EFTA01482103

Due Diligence Report Jeffrey Epstein JP Morgan Chase EFTA01482103 Executive Summary On 2/22/2011, GS&I was requested by Paul V Morris to conduct a background investigation. Full research was conducted on MC2 Models Management LLC in NY only. Media research was conducted on Jeffrey Epstein and J Epstein and Co. Throughout this search, the following records were researched: Company and corporate records, RDC (Regulatory Data Corp), MIS (McDonald Information Services), CSSS/FPS internal database search (JPMorgan Chase Fraud Prevention List Review), state & federal court searches, publications, regulatory sanctions, FINRA/NFA and OFAC (Office of Foreign Asset Control). Please Note: All research is subject to the availability of electronic database resources. EFTA01482104 Our searches revealed the following: MC2 Models Management LLC Company records search revealed records found. flax ID not provided.E- Address confirmed. Reference the "Liens and Judgments" section to view the (Liens/Judgments) found for MC2 Models Management. glIThe following derogatory information was reported. NOMC2 Model Management LLC has two outstanding federal tax liens totaling $593,789 ($443,728 + $150,061).B Corporate records search revealed no records found. UState of domicile: not confirmed. Other databases (RDC/MIS) revealed no records found. Internal database search revealed no records found. State court searches revealed no records found. Federal court searches revealed no records found. Publications revealed records found. Due to the amount of news stories found, search parameters had to be adjusted. 3The following derogatory information was reported.1121MC2 Model Management received $1 million from Epstein in 2005. It is unknown if the money was given as a secret investment or payment for services as a procurer.140ean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money. In addition, Brunel was a frequent passenger on Epstein's private jet and often visited Epstein in jail.M'MC2 Model Management was issued a citation by the Florida Business and Professional Regulation for acting as a talent agent without a license.B Regulatory sanctions search revealed no records found. FINRA/NFA database searches revealed no records found. A search of OFAC did not reveal any matches. EFTA01482105 Jeffrey Epstein Internal database search revealed the following: eference the accounts titled "210203, "Forums LLC", "YHS LLC", "I Correct com LLC", "The 2007 Jeffrey E Epstein Insurance Trust 1 Dtd November 1 2007" and "N A Property Inc, 742010" for previous research. f3f= he following information was previously reported to Mary C Casey on 09/21/2006 under the account YHS, LLC (DDR # 7391/06): Several newspaper articles were found that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes. Jeffrey Epstein served 13 months in jail. Other database search revealed the following: The following derogatory information was reported. f3f= effrey Epstein is required to register as a sex offender.® Publications revealed records found. Due to the amount of news stories found, search parameters had to be adjusted. The following derogatory information was reported. s of 3/4/2011: Numerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating in child trafficking and molesting underage girls. ftf effrey Epstein has settled a dozen civil lawsuits out of court from his victims regarding solicitation for an undisclosed amount. Regulatory sanctions search revealed no records. A search of OFAC did not reveal any matches. EFTA01482106 J Epstein and Co Internal database search revealed the following:UReference the accounts titled "Jeffrey Epstein, 210203, 10071008 and 2065010" for previous research. Publications revealed nothing derogatory. Regulatory sanctions search revealed no records. A search of OFAC did not reveal any matches. EFTA01482107 TABLE OF CONTENTS U TOC \o "1-3" \h \z \u UE HYPERLINK \l "Toc287267481" COMPANY INFORMATION PAGEREF _Toc287267481 \h MUM • HYPERLINK \l "_Toc287267482" BOTHER DATABASE SEARCHES - (SEX OFFENDER) U PAGEREF Toc287267482 \h • HYPERLINK \1 "_Toc287267483" UNPUBLICATIONS 1 PAGEREF _Toc287267483 \h U1213M2 E HYPERLINK \l "_Toc287267484" UROFAC/CONTROL