IN THE CIRCUIT COURT OF THE

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRAJUDICIAL STATEMENTS AND COMMENTARY TO THE MEDIA AND PRESS, WITH INCORPORATED LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extrajudicial Statements and Commentary to the Media and Press as set forth below, and states: 1. In an article posted on www.palmbeachdailvnews.com on October 15, 2010, entitled "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: 1) "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very substantial cloud over Mr. Edwards' head." (Exhibit 1). FOWLER WRITE Bun err P.A. • Esetwo SANTO PtAzA, 1395 BMCKELL AVENUE, 141N Rom, MIAMI, FLORIDA 33131 • (305) 789-9203 EFTA01102188 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. 2. In an article appearing on www.palmbeachdailynews.com, posted February 28, 2011, and updated March 1, 2011, entitled "Jeffrey Epstein Introduced Woman to Prince Andrew, She Tells London `Daily Mail'," Mr. Edwards is quoted as saying: "I feel terrible for Virginia and all of the other girls that were sexually abused, but I was not surprised at all by the story." Edwards also said. "I represented several girls that, similar to Virginia, were very young and vulnerable and were badly abused by Epstein. These girls will never completely heal from what they went through. What is most troublesome though is that these serious crimes went virtually unpunished. I currently represent several victims that want Epstein prosecuted for the crimes he committed against them, which is why we filed a claim under the Crime Victim's Rights Act in an effort to overturn the illegal plea deal and get true justice for these victims." (Exhibit 2). 3. On March 8, 2011, the BARD Marketing firm issued a press release on behalf of Mr. Edwards' current law firm, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., which stated that Mr. Edwards "successfully represented" ten women between 12 and 15 years old "by proving that Epstein and his international sex trafficking criminal enterprise exploited them and hundreds of other underage girls." (Exhibit 3) (emphasis added). The press release quotes Mr. Edwards as stating inter alio that "we took on powerful people and sought to level the playing field to protect victims" and that the media attention will hopefully "inspire victims to report these crimes." (Id). 4. On March 11, 2011, the British publication "The Telegraph" published an article entitled "Convicted Paedophile Jeffrey Epstein is Facing a New Criminal Investigation and is Involved in a Civil Suit with a Lawyer." (Exhibit 4). The source for much of that article's information is Mr. Scarola, who is quoted to have said the following (Id): - 2 - FOWLER WHITE BURNETT P.A. • BPI IWO SANTO PLAZA, 1395 WUCKEIL AVENUE, 14- FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA01102189 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. a. "We would be very keen to speak with Prince Andrew, given his relationship with Jeffrey Epstein." b. "We want to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where, how frequently and the extent to which it involved the transport of children inside and outside the United States for sex." c. "We have reason to believe that Prince Andrew has been in the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged chi I dren." 5. On March 11, 2011 the Palm Beach Daily News published an article entitled "Jeffrey Epstein Address Book `Holy Grail' of Famous Names." (Exhibit 5). This article refers to the fact that "[t]he British press has been having a field day digging up new details about Epstein's friendship with Prince Andrew." (Id.). 6. Two days later, another British publication, "The Observer," reported: "Edwards' lawyer, Jack Scarola, said last week that his team intended to try and get a statement from the prince [Andrew] about what he may or may not have seen while attending parties with Epstein." (Exhibit 6). 7. An article published in the "Independent" on March 13, 2011 reported that Mr. Scarola said: "We are in the process of scheduling a further deposition of Mr. Epstein at which we intend to question him regarding the details of his child abuse, including all circumstances in which he may have been involved in procuring sexual favours from minors for his high-profile friends." (Exhibit 7). 8. Again, on March 17, 2011, the BARD Marketing firm, on behalf of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., issued a press release entitled "Victims of Sexual Abuse Demand Justice." (Exhibit 8). The press release states that "Edwards proved that Epstein - 3 - FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICICELL AVENUE, 14m FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA01102190 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. and his international sex trafficking criminal enterprise exploited them and hundreds of other underage girls." (Id.) (emphasis added). 