reveal that the case had previously been resolved by the non prosecution agreement entered into by Epstein and the U.S. attorney's office discussed previously. Moreover, the FBI did not notify Jane Doe no. 1 or Jane Doe no. 2 that a plea agreement had been reached previously and that part of the agreement was a non prosecution agreement with the U.S. attorney's Office for the Southern District of Florida and that the non prosecution agreement was would resolve the federal case completely. Whether the FBI itself had been properly informed of the non prosecution agreement is also unclear. We're not alleging misconduct by the FBI, but rather that the FBI was not properly informed about the case or in any event was acting at the direction of The U S Attorney's Office. In About April of 2008, Jane Doe number one contacted the FBI because Epstein's counsel was attempting to take her deposition as and private investigators were harassing her. Assistant U. S Attorney Marie Vilafana secured pro bono counsel to represent Jane Doe number one and several other identified victims in connection with a criminal investigation. Pro Bono Council was able to assist Jane Doe number one in avoiding the improper deposition. AUSA Vilafana secured pro bono counsel by contacting Meg Garvin of the National Crime Victims Law center in Portland, Oregon which is based in the Lewis and Clark College of Law. During the call, Ms. Garvin was not advised that a non prosecution agreement had been reached in the matter. On May 30, 2008, another of my clients who was recognized as an Epstein victim by the U S Attorney's office received letters from the FBI advising her that her case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation. The statement in the notification letter was deceptive because it did not reveal that the case had been resolved by the non prosecution agreement entered into by Epstein and the U S Attorney's Office in September of 2007. In mid June 2008 I contacted a USA Vilafana to inform her that I represented Jane Doe number one and later Jane Doe number two. I asked to meet to provide information about the federal crimes committed by Epstein. Hoping to secure a significant federal indictment against Epstein, AUSA Vilafana and I discussed the possibility of federal charges being filed. At the end of the call, AUSA Vilafana asked me to send any information that I wanted considered by the U.S. attorney's Office in determining whether to file federal charges. I was not informed that previously In September of 2007 the U S Attorney's Office had reached an agreement not to file federal charges. I was also not informed that any resolution of the criminal matter was eminent at the time. Presumably, the reason the U S Attorney's office withheld this information from me was because of the confidentiality provision that existed in the non prosecution agreement. At this point it's clear that AUSA Vilafana was restricted in what she was being permitted to tell me. On July 3rd, 2008 I sent to Ausa Vilafana a letter. In the letter I indicated my client's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients, we urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of of our federal laws. We urge you to move forward with the traditional indictments and criminal prosecution, commiserate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator. When I wrote this letter, I was still unaware that a non prosecution agreement had been reached with Epstein. In fact, that continued to be concealed from me and the victims by the U.S. attorney's office. I only learned of this fact later on as alleged in the preceding paragraphs and elsewhere in the affidavit and in this case, deliberate concealment from crime victims and their legal counsel of the existence of the non prosecution agreement would be fraud and government misconduct. Documents related to that fraud and misconduct would then fall outside of many of the privileges being asserted. An illustration of a document to which the crime fraud misconduct exception applies on this basis is found on page three of the Supplemental Privilege Log. The entry reads file folder entitled 12507 STAR to Acosta containing drafts of 11.30.07 letters from Acosta to Ken Starr and from Jay Sloman to Jay Lefkowitz. Performance and Victim Notification with Handwritten Notes and Edits by Marie Villefana. Again, these materials are central to to the dispute in the case as they involve discussions between the U.S. attorney's office and defense attorneys about notification to crime victims and given the dates and communications, in all likelihood they would be related to the deceptive notification that the government made to the victims a few weeks later.
- [12:44]
Bluff / Bretzky / Lady Luck
What's up everybody? It's Bretzky and America is turning 250 and I can't think of a better way to celebrate that than playing on an American owned social casino. Spin quest.com with all of your favorite games Live Crabs, Bubble Crabs Live Blackjack, there's no better place to play for free and win real cash prizes.