LIST SEARCH PAGEREF Toc287267484 \h 11723i#fl EFTA01482108 COMPANY INFORMATION Copyright 2009 Experian Information Solutions, Inc. All Rights Reserved Experian Business Reports November 9, 2009 FILE ESTABLISHED: December 1, 2005 MC2 MODEL MGMT 6 W 14TH ST STE 3 NEW YORK, NY 10011-7506 UNITED STATES * * * * * * * * * * COMMUNICATIONS * * * * * * * * * * TELEPHONE: 646-638-3722 URL: http://www.smartbusinessreports.com/Main.aspx?link=1009 * * * * * * * * * * COMPANY IDENTIFIERS * EXPERIAN FILE NUMBER: 704982206 * * * * * * * * * * COMPANY INFORMATION * LEGAL STATUS: CORPORATION EMPLOYEES: 6 - 10 * * * * * * * * * * EXECUTIVES OFFICERS: ROB LASALLE, CONTROLLER FERNANDEZ YOBELIN, OFFICE MAN SCOTT LIPPS, PRESIDENT * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * MARKET AND INDUSTRY * * * PRIMARY SIC: 9999 - NONCLASSIFIABLE ESTABLISHMENTS SECONDARY SIC: 7699 - REPAIR SERVICES, NEC BUSINESS ANALYSIS: TRADE PAYMENT EXPERIENCES: (TRADE LINES WITH AN '*' ARE NEWLY REPORTED) RECENT ACCOUNT STATUS * * * * * * * HIGH -DAYS PAST DUE- BUSINESS DATE LAST CREDIT BALANCE 1- 31- 61- EFTA01482109 CATEGORY REPTD SALE $ CUR 30 60 90 91+ AIR TRANS 07/30/09 Payment Terms: NET 30 Comments: CUST 3 YR FOOTNOTES: + IN FIRST COLUMN INDICATES COMPANY IS PAYING FASTER THAN THE INDUSTRY NORM; - IN FIRST COLUMN INDICATES COMPANY IS PAYING SLOWER THAN THE INDUSTRY NORM; = IN FIRST COLUMN INDICATES COMPANY PAYS THE SAME AS THE INDUSTRY NORM; <,> SIGNS INDICATE TRUE HIGH CREDIT OR BALANCE IS < OR > AMOUNT SHOWN TRADE PAYMENT TOTALS: RECENT ACCOUNT STATUS HIGH -DAYS PAST DUE- CREDIT BALANCE 1- 31- 61- $ $ CUR 30 60 90 91+ CONTINUOUSLY REPORTED: 1 DBT: N/A NEWLY REPORTED: -- DBT: N/A TRADE LINE TOTALS: 1 DBT: N/A TAX LIENS: Date Filed: 7/21/2009 Type: FED-TX-LN Document Number: 10456325 Filing Location: ALBANY COUNTY CLERK Liability Amount: USD 443,728 LOAD-DATE: November 9, 2009 EFTA01482110 NEW YORK JUDGMENT AND LIEN FILINGS Debtor Information Name: MC2 MODialifilliULLER Address: NEW YORK, NY 10011-7506 NEW YORK COUNTY Creditor Information Name: INTERNAL REVENUE SERVICE Filing Information Filing State: NEW YORK Filing Date: 11/22/2010 Amount: $150,061 IRS Serial Number: Certificate Number: Filing 1 Filing Number: mila Filing Type: FEDERAL Filing Date: 11/22/2010 Filing Court: NEW YORK DEPARTMENT OF STATE Filing County: KINGS Filing Office: NY EFTA01482111 NEW YORK JUDGMENT AND LIEN FILINGS Debtor Information Name: MC2MODidireill i Address: NEW YORK, NY 10011-7506 NEW YORK COUNTY Creditor Information Name: INTERNAL REVENUE SERVICE Filing Information Filing State: NEW YORK Filing Date: 7/21/2009 Amount: $443,728 Property Attached: Block: 05443; Lot: 00017 Filing 1 Filing Number: 10456325 Filing Type: FEDERAL TAX LIEN Filing Date: 7/21/2009 Book/Page: FLO9/452 Filing Court: ALBANY COUNTY CLERK Filing County: ALBANY Filing Office: NY EFTA01482112 OTHER DATABASE SEARCHES - (SEX OFFENDER) EFTA01482113 ES EFTA01482114 PUBLICATIONS Copyright 2010 Newstex LLC All Rights Reserved Newstex Web Blogs Copyright 2010 Brand X Brand X (Los Angeles Times) July 30, 2010 Friday 11:12 AM EST LENGTH: 658 words HEADLINE: Brand X Files: Kara DioGuardi out at 'Idol.' Montana Fishburne porn tape reported. Brazil's sex tourism boom BYLINE: LATimes BODY: Jul. 30, 2010 (Los Angeles Times delivered by Newstex) -- The Justice Department is investigating Jeffrey Epstein in connection with child trafficking: Probe of the convicted billionaire widens to include a famous modeling agency. The FBI is also investigating Epsteins friend Jean Luc Brunel, whose MC2 modeling agency allegedly appears to have been a source of young girls from overseas who ended up on Epsteins private jets. (The Daily Beast) LOAD-DATE: July 30, 2010 EFTA01482115 Copyright 2007 N.Y.P. Holdings, Inc. All Rights Reserved The New York Post October 6, 2007 Saturday SECTION: All Editions; Pg 10 LENGTH: 376 words HEADLINE: MODEL SHOP DENIES EPSTEIN TIE BODY: THE owners of MC2 models are denying industry speculation that massage maven Jeffrey Epstein is a secret financial backer of the agency being run by scandal-scarred Jean-Luc Brunel, who was once accused of taking advantage of underage models. Epstein, who this week agreed to plead guilty