EFTA00601577.pdf

I. INTRODUCTION 1. I have been retained by the law firm of Searcy Denney Scarola Barnhart & Shipley, PA. to provide expert analysis and opinion on behalf of Mr. Bradley J. Edwards in the case originally styled Jeffrey Epstein, Plaintiff, vs. Scott Rothstein, individually, Mr. Bradley J. Edwards, individually, and'. M., individually, Defendant, CASE NO.: 502009CA040800XX30GMBAG, which is pending in the Circuit Court of the 15ih Judicial Circuit, in and for Palm Beach County, Florida. IL QUALIFICATIONS 2. I am an adjunct professor at the College of Information Sciences and Technology at The Pennsylvania State University, University Park, Pennsylvania, since 2017, where I have been employed since 2001. I was a tenure-track professor at The Pennsylvania State University from 2009 through 2016, departing as a tenured full professor in 2017. I am a principal scientist at the Qatar Computing Research Institute. I was a Senior Fellow at the Pew Internet & American Life Project, which is part of the Pew Research Center, from 2010-2012. I was a University Expert at the National Ground Intelligence Center from 2011 through 2014. Prior to my employment at The Pennsylvania State University, I was a Lecturer in the Computer Science Program at the University of Maryland (Asian Division) for 1 year, and before that, I was an Assistant Professor in the Department of Electrical Engineering and Computer Science at the United States Military Academy, a.k.a. West Point, for 3 years. 3. In addition to my academic credentials, my professional experience includes 20 years of practice in the U.S. military, serving in the Infantry as an enlisted soldier and then as a communications officer, working primarily in a variety of information technology-related positions. 4. I have authored approximately 250 academic publications, focusing on the areas of Web data, digital analytics, Web analytics, Web searching, Web search engines, social media, and 1 EFTA00601577 related areas. Approximately 200 of my publications address aspects of search analytics, Web analytics, online advertising, search engines, or Web searching. My recent research work focuses on online news analytics, which is the investigation of the online qualitative and quantitative attributes of news stories with other digital content, and social computing analytics, which is the investigation of social behavior using algorithmic methods. I am also the editor-in-chief of the international academic journal, Information Processing and Management which is a top journal in information science field, and former editor-in-chief of the journal, Internet Research, a top- ranked journal in the web science domain. I have authored, co-authored, or co-edited four books, including Web Search: Public Searching of the Web (2007), Understanding User — Web Interactions via Web Analytics (2009) and Understanding Sponsored Search (2011). A copy of my complete Curriculum Vitae, which includes a list of all publications I have authored in the past 10 years, is attached as Appendix A. 5. My fields of professional expertise include web analytics, search engines, web searching, social media, online advertising, and related computer science and data science areas. In the course of my academic career, I have worked with a variety of search engines and information searching applications in order to understand user searching behavior on the Web and other environments. For example, as part of my Master's program in Computer Science, I designed and coded a text-based search engine. For my Doctorate program in Computer Science, I developed a program interface for Web search engines and implemented it on the Gigabyte search engine. In subsequent research, I have worked with the Microsoft Internet Information Services (IIS) and Verity commercial searching systems. 6. As a computer scientist, I have engaged and am experienced with the classic computer science areas, such as programming, software development, algorithms, and networking. 2 EFTA00601578 I have done extensive server set-up and log analysis. As my master's project, for example, I designed and coded a tool for network performance evaluation and monitoring. I have taught a wide variety of computer courses, including microcomputing, programming (in various languages), and the Web/Internet, at both the undergraduate and graduate level. 