- [13:05]
Spin Quest Announcer
Spin Quest.com Spin Quest is a free to play social casino void where prohibited. Visit spinquest.com for more details. All right folks, we're going to wrap up right here and in the next episode we're going to pick up with where we left off. All of the information that goes with this episode can be found in the description box. What's up everyone and welcome to another episode of the Epstein Chronicles. In this episode, we're going to pick up where we left off with the Brad Edwards CVRA affidavit. Another illustration of where the Crime Fraud misconduct exception could potentially apply is with regard to information that the government possesses that Matthew Menshel has a personal or business relationship with defendant Jeffrey Epstein. This could potentially show misconduct by mental and it also potentially a motive to violate the victim's rights. As explained previously, the government's privilege log has numerous entries showing that Menshel was substantially and personally involved in making decisions related to the Epstein prosecution. Of the first privilege log with regard to box number three, P. 0119232 P. 011966, the victims have information suggesting that immediately after leaving the employment with the U.S. attorney's Office, Menshel was associated with Epstein controlled entities or had some business relationship with them. The documents that the government possessed showing a personal or business relationship between one of its prosecutors and the man he was charged with prosecuting should be produced. The government has admitted that its internal affairs component, the Office of Professional Responsibility, has collected information about possible improper behavior during the investigation of the Epstein matter. Government answers to RFA22 the fact that the government's own investigating agencies have collected such information demonstrates that there is a prima facie case of improper behavior which is enough to trigger the crime. Fraud misconduct exception 2. Various privileges factual Materials Not Privileged as noted in the accompanying legal memorandum, factual materials are generally not covered by the privileges at issue in the case. Many of the material to which the government is asserting privilege are factual materials. Assertion of the Attorney Client Privilege the government has asserted attorney client privilege regarding many documents. Yet with regard to most of these assertions, it's impossible to determine who is the attorney, who is the client, whether professional legal services are being rendered, and whether the communications were confidential to those involved in the delivery of legal services. Accordingly, it's very difficult for me to respond to many of the assertions of attorney client privilege, and in any event, the government has failed to carry its burden of showing that privilege applies. An illustration of documents at to which attorney client privilege appears to have been improperly asserted or inadequately described is found on page seven of the first privilege log. With regard to supplemental box number three, the entry for these 22 pages of documents reads File folder entitled Information Packet Drafts, containing several descriptions. To see how the attorney client privilege applies to these documents, I could provide many other illustrations of the problem. The government's attorney client privilege claim directly covers situations where it was in a fiduciary relationship with the victims and therefore is limited in now asserting privilege. For example, page three of the Supplemental Privilege Log contains an entry concerning Acosta containing drafts of 1137 letters from Acosta to Ken Starr and from Jay Sloman to Jay Lefkowitz Performance and Victim Notification with handwritten notes and edits by Marie Vilafana. This information goes very directly to the issue involved in the case as it goes directly to victim notification. Yet the government has asserted an attorney client privilege to prevent the victims from learning what's in these documents. The fiduciary exception to the attorney client privilege of applies in this situation and limits the government's ability to invoke a privilege. This also appears to be shared communication between the government and Epstein's attorneys and it's unclear how the attorney client privilege could ethically apply to such documents. As one example of why the victims have established a compelling need for material described in the preceding paragraph is the fact that the court has indicated that it will be considering a an estoppel argument raised by the government as a defense in the case. The Court has noted that this argument implicates a fact sensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities and the federal offense victims, including an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims in in the dark on the pendency of negotiation between Epstein and federal authorities until well after the fact and presentation of the non prosecution agreement to them was completed. The materials to which the government is asserting attorney client privilege go directly to that interface between the victims, the government and Epstein. The victims have a