9. The Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. website, www.pathtojustice.com, also issues press releases and links online articles relating to Mr. Epstein and the lawsuits. These press releases are titled: 1) "Brad Edwards Files Motion in Jeffrey Epstein Case — Violation of Crime Victim's Rights Act," (March, 2011); 2) "London Papers Quote Edwards in Recent Jeffrey Epstein / Prince Andrew Scandal" (March, 2011); and 3) "Edwards Prevails on Key Rulings in Epstein Case" (May, 2010). (Exhibit 9). 10. Moreover, the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Facebook Fan page, http://www.facebook.com/#!/FarmerJaffeWeissing, refers to Mr. Epstein as a "billionaire pedophile" and that "Edwards helped 10 women seek justice, who were sexually molested and abused by Epstein." (Exhibit 10). 11. At a hearing before this Court on March 31, 2011, Mr. Scarola repeatedly labeled Mr. Epstein a "pedophile." (Exhibit 11). 12. Mr. Edwards and his attorneys should not be permitted to wage a media campaign against Mr. Epstein, taint the jury pool, and pre-try their case in the court of world opinion. Accordingly, all statements and comments by Mr. Scarola and Mr. Edwards to the press and media regarding Mr. Epstein's alleged sexual abuse of underage women -- other than what appears in the public record -- should be barred by the Court. 13. Undeniably, this Court has the discretion to control and prohibit such extrajudicial commentary and pretrial publicity in order to insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Ha. 1976); Sentinel Commc'n - 4 - FOWLER WHITE BURNET' P.A. • ESP/RDO SANTO PLAZA, 1395 BRICKED. AVENUE, 14" FLOOR, MIAMI, FLORIDA 33131 • (305) 789.9200 EFTA01102191 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. Co. v. Watson, 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limitations imposed by a court on communications between lawyers and/or litigants and the media are permissible for good cause shown in order to assure a fair trial. See McIntosh, 340 So. 2d at 910; Florida Freedom Newspapers, Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988) (there is no constitutional impediment to a court prohibiting counsel from making prejudicial statements that are intended for publication). 14. The Florida Supreme Court in McIntosh, 340 So. 2d at 910, recognized that restrictions on extrajudicial comment are within the power of the trial judge: Limitation placed on lawyers, litigants and officials directly affected by court proceedings may be made at the court's discretion.... Muzzling lawyers who may wish to make public statements ... has long been recognized as within the court's inherent power to control professional conduct. The Florida Supreme Court later stated: "Prohibition on comment is an acceptable alternative to prior restraint." McCrary, 520 So. 2d at 35-36 (order prohibiting public comment on evidence and charges against two defendants by members of state attorney's office and sheriff's office was proper preventive measure where prejudicial publicity threatened to impair the right to a fair trial). 15. Communications by Mr. Scarola and Mr. Edwards, as attorneys and officers of the court, with the media and press are also limited by the requirements of Rule 4-3.6 of the Rules Regulating The Florida Bar Rule 4-3.6, entitled "Trial Publicity": (a) Prejudicial Extrajudicial Statements Prohibited. A lawyer shall not make an extrajudicial statement that a reasonable person would expect to be disseminated by means of public communication if the lawyer knows or reasonably should know that it will have a substantial likelihood of materially prejudicing an adjudicative proceeding due to its FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 DRICKELL AVENUE, I 4m FLOOR, MIAMI, FLORIDA 33131 - (305) 789-9200 EFTA01102192 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. creation of an imminent and substantial detrimental effect on that proceeding. (b) Statements of Third Parties. A lawyer shall not counsel or assist another person to make such a statement. Counsel shall exercise reasonable care to prevent investigators, employees, or other persons assisting in or associated with a case from making extrajudicial statements that are prohibited under this rule." 16. Florida Bar Rule 4-3.6 incorporates the "substantial likelihood of material prejudice" standard that the United States Supreme Court found to be a "constitutionally permissible balance between the First Amendment rights of attorneys in pending cases and the state's interest in fair trials." Gentile v. State Bar of Nevada, 501 U.S. 1030, 1075, III S. Ct. 2720, 2745, 115 L. Ed. 2d 888 (1991). 