7. Concerning user searching behaviors on the Web and web analytics, I have worked directly with real-user searching data from several web search engines. I've also analyzed web data of visitor traffic and other attributes from a variety of websites and social media platforms. I've analyzed real-user data from online search marketing campaigns and user referral traffic to websites. I have conducted research and teaching concerning aspects of websites, including search engine keyword advertising. I've developed web analytics models and processes for analysis of business goals, and I have used web analytics data in both my research and teaching. I've also conducted other research on user searching behaviors. I have advised government agencies and companies in consulting and expert witness matters. A list of cases in which I have testified as an expert in deposition or trial in the past four years is attached as Appendix B. I am being compensated for my work on this case at the rate of $400 per hour. III. ASSIGNMENT AND MATERIALS CONSIDERED 8. In providing my expert opinion, I have been asked to respond to the following question: 9. What is the level of dissemination of defaming statements associating Mr. Bradley J Edwards with the illegal activities of Mr. Scott Rothstein as a result of Mr. Jef•ey Epstein's lawsuit against Mr. Edwards? 3 EFTA00601579  10. For brevity, I refer to the statements associating Mr. Edwards with the illegal activities of Mr. Rothstein as a result of Mr. Epstein's lawsuit as the defaming statements, the statements, or the defaming statements associatingMr. Edwards with Rothstein's illegal activities. II. The defaming statements associate Mr. Edwards with the illegal activities of a Mr. Scott Rothstein, who is a "notorious Ponzi scheme?". Now a debarred lawyer, he is serving a 50- year prison sentence' for operating the $1.4 billion fraud from his Fort Lauderdale law firm office, including forging the signatures of three federal judges on fake legal documents3. Prior to prison, in addition to spending money lavishly via the fruits of his fraud, he paraded as a philanthropists, resulting in some recipients having to return his charitable gifts°. After originally fleeing the US7 with a reported 16 million in US dollars8, he returned to the US, agreeing to work with prosecutors in exchange for a reduced sentence. However, prosecutors withdrew the reduced sentence offer as they determined Mr. Rothstein lied during the investigation and was attempting to hide assets8. 12. My analysis is based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the I Ponzi schemer Scott Rothstein hod to feds and should serve 50-year prison term, prosecutors say http://www.sun-sentinel.comilocalthrowardifl- rcg-scott-rothstein-no-sentence-reduction-20170926-story.html 2 Miami, FL - Ponzi Schemer Scott Rothstein Gets 50-year Sentence https://www.vosimeias.com/5745012010/06/09/miami-fl-ponzi-schema- scott-rodistein-gets-50-year-sentencet Florida Pont schemer jailed for SI/billion fraud currently serving a 50-year sentence and his wife officially divorce http://www.dailymail.co.uldnewilanicle-3169768/Divorce-finalized-I-2B-Ponzi-schemer-Rothstein.htmkthaz4w3nn9pfa 3 Miami, FL - Ponzi Schemer Scott Rothstein Gets 50-year Sentence hrips://www.vosimeias.com/57450.12010/06139/miami-fl-ponzi-schemer- scott-rodistein-gets-50-year-sentence/ 4 Rothstein Reveals How SI.2 Billion Ponzi Scheme Money Was Spent hrip://miami.cbslocalcomr2011il2+30/rodistein-reveals-how-l-2-billion- porin-scheme-money-was-spent: The Ultimate Ponzi: Scott Rothstein Book Excerpts Reveal Juicy Details httpsurAvww.huffingtonpost.comr2Ol3103/I2fscott-rothstein-book-the-ultimate-ponzi_n_2862093.html; Scott Rothstein's Cheating Life hrip://www.browardpaltribeach.cominews/scott-rothsteins-cheating-life-644.4966 South Florida lawyer Scott Rothstein faces arrest in Ponzi scheme http://www.tampabay.cornfnewstpoliticsistateroundursouth-florida-lawyer- scott-rotbstein-faces-arrest-in-ponzi-scheme/I055500 ° South Florida lawyer Scott Rothstein faces arrest in Ponzi scheme http://www.tampabay.comincws/politicsistateroundupfsouth-florida-lawyer- scott-rodistein-faces-arrest-in-ponzi-scheme/I055500; Scott Rothstein Charged with Racketeering https://www.cbsnews.comtnews/scott- rodistein-charged-with-radcetecrinW 7 Ponzi schemer Scott Rothstein lied to feds and should serve 50-year prison term, prosecutors say http://www.sun-sentinel.comilocalthrowardal- reg-scott-rothstein-no-sentence-reduction-20170926-story.html 3 Rothstein Sentenced to 50 Years Behind Bars hupiliwww.nbcmiami.comtnewsilocaVRothstein-Sentenced-95951004.html 9 Ponzi schemer Scott Rothstein lied to feds and should serve 50-year prison term, prosecutors say http://www.sun-sentinel.comilocalthrowardffi- reg-scott-rothstein-no-sentence-reduction-20170926-story.html 4 EFTA00601580 principles of web data collection, web analytics, web search, search engines, websites, web traffic analysis, and related market analysis. 