# Profoundd archive — Epstein Files
# Bates number: EFTA00207294
# Title:        UNITED STATES DISTRICT COURT
# Dataset:      9
# Pages:        38
# Images:       38 detected
# Tags:         epstein, doj, dataset-9, image-described
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=== SUMMARY ===
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH • • x No. 10 M8-85 (LMM) REPLY DECLARATION OF ANNE B. CARROLL Pursuant to 28 U.S.C. § 1746, Anne B. Carroll declares as follows: 1. I am Vice President and General Counsel of movant Daily News, L.P., publisher of the New York Daily News (the "Daily News"). I am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of


=== EXTRACTED TEXT ===
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
IN RE APPLICATION TO QUASH 
SUBPOENAS TO DAILY NEWS, L.P., 
AND GEORGE RUSH • • 
x No. 10 M8-85 (LMM) 
REPLY DECLARATION OF ANNE B. CARROLL 
Pursuant to 28 U.S.C. § 1746, Anne B. Carroll declares as follows: 
1. I am Vice President and General Counsel of movant Daily News, L.P., publisher of 
the New York Daily News (the "Daily News"). I am admitted to practice before this Court. 
2. I make this Declaration in further support of the motion of the Daily News and 
Daily News journalist George Rush for an Order pursuant to Fed. R. Civ. Proc. 45(cX3XAXiii) 
quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe in an 
action pending in the United States District Court for the Southern District of Florida captioned 
Doe v. Jeffrey Epstein, No. 08-cv-80893-1CAM, or in the alternative for a Protective Order 
pursuant to Fed. R Civ. Proc. 26(cXI). 
3. Annexed hereto as Exhibit A is a true and correct copy of E & J Gallo Winery v. 
Encana Energy Servs.. Inc. 33 Med. L. Rptr. 1413 (S.D.N.Y. 2005) (Preska, J.). 
4. Annexed hereto as Exhibit B is a true and correct copy of L.W. v. Knox County 
Bd. of Educ.. 36 Med. L. Rptr. 1721 (E.D. Tenn. 2008). 
5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this 
proceeding, sworn to on April 30, 2010. 
6. Jane Doe's brief in opposition to Jeffrey Epstein's motion for summary judgment 
dismissing the federal claims in this action ("Si °pp.') may be found on PACER, S.D. Ma. Civil 
Docket for Jane Doe v. Jeffro Epstein, Case # 9:08-cv-80893-KAM ("Dockerp, ppeP4 
EFTA00207294
expressions of confidence in the strength of the evidence in her own case may be found at, e.g., SJ 
Opp 2 (Doe "has ample evidence that [Epstein] committed federal sex offenses against her"); 11 
(Epstein's fraudulent concealment of assets "evidences [his] awareness that he is liable to the girls 
for substantial sums of money because of his sexual abuse of them," citing Epstein's Mar. 8, 2010, 
deposition); 12 ("Epstein does not deny that he repeatedly sexually abused Jane Doe when she was 
a minor"); 35 ("Jane Doe can easily prove her case"). 
7. Specific examples given in Doe's opposition to summary judgment of invocations 
of the 5th Amendment warranting adverse inferences include Epstein's silence in the face of such 
confrontational Requests for Admission as "[y]ou have committed sexual assault against Plaintiff, 
a minor," and "[y]ou digitally penetrated Plaintiff when she was a minor," SJ Opp. at 4, and his 
refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 
8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in 
Epstein v. Rothstein, Edwards  No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm 
Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/23947743/121009-
epstein. 
9. Shortly after receiving service of the subpoenas served on Daily News, L.P., and 
George Rush which movants seek to quash in this proceeding, I asked plaintiffs counsel Bradley 
Edwards whether he would withdraw them in exchange for an affidavit from Mr. Rush attesting to 
the fact that he had interviewed Mr. Epstein. Mr. Edwards said he would not. 
10. On Friday, April 30, 2010, I received service of a subpoena from Doe's counsel 
requiring movant journalist George Rush to appear before this Court on May 4, 2010, at 11:00 
a.m., for the purpose of giving testimony in an evidentiary hearing in connection with this matter. 
A copy of the subpoena is annexed hereto as Exhibit F. 
I I. On Friday, April 10, 2010, 1 entailed the Supplementary Affidavit of 
- 2 - 
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George Rush (Exhibit C hereto) in this proceeding to counsel for plaintiff Doe and asked if, 
having seen it they would withdraw the testimonial subpoena to Rush, given that there are no 
material facts in dispute among the parties to this proceeding. Counsel responded that they would 
do so only if movants would stipulate to the accuracy of all facts alleged in the subpoenas of Brad-
ley Edwards and Michael Fisten submitted in support of Doe's opposition to movants' motion to 
quash or for a protective order. I declined. 
1 declare under penalty of perjury that the foregoing is true and correct. 
Executed on May 3, 2010 
/1/4A-c e Anne B. Carroll (AC 5322) 
- 3 - 
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EXHIBIT A 
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Media Law Reporter Page 1 of 
Kir-:; Media Law Reporter's 
Source: Media Law Reporter Cases > U.S. District Courts, New York > E&J Gallo Winery v. Encana Energy Services Inc., 33 
Med.L.Rptr. 1413 (S.D.N.Y. 2005) 
33 Med.L.Rptr. 1413 
EL) Gallo Winery v. Encana Energy Services Inc. 
