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ie ‘on vthe tape were not.“sources” in the tradition’ sense of the ‘word:= all individuals were simply’ chatting: cece
ea" with. ‘Mr. Rush about: Mr. Epstein’ and. his. propensity to molest. children: For example,’ when. discussed 2
: M, RASH tell me that: | was a “source” ” for’ his reporting.
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. : a
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 oe 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 f 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 ebiainable 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 . i
* personal interview that we all now know to have been tape recorded. It is therefore evidence of a ew, alee |
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.
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 il contrary to claims. he makes in his complaint . ae |
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, ony
21. -During a télephone 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. : :
ae (225 at 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.
ls WBE ‘The people: for: whom. George Rush: played: the. tape or told in detail of the information’ a
- ‘the tape with. Mr. Rush, a was nota‘ “source” -in the” traditional s sense. of that Tenn. AL no 1 point ¢ did. Mre oe ry
* senate a 24 7 Because Epstein and ali other co- conspirators | fives 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 te
Mert ammnetatmt op
ef, og ‘before, the jury.. As even’ a ‘quick: perusal of. the 1 more. ‘than 500 entries on ihe docket sheét for’ Jane aan + r : “4
Doe’ s (consolidated) case will confirm (see-Case no. 9:08- 30119 (S.D: Fla. ): (case number. for consolidated ee Rogen
: . cases on discovery), Jane Doe.and other. plaintiffs have made exhaustive attempts to, obtain information ih
from Epstein about his abuse: These attempts have included repeated requests for admission, requests ee A;
“for production, interrogatories, ‘and. depositions - ~ all the means that are listed. in the Federal Rules‘of 2 4
Civil Peaceciice for obtaining discovery. These means have all’ been exhausted without s success. Neither ee |
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