13. The materials that I considered in preparing this report are listed in Annendix C. IV. SUMMARY OF OPINIONS 14. Based on my research and analysis in connection with this assignment, which is described in more detail in the body of this report, along with my own experience, training, knowledge, and education as stated, I have reached the following opinion: 15. The defaming statements associating Mr. Bradley J. Edwards with the illegal activities of Mr. Scott Rothstein as a result of Mr. Jeffrey Epstein's lawsuit against Mr. Edwards have been disseminated to at least 74 online media or other sites in 104 separate stories or articles with a combined 9,669,542 potential daily visitors since the lawsuit was filed to the date that 'filed this report, inclusive. 16. This number is conservative, and it is more likely than not, that the defaming statements have received wider dissemination due to factors, discussed in more detail later in this report, such as: a. It is a reasonable assumption that I have not located all references to the defaming statements on every website by the time of the submission of this report. So, there may be more sites with articles containing the defaming statements that are not included in my calculations. b. The focus of my analysis was the online dissemination of the statements. Therefore, I examined only online sources and not the dissemination of the statements made via print or broadcast media. It is reasonable to assume that the statements made were disseminated via these other channels. 5 EFTA00601581  c. I have not included dissemination of the defaming statements in the book, Filthy Rich10 by authors James Patterson and John Connolly. Therefore, this source of dissemination is not included in my analysis. d. In my analysis, I have not attempted to measure face-to-face dissemination of articles containing the defaming statements. Therefore, these sources of dissemination are not included in the count of daily unique visitors. e. Since I do not have access to certain online sources where articles containing the defaming statements may have been disseminated (e.g., email messages, personal social media messages, articles behind firewalls, etc.), these sources are not included in the count of daily unique visitors. f. Given the nature of the Web, there are possibly sites that have hosted the defaming statements that I could not locate or where the statements have been removed. Therefore, these sources of dissemination are not included in the count. g. Also, there are sites that hosted the articles containing the defaming statements where the visitor data is not accessible or where I could not confirm the number of visitors. In these cases, even though I had confirmed the site had posted one or more articles containing the defaming statements, I did not include these sites in my calculation of the unique daily visitors. h. I did not consider the dissemination via social media platforms of articles containing the defaming statements. Therefore, these sources of dissemination are not included in the count of daily unique visitors. 1° James Patterson and John Connolly (2016) Filthy Rich. A Powerful Billionaire_the Scx Scandal that Undid Himand All the Justice that Money Can Buy - The Shocking True Story of Jeffrey Epstein. Little, Brown and Company. 6 EFTA00601582  i. There were many sites that published multiple articles on multiple days that contained or referenced the defaming statements; however, I did not use these multiple articles from the same site with different publication dates in my calculations in determining the number of daily unique visitors who have been exposed to the articles containing the defaming statements. J. I did not include unique daily visitors to articles that link from that article to one or more of the articles containing the defaming statements; unless the article directly referenced the defaming statements, I did not include it in my analysis. k. I did not include the number of individuals who after reading the articles shared the articles or contents contained within those articles with others, which would include multiple individuals reading the same article at or about the same time at