U.S. District Court 
Southern District of New York 
No. M8-85 
January 12, 2005 
EPO GALLO WINERY, a California corporation v. ENCANA ENERGY SERVICES INC., a 
Delaware corporation, f/k/a PANCANADIAN ENERGY SERVICES INC.; ENCANA 
CORPORATION, a Canadian corporation, f/k/a and successor to PANCANADIAN ENERGY 
CORPORATION 
Headnotes 
NEWSGATHERING 
[1] Forced disclosure of information — Disclosure of unpublished information — In civil actions (.60.1003) 
Forced disclosure of information — Common law privilege (.60.20) 
Plaintiff's subpoena seeking documents and testimony from nonparty media entity will be quashed, since information 
sought is subject to full protection of qualified reporter's privilege, in that nonparty engages in newsgathering 
activities, information sought involves confidential sources and information, information was gathered with intent to 
distribute it to public in form of published price indices, and creation of price indices involves subjective editorial 
judgment, since plaintiff failed to overcome privilege by making sufficient showing that material sought is highly 
material and critical to its claims, and that it exhausted other available sources of information, and since subpoena is 
unduly burdensome under Fed. R. Civ. P. 45(c). 
Case History and Disposition 
Civil action in which plaintiff issued subpoena seeking documents and testimony from nonparty media entity. On 
nonparty's motion to quash. 
Granted. 
Attorneys 
Stephen Williams, of Cotchett, Pitre, Simon & McCarthy, Burlingame, Calif., for plaintiff. 
Allison Gooding, of Gibson Dunn and Crutcher, New York, N.Y., for defendants. 
Victor A. Kovner, Matthew Leish, and Duffy Carolan, of Davis Wright Tremaine, New York, for nonparty McGraw-Hill 
Companies. 
Opinion Text 
Opinion By: 
Preska, J.: 
ORDER 
Non-party The McGraw-Hill Companies, Inc. ("McGraw-Hill"), by its attorneys, "Victor A. Kovner and Matthew A. Leish, 
Davis Wright Tremaine LIP (Duffy Carolan, Davis Wright Tremaine LIP, of counsel) having moved for an Order quashing a 
subpoena duces tecum and ad testificandum issued to McGraw-Hill by Ha Gallo Winery ("Gallo") on October 25, 2004 in 
stinn ittp://medialaw.bna.conthnedw/disnlav/hateh mint disnlav arin7crarrhid=11711717 
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connection with the underlying action pending in the Eastern District of California; and 
The court having considered the Declaration of Larry Foster in Support, dated December 13, 2004, with exhibits; the 
Declaration of Duffy Carolan in Support, dated December 8, 2004, with exhibits; the Supplemental Declaration of Larry 
Foster in Support, dated January 6, 2005; the Declaration of Barbara L Lyons in Opposition, dated December 27, 2004; 
the Declaration of Steven N. Williams 
Page 1414 
in Opposition, dated December 28, 2004, with exhibits; the Request for Judicial Notice submitted in Opposition by Mr. 
Williams, dated December 28, 2004; the Joinder by Encana defendants in McGraw-Hill's motion; the Declaration of Julie K 
Buxbaum in Support of the Joinder by Encana, dated December 22, 2004, with exhibits; the Supplemental Confidential 
Declaration of Mr. Williams in Opposition, dated December 28, 2004, with exhibit; the various Memoranda of law 
submitted by McGraw-Hill, Gallo, and the Encana defendants; and argument of counsel; 
The Court hereby finds as follows: 
[ 1 ] The Gallo subpoena seeks documents and testimony that are subject to the full protections of the qualified reporter's 
privilege as recognized in this Circuit. In re Petroleum Products Antitrust Litigation, 680 F.2d 5 [8 Med.L.Rptr. 1525) (2d. 
Cir. 1982); see also In re Pan Am Corp., 161 B.R. 577 [22 Med.L.Rptr. 1118) (S.D.N.Y. 1993). McGraw-Hill has 
established that its division Plans is engaged in newsgathering activities in connection with its publication of price indices 
(also referred to as price assessments); that the subpoenaed documents and testimony involve confidential sources and 
confidential information; that Platts gathers information from its sources with the intent to distribute it to the public in the 
form of its published price indices; and that the creation of the indices involves subjective editorial judgments. 
Accordingly, to overcome the privilege, Gallo must make a clear and specific allowing that the documents and testimony it 
seeks are (1) highly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other 
available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. 
Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 1996). 
Gallo has failed to make a sufficient showing that the subpoenaed documents and testimony are either highly material, as 
required to satisfy the first prong of the three-part test, or critical to its claims, as required to satisfy the second prong. 
Gallo also has failed to show that it has exhausted other available sources of information, including the Encana 
defendants, the CFTC, and other energy companies. In particular, because Gallo cannot establish that it has exhausted the 
deposition process, or that it has completed its litigation efforts to seek documents and testimony from alternative 
sources, it cannot make a clear and specific showing of exhaustion. 
Finally, I find that the subpoena is unduly burdensome under Federal Rule of Civil Procedure 45(c). While Gallo has 
narrowed its subpoena to the Henry Hub and hubs in California, this narrowing does not decrease the burden on McGraw-
Hill for the reasons set forth in the Declarations of Mr. Foster. 
Accordingly, it is hereby ORDERED that McGraw-Hill's motion to quash the subpoena duces tecum and ad testificandum is 
granted. 
- End of Case - 
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inp://inedialaw.bna.com/rnedw/displav/batch print display.ado?searchid=11231712 5/3/201( 
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EXHIBIT B 
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Media Law Reporter Page 1 of 
  Media Law Reporter®
Source: Media Law Reporter Cases > U.S. District Courts, Tennessee > L.W. v. Knox County Board of Education, 36 Med.L.Rptr. 
1721 (E.D. Tenn. 2008) 
36 Med.L.Rptr. 1721 
L.W. v. Knox County Board of Education 
U.S. District Court 
Eastern District of Tennessee 
No. 3:05-CV-274 
March 25, 2008 
L.W., a minor, by and through his parents SAMUEL and TINA WHITSON v. KNOX COUNTY 
BOARD OF EDUCATION, et at. 
