ae A ‘on vthe tape were not.“sources” in the tradition’ sense of the word:~ all individuals were simply’ chatting: pecs ea" with. ‘Mr. Rush about: Mr. Epstein’ and. his. propensity to molest. children: For example,’ when. discussed 2
: A, RSH tell me that: | was: a “source” ” for’ his reporting.
18. While research by other plaintiffs’. ‘attorneys and myself hs 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 about Jane Doe or.any of the other. specific victims of Mr. '- .Epstein’s molestation. Mr. Dershowitz ‘is acting as an ‘attorney for Mr. Epstein, and therefore it is. ; 4 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: Epstein’ s own voice relating to these matters.. George Rush’s taped conversation with Mr..Epstein is the only. known, one.in existence, making it very unique 4 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. | have been. informed by Epstein’s attorney that , : .. Epstein intends to invoke his Fifth Amendment rights rather than answer any substantive e questions : ” about the abuse’ of Jane Doe and other girls at trial. faa
49, The Rush interview is, in any event, unique and. ‘not otherwise abieinable from other . witnesses because it can be used. to prove perjury (a federal crime) on the part of Epstein: Epstein lied.
“about not: knowing: George Rush. See deposition of Jeffrey Epstein, taken in. Jeffrey Epstein, case
~ 50-2008-CA-~ 028051,° ‘page-154, line 4 through. 155 line 9, wherein Jeffrey Epstein clearly i impresses that "he does not recognize ‘George ‘Rush from the New York Daily 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 w, wales | criminal event. If we receive the tape, we intend to alert’ the appropriate law enforcement authorities, , ; . L ~” both federal and state, SO that they can pursue any. appropriate criminal investigation perjury charges. 4
7 20. The tape is.also crucial rofl to dismiss the frivolous complaint filed by Jeffrey Epstein. against her, as he clearly acknowledges knowing iil contrary ‘to claims. he makes in his complaint . re | against her and also contradictory to other statements he has made: in depositions related to knowing -. i etl that regard, this tape provides evidence of other false statements Epstein has’ made under oath, Sony
21. -During a telephone call with George Rush, he provided me more than a description of ie tape, and in fact described the general tenor of the entire interview, so that t nothing i in the interview can be fairly regarded as confidential at this point. : :
Bae (22: mt As George Rush. admitted in: his affidavit, he’ played the. tape for at lege two. other : persons who also, confirmed Epstein’ s arrogance as he speaks about his actions with minors.
I WBE ‘The people: for: whom. George Rush: played the. tape or told in detail of the information’ a
- ‘the tape with. Mr. Rush, 1 was nota® “source” -in the” traditional s sense. of that Term. At no i point ¢ did. Mr i
"went a 24 tb Because Epstein and ali other co- conspirators | fave: invoked the sig amendment as. sto all relevant questions, . this tape: is the only: way that Jane Doe can: ‘put Epstein’ sown perceptions of what - a he has. done‘before the j jury and the only way that Jane. Doe’ can. put Epstein’ s.admissions and statement oe
Msi amnnetatm op
ef og ‘before, the jury.. As even: a quick: perusal of. the 1 more. ‘than 500 entries on the docket sheét for’ ‘Jane we + : 7 : “4
Doe’ s (consolidated) case will confirm (see-Case no. 9:08- 30119 (S.D: Fla. ): (case number. for consolidated eee Rongee
: . cases on discovery), Jane Doe.and other. plaintiffs have made exhaustive attempts to, obtain information i
from Epstein about his abuse: These attempts have included repeated requests for admission, requests 7 a A; “for production, interrogatories, ‘and. depositions - ~ all the means that are listed. in the Federal Rules‘of 2 4 Civil Peacectiice for obtaining discovery. These means have all: been exhausted without s success. Neither ee |
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