the same computer as well as all individuals who learned of the content of the articles from others who had read the articles. I. Finally, I did not include the counts of those who may have been searching and saw the defaming statements made in the search results listing. V. BACKGROUND WEB ANALYTICS FOR TRAFFIC ANALYSIS 17. In the course of forming this opinion, I implemented numerous web analytics and related techniques commonly used in the industry. In order to more clearly discuss these techniques, I define the following terms: • Direct Traffic: visitors to a website that come from entering a website link into a browser location bar (e.g., not coming via a link on another website). • Dissemination: the act of spreading or the circulation of information or articles. 7 EFTA00601583  • Domain: a specific Internet website that are administered as a unit and defined by an Internet Protocol (IP) address. • Reach: the percentage or number of people who visit a website out of the total targeted population. • Referral Traffic: visitors to a site that come from websites other than search engines. • Repeat Visits: visitor traffic to a website in a given period that just includes multiple visits from the same set of IP addresses (i.e., IP addresses with more than one visit); provides a count of the people who have visited a site more than once in a given period. An individual is usually defined by a combination of IP address and browser within a given period but can also be defined by more sophisticated methods. • Search Engine: a program and associated hardware and processes that allows people to find information on the Web, typically via the submission of queries consisting of terms. • Search Traffic: visitors to a site that come from search engines rather than from other websites or via direct navigation. • Search: a submission of a query to a search engine, usually in the form of terms forming a query. • Share: sharing of an article or webpage typically via some social media platform. • Social Media: content that is shared via a social networking website. 8 EFTA00601584  • Unique Visits: visitor traffic to a website within a given period that includes only the first visit (i.e., subsequent visits are ignored), which excludes repeat visits; provides a count of the individuals who have visited a site in a given period. • Unique Daily Visitors: visitor traffic to a website who visits a site at least once in a given 24-hour period. Each visitor, to the site, is counted once during the reporting period, which means it excludes repeat visits; provides a count of the individuals who have visited a site on a given day. • Visits: a count of all the traffic to a website in a given period, including both unique and repeat visits. • Web Ana tics: the measurement, collection, analysis, and reporting of web data. 18. In forming my opinion, I utilized accepted web analytics and related methodologies. To that end, I employed various publicly available online analytic services, as well as subscription-based services in conducting my research, including: • Alexa: an online service that provides web traffic data and analysis. • Google Keyword Tool: an online service that provides the number of searches for a given set of keywords in a given month on the Google search engine. • Google Trends: an online service that shows how often a particular term is relatively searched on the Google search engine in a given period. • Quantcast: an online service that provides web traffic data and analysis. • SimilarWeb: an online service that provides web traffic data and analysis. 19. These tools offer a variety of data and analysis services, and they are frequently utilized by industry professionals in the search engine optimization, web analytics, and search engine marketing fields for the market, customer, and competitive analysis. Furthermore, where 9 EFTA00601585 possible, I did my own assessments, as outlined below, in order to validate the data and analysis results. 20. I also utilized search engines, primarily Google and Bing, to assess the dissemination of articles containing the statements. 21. When necessary, I used multiple data sources, which is a data verification technique known as triangulation'', where one uses multiple and disparate sources for analysis and then compare the results from the separate analysis. If the results are similar, it reinforces the conclusion that the overall data analysis is valid. 