Headnotes 
NEWSGATHERING 
(1) Forced disclosure of Information — Disclosure of unpublished Information — In dvil actions (.60.1003) 
Forced disclosure of information — Common law privilege (P60.20) 
Forced disclosure of information — Statutory privilege ("shield" laws) (P60.25) 
Given federal claims raised by plaintiffs, nonparty reporter's motion to quash subpoena in civil action must be resolved 
under federal, and not state, law; motion is granted, even though reportor's privilege does not exist in U.S. Court of 
Appeals for Sixth Circuit, since, under Fed. R. Civ. P. 26, plaintiffs have failed to show that reporter possesses any 
unique evidence not addressed during her previous deposition or otherwise available from individuals referenced in 
article, since plaintiffs have had ample opportunity to obtain information sought, and since burden and expense of 
proposed discovery outweighs its likely benefit. 
Case History and Disposition 
Motion by nonparty reporter to quash subpoena in civil action. 
Granted. 
Attorneys 
Charles W. Pope Jr., of Pope Law Offices, Athens, Tenn.; Heather G. Hacker, Alliance 
Page 1722 
Defense Fund, Folsom, Calif., and Nathan W. Kellum and Jonathan Scruggs, of Alliance Defense Fund - Memphis, 
Memphis, Tenn., for plaintiffs. 
Martha H. McCampbell, Office of Knox County Law Director, Knoxville, Tenn.; and Gary M. Prince and P. Alexander Vogel, 
of O'Neil, Parker & Williamson, Knoxville, for defendants. 
Opinion Text 
Opinion By: 
Guyton, U.S. Magistrate Judge: 
This civil action is before the Court pursuant to 28 U.S.C. §636(b), the Rules of this Court, and by the Order [Doc. 192) of 
the Honorable Thomas W. Phillips, United States District Judge, for disposition of non-party Endo Mellon's Motion to 
Quash Subpoena and for Protective Order. [Doc. 189) On March 24, 2008, the parties appeared before the Court for a 
hearing on the instant motion. Attorney Richard Hollow appeared on behalf of Ms. Mellon, attorneys Martha McCampbell 
and Gary Prince appeared on behalf of the defendants, and attorney Jonathan Scruggs appeared on behalf of the 
crtnnir http://medialaw.bna.com/medw/disnlav/hatch mint dicnlav arin7cearchirl=11911711 
EFTA00207301
Media Law Reporter Page 2 of 
plaintiffs. 
Ms. Mellon moves the Court to quash a deposition subpoena served on her by the plaintiffs, with the deposition set to 
occur on March 26, 2008, in Houston, Texas. ' As grounds, Ms. Mellon states that the plaintiffs seek to depose Ms. Mellon 
regarding a newspaper article 2 she authored in May, 2005, on matters at issue in this litigation. Ms. Mellon argues that 
Tennessee's Shield Law protects her from having to testify in this matter, and further argues that, even if Tennessee's 
Shield Law does not apply, that the deposition should still be quashed under the standards established by Rule 26(b)(2) of 
the Federal Rules of Civil Procedure. The plaintiffs oppose the motion, arguing that under Rule 501 of the Federal Rules of 
Evidence, it is federal common law, not Tennessee Law, that controls, and that the Sixth Circuit does not recognize a 
reportorial privilege. Plaintiffs further argue that under Rule 26, the discovery sought is highly necessary for plaintiffs' case 
and unavailable from other sources, and thus the deposition should be permitted. 
1 Ms. Mellon, formerly a newspaper reporter in Knoxville, currently resides in Houston, where she continues to 
work as a newspaper reporter. 
2 The Court notes, for the sake of reference, that the newspaper article at Issue was filed by the plaintiffs in 
conjunction with their motion for preliminary injunction. [Doc. 21, Exhibit G) 
( 1 ] Under Rule 501 of the Federal Rules of Evidence, questions of privilege are generally controlled by federal common 
law when the court's jurisdiction is based upon a federal question, but state law generally controls when the court is 
exercising diversity jurisdiction. Fed. R. Evid. 501. In the instant case, the Court is faced with several federal claims, but 
plaintiff also relies in part on claims under the Tennessee Constitution, thus there is a mix of state and federal claims. The 
Sixth Circuit has held that, when faced with a combination of federal claims and pendent state law claims, federal common 
law controls under Rule 501. Hancock v. Dodson, 958 F.2d 1367, 1372-73 (6th Cir. 1992) ("Since the instant case is a 
federal question case by virtue of the appellant's section 1983 claim, we hold that the existence of pendent state law 
claims does not relieve us of our obligation to apply the federal law of privilege/1 Given the federal claims raised by the 
plaintiffs, the Court accordingly finds that the instant motion must be resolved under federal, not state, law. 
Turning next to the question of whether there is a reportorial privilege in the Sixth Circuit, the Court finds that there is 
not. The Sixth Circuit has clearly recognized that reporters do not possess a special privilege against being compelled to 
testify. In re Grand Jury Proceedings, 810 F.2d 580, 584-85 [13 Med.L.Rptr. 2049) (6th Cir. 1987). Rather, the Court 
must apply the balancing test established by Rule 26. In re DaimlerChrysler AG Securities Litigation, 216 F.R.D. 395 (E.D. 
Mich. 2003) (finding that the Sixth Circuit does not recognize a general reportorial privilege, but quashing a deposition 
subpoena of a reporter under Rule 26 as unduly burdensome and duplicative). Under Rule 26(b)(2)(C): 
[title frequency or extent of use of the discovery methods otherwise permitted under these 
rules and by any local rule shall be limited by the court if it determines that: (i) the 
discovery sought is unreasonably cumulative or duplicative, or is obtainable from some 
other source that is more convenient, less burdensome, or less expensive; (ii) the party 
seeking discovery has had ample opportunity by discovery in the action to obtain the 
information sought; or (iii) the burden or expense of the proposed discovery outweighs its 
likely benefit, taking into account 
Page 1723 
the needs of the case, the amount in controversy, the parties' resources, the importance of 
the issues at stake in the litigation, and the importance of the proposed discovery in 
resolving the issues. 
Fed. R. Civ. P. 26(b)(2)(C). 
During the motion hearing, defense counsel stated that all of the individuals referenced in the article have been deposed 
in this matter, and that none of those individuals have refuted the article during their depositions. Additionally, Ms. 
