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‘present during acts of sexual abuse by Epstein. In any event, ALL of thase individuals have also invoked
- their 5" 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 ofjJane oo | |
Doe and other minors girls. This creates a serious issue for Jane Doe in proving her sexual molestation : -
\- claire against Epstein. By its nature, sexual molestation takes place i in private, with only the abuser and - i
the victim typically available to testify. in this case, Epstein’s abuse of Jane Doe took place in private, Se )
on with onl y 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.
it. Additionally, Mr. Epstein. has recently filed a lawsuit against me » personally that has no.
. merit whatsoever, a fact known to. Mr. Epstein. and his attorneys. He filed the lawsuit against Brad |
) rds, Scott Rothstein, and L.M. (another Epstein victim of his molestation). ‘That lawsuit implies that 7 |
a civil case ‘against him (currently pending in Florida state court) is fabricated and that I and|-
have conspired to commit-fraud against, him (presumably that she made up the case against. him,
implying that he does not know ‘While the present subpoena before the Court has been filed by
Jane Doe, the Court should be aware that attorneys representing li may also file a. subpoena for the
George Rush tape shortly. . :
12. Despite Mr. Epstein and all of his co- conspirators, asserting a a 50 amendment privilege Le,
Z against self-incrimination, George Rush of the New York Daily news did contact me to.inform me that ~
Mr. Epstein spoke personally with hirn about i issues related to the various charges of sex. abuse against
13.0 ‘Paraphrasing from memory of n my conversation 1 with Mr. Rush, Mr. Epstein told him that
he may have.come “too close to the line’ but that hé shoul id not have been punished as severely as he
was and that his conduct was at most worthy of a $100 fine. This is a statement that shows two things
_of great importance to Jane Doe's pending civil action. First, it isin effect an admission by Epstein of his:
_ fiability: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 Doe's 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.
os Rush is a clear dernonstration that Epstein lacks remorse for committing felony child molestation: against
“jane Doe. This will be a. central I issue in the punitive damages case against Epstein at trial. Here again,
Jane Doe has di ligently. 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 r means of obtaini ings as
=. Statement from. Epstein on these subjects. a *
Pn 14. oo “Mr, Rush also told me that Me. Epstein spoke special about c one ofr my ai | es “ a |
ee and he: made derogatory remarks about her. fe ene wo ‘
” S150 ‘Additionally, | Mr. ‘Rush: said that Epstein. spoke directly about another civi ic case that was :
. filed against him Uane Doe 102 v. Epstein); ‘that case alleges: that Epstein repeatedly: sexually abused ao
” 15 year old girl, forced her to have sex with his friends and flew heron his: private plane. nationally. and)
: international y for the purposes of sexually. molesting - and. abusing. her.: ‘Epstein flippantly_ told George
oS Rush that that case was: di ismissed, in away to: indicate that the: allegat tions are. ridiculous and untrue.
= 16. % Mr, Rush indicated that he taped the. conversation between him and Mr. Epstein.
a 47 o Mr. Rush also spoke at length to Michael Fisten, an investigator with: my fi 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. , : :
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