to soliciting underage prostitutes at his Florida mansion in a deal that will send him to prison for about 18 months, reportedly gave "millions" to start MC2, which opened in October 2005 with offices in New York, Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was described in court documents as being just 14. "E equals MC squared . . . get it, like the equation? E equals Epstein. He just thinks everyone is too dumb to figure it out," said a model industry insider. "He's a desperate old man that fantasizes and takes advantage of young girls." The trouble doesn't stop there. Karins Models founder Brunel, who's currently a partner in MC2, denied allegations in a 1997 "60 Minutes" segment that he took advantage of young models who were high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night carousing, which he also denied. Disgraced former Elite models exec Gerald Marie is also involved with MC2, says our source. Marie was accused of having sex with underage models in a 1999 BBC documentary where he was filmed saying he hoped to seduce contestants in a modeling contest in which the average age of participants was 15. He also dated Linda Evangelista when she was a teen. "He's also involved in the agency," said the source. "Gerald and Jean-Luc like the same things. They hang out because they have young girls in common, like two guys who enjoy the same wine." MC2 president Jeffrey Fuller confirmed Brunel was a partner in the company, but denied any working relationship with either Epstein or Marie. "We have no relationship business-wise with Gerald Marie. Jeffrey Epstein has no ownership or involvement in our company and never has. Jean-Luc Brunel and I are the only two partners and owners of MC2 Model Management," Fuller said. Epstein's rep said he was not involved in the agency. "He has no business relationship with them," said Howard Rubenstein. LOAD-DATE: October 9, 2007 EFTA01482116 Copyright 2010 States News Service States News Service September 16, 2010 Thursday LENGTH: 494 words HEADLINE: THE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION SWEEPS DADE AND BROWARD COUNTIES FOR UNLICENSED TALENT AGENTS BYLINE: States News Service DATELINE: TALLAHASSEE, FL BODY: The following information was released by the Florida Department of Business and Professional Regulation: Yesterday, Department of Business and Professional Regulations Division of Regulation investigators conducted a sweep of Dade and Broward counties for unlicensed talent agents. During the sweep, investigators visited talent agencies to check for proper licensure and issued two citations and one cease and desist notice to unlicensed talent agents. Talent agents play an important role for aspiring actors, singers and models, and it is important that they have the required education and credentials to navigate entertainment industry, said Secretary Charlie Liem. The following agencies were issued penalties for acting as a talent agent without a license: NameAddressPenalty One Source Talent1250 E. Hallandale Beach Blvd., Suite 603, Hallandale Beach Fla. 33009Cease and Desist Notice MC2 Model Management 1674 Alton Rd., Suite 500 Miami Beach, Fla. 33139Citation Seth Rudolph and Associates, Age Model Management940 Lincoln Rd., Suite 202 Miami, Fla. 33139 Citation The South Florida talent agent sweep was part of DBPRs quarterly statewide unlicensed activity operation. This quarter, department investigators focused on the smaller professions regulated by the department, such as landscape architects, auctioneers and talent agents. The department is charged with regulating 18 different professions with more than 410,000 licensees. For more information about what services require a DBPR license, please visit MyFloridaLicense.com/dbpr/services. Hiring an unlicensed individual can threaten the financial and personal safety of consumers, as well as the livelihood of state-licensed professionals. Unlicensed individuals may not carry workers compensation or liability insurance, and consumers may end up paying for injuries on the job. Additionally, unlicensed individuals often underbid licensed professionals, which results in law-abiding professionals losing work to those who do