compelling need for the information and the fiduciary exception to the attorney client privilege over applies to permit the court to provide these documents to the victims. The government has not explained any harm that would come from releasing the documents covered by attorney client privilege to the victims. If the government raises any such harm, I respectfully request an opportunity to provide additional information on that alleged harm. Deliberative Process Privilege Some of the correspondence that is being withheld by the government under the deliberative process privilege concerns an investigation that the Justice Department's Office of Professional Responsibility opened with regard to the Epstein case. This investigation was undertaken at the request of the victims in the case. On December 10, 2010, Co Councel Professor Paul Cassel of the University of Utah College of Law and I met with U.S. attorney for the Southern District of Florida regarding this case in the U.S. attorney's office in Miami, Florida. On that date, Professor Cassell presented a letter to the U s attorney Mr. Ferrer asking him to personally investigate what happened during the Epstein prosecution and how the victims were treated during that investigation. Based on the privilege log that has been provided as well as subsequent correspondence sent to Professor Cassell, that request for investigation was turned over to OPR in Washington. The ultimate outcome of the OPR investigation is unclear. What is clear is that many documents are being withheld about that investigation, documents that would go to the central issue in the case. Approximately three whole pages of privilege log pages 12 through 14 of the supplemental log relate to the OPR investigation of how the Epstein case was handled and how the victims were treated. A Deliberative Process Privilege can only be asserted with regard to the process of reaching a decision, not the ultimate decision itself. The government here has apparently asserted a deliberative process claim over not only the OPR process but also over the OPR decision. It's not clear which document embodies the final OPR decision or given the inadequacies of the government's log, whether that final decision has been produced. Given the limited description of the document that have been provided, it appears that the OPR decision making may be reflected in a document found on page 13 of the Supplemental log. The description there reads Draft letter marked Confidential to be opened by addressee only Robin C. Ashton to Wifredo Farrar with a handwritten correction. No dates provided regarding the letter, nor is there any indication as to whether the letter was or was not circulated to other persons. It is also noteworthy that this letter is described as a draft letter. Nowhere in the privilege log is the final version of that letter indicated raising questions about what was draft and what was final. If this is the final embodiment of the OPR's conclusions, then this letter would not be protected by process of privilege because the deliberations would have come to an end. It's also worth noting that because OPR is an agency that investigates misconduct by federal prosecutors, it would not be providing a attorney client advice to prosecutors and its documents would not be attorney client privileged with regard to, for example, the U.S. attorney's Office for the Southern District of Florida. The fact that OPR has investigated many of the exact claims raised by Django 1 and 2 and were able to gather documents unobstructed by the government in order to reach its conclusion likely means that production of the OPR file to the victims in this case could significantly shortcut this discovery process and the litigation. Additionally, if OPR needed the documents to investigate and make findings regarding the victim's claims, then logically the victims share that need and have no other means through which to obtain the documents. The government has not explained any harm that would come from releasing the documents covered by the process of privilege to the victims. If the government raises any such harm, I respectfully request an opportunity to provide additional information on that alleged harm. Investigative Privilege the investigative privilege is a qualified privilege which balances the need of a particular litigant for access to information against any public interest in non disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankhauser vs. Rizzo on the facts of this case. Favor Weigh in favor of disclosing the information the victims have requested with regard to Factor one, the extent to which disclosure will thwart governmental process by discouraging citizens from giving the government information I presented four victims of Epstein sex offenses in federal court, Jando Number one, Jane two and a victim I will refer to as SR And MJ Sr. And other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about the case, that will not discourage them from providing information, but rather will encourage them. I have also talked personally to attorneys for a number of other victims in the case. I have been told that many of these victims hope that Jane Doe 1 and Jane Doe 2 are successful in their case.