22. In situations where I believed that I could not adequately verify the number of individuals or did not have confidence in the numbers in those situations, I did not include those numbers in the calculation. 23. Concerning the accuracy of the analysis, the number of domains where the statements have been disseminated is reliable, as this is straightforward to verify (i.e., the article is either posted on a site or it is not and the article either contains the defaming statements or no). If anything, this is an undercount, as some domains, for example, may have removed such articles, making them no longer available. There are possibly articles containing the defaming statements that I have not been able to locate by the time that I submitted this report. 24. Concerning traffic numbers for domains, the traffic services I used are the de facto industry standard, with billions of dollars in online advertising spend being based on these and related numbers12. Therefore, I consider them reliable for the purpose employed here. II Triangulation (social sciaice) http://en.svikipedia.orghvikilTriangulation_%28social_science%29 13 U.S. Digital Advertising Will Nlake S83 Billion This Year, Says ENIarketer http://www.adweek.comidigitaVu-s-digital-advenising-will-make- 83-billion-this-year-says-emarketer/ 10 EFTA00601586  25. My analysis is based on my experience, training, knowledge, and education and is formed through the application of that experience, training, knowledge, and education in the principles of web data collection, web analytics, web search, search engines, websites, and related areas. VI. METHODOLOGY TO DETERMINE THE DISSEMINATION OF THE DEFAMING STATEMENTS AGAINST MR. EDWARDS 26. My opinion is that articles containing the defaming statements have been disseminated to at least 74 online media or other sites in 104 separate stories or articles with a combined 9,669,542 potential daily visitors. 27. This is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors outlined above. 28. Concerning the procedure employed in determining the dissemination of the statements, nearly every major news site that I investigated has carried some aspects of the overall case relating to Mr. Edwards and Mr. Epstein, or other parties involved. In fact, there are hundreds of news articles and postings concerning the general story from news outlets worldwide, with combined potential viewership in the multi-millions. 29. However, I was not interested in articles that just discussed the story in general or other aspects of the story. I was specifically interested in only those articles that referenced directly the defaming statements. Naturally, this narrow focus is a much smaller subset of news articles and other articles than are the articles addressing the overall story. 11 EFTA00601587  30. To isolate these articles of interest, I generated a series of queries13 that specifically targeted news articles from the case that addressed the defaming statements (e.g., Jeffrey Epstein v. Scott Rothstein and Bradley 2 Edwards lawsuit) to retrieve a set of articles that directly related to the defaming statements". I employed a modified snowball technique1s, starting with one seed query, adding and modifying terms until I was not retrieving new results. I also located some articles via navigating from the set of retrieved articles. 31. An example of a search engine results page in response to one of these queries is shown in Figure 1. 32. Figure 1: Google search results for the search edwards epstein Ponzi scheme. edwards epstein, edwards epstein Ponzi scheme, brad edwards float brad edwards lawyer Pond, brad edwards dirty lawyer, Jeffrey Epstein v. Scott Rothstein and BradleyJ. Edwards lawsuit. Edwards Epstein Attonzey's Suit Against Billionaire Allowed as Long as Justices Say It's OK, Just an 'Ordinary Guy,' Lawyer Dishes on Surviving Rothstein. Battling Epstein. " In addition to the queries, I located some anicles via direction navigation. " https://en.wikipedia.orginikiiSnowball_sampling 12 EFTA00601588  C Y Secure F https www.google.com/st•.. Google edwards epstein Ponzi scheme I O, All News images Videos More Settings Tools About 290.000 results (0.57 seconds) Jeffrey Epstein paid $5.5M to settle lawsuits I Page Six https://pagesiz.corn/2017/10104/jeffrey-epstein-paid-5-5m-to-settle4awsuits/ • Oct 4.2017 • Rothstein Is serving a 50-year sentence for running a $1.2 billion Ponzi scheme. Epstein had sued the Florida attorneys. claiming Edwards Jeffrey Epstein paid 3 women $5.5 million to end sex lawsuits ‘vvowpalmbeachpost.cominewsicrime.../epstein.../8GEJI4YYa2X4ffig4HAgyJ/ • Oct 3. 