not meet state licensure requirements. Here are some tips to help consumers protect themselves against unlicensed activity: Always ask to see the State of Florida license. Note the license number and verify that the license is current. To check a EFTA01482117 license, call 850-487-1395 or visit MyFloridaLicense.com. Ask for references and check each one. Do not pay cash and be cautious of writing checks made payable to individuals, especially when dealing with a company. Get everything in writing, including a detailed description of the work to be completed, a completion date and the total cost. Report suspected unlicensed activity at MyFloridaLicense.com or toll-free at 1-866-532-1440. The departments mission is to license efficiently and regulate fairly. The department licenses more than one million businesses and professionals ranging from real estate agents, veterinarians, and accountants to contractors and cosmetologists. For more information, please visit MyFloridaLicense.com. LOAD-DATE: September 18, 2010 EFTA01482118 Copyright 2010 Newstex LLC All Rights Reserved Newstex Web Blogs Copyright 2010 Jezebel Jezebel August 4, 2010 Wednesday 1:00 PM EST LENGTH: 1373 words HEADLINE: The Sex-Trafficking Model Scout [Predators] BODY: Aug. 4, 2010 (Gawker Media delivered by Newstex) Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 underaged girls, was assisted by a prominent modeling agent and scout. Here's what we know about Jean Luc Brunel. Jeffrey Epstein, you will no doubt recall, is the man who thought ferrying Bill Clinton on his private jet, lawyering up with superstar Alan Dershowitz, and making frequent $100,000 donations to the Palm Beach Police Department would insulate him from prosecution for his various depravities. Which included, for the record: buying a 14-year-old Yugloslavian named from her parents in order to keep as his "sex s ave ; paying a retinue of women to trawl Palm Beach or eenagers economically desperate enough to agree to give Epstein "massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday present"; and befriending Michael Wolff. But as Conchita Sarnoff wrote at The Daily Beast: Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and 'deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money.' The FBI investigated Epstein, and identified around 40 underaged victims. Sarnoff reports that the FBI is also investigating MC2 and Brunel for possibly engaging in child sex trafficking. Since pleading guilty to reduced charges of soliciting sex with a minor and serving 13 months of part-time jail, Epstein has become the focus of numerous civil lawsuits from his victims. He has so far settled a dozen. These same civil complaints allege that young girls from South America, EFTA01482119 Europe, and the former Soviet republics, few of whom spoke English, were recruited for Esptein's sexual pleasure. According to a former bookkeeper, a number of the girls worked for MC2, the modeling agency owned by Jean Luc Brunel, a longtime acquaintance and frequent guest of Epstein's. Brunel, along with numerous young models, was a frequent passenger on Epstein's private jet, according to flight manifests. The agency owner also allegedly received $1 million from Epstein in 2005, when he founded MC2 with his partner, Jeffrey Fuller; although Fuller and Brunel denied any such payment from the billionaire pervert in 2007, when rumors started swirling, Sarnoff got confirmation from a former bookkeeper at the agency. Whether the money was a secret investment in MC2, or a payment for Brunel's services as a procurer, is unknown. Brunel also visited Epstein in jail. So who is Jean Luc Brunel? Although he did not respond to our interview request, we spoke to a number of people who have worked with his agency. While MC2 isn't considered a major industry player, it isn't exactly bottom- shelf, either: MC2 in New York most recently launched the career of Latvian editorial star Ginta Lapina (Brunel "discovered" Lapina via an MC2 scouting competition for young teens) and currently represents Vogue China covergirl Liu Dan. Worldwide, MC2 represents such stars as Sessilee Lopez in Miami, and top models Candace Swanepoel, Marina Lynchuk, Natalia