Mellon's counsel stated that Ms. Mellon was deposed in this matter by the plaintiffs on May 26, 2006, during which Ms. 
Mellon answered several questions as to the veracity of the article. 3 Ms. Mellon's counsel also stated that the deposition 
would pose a significant hardship for Ms. Mellon, as it would necessarily require Ms. Mellon to miss work, as well as 
requiring Ms. Mellon to incur additional expenses associated with an attorney traveling out of state to attend a deposition. 
3 A copy of the transcript from Ms. Mellon's May 26, 2006, deposition has been filed. [Doc. 190, Exhibit 8) 
In contrast, the plaintiffs argue that the previous deposition of Ms. Mellon is of no use at trial if the plaintiffs cannot also 
introduce the underlying newspaper article, and thus that they need to conduct a second deposition in light of the Court's 
Order precluding the introduction of the newspaper article as an exhibit at trial. The plaintiffs contend that the information 
they seek from Ms. Mellon cannot be obtained from any other source, and that the information sought is essential to their 
Itto://mectialaw.bna.com/medwklisnlav/hatch nrint disnlav arlilicestrrhiti=11111711 </l/lnin 
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Media Law Reporter Page 3 of 
case. 
With these facts in mind, the Court turns to the Rule 26 factors. Under the first factor, the Court finds that the discovery 
sought is unreasonably cumulative or duplicative, or is obtainable from some other source that is more convenient, less 
burdensome, or less expensive. Specifically, the Court finds that the plaintiffs have failed to show that Ms. Mellon posses 
any unique evidence not addressed during Ms. Mellon's previous deposition or otherwise available from the individuals 
referenced in the article. There is no evidence that any of the individuals referenced in the newspaper articles have denied 
making the statements attributed to them in the article, and thus Ms. Mellon's second deposition would be cumulative to 
her own previously given deposition and that of the other witnesses. 
With respect to the second factor, the Court finds that the plaintiffs have had ample opportunity to obtain the information 
sought. The plaintiffs have previously deposed Ms. Mellon, and had ample opportunity to question her at that time, as well 
as ample opportunity to depose the individuals referenced in the article. With respect to the third factor, the Court finds 
that the burden and expense of the proposed discovery outweighs its likely benefit. Given the almost three year period 
since the article was published, and given the plaintiffs' failure to establish the uniqueness of Ms. Mellon's additional 
testimony, the Court finds that the likely benefit of this deposition would be small, and that any likely benefit is 
outweighed by the cost in time and money to Ms. Mellon posed by the deposition. 
Thus, the Court finds that all of Rule 26 factors weigh in favor of Ms. Mellon, and, accordingly, Ms. Mellon's motion is 
hereby GRANTED. The deposition of Ms. Mellon scheduled for Mardi 26, 2008, is hereby QUASHED. 
IT IS SO ORDERED. 
- End of Case - 
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tttni/meilialaw hna ram/medwhiienInv/hnirh nr:nt el;ortiov orincIoaor"Mei=i 1O917l4 cninnIr 
EFTA00207303
EXHIBIT C 
EFTA00207304
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
 x 
IN RE APPLICATION TO QUASH 
SUBPOENAS TO DAILY NEWS, L.P., 
AND GEORGE RUSH 
 x No. 10 M8-85 (LMM) 
SUPPLEMENTARY AFFIDAVIT OF GEORGE RUSH 
STATE OF NEW YORK ) 
) ss.: 
COUNTY OF NEW YORK ) 
GEORGE RUSH, being duly sworn, deposes and says: 
1. I make this affidavit in further support of the motion of Daily News, L.P., and 
myself to quash subpoenas served on us in this action. 
2. My counsel was recently advised by one of plaintiff's attorneys that there is an 
additional individual -- Michael Fisten, private investigator for Doe's attorney Bradley Edwards 
-- to whom I described certain aspects of the taped interview with Jeffrey Epstein but whom I did 
not identify in my prior affidavit. Hearing that refreshed my memory that in fact I did speak to 
Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein 
must have occurred prior to October 22, 2009, because my conversation with Mr. Fisten took 
place on or about that date, is also correct. My statement in my prior affidavit that the interview 
took place on November 18, 2009, was drawn from an erroneous entry in my Outlook calendar. 
(Despite a diligent effort, I have been unable to establish the exact date on which the interview 
with Mr. Epstein took place.) My mistakes in failing to recall the discussion six months ago with 
Mr. Fisten (which in my memory became conflated with my conversations with Mr. Edwards) 
and in giving the wrong date for the interview were wholly inadvertent and by no means were, as 
EFTA00207305
Doe's lawyers suggest in their opposition papers to this motion, intentional falsities. 
3. Although I do not have a present memory of every item we discussed concerning 
the interview, I cannot dispute the subject matters that Fisten and Edwards say in their affidavits 
were covered, because most of them do at least roughly correspond to parts of the content of the 
interview. There are, however, additional matters discussed in the interview that plaintiff does 
not allege were disclosed to her litigation team and that have link or no relevance to this case. 
4. 1 do dispute both men's characterization of a number of matters discussed, 
however. As this Court will be able to confirm if it does an in camera review of the recording, 
Edwards' and Fisten's accounts of what I allegedly told them -- or what is allegedly on the tape - 
- are off the mark or simply untrue in several important respects. Most prominently, Mr. Epstein 
did not state on the tape either that "he may have come too close to the line" (Edwards Aff't ¶ 13) 
or that "the only thing he might have done wrong was to maybe cross the line a little too closely" 
(Fisten Afft ¶ 7). 
5. Mr. Epstein did not make a "damning admission" during the interview about Jane 
Doe (or any other woman). (Doe Opp. Br. at 1, 20.) In fact, he made no reference whatsoever 
to Jane Doe, the plaintiff in this case. Therefore, plaintiff's allegation that the tape "is the only 
direct evidence in existence or available to Jane Doe to prove what Epstein thinks about what he 
did to her" (Opp. Br. at 22-23) is untrue. 