17. The foregoing authorities make perfectly clear that in appropriate cases extrajudicial statements can and should be prohibited. See also Rodriguez v. Feinstein, 734 So. 2d 1162, 1164-65 (Fla. 3d DCA 1999) (proper for a court to determine on a case-by-case basis whether good cause is shown to impose limitations on communications between counsel and the media). This is an exceedingly appropriate case for prohibiting extrajudicial statements because the ongoing media blitz by Mr. Edwards and Mr. Scarola is substantially likely to prejudice the pending litigation. Indeed, their extrajudicial commentary is unquestionably intended to -- and will -- poison the jury pool against Mr. Epstein. Indeed, their carefully-crafted media campaign against Mr. Epstein is designed to incite the public and muddy the water.' I In a letter of March 18, 2011, in an effort to conserve this Court's time and resources, undersigned counsel requested that Mr. Scarola enter into a written agreement guaranteeing that Mr. Scarola, Mr. Edwards, and their respective agents and employees will not engage in any extrajudicial commentary concerning Mr. Epstein's alleged sexual abuse of or involvement with minor females. The undersigned's efforts have not, unfortunately, been successful. An e-mail - 6 - FOWLER WHITE Bure4err P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14Th Ewa), MIAMI, FLORIDA 33131 • (305)789.9200 EFTA01102193 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. 18. There is no merit to any argument by Mr. Scarola and/or Mr. Edwards that their statements to the media were justified because they were merely responding to statements to the media by an "Australian victim;" that they informed the public of a threat to public safety; and they encouraged other victims to come forward. These purported justifications are frivolous. 19. Instead of simply responding "no comment," defense counsel capitalized on the opportunity to speak extensively to the press regarding matters which can only serve to inflame a potential jury pool and thereby prejudice Mr. Epstein. They were intended to, and did, make sensational tabloid headlines. Moreover, at least one extrajudicial statement was made prior to the media frenzy surrounding Ms. Roberts. 20. The extrajudicial statements of Mr. Scarola are not intended to serve the public good, but, rather, to put pressure on Mr. Epstein by implicating his alleged acquaintances. This is precisely the sort of pretrial publicity that Florida Bar Rule 4-3.6 is designed to preclude. 21. Mr. Edwards' and Mr. Scarola's repeated attempts to poison the well are exacerbated by the publication of patently false statements by Mr. Edwards' present law firm. Press releases issued on behalf of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., by its public relations firm include categorically false statements that Mr. Edwards "proved that Epstein and his international sex trafficking criminal enterprise exploited" "ten women . . between 12 and 15 years of age" and "hundreds of other underage girls." (Exhibit 8) (emphasis added). Mr. Edwards has not proven anything of the sort. The foregoing statements are blatant misrepresentations that must be stopped. response to the above March 18, 2011 letter was received on March 21, 2011 rejecting the request. - 7 - FOWLER WHITE BURNETT P.A. • Esnuro SANTO PLAZA, 1395 BRICKEU. Avenue, 14Th FLOOR, Mimi], FLORIDA 33131 • (305) 7894200 EFTA01102194 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. 22. The media attacks on Mr. Epstein fueled by Mr. Scarola and/or Mr. Edwards have far-reaching ramifications, and create an "imminent and detrimental" effect on the subject litigation. The technological advancements of the 21st century result in the immediate dissemination of comments by counsel to the press. Most, if not all, of the cases cited by Defendants predate the "World Wide Web." In this day and age of the intemet, on-line newspapers, blogs and search-engines like Google and Yahoo, a search of Plaintiff Epstein's name on the Internet will instantaneously reveal any and all pretrial publicity regarding Epstein and all matters relating to these proceedings. These search results will include the most recent as well as older postings. Unlike the days of old when newspapers were the primary source of information and their content was largely forgotten and not readily accessible once thrown in the garbage can, the information on the Internet is always available and easily revisited. Whatever appears now in the press and Internet will continue to generate comment in the press and Internet until the time of trial. 23. In view of prejudicial media frenzy fueled by Mr. Scarola and Mr. Edwards, Mr. Epstein requests the entry of a narrowly - drawn limitation barring them from making extrajudicial statements concerning Mr. Epstein's alleged sexual abuse of, or involvement with, underage women other than what appears in the public record. Specifically, Plaintiff proposes the entry of an Order incorporating the following provisions: 1. No person covered by this order shall make any statement to members of any television, radio, newspaper, magazine, internet (including, but not limited to, bloggers), or other media organization about this case, other than matters of public record, that could interfere with a fair trial or otherwise prejudice the parties or the administration of justice; - 8 - FOWLER WurrE Stm.Err P.A. • ESNIUTO Snwro PLAZA, 1395 B/UCKELL AVENUE, 14,w FLOOR, MIAMI, FLORIDA 33131. (305) 789-9200 EFTA01102195 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. 