2017 - Palm Beach billionaire Jeffrey Epstein paid $2.5 million. $2 million & $1 ... that Edwards had nothing to do with Rothstein's Pond scheme. ... PALM BEACH PERV Jeffrey Epstein Paid Victims MILLIONS! www.gossipeztra.com/2017/10/04/jeffrey-epsteimpaid-victims-millions-79822 • Oct 4. 2017 - Epstein has sued both lawyers. alleging that Edwards invented the sex-slave narrative to perpetuate the Ponzi scheme overseen by Rothstein. Newest lawsuit against Epstein expected to include victim... www.palmbeachdailynews.cominewsfiocal/...epstein.../CZ14sOESb004ribinjc1hU • Oct 20. 2013 - One or more victims of Palm Beecher Jeffrey Epstein are expected to testify ... criminal issues.' Ponzi-scheme allegations surrounding Edwards' ... Billionaire Jeffrey Epstein shells out more money in latest sex abuse ... vmw.nydailynews.com/.../billionaire-jeffrey-epstein-shells-money4atest-sex-abuse-la... • Dec 19. 2009 - Epstein has filed a suit charging that Edwards took pan in a Ponca scheme in which his former law partner. Scott Rothstein. gulled investors by ... 33. I then personally verified that each article contained the defaming statements, by reviewing each article used in my analysis to ensure that the articles directly referenced in some way the defaming statements. 34. So, articles relating to the overall story that did not mention the defaming statements were not included in the analysis. 13 EFTA00601589  35. In the end, I had a set of 104 online news articles or stories to the date that I filed this report that specifically referenced the defaming statements to conduct my analysis, as outlined below. These articles are listed in Appendix D. 36. Each of these 104 online articles was posted online. The 104 online articles were distributed among 74 unique domain websites (i.e., some websites posted multiple articles that contain the statements). These 74 domains are also listed in Appendix D with the specific articles links. 37. As seen from the list of domains that have published articles or stories containing references to the statement, many of these domains are those of major news organizations or sources, including BuzzFeed, Forbes, New York Daily News, Page Six, Radar Online, The Daily Mail, The Telegraph, etc. 38. There are regional Florida newspapers, where Mr. Edwards' law office is located, that published articles containing the defaming statements, including The Palm Beach Daily News and The Palm Beach Post. 39. I then used a variety of web analytics traffic services and other sources to get the unique daily visitor traffic for each of these domains. I used multiple services when necessary to get the unique daily visitor traffic for each of these domains, as these traffic services may use different techniques to arrive at their traffic numbers. In end, I used primarily SimilarWeb, as the service was generally providing the most consistent results across websites. 40. In cases where I determined I could not get unique daily visitor traffic numbers or the unique daily visitor traffic was not reliable, in my opinion, I did not include the unique daily visitor traffic numbers for that domain in the numbers. This usually occurred for the sites with a smaller number of daily visitors or sites with an extremely large number of daily visitors. 14 EFTA00601590  41. Unique daily visitors measure is an industry standard web analytics metric for measuring people that visit a website in a given day, also known as unique audience'. It is generally averaged out over multiple days with a given period, such as week or month, as there are normal daily fluctuations. 42. Table 1 shows the unique daily visitor traffic for the listed domains that posted articles or stories referencing the statements and the associated unique daily visitor traffic for each of those domains, along with the number of articles containing the defaming statements posted on that site. 43. Table 1: Domains that published articles or stories containing the defaming statements with the domain's number of unique daily visitors and the number of articles containing the statements published on that domain to the date that I filed this report. Domain Unique Number No. Domain Visitor Traffic of Articles (Daily) Published 1 15thcircuit.co.palm-beach.fl.us a 1 2 aangirfan.blogspot.qa a 1 3 able2know.org 18980 1 4 abovethelaw.com 51000 2 5 absolutewrite.com 37333 1 a 6 amlawdaily.typepad.com 1 7 anonhq.com 18689 1 8 archive.org b 1 9 articles.sun-sentinel.com 14979 1 b 10 books.google.com.qa 