6. As I stated in my prior affidavit, in my meeting with my three sources for whom I 
played a short segment of the interview tape in the process of an exchange of information to 
assist my reporting, there was an agreement that the contents of the interview were to be held in 
confidence. Plaintiff Jane Doe does not contest this. In addition, I have since learned from one 
of those three sources that in fact he was not present in the room when the recording was played 
- 2 - 
EFTA00207306
and heard none of it. He has expressed a willingness to submit an affidavit to that effect in this 
proceeding, should the Court find that appropriate or necessary. 
7. I reiterate that the disclosures I made about the contents of the tape were solely in 
the context of seeking information from sources in the course of my reporting. Reporters doing 
investigative journalism customarily use information given to them by one side in a dispute as a 
basis for questions aimed at testing the veracity of that information and drawing out the positions 
of the other side, as I did in this case. I do not view my having used certain information gained 
during the Epstein interview in this way to be a waiver of the essential confidentiality of the 
interview because I did not intend to, and did not, publish the information imparted to me by Mr. 
Epstein during the interview. Mr. Edwards' bald statement that he and my other sources with 
whom I spoke about the tape "were not sources in the tradition [sic] sense of the word," but 
rather individuals with whom 1 was "simply chatting" (Edwards Afft ¶ 23) fundamentally 
misunderstands how I and reporters generally gather information. 
8. While it is correct that, in response to Mr. Fisten's request for a copy of the tape, I 
said that I would consider doing that but needed to check with the newspaper's lawyer (Fisten 
Afft ¶ 10), in fact I never intended to give him a copy, never discussed the issue with the 
newspaper's lawyer, and never gave him a copy, as he confirms. 
9. The statements by Mr. Fisten that I told him that I had "compiled very negative 
information on Epstein concerning his exploits with underage girls and how he eluded the justice 
system" and that I presented the story to my publisher, "who killed [it)" (Fisten Afft ¶ 6), is 
false: I never represented that I had gathered any information about Mr. Epstein that was not a 
matter of public record, and the Daily News publisher did not "kill" my story -- in fact my article 
about the Epstein case was subsequently published in the paper. Besides being wrong, Mr. 
- 3 - 
EFTA00207307
Fisten's statements are also gratuitous because they have no bearing at all on the issues before 
this Court. 
10. There is no question that the subpoenas in this case are oppressive and highly 
burdensome to the Daily News and to me as a reporter. Forcing me to testify and to give up the 
tape of my off-the-record interview would compromise my reporting by deterring other sources 
from speaking to me out of fear that they will become involved in third-party litigations and 
force me to change the way I go about my work; for example, 1 would no longer keep newsga-
thering materials important to my work, and I know I would have to think twice before taking on 
reporting projects that involve civil litigations, which up to now I have done frequently. Such 
subpoenas against the press in aid of private disputes, seeking information that offers, in this 
case, at best marginal support, would place extraordinary and undue time demands on myself and 
other reporters and impose heavy financial costs on newspapers seeking to protect their reporting 
at a time when the industry is struggling. 
Sworn to before me this 
t)44—  day of April, 2010 
NotalyeARNotary PublicREs
Outlined York 
Caraiklion bias °only Matta 29. 2014 
4 
EFTA00207308
EXHIBIT D 
EFTA00207309
Case 9:08-cv-80893-KAM Document 140-1 Entered on FLSD Docket 04/13/2010 Page 1 of 
7Q 
Page 527 
1 
2 
3 
4 
5 
6 
7 
8 times you went to Mr. Epstein's home? 
A. I don't know. Like 17. 
Q. And I think you testified you never took 
anyone to Mr. Epstein's home, correct? 
A. Yes. 
Q. That's correct? 
A. Yes. 
Q. I asked you a little bit, I asked you at 
9 your last deposition what occurred at the first time 
10 that you went to Mr. Epstein's home. And whatever 
11 you said will be obviously on the record, so it will 
12 be there. But I want to bring you back to that time 
13 so I can ask some follow-up questions. 
14 It's my recollection, correct me if I'm 
15 wrong, please, is that when you went to 
16 Mr. Epstein's home III. was the one who took you, 
17 correct? 
18 A. Yes. 
19 Q. And it was your testimony that when you, 
20 at some point during the time you were in 
21 Mr. Epstein's home the first time, you took off your 
22 clothes in conjunction 
23 A. Yes. 
24 Q. -- with III., correct? 
25 A. Yes. 
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 
Bectronically signed by cyndila booklets (601.051-976-2934) 
Electronically signed by gnat,. hopkins (601-051.9762931) 
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EFTA00207310
EXHIBIT E 
EFTA00207311
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
JEFFREY EPSTEIN, 
Complex Litigation, Fla. R. Civ. Pro. 1.201 
CASE NO. 
Plaintiff, 
v. 
SCOTT ROTHSTEIN, individually, 
ilrDLEY J. EDWARDS, individually, and 
., individually, 
Defendants. 50 2009 cAo 03 (JUI0X04B 
COMPLAINT COPY 
RECEIVED FOR FILING 
AC 20011 
0MAMON M, rogrc 
Oirtiftts & OOMPTligaiR 
Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his 
undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, 
individually, BRADLEY J. EDWARDS, individually, and M., individually. Accordingly, 
EPSTEIN states: 
SUMMARY OF ACTION 
Attorney Scott Rothstein aided by other lawyers and employees at the firm 
of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal 
of the ethical, legal and fiduciary duties to their own clients and professional obligations 
to the administration of justice, deliberately engaged in a pattern of racketeering that 
involved a staggering series of gravely serious obstructions of justice, actionable frauds, 
and the orchestration and conducting of egregious civil litigation abuses that resulted in 
profoundly serious injury to Jeffrey Epstein one of several targets of their misconduct 
EFTA00207312
Epstein v. RRA, et al. 
