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18. 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 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
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
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 Epstein's attorney that
Epstein intends to invoke his Fifth Amendment rights rather than answer any substantive questions
about the abuse of Jane Doe and other girls at trial.
19.
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
about not knowing George Rush. See deposition of Jeffrey Epstein, taken in [REDACTED] v. Jeffrey Epstein, case
50-2008-CA-028051, page 154, line 4 through 155 line 9, wherein Jeffrey Epstein clearly 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
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.
20.
The tape is also crucial for [REDACTED] to dismiss the frivolous complaint filed by Jeffrey Epstein
against her, as he clearly acknowledges knowing [REDACTED] 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 made under oath,
21.
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.
22.
As George Rush admitted in his affidavit, he played the tape for at least two other
persons who also confirmed Epstein's arrogance as he speaks about his actions with minors.
23
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.
24.
Because Epstein and all other co-conspirators have invoked the 5th amendment as to all
relevant questions, this tape is the only way that Jane Doe can put Epstein's own perceptions of what
he has done before the jury and the only way that Jane Doe can put Epstein's admissions and statement
s before the jury. As even a quick perusal of the more than 500 entries on the docket sheet for Jane
Doe's (consolidated) case will confirm (see Case no. 9:08-80119 (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
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