1 a 11 cannonfire.blogspot.qa 1 12 casetext.com 20947 1 a 13 deeppoliticsforum.com 1 14 docplayer.net 42400 1 15 docuri.com 6024 1 16 forum.davidicke.com 11607 1 a 17 fullcontentdaily.com 1 Is Nielsen Online Ratings Metrics Guidelines, http://digitalmeasurernent.nielsen.comifilcsimetrics-guidelines.pdf 15 EFTA00601591  Domain Unique Number No. Domain Visitor Traffic of Articles (Daily) Published 18 girlsjustwannahaveguns.com 8461 1 19 ijr.com 63500 1 20 jonathanturley.org 11827 1 21 law.justia.com 92567 1 22 lawnewz.com 114800 1 23 mondoweiss.net 13949 1 24 nesaranews.blogspot.qa 6227 1 a 25 novaordemnews.blogspot.qa 1 26 pagesix.com 55600 1 a 27 peuplesobservateursblog.wordpress.com 1 28 radaronline.com 303367 1 a 29 seeker401.wordpress.com 1 30 sites.eveyo.com 21627 1 31 static I .squarespace.com b 1 a 32 tabublog.com 2 a 33 theawarenesscenter.blogspot.qa 1 34 thegoldwater.com 21239 1 35 themillenniumreport.com 8640 1 a 36 www.4dca.org 2 37 www.abajournal.com 17782 1 a 38 www.alecomm.com 1 39 www.browardpalmbeach.com 17431 1 40 www.buzzfeed.com 717350 1 41 www.courthousenews.com 8785 1 a 42 www.dailybusinessreview.com 1 43 www.dailymail.co.ulc 1245477 3 44 www.democraticunderground.com 114467 1 45 www.documentcloud.org 38367 1 46 www.facebook.com b 1 47 www.fairfaxunderground.com 9860 1 48 www.floppingaces.net a 1 49 www.floridabulldog.org a 2 50 www.forbes.com 3942600 2 51 www.freerepublic.com 181467 1 52 www.garyeto.com a 1 53 www.gossipextra.com 41647 3 54 www.gpo.gov 58667 I 55 www.ieyenews.com a I 56 www.justice-integrity.org a 3 16 EFTA00601592  Domain Unique Number No. Domain Visitor Traffic of Articles (Daily) Published 57 www.law.com 34000 1 58 www.law360.com 46333 1 59 www.librarything.com 105333 1 60 www.nydailynews.com 1785333 2 61 www.pacificpundit.com 6399 1 62 www.palmbeachdailynews.com 8320 7 63 www.palmbeachpost.com 183000 3 64 www.pressreader.com b 5 65 www.reddit.com b 1 66 www.rigorousintuition.ca a 1 67 www.scribd.com b 3 68 www.slideshare.net b 1 69 www.sott.net 112333 1 70 www.talkleft.com a 3 71 www.telegraph.co.uk 4828 2 72 www.the5thestate.asia a 1 73 www.veteranstoday.com 46000 1 74 www. um u.com b 2 9,669,542 104 a - Unique daily visitor traffic not available b - Unique daily visitor traffic not verifiable 44. As shown in Table 1, there are 74 domains that hosted 104 articles containing the defaming statements against Mr. Edwards with these defaming statements begin disseminated to, conservatively, a potential 9,669542 daily visitors to these websites. 45. I used each domain's unique daily visitor count to calculate the dissemination of the articles containing the statements to various websites and potentially to visitors to that site (i.e., as visitors to the news sites, these individuals could have been exposed to the articles containing the statements), using the unique daily visitor number only once for each domain, regardless whether that domain published more than one article referring to the statements. VII. RESULTS FOR ANALYSIS OF THE DISSEMINATION OF THE DEFAMING STATEMENTS AGAINST MR. EDWARDS 17 EFTA00601593  46. Based on my analysis as outlined above, my opinion is that the defaming statements associating Mr. Edwards with the illegal activities of Mr. Rothstein as a result of Mr. Epstein :s lawsuit against Mr. Edwards have been disseminated to at least 74 online media or other sites in 104 separate stories or articles with a combined 9,669,542 potential daily visitors since the lawsuit wasfiled to the date that !filed this report, inclusive. 47. This is a conservative number, and more likely than not, articles containing the defaming statements made have been disseminated to more individuals. VIII. WHY THE NUMBER IS CONSERVATIVE 48. This is a conservative number, and it is more likely than not, the defaming statements have received wider dissemination due to factors such as: a. Although I spent considerable effort to locate published articles that contained the defaming statements, it is reasonable to assume that I have not located all such articles by the time of the submission of this report. So, there are most likely more sites with articles containing the defaming statements that are not included in my calculations, which would increase the dissemination of the articles on domains and increase the traffic count. b. The focus of my analysis was the dissemination of online articles containing the defaming statements, and I examined only online sources and not print or broadcast media. c. I have not included dissemination of the defaming statements in the book, Filthy Rich17 by authors James Patterson and John Connolly. As Mr. Patterson is a well-known author, the book had an initial printing of 500,00018, is well ranked in Amazon's electronic book " lames Patterson and John Connolly (2016) Filthy Rich: A Powerful Billionaire, the Sex Scandal that Undid Him, and All the Justice that Money Can Buy - The Shocking True Story of Jeffrey Epstein. Little, Brown and Company. "FILTHY RICH - PATTERSON, JAMES! CONNOLLY, JOHN (CONY MALLOY, TIMOTHY (CON) - NE lutpurAvvAcebay.com.autitmiFILTHY-R/CH-PATIERSON-JAMES-CONNOLLY-JOHN-CON-MALLOY-TIMOTHY-CON- NE/I92248712306?