Page 2 
and others. Rothstein and RRA's fraud had no boundary; Rothstein and his co-
conspirators forged Federal court orders and opinions. Amongst the violations of law 
that are the subject of this lawsuit are the marketing of non-existent Epstein settlements 
and the sanctioning of a series of depositions that were unrelated to any principled 
litigation purpose but instead designed to discover extraneous private information about 
Epstein or his personal and business associates (including well-known public figures) in 
order to defraud investors and support extortionate demands for payment from Epstein. 
The misconduct featured the filing of legal motions and the pursuit of a civil litigation 
strategy that was unrelated to the merits or value of their clients' cases and, instead, 
had as its improper purpose the furthering of Rothstein's misrepresentations and deceit 
to third party investors. As a result, Epstein was subject to abusive investigatory tactics, 
unprincipled media attacks, and unsupportable legal filings. This lawsuit is filed and will 
be vigorously pursued against all these defendants. The Rothstein racketeering 
enterprise endeavored to compromise the core values of both state and federal justice 
systems in South Florida and to vindicate the hardworking and honest lawyers and their 
clients who were adversely affected by the misconduct that is the subject of this 
Complaint. 
Plaintiff reserves the right to add additional defendants — co-conspirators as the 
facts and evidence is developed. 
GENERAL ALLEGATONS 
1. This is an action for damages in excess of $15,000.00, exclusive costs, interest, 
and attorneys' fees. 
EFTA00207313
Epstein v. RRA, et al. 
Page 15 
40. EDWARDS filed amended answers to interrogatories in the state court matters, 
i. and.., and listed additional high profile witnesses that would allegedly be called 
at trial, including, but not limited to: 
(i) Bill Richardson (Governor of New Mexico, formerly U.S. 
Representative and Ambassador to the United Nations); and 
(ii) Any and all persons having knowledge of EPSTEIN'S charitable, 
political or other donations? 
41. The sole purpose of the scheduling of these depositions or listing high profile 
friends/acquaintances as potential witnesses was, again, to "pump" the cases to 
investors. There is no evidence to date that any of these individuals had or have any 
knowledge regarding RRA's Civil Actions. 
42. In furtherance of their illegal and fraudulent scheme against EPSTEIN, 
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, 
in her Civil Action against EPSTEIN: 
a) Included claims for damages in Jane Doe's federal action in 
excess of $50,000,000.00 rather than simply alleging the 
jurisdictional limits. 
b) Organized a Jane Doe TV media interview without any legitimate 
legal purpose other than to "pump* the federal case for potential 
2 These high-profile celebrity 'purported* witnesses have no personal knowledge regarding the facts on 
these "Three Cases", but were being contacted, subpoenaed or listed to harass and intimidate them and 
Epstein, and to add "star" appeal to the marketing effort of the Ponzi scheme. 
EFTA00207314
Epstein v. RRA, et al. 
Page 16 
investors or to prejudice Epstein's right to a fair trial in Palm 
Beach County. 
c) EDWARDS, Berger and Russell Adler (another named partner in 
RRA) all attended EPSTEIN's deposition. At that time, 
outrageous questions were asked of EPSTEIN which had no 
bearing on the case, but so that the video and questions could be 
shown to investors. 
d) Conducted and attempted to conduct completely irrelevant 
discovery unrelated to the claims in or subject matter of the Civil 
Actions for the purpose of harassing and embarrassing witnesses 
and EPSTEIN and causing EPSTEIN to spend tens of thousands 
of dollars in unnecessary attorneys' fees and costs defending 
what appeared to be discovery related to the Civil Actions but was 
entirely related to the furtherance of the Ponzi scheme. 
e) After EDWARDS was recruited and joined RRA in the spring of 
2009, the tone and tenor of rhetoric directed to cases against 
EPSTEIN used by Attorney EDWARDS and Berger changed 
dramatically in addressing the court on various motions from 
being substantive on the facts pled to ridiculously inflammatory 
and sound-bite rich such as the July 31, 20O9, transcript when 
EDWARDS stated to the Court in ..M.: `What the evidence 
is really going to show is that Mr. Epstein — at least dating back as 
EFTA00207315
Epstein v. RRA, et al. 
Page 17 
0 
g) far as our investigation and resources have permitted, back to 
1997 or '98 - has every single day of his life, made an attempt to 
sexually abuse children. We're not talking about five, we're not 
talking about 20, we're not talking about 100, we're not talking 
about 400, which, I believe, is the number known to law 
enforcement, we are talking about thousands of children... and it 
is through a very intricate and complicated system that he devised 
where he has as many as 20 people working underneath him that 
he is paying well to schedule these appointments, to locate these 
girls." 
As an example, EDWARDS filed an unsupportable and legally 
deficient Motion for Injunction Restraining Fraudulent Transfer of 
Assets, Appointment of a Receiver to Take Charge of Property of 
Epstein, and to Post a $15 million Bond to Secure Potential 
Judgment, in Jane Doe v. Epstein, Case No. 08-CV-80893-
Marra/Johnson. The motion was reported in the press as was the 
ultimate goal (i.e., to "pump" the cases for investor following). 
However, the Court found "Plaintiffs motion entirely devoid of 
evidence .. ", and denied the motion in toto. 
ROTHSTEIN told investors he had another 52 females that he 
represented, and that Epstein had offered $200 million to resolve, 
EFTA00207316
Epstein v. RRA, et al. 
Page 18 
but that he could settle, confidently, these cases for $500 million, 
separate and apart from his legal fees. 
h) ROTHSTEIN and the Litigation Team knew or should have known 
that their three (3) filed cases were weak and had minimal value 
for the following reasons: 
(i) - testified she never had any type of sex with 
Epstein; worked at numerous strip clubs; is an 
admitted prostitute and call girl; has a history of 
illegal drug use (pot, painkillers, Xanax, Ecstasy); 
and continually asserted the 5th Amendment 
during her depositions in order to avoid answering 
relevant but problem questions for her; 
(ii) — testified she worked at eleven (11) 
separate strip dubs, including Cheetah which 
RRA represented and in which ROTHSTEIN may 
have owned an interest and.. also worked at 
Platinum Showgirls in Boynton Beach, which was 
the subject of a recent police raid where dancers 
were allegedly selling prescription painkillers and 
drugs to customers and prostituting themselves. 
