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a 4 on v the tape were not “sources” in the tradition sense of the word’ alf individuals were simply chatting: no with. Mr. Rush about-Mr. Epstei in ‘and. his propensity to molest. chil dren: For exampl a, awhen 1. discussed _ - : Rush tell me that. | was: a “source” for his reporting. > - he has done’ before the jury and the only way that jane. Doe can. put Epstein’ s.admissions and statement - eg ‘before. the jury.. As even a quick: perusal of: the | more ‘than 500 entries on the docket sheet for’ Jane 18. While research by other plaintiffs’ attorneys and myself has uncovered. other persons _ that. were acquaintances of Mr. Epstein, specifically Donald Trump, A Alan Dershowitz, Bill Clinton, Tommy Mottola, and David Copperfi eld, we have. no information that any of those people {other than. Mr. Dershowitz} have spoken to Mr. Epstel n 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 gifls. 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 a Z| 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 fram 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 substanti ive questions 7 about the abuse: of Jane Doe and other girls at trial. . 49. 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 fied. “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 impresses that he does not recognize George ‘Rush from the New York Daily News, despite the fact that -he gavea * personal interview that we all now know to have been tape recorded. It is therefore evidence of a ce criminal event. If we receive the tape, we intend to alert’ the appropriate law enforcement authorities, vod ~” both. federal and state, $0 that they can pursue any appropriate criminal investi igation perjury charges. . 20. The tape is also crucial foto dismiss the frivolous complaint filed by Jeffrey Epstein.” against her, as he clearly acknowledges knowing EE contrary to claims. he makes in his complaint against her and also contradictory to other statements he has made in depositions related to knowing LM. In that regard, this tape provides evidence of other false statements Epstein has made under oath, 24. During a telephone call ‘with George Rush, he provided me more than a description of the tape, and in fact described the general tenor of the entire interview, so that t nothing | in the interview can be fairly regarded as confidential at this point. : ce (220 oe : AS George Rush. admitted. in: his affidavit, he played the. tape for at feast. two. other . - persons who al ‘SO, confirmed ‘Epstein’ s arrogance as he speaks about his actions with minors. ©. 23... The’ people for whom George Rush’played the tape or told in detail of the Information — the tape with. Mr. Rush, 1 was nota: “source” in the” traditional.s sense, of that term. A. no ? point d did. Mr we 624. 2 Because ‘Epstein and all other co- conspirators | have irivoked the 5th amendment as sto all . relevant’ questions. this tape | is. the only: way that Jane Doe can: ‘put Epstein’ '$ own perceptions of what es 7 Doe’s (consolidated). case will confirm. (see-Case no. 9:08- 80119 (S.D: Fla. } (case number for consolidated cases on di scovery), Jane Doe.and other plaintiffs have. made exhausti ive attempts to, obtain information a from Epstein about his abuse: These attempts have included repeated requests for admi ission, requests “for production, interrogatories, and. depositions - ~ all the means that are listed. in the Federal Rules-of . wil Procedure for obtaining discovery. These means have all been exhausted without s success. Neither oo HOUSE_OVERSIGHT_013491