- [23:52]
Bluff / Bretzky / Lady Luck
Happy Birthday America. It's time to celebrate and play your favorite Las Vegas casino games by American owned sports spin quest.com what's better than fireworks and American Pie? Hitting a blackjack in the palm of your hand and you won't lose your fingers. Over a thousand games including slots and live dealers and 30 coin packs are on sale for 10 spinquest.com buy American players. For American players, Spin Quest is a
- [24:18]
Spin Quest Announcer
free to play social casino void where prohibited. Visit spinquest.com for more details. With regard to factor number two, the impact upon persons who have given information of having their identities disclosed. Jang Do 1 and Jane Doe 2 are not asking for information that would identify any particular victim. Accordingly, there will be no effect on other victims. Additionally, I'm aware of the true names of many of Epstein's victims and that information has not been disseminated to the public where those individual victims did not wish for their identities to be disseminated all right, we're going to wrap up this episode right here and in the next episode dealing with the topic, we're going to pick up with where we left off. All of the information that goes with this episode can be found in the description box. What's up everyone? And welcome to another episode of the Epstein Chronicles. In this episode, we're going to pick up where we left off with Brad Edwards and the CVRA affidavit. With regard to factor three, the degree to which governmental self evaluation and consequent program improvement will be chilled by disclosure this is a lawsuit to force the compliance by the government with its CVRA obligation. Accordingly, the government's program of providing victims rights will be directly improved if the victims are able to enforce their rights in this lawsuit. With regard to factor four, whether the information sought is factual data or a summary, many of the items that the victims seek are factual summaries. An example of this is found at page 18 of of the first privilege log. With regard to box number 3P011778 to P011788. The entry reads file folder entitled 61209 victim notification log containing chart with victim contact information and attorney notes regarding dates and types of contacts. This would include, for example, dates of contacts with Jane Doe number one and and Jane Doe number two, which would be purely factual information. With regard to factor five, whether the party seeking the discovery is an actual or potential defendant in any criminal proceeding either pending or reasonably likely to follow from the incident in the question, Jane Doe 1 and Jando 2 are plainly victims of a crime, not criminal defendants. Indeed, as the court is aware, it's the criminal defendant Jeffrey Epstein who who has undertaken several limited intervention efforts to try and block disclosure of information to the victims. With regard to the factor six, whether the police investigation has been completed the investigation at Epstein was completed years ago and the government has not produced in its privilege log any information indicating recent investigative activity. With regard to factor seven, whether any interdepartment disciplinary proceedings have arisen or may arise from the investigation, it appears that OPR investigation has arisen as a direct result of the victim's efforts in the case. However, it does not appear that release of any information to the victims would hamper any disciplinary proceedings. Indeed, to the extent that the victims are able to obtain information about the case and find information about misconduct, they can provide the information to the government and and other disciplinary entities as appropriate. With regard to factor eight, whether the plaintiff suit is non frivolous and broad in good faith, it should be clear at this juncture of a five year long case that the victims have substantial claim that is brought in good faith with regard to Factor 9, whether the information sought is available through other discovery or from other sources. As recounted throughout this affidavit, the victims have no other way to obtain the information at issue than in this privileged debate as it involves information internal to the Justice Department. With regard to factor 10, the importance of information sought to the plaintiff's case, the information that the victims are seeking is highly important to their case. Indeed, without adequate proof, the court has indicated that it may have to deny the victim's petition. Throughout this affidavit, I have provided numerous examples and explanations on of why the victims need the information that they're requesting. The documents to which the government is asserting investigative privilege, for example, bear directly on the government's alleged estoppel defense, which victims need to complete evidentiary record to dispute work product doctrine. A work product claim can be defeated by showing of substantial need and undue hardship to obtain the material in other ways. In this affidavit have tried to articulate the specific and compelling need for all the materials that victims are seeking. I will not repeat all of those assertions here, but simply note that I stand ready to provide any additional information that the court may require to determine the compelling need that the victims have for the materials they have requested, as well as the undue hardship, if not actual impossibility of obtaining the materials in other ways. Any balancing of considerations tips decisively in the victim's favor. As one example, the victims have a compelling need for the materials that OPR collected as part of its investigation. Because Justice Department attorneys are generally required to talk to OPR investigators, OPR was apparently able to