_trkparms 18 EFTA00601594 and other sections19, and also, a top USA Today top selling book20. The book is available and/or has been reviewed on at least 20 websites, including USA Today, New York Journal of Books, The Daily Beast, and the New York Post, and is available from major online retailers, including Amazon, Wal-mart, Barnes and Noble, and eBay, among others, as shown in Appendix E. This source of dissemination is not included in my calculation. d. In my analysis, I did not attempt to measure face-to-face dissemination that may have occurred after individuals may have read articles containing the defaming statements, which would increase the count. Therefore, this is not included in my calculations. e. Naturally, I could not access certain online sources where the defaming statements made may have been disseminated (e.g., email messages, social media messages, articles behind firewalls, etc.). Therefore, these numbers are not included in my calculations. f. Also, there are possibly sites that have hosted articles containing the defaming statements where the articles have been removed. Therefore, they are not included in my calculations. g. For sites where one or more of the articles containing the defaming statements are posted but where I could not locate or not determine reliable daily unique visitor traffic, I have not included these sites in my calculations. h. I did not include the dissemination of the articles containing the defaming statements directly to social media platforms. "Filthy Rich: A Powerful Billionaire, the Sex Scandal that Undid Him, and All the Justice that Money Can Buy: The Shocking True Story of Jeffrey Epstein https://www.amazon.comfdpfB01EFL9BMC/ref=dp-kindle-redirecttencodingnUTEStzbtkr=l "Patterson takes on sordid Jeffrey Epstein case in 'Filthy Rich' hnps://www.usatoday.com/story/../filthy-richieffrey- epstein...patterson../916052661 19 EFTA00601595  i. I did not include articles that link to one of the articles containing the statements in my calculations of dissemination. Unless the article directly mentioned the statements, I did not include that article in my calculations. j. Many sites published multiple articles on multiple days that quoted or referenced the statements; however, I did not use these multiple publication dates from the same site in my calculations of unique visitor traffic. If a domain published only one article containing the statements, then I directly used the unique daily visitors number. If a domain published multiple articles concerning the statements, I did not count the traffic for the subsequent articles containing the statements made, even though research shows that repeat traffic to websites is generally only about 30%21, meaning that 70% of the traffic would be unique. However, I was not comfortable using this figure given the nature of these sites, which might have higher repeat visitors day-to-day. Therefore, I did not include the visitors to multiple articles in my calculations. k. Finally, I did not include the count of people who may have been searching and may have seen the statements made in the search results, without needing to visit the actual articles, which can easily happen, as shown in Figure 2. I. Figure 2: Example of search results with the defaming statements appearing in the result snippets, requiring no need to visit the website hosting the articles themselves. ri Teevan, J., Adar, E.. Jones. R. and Potts. M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings ofthe 29th annual international ACM SlOIR conference on Research and development in information retrieval (SIGIR '06). ACM, Ncw York, NY, USA, 703-704. 20 EFTA00601596  C li Secure https www.google.com Go gle edwards epstein Ponzi scheme q All News Images Videos More Settings Tools About 290 COO results (0 57 seconds) Jeffrey Epstein paid S5.5M to settle lawsuits I Page Six