Chabanenko, and Elisa Sednaoui in Tel Aviv. Brunel isn't involved with the business on a day-to-day basis, although he owns an 85% stake in MC2. Instead, "Right now he does scouting for [the] agency and takes care of the international relations with other agencies," reports one source. Scouts scour the world for un-agented teenaged girls who could make it as models; they work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight " even relative to the almost totally unregulated modeling industry itself. "He travels a lot," says another person who has worked with Brunel. (The company blog refers to Brunel as a "scouting tsunami," and MC2 is fairly well-known for the strength of its international scouting.) Models we spoke to report mostly positive experiences with Brunel " one praised his sense of humor and said he is "lovely to all of his models," and another described him as highly intelligent and cultured, adding, "he knows a lot about the opera and he paints" " although it should be noted that none of the models whom we spoke to had been told of either his connections with Epstein, or his past. And what a past it is. These accounts from Michael Gross' 1995 book Model describe Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karins, now known as Karin Paris: "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karins was a dream for a playboy. His problem is that he knows exactly what girls EFTA01482120 in trouble are looking for. He's always been on the edge of the system. John Casablancas gets with girls the healthy way. Girls would be with him if he was the butcher. They're with Jean-Luc because he's the boss. Jean-Luc likes drugs and silent rape. It excites him." "I really despise Jean-Luc as a human being for the way he's cheapened the business," says John Casablancas. "There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano...They were very well-known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." It should be noted that aside from being a professional rival, Casablancas, the founder of the agency Elite, was eventually drubbed out of the industry for his own modelizing. How pervy do you have to be for John Casablancas to call you a perv? Pervy enough to drug and rape numerous teenagers, according to 60 Minutes and Diane Sawyer, who investigated Brunel in 1988. The program interviewed nearly two dozen models who said they had been sexually assaulted by Brunel and/or by his fellow agent, Claude Haddad. Even at that time, Brunel had a reputation as a man one could go to to procure a "date" with a young model. CBS spoke to five models who said that Brunel and/or his friends had drugged and raped them. Said producer Craig Pyes, "Hundreds of girls were not only harassed, but molested." When Gross interviewed Brunel, this is what he had to say for himself: "You get laid tonight with a model, is that a crime? I don't understand why people go into your personal life, what you do yourself, and to yourself, and they don't look at things that are really important." Since then, Brunel has been involved with a succession of agencies in New York and Paris. Although the 60 Minutes scandal eventually led Eileen Ford to stop working with him, he continued his involvement with Karins. In 1988, when powerhouse agency Next opened its doors, Brunel took an ownership stake. He also "discovered" Christy Turlington when she was 14. MC2 is only his latest venture. Because no criminal charges were ever filed by any of his accusers, and because the industry has a short memory " most models working today weren't even born when Sawyer and Pyes started looking into Brunel's activities " Brunel has been free to continue as he pleases. A French citizen, he even avoided testifying in his friend Epstein's trial. And so Brunel is still criss-crossing the globe, trawling for 5110" 13-year- olds from Eastern Europe and (the whiter parts of) South America. And apparently taking the occasional ride with them on Epstein's private jet. Is there any better argument for the regulation of the modeling industry? Image via Models Jeffrey Epstein Pedophile Billionaire and his Sex Den [TDB] EFTA01482121 A Sex-Crime Investigation Reveals Jeffrey Epstein's Dangerous