Case Document Entered on FLSD Docket Page of present during acts of sexual abuse by Epstein In any event ALL of those individuals have also invoked their th amendment rights against self-incrimination and thus have left Plaintiff with no information about what Epstein or other conspirators inside his house were doing during the sexual abuse of Jane Doe and other minors girls This creates a serious issue for Jane Doe in proving her sexual molestation claim against Epstein By its nature sexual molestation takes place in private with only the abuser and the victim typically available to testify In this case Epsteins abuse of Jane Doe took place in private with only Epstein and Jane Doe present during the abuse Jane Doe has no other reasonable avenues of discovery to provide direct proof of claim of sexual abuse by Epstein 267Additionally Mr Epstein 267has 267recently filed lawsuit 267against-me 267personally that has merit whatsoever,_ a fact known to Mr Epstein and his attorneys He filed the lawsuit against Brad Edwards Scott Rothstein and LM another Epstein victim of his molestation That lawsuit implies that L.M.s civil case against him currently pending in Florida state court is fabricated and that L.M and I have conspired to commit fraud against him presumably that she made up the case against him implying that he does not know L.M While the present subpoena before the Court has been filed by Jane Doe the Court should be aware that attorneys representing L.M may also file a subpoena for the George Rush tape shortly ll Desplte Mr Epstein and a oftils co-c6nspirafors asserting a th amendment priv"iiege against self-incrimination George Rush of the New York Daily news did contact me to inform me that Mr Epstein spoke personally with him about issues related to the various charges of sex abuse against him Paraphrasing from memory of my conversation with Mr Rush Mr Epstein told him that he may have come too close to the line but that he should not have been punished as severely as he was and that his conduct was at most worthy of a fine This is a statement that shows two things of great importance to Jane Does pending civil action First it Is in effect an admission by Epstein of his liability to Jane Doe for sexually abusing her Jane Doe does not have any other admission of Epstein of his sexual abuse of her and Epstein has filed an answer to Jane Does complaint that has the functional effect of denying abuse of her Jane Doe has diligently pursued all possible ways of obtaining an admission from Epstein of his molestation of Jane Doe without success Second the statement to Mr Rush is a clear demonstration that Epstein lacks remorse for committing felony child molestation against Jane Doe This will be a central issue in the punitive damages case against Epstein at trial Here again Jane Doe has diligently pursued all possible ways of obtaining a statement from Epstein about his lack of remorse for abusing Jane Doe without success There are no other reasonable means of obtaining a statement from Epstein on these subjects Mr Rush also told me that Mr Epstein spoke _specifically about one of my clients L.M and he made derogatory remarks about her Additionally Mr Rush said that Epstein spoke directly about another civil case that was filed against him Jane Doe Epstein that case alleges that Epstein repeatedly sexually abused a year old girl forced her to have sex with his friends and flew her on his private plane nationally and internationally for the purposes of sexually molesting and abusing her Epstein flippantly told George Rush that that case was dismissed in a way to indicate that the allegations are ridiculous and untrue Mr Rush indicated that he taped the conversation between him and Mr Epstein Mr Rush also spoke at length to Michael Fisten an investigator with my firm that was assisting with the investigation of the case Mr Fisten reported to me shortly after the conversation with Mr Rush that he had such a conversation Case Document Entered on FLSD Docket Page of While research by other plaintiffs attorneys and myself has uncovered other persons that were acquaintances of Mr Epstein specifically Donald Trump Alan Dershowitz Bill Clinton Tommy Mottola and David Copperfield we have no information that any of those people other than Mr Dershowitz have spoken to Mr Epstein aboutJane Doe or any of the other specific victims of Mr Epsteins molestation Mr Dershowitz is acting as an attorney for Mr Epstein and therefore it is presumably unlikely to question him about any admissions that Epstein may have made regarding Jane Doe or other minors girls Additionally we have no information that any of those individuals or any other individuals have any taped statements of Epsteins own voice relating to these matters George Rush..s.taped conversation with Mr Epstein.is the only known.one.Jn existence making it very unique and it contains information not otherwise obtainable through other means or sources Indeed without the Rush tape conversation the jury that handles the case will not hear any words from Epstein himself about his abuse of Jane Doe and other young girls I have been informed by Epsteins attorney that Epstein intends to invoke his Fifth Amendment rights rather than answer any substantive questions aboutthe abuse of Jane Doe and other girls at trial The Rush interview is in any event unique and not otherwise obtainable from other witnesses because it can be used to prove perjury a federal crime on the part of Epstein Epstein lied aboutnot 267knowing George Rush See deposition of Jeffrey Epstein;-taken intM Jeffrey Epstein case page line through line wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Dally News despite the fact that he gave a personal interview that we all now know to have been tape recorded It is therefore evidence of a criminal event If we receive the tape we intend to alert the appropriate law enforcement authorities both federal and state so that they can pursue any appropriate criminal Investigation perjury charges The tape is also crucial for L.M to dismiss the frivolous complaint filed by Jeffrey Epstein against her as he clearly acknowledges knowing L.M contrary to claims he makes in his complaint against her and also contradictory to other statements he has made in depositions related to knowing L.M In that regard this tape provides evidence of other false statements Epstein has mad under oath During a telephone call with George Rush he provided me more than a description of the tape and in fact described the general tenor of the entire interview so that nothing in the interview can be fairly regarded as confidential at this point As George Rush admitted in his affidavit he played the tape for at least two other persons who also confirmed Epsteins arrogance as he speaks about his actions with minors The people for whom George Rush played the tape or told in detail of the information on the tape were not sources in the tradition sense of the word all individuals were simply chatting with Mr Rush about Mr Epstein and his propensity to molest children For example when I discussed the tape with Mr Rush I was not a source in the traditional sense of that term At no point did Mr Rush tell me that I was a source for his reporting Because Epstein and all other co-conspirators have invoked the th amendment as to all relevant questions this tape is the only way that Jane Doe can put Epsteins own perceptions of what he has done before the jury and the only way that Jane Doe can put Epsteins admissions and statement before the jury As even a quick perusal of the more than entries on the docket sheet for Jane Does consolidated case will confirm see Case no S.D Fla case number for consolidated cases on discovery Jane Doe and other plaintiffs have made exhaustive attempts to obtain information from Epstein about his abuse These attempts have included repeated requests for admission requests for production interrogatories and depositions all the means that are listed in the Federal Rules of Civil Procedure for obtaining discovery These means have all been exhausted without success Neither Case Document Entered on FLSD Docket Page of Jane Doe nor any of the other plaintiffs have been able to obtain even a single word of information from Epstein about his abuse of minor girls I made a good faith albeit unsuccessful effort to resolve this matter with Anne News iri-order to avoid,inv 267court-ini:ervention 1explairieei-Hiafwe needed this tape for several reasons including those cited by her in her pleading The tape is detrimental to Epsteins personal complaint against L.M and me the tape is evidence of perjury committed by Epstein the tape is the Best Evidence of his lack of remorse for his actions and will be presented in the punitive damages phase of the civil trials against him and perhaps most important thenape is tile onlywaythat tile jrnytbnsillering Jane-Ool cas Will.be abletb 267earEp-stelns vtlke am:i own statements about his abuse ofJane Doe and other minor girls Without the tape the jury will not have the opportunity to hear Epstein give any substantive information about Jane Does complaint Indeed they will not have the opportunity to even hear Epsteins voice utter any substantive words other than in essence I take the Fifth Ms Carroll has made it clear that Rushs disclosures were viewed unfavorably by his employer I declare under penalty of perjury that the foregoing is true and correct FURTHER AFFIANT