(iii) Jane Doe (federal case) seeks $50 million from 
Epstein. She and her attorneys claim severe 
EFTA00207317
Epstein v. RRA, et al. 
Page 19 
emotional distress as a result of her having 
voluntarily gone to Epstein's home. She testified 
that there was never oral, and or sexual 
intercourse; nor did she ever touch his genitalia. 
Yet, Jane Doe suffered extreme emotional distress 
well prior to meeting Epstein as a result of having 
witnessed her father murder his girlfriend's son. 
She was required to give sworn testimony in that 
matter and has admitted that she has lied in sworn 
testimony. Jane Doe worked at two different strip 
dubs, including Platinum Showgirls in Boynton 
Beach. 
i) Conducted ridiculous and irrelevant discovery such as 
subpoenaing records from an alleged sex therapist, Dr. Leonard 
Bard in Massachusetts, when the alleged police report reflected 
that EPSTEIN had only seen a chiropractor in Palm Beach named 
Dr. Bard. No records relating to EPSTEIN existed for this alleged 
sex therapist, Dr. Bard, and the alleged subpoena for records was 
just another mechanism to "pump" the cases for investor appeal; 
j) Allowed a Second Amended Complaint to be filed on behalf of 
alleging that EPSTEIN forced the minor into "oral sex," yet 
■. testified that she never engaged in oral, anal, or vaginal 
EFTA00207318
Epstein v. RRA, et al. 
Page 20 
intercourse with EPSTEIN and she had never touched his 
genitalia. 
k) Told investors, as reported in an Associated Press article, that 
celebrities and other famous people had flown on EPSTEIN'S 
plane when assaults took place. Therefore, even though none 
(zero) of RRA's clients claim they flew of EPSTEIN'S planes, the 
Litigation Team sought pilot and plane logs. Why? Again, to 
prime the investment "pump" with new money without any 
relevance to the existing claims made by the RRA clients. 
I) After EDWARDS joined RRA, EDWARDS and former Circuit 
Judge William Berger filed and argued motion to make the Non-
Prosecution Agreement (NPA) between Epstein and USAO 
public. But, RRA, EDWARDS and Berger, and their three clients, 
already had a copy of the NPA. They knew what it said and they 
knew the civil provisions in the agreement had no impact 
whatsoever on the three pending Civil Actions. 
The concept behind certain civil provisions in the NPA was 
to allow an alleged victim to resolve a civil claim with Epstein, 
maintain her complete privacy and anonymity and move on with 
her life. As an assistant United States Attomey stated at a 
hearing in federal court, the NPA was not designed "to hand them 
a jackpot or a key to a bank." 
EFTA00207319
Epstein v. RRA, et al. 
Page 21 
43. ROTHSTEIN, with the intent and improper motive to magnify his financial gain 
so continue to fund the fraudulent and illegal investment and/or Ponzi scheme, had 
EDWARDS demand excessive money from EPSTEIN in the Civil Actions. 
44. The actions described in paragraph 42 above herein had no legitimate purpose in 
pursuing the Civil Actions against EPSTEIN, but rather were meant to further the 
fraudulent scheme and criminal activity of ROTHSTEIN so that he and others could 
fraudulently overvalue the settlement value of the existing and non-existent claims 
against EPSTEIN to potential investors. 
45. As a result of the fraudulent investment or (Ponzi) scheme, RRA and its 
attorneys in the Civil Actions against EPSTEIN may have compromised their clients' 
interests. ROTHSTEIN and the Litigation Team would have been unable to give 
unbiased legal counsel because outside investor(s) had been promised a financial 
interest in the outcome of the actions. Additionally, if a plaintiff received payments from 
investment monies while her action is pending, this clearly could impact the plaintiff's 
decision of whether or not to settle the current litigation or shade their testimony (i.e. 
commit perjury) to gain the greatest return on the investment and to further promote the 
Ponzi Scheme. 
46. The truthfulness of■ allegations and testimony in ■.'s state civil 
action have been severely compromised by the need to seek a multi-million dollar 
payout to help maintain RRA's massive fraud. Because fictitious settlements of tens of 
millions of dollars in cases relating to EPSTEIN were represented to Investors" in this 
Ponzi scheme, RRA and the attorneys in the Civil Actions needed to create a fiction that 
EFTA00207320
Epstein v. PRA, et al. 
Page 22 
included extraordinary damages. However, the actual facts behind her action would 
never support such extraordinary damages. Therefore, extraordinary measures were 
undertaken to create an entirely inflated value of her claims against EPSTEIN. 
a. Though she held herself out as a "victim" of Epstein, she admitted to having 
returned over and over again to him despite her current claim of abuse. She 
has now admitted, under oath, to being a call girt/escort since the age of 15. 
(in her deposition September 24, 2009 Transcript "Dr 280:16-19). She 
testified "Well, I lived life as a prostitute," (see DT 156:7) and "I am a 
prostitute when I make money" (see DT 156:12-13). ■. admitted her 
activity with men other than Epstein to making $1,000 a day from prostitution 
on maybe more than 20 occasions in one year alone (DT 157:11-158:21). 
admitted under oath to keeping a list of amounts she collected from 
"Johns" in 'two or three" lined books including a book of 'Psalms" that she 
obtained from a religious store (DT 152:1-14). Under the circumstances, her 
claim for damages against EPSTEIN, one of ■.'s many "Johns" during that 
same period, would be so incredible and certainly not likely to produce the 
extraordinary settlements promised to "RRA'S investors." 