Dream World [New York] Earlier: Pervy Billionaire May Have All The Sex-Trafficking Defense Money Can Buy Why Superrich Guys Feel Entitled To Keep Underaged Sex Slaves Newstex ID: GAWK-0016-47599781 NOTES: The views expressed on blogs distributed by Newstex and its re- distributors ("Blogs on Demand®") are solely the author's and not necessarily the views of Newstex or its re-distributors. Posts from such authors are provided "AS IS", with no warranties, and confer no rights. The material and information provided in Blogs on Demand® are for general information only and should not, in any respect, be relied on as professional advice. No content on such Blogs on Demand®, is "read and approved" before it is posted. Accordingly, neither Newstex nor its re- distributors make any claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained therein or linked to from such blogs, nor take responsibility for any aspect of such blog content. All content on Blogs on Demand® shall be construed as author-based content and commentary. Accordingly, no warranties or other guarantees will be offered as to the quality of the opinions, commentary or anything else offered on such Blogs on Demand®. Reader's comments reflect their individual opinion and their publication within Blogs on Demand®, shall not infer or connote an endorsement by Newstex or its re-distributors of such reader's comments or views. Newstex and its re-distributors expressly reserve the right to delete posts and comments at its and their sole discretion. LOAD-DATE: August 4, 2010 EFTA01482122 Copyright 2010 ProQuest Information and Learning All Rights Reserved ProQuest SuperText Copyright 2010 Palm Beach Post Palm Beach Daily News October 16, 2010 Saturday Dn1 Edition SECTION: A SECTION; Pg. A.5 LENGTH: 823 words HEADLINE: Claim: Epstein filed lawsuit to 'intimidate' victims' attorney BYLINE: MICHELE DARGAN Daily News Staff Writer BODY: Billionaire sex offender Jeffrey Epstein filed his 2009 lawsuit against attorney Brad Edwards in an effort to get Edwards to drop sex abuse lawsuits filed against Epstein, attorney Jack Scarola said Friday. "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein," Scarola said. Edwards secured deals for victims N, and Jane Doe, who were among nearly two dozen young women who received confidential settlements from Epstein. Edwards filed a new lawsuit last month against Epstein on behalf of victim M.J., asking for $50 million in damages. At a court hearing Friday, Scarola told Circuit Judge David Crow that all lawsuits were settled for "very substantial sums of money, which is directly contrary to the assertions that Mr. Epstein made that these cases were fabrications." The hearing was related to Epstein's lawsuit against Edwards, alleging Edwards was involved in false claims made by Ponzi schemer Scott Rothstein. Epstein says Rothstein lured investors to his scheme by telling them Epstein had agreed to settle sex abuse lawsuits for as much as $200 million. Edwards worked at Rothstein's firm for less than a year; Rothstein is named as a defendant. Speaking on behalf of Epstein, attorney Joseph Ackerman said, "Except in certain cases, we believe the Rothstein firm was marketing cases that didn't exist, not necessarily the ones he settled. We believe actions were taken in those cases that were an abuse of process to inflate the marketing." Edwards filed a counterclaim, alleging Epstein filed a frivolous lawsuit to get him to back down from representing the victims. Epstein had filed a complaint with the Florida Bar against Edwards, raising allegations that Edwards and others were involved in Rothstein's wrongdoing. After investigating the claim, the Florida Bar dismissed the complaint. In July, Edwards received a letter from the U.S. Attorney's Office -- the office responsible for prosecuting Rothstein -- identifying Edwards as a EFTA01482123 potential victim of Rothstein. Scarola wants the judge to sever the cases and fast-track Edwards' case. "This constitutes a very substantial cloud over Mr. Edwards' head," Scarola said. "Public allegations have been made against him that he was a participant in this major fraud, one of the largest in the history of South