investigate the claim of misconduct related to the Epstein case by getting statements from the attorneys involved. These interviews appear to be recorded in materials found at page 14 of the Supplemental Privilege Log DE 216.1 with regard to Supplemental Box 3, p. 0139562, p. 013846, a total of 14 pages. Judging from the entry, these notes would be factual statements from Justice Department prosecutors about how the Epstein case was handled and whether any misconduct occurred during the handling of the case. Those are central issues in the case. There's no other way for the victims to obtain information about these subjects. Because the Justice Department has declined to provide information on the subject, the victims have established a substantial need for the material they were requesting in the previous paragraphs of this affidavit that review request by request to their document production request numbers 1 through 25, and supplemental request number 1. As another example of why the victims have established a compelling need for the materials is the fact that the court has indicated that it will be considering an estoppel argument raised by the government as a defense in the case. The Court has noted that this argument implicates a fact sensitive equitable defense which must be considered in the historical factual context of the entire interface between Epstein, the relevant prosecutorial authorities, and the federal offense victims, including an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims in the dark on the pendency of negotiation between Epstein and federal authorities until after the fact and presentation of the non prosecution agreement. The materials to which the government is asserting work product protection go directly to that interface between the victims, the government, and Epstein. The victims have no other way of showing what that interface is. The government will not be harmed if the materials are provided to the victims. Grand Jury Information the victim's legal pleading has explained why the government has not properly asserted any grand jury secrecy to the documents at issue. In addition, many of the government's grand jury privilege assertions appear to broadly cover both grand jury and non grand jury information. Even if the court allows the government to assert some form of grand jury privilege, it should require the government to sever grand jury material from non grand jury material. An illustration of this problem comes from page 12 of the first privilege log with regard to box number 2P to P00 8686. The entry reads file folder entitled FBI summary charts containing chart prepared at direction of a USA containing victim names, identifying information, Summary of activity, and other information relevant to the indictment. This does not appear to be a document that was ever presented to the grand jury or that directly discloses grand jury proceeding. Moreover, to the extent that it involves some kind of limited disclosure of grand jury proceedings, that limited disclosure could be redacted and the other information provided to the victims. It does not appear that any of the alleged grand jury materials that the government is asserting privilege involve ongoing grand jury issues. Moreover, it does not appear that disclosing any of the materials would tip off a potential target to a government investigation. Of course, Jeffrey Epstein and his associates are well aware of the government's investigation into their crimes against young girls for sexual purposes. The government has not explained any harm that would come from releasing the documents to the victims. If the government raises any such harm, I respectfully request an opportunity to provide additional information on that alleged harm. Privacy Rights of Other Victims Jane Doe Number One and Jane Doe Number two do not seek confidential or identifying information about any other victim to clarify that fact. On July 31, 2013, I sent a letter to the government stating in part that to avoid any interference with any privacy rights of victims who are not parties to this litigation, Jane Doe Number one and Jane Doe Number two are not seeking any identifying information about other victims in any of the documents that Jane Doe Number one or Jane Do Number two have requested from the government that they produce. The government should not produce the names of other victims or other identifying information, eg, address or telephone number, but should instead redact that information. I declare under penalty of perjury pursuant to U.S. code 28 Section 1746, that the foregoing is true and correct to the best of my knowledge and belief, executed this 16th day of August 2013. And this document was signed by Brad Edwards. Alright, so that finishes up the affidavit of Brad Edwards when it comes to the cvra. And now with this new dump, we have a lot of court records to dive into and the grand jury material especially because we've never seen that, right? So I want to make sure that we get a handle on that as well. So over the next couple of days, we're going to be diving deep into that grand jury material and that way everybody gets to see for themselves what we've been saying for all these years that the fix was in and this has been a cover up since the start. All of the information that goes with this episode can be found in the description box. Hey everybody. Lady luck here and we're celebrating America's 250th birthday. Now all summer long, I'm going to be celebrating by playing on spinquest.com which is an American owned social casino. It obviously features over a thousand slot games and live blackjack, live craps, live bubble craps. Head on over to spinquest.com get yourself a $30 coin pack for just 10 bucks. Spin Quest is a free to play social casino. Visit spinquest.com for more details.