47. In April 2007, before she was represented by EDWARDS, and RRA,.. 
gave sworn taped recorded testimony to the agents of the FBI. She was represented 
by a lawyer other than EDWARDS at that statement She spoke of EPSTEIN in a very 
positive and friendly terms and directly contradicted the central allegations on which 
■.'s civil action against Epstein is now based. However, once in the hands of 
EFTA00207321
Epstein v. RRA, et al 
Page 23 
EDWARDS and RRA, Ill's story changed dramatically. All of a sudden she wanted to 
sue EPSTEIN and like other RRA clients, sought tens of millions of dollars. 
a. For example, in her sworn statement to the FBI, was insistent that 
"Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she 
stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an 
awesome man and it really would be a shame. It's a shame that he has to 
go through this because he's an awesome guy and he didn't do nothing 
wrong, nothing." (pp. 57-58 - FBI). In fact, III spoke so highly of 
EPSTEIN and her interactions with him that the US Attorney's office 
informed a federal court in July 2008 that the US Attorney could not 
consider a victim. 
Yet, by September 24, 2009, the date on which In began her 
deposition in her civil action and now represented by RRA and 
EDWARDS, Ill's new and very different tale about purported sexual 
misconduct under the supposed influence of EPSTEIN had been 
thoroughly rehearsed and her role into the ROTHSTEIN scam was 
complete. In her deposition in her civil action,.. declared that: 
"I, I don't realty care about money." (DT 206:8) 
"He needs time in jail. He doesn't want to be — this is not right for 
him to be on the streets living daily .." (DT 219:21-23) 
EFTA00207322
Epstein v. RRA, et al. 
Page 24 
"You don't think my whole life I have lived that shifty life because of 
Jeffrey Epstein?" (DT 222:7-8) 
b. In her sworn FBI testimony (pre-EDWARDS and RRA), ■. was 
emphatic that her interactions with Epstein involved no inappropriate 
sexual touching in any way. In fact, it was exactly the opposite: 
Q: Did he at any point kiss you, touch you, show any kind of 
affection towards you? 
A: Never, never. (p. 21 — FBI) ... 
Q: So he never pulled you closer to him in a sexual way? 
A: I wish. No, no, never, ever, ever, no, never. Jeffrey is an 
awesome man, no. (p. 21 - FBI) 
Yet, filed her second amended complaint in April 20O9, 
after EDWARDS joined RRA, the allegations against EPSTEIN in 
■.'s complaint became even more salacious. In paragraph 12 of 
■.'s Second Amended Complaint, ■. alleges among other 
things, that: 
"Jeffrey Epstein coerced, induced, or enticed . .the then minor 
Plaintiff to commit various acts of sexual misconduct. These acts 
included, but were not limited to, fondling and inappropriate and 
illegal sexual touching of the then minor Plaintiff, forcing or inducing 
the then minor plaintiff into oral sex or other sexual misconduct..." 
EFTA00207323
Epstein v. RRA, et at. 
Page 25 
c. In her sworn FBI statement (pre-EDWARDS and RRA), testified that 
, the individual who first brought ■. to EPSTEIN's 
home, told ■. "make sure you're 18 because Jeffrey doesn't want any 
underage girls." (p. 8 - FBI). 
Yet at her September, 2009 deposition now represented by 
EDWARDS and RRA,■. told a very different story: 
Q: My question was what did Carolyn tell you to tell Mr. Epstein 
about your age? 
A: She said it didn't matter. 
Q: That's your recollection about what she said? 
A: Yes, she said — I remember her saying it doesn't matter. Don't 
worry about it. 
(DT 199:20-25) 
d. Pre-EDWARDS and RRA, testified to the FBI : "I always made 
sure — I had a fake ID, anyways saying that I was 18? (p. 8 - FBI). 
Yet, when questioned about her fake ID at her September 2009 depo, she 
stated: 
O: And did you have a fake ID? 
A: No. 
Q: Have you ever had a fake ID? 
EFTA00207324
Epstein v. RRA, et al. 
Page 26 
A: No. 
(DT 300:5-8) 
e. In her FBI statement (pre-EDWARDS and RRA), fl testified 
about others ■ brought to the Epstein home. testified that women she 
brought to EPSTEIN's home were eager for the opportunity and content with their 
experiences: 
A: None of my girls ever had a problem and they'd call me. They'd 
beg me, you know, for us to go to Jeffrey's house because they 
love Jeffrey. Jeffrey is a respectful man. He really is. I mean, and 
he all thought we were of age always. This is what's so sad about 
it. (p 30 - FBI). 
Q: Did any of the girls complain about what happened after they left 
there? 
A: No. You asked me that question. No, everybody loved Jeffrey. 
(p. 44 - FBI) 
A: Every girl that I brought to Jeffrey, they said they were fine with 
it. and like for example j.— another of RRA's clients in the 
Civil Actions], a lot of girls begged me to bring them back for the 
money. And as far as I know, we all had fun there. (p. 45 - FBI) 
EFTA00207325
Epstein v. RRA, et al.
Page 27 
Yet, with EDWARDS and RRA as her attorneys, • did a "180" at her 
September, 2009 deposition in saying: 
A: . . . Once they were there, they were scared out of their mind. 
They did it anyways and some of them walked out and said a 
don't ever do this to me again. That was the worst thing that ever 
happened to me. (DT 170:6-11) 
. . A: And then, a lot of girls weren't comfortable. (DT 171:13) 
f. The above represent only a few of the dramatic changes 115 made 
in her testimony prior to her representation by EDWARDS/RRA and after she 
hired ROTHSTEIN, EDWARDS and RRA. 
48. As a result of the fraudulent investment or (Ponzi) scheme, may knowingly 
have compromised her alleged interests in her Civil Action, or committed a fraud on the 
court. 
49. RRA and the Litigation Team took an emotionally driven set of facts involving 
alleged innocent, unsuspecting, underage females and a Palm Beach Billionaire and 
sought to turn it into a gold mine. Rather than evaluating and resolving the cases based 
on the merits (i.e. facts) which included knowledgeable,



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