Florida, and we want, expeditiously, to have that cloud removed." Epstein, 57, finished serving his one-year probation in July on state charges of soliciting prostitution and soliciting a minor for prostitution. More than two dozen underage girls were identified in federal documents as having been sexually abused by Epstein. A secret deal with federal prosecutors revealed Epstein could have been charged with multiple federal counts of sexual exploitation of minors, resulting in much harsher penalties. But the feds deferred to two state charges that got him an 18-month sentence. He served only 13 months in a vacant wing at the Palm Beach County Stockade. In more than 62 pages of court documents, Scarola asserts the court should rule in Edwards' favor for at least two reasons: that Epstein has elected to invoke his Fifth Amendment privilege in depositions, and Epstein's claims are unsupported and contradicted by the evidence. "Under the well-established 'sword and shield' doctrine, Epstein cannot seek damages from Edwards while at the same time asserting a Fifth Amendment privilege to block relevant discovery," Scarola wrote in court papers. "Epstein's deposition was taken at least five times," court papers say. "During all of these depositions, Epstein refused to answer any substantive questions about his sexual abuse of minor girls." Ackerman said the Rothstein lawsuit is a different situation than Epstein taking the Fifth in depositions regarding the victims, because the allegations against Rothstein and Edwards "took place outside of Epstein's personal knowledge. "This is not a case where Mr. Epstein has personal knowledge of what happened at the Rothstein firm in regard to these claims," Ackerman said. "These investors went to the Rothstein firm and were shown case files for the L.M. litigation against our client for the purpose of putting investments in. The complaint is not based on whether our client is guilty or not guilty for the crimes for which he settled or pled guilty to. What he has said in the complaint is they took the cases against me ... to attempt to inflate the value for the purpose of the investment." Scarola told Crow that Epstein has refused to answer any questions regarding his basis for claims against Edwards. "We have undertaken not only to demonstrate absence of any evidence to support any claims that have been made against Mr. Edwards, but to affirmatively and conclusively demonstrate his complete and total innocence with respect to these matters," Scarola said. mdargan@pbdailynews.com LOAD-DATE: October 19, 2010 EFTA01482124 Copyright 2010 The Palm Beach Newspapers, Inc. All Rights Reserved Palm Beach Post (Florida) April 1, 2010 Thursday FINAL EDITION SECTION: LOCAL & BUSINESS; Pg. 2B LENGTH: 609 words HEADLINE: METRO REPORT BODY: COURTS WEST PALM BEACH -- Yet another woman on Wednesday sued multimillionaire sex offender Jeffrey Epstein for forcing her to give him sexually charged massages at his Palm Beach mansion when she was as young as 15. In the lawsuit filed in U.S. District Court, the woman, now 20, claims Epstein threatened to harm her or her family if she revealed the abuse. Epstein pleaded guilty to two prostitution-related felonies in 2008 and served 13 months of an 18-month sentence. Some of the nearly 20 women who sued him have settled their lawsuits for undisclosed amounts. His attorney wasn't available for comment. EFTA01482125 OFAC/CONTROL LIST SEARCH H EFTA01482126 Bridger Insight XG Quick Name Check Entity Type : U HTMLCONTROL Forms.HTML:Select 1 NEE *Full Name E HTMLCONTROL Address : E HTMLCONTROL City : • HTMLCONTROL State : ti HTMLCONTROL Forms.HTML:Text.1 Forms.HTML:Text.1 Forms.HTML:Text.1 Forms.HTML:Text.1 Postal Code : HTMLCONTROL Forms.HTML:Text.1 Country : • HTMLCONTROL Forms.HTML:Text.1 (*) Denotes a Required Field M22 • HTMLCONTROL Forms.HTML:Submitbutton.1 Ming HTMLCONTROL Forms.HTML:Submitbutton.1 122i2 Quick Name Check Results NO MATCHES Confidential Due Diligence Report EFTA01482127 Confidential - This report is not to be disseminated or photocopied to any third party without the express consent of Global Security & Investigations. 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