2. Nothing set forth in paragraph I shall prohibit the parties in this action or their counsel (a) Stating, without elaboration or any kind of characterization whatsoever: (i) the general nature of an allegation or defense made in this case; (ii) information contained in the public record of this case; (iii) scheduling information; (iv) any decision made or order issued by the court which is a matter of public record. (b) Explaining, without any elaboration or any kind of characterization whatsoever, the contents or substance of any motion or step in the proceedings, to the extent such motion or step is a matter of public record in this case and any ruling made thereon to the extent that such ruling is a matter of public record. The Plaintiff requests to grant further protection so that such matters do not become public record for prejudicial extrajudicial statements. The Plaintiff further requests that the court require the Defendant and his counsel to establish good cause in the advance of any filing with such references and advance of any statements for the media. 24. In addition, Mr. Scarola should be prohibited from labeling Mr. Epstein in open court as a "pedophile," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations. 25. The extrajudicial statements by Mr. Scarola and Mr. Edwards throw roadblocks in the "path to justice" and should not be permitted. - 9 - FOWLER WHITE Buiturrr P.A. • Esvutrro SANTO PLAZA, 1395 BRICKELL AVENUE, 14Thl FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA01102196 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. WHEREFORE, Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, respectfully requests that the Court grant his Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff from Making Extrajudicial Statements and Commentary to the Media and Press, and grant such other and further relief as is deemed necessary and proper. Respectfully submitted, By: and Joseph L. Ackerman, Es Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Christopher E. Knight Fla. Bar. No. 607363 FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for Jeffrey Epstein - 10 - FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRKKEII. AVENUE, 14n. FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA01102197 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail this day of May, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack A. Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 h L. Ack rman, Esq. Fla. Bar No. 235954 Christopher E. Knight, Esq. Fla. Bar No. 607363 W:1110143V4TWPRO29-to preclude opposing counsel's extrajudicial statemems-HSG.dacx — 1 I — FOWLEft WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKEIL AVENUE, Mut FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA01102198 Claim: Epstein filed lawsuit to 'intimidate' attorney Edwards prosecuting sex abuse cases Page 1 of 2 PalmBeachDailyNlpyymgm Plnttnis pane U Dos(' Claim: Epstein filed lawsuit to 'intimidate' attorney Edwards prosecuting sex abuse cases By MICHELE DARGAN DAILY NEWS STAFF WRITER Updated: 8:21 p.m. Friday, Oct. 15, 2010 Posted: 8:04 p.m. Friday, Oct. 15, 2010 Billionaire sex offender Jeffrey Epstein filed his 2009 lawsuit against attorney Brad Edwards in an effort to get Edwards to drop sex abuse lawsuits filed against Epstein, attorney Jack Scarola said Friday. "The sole motivation for these claims against Mr. Edwards Is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein," Scarola said. Edwards secured deals for victims L.M., E.W. and Jane Doe, who were among nearly two dozen young women who received confidential settlements from Epstein. Edwards filed a new lawsuit last month against Epstein on behalf of victim M.J., asking for $50 million in damages. At a court hearing Friday, Scarola told Circuit Judge David Crow that all lawsuits were settled for "very substantial sums of money, which is directly contrary to the assertions that Mr. Epstein made that these cases were fabrications." The hearing was related to Epstein's lawsuit against Edwards, alleging Edwards was involved in false claims made by Ponzl schemer Scott Rothstein. Epstein says Rothstein lured investors to his scheme by telling them Epstein had agreed to settle sex abuse lawsuits for as much as $200 million. Edwards worked at Rothstein's firm for less than a year: Rothstein is named as a defendant. Speaking on behalf of Epstein, attorney Joseph Ackerman said, "Except in certain cases, we believe the Rothstein firm was marketing cases that didn't exist, not necessarily the ones he settled. We believe actions were taken in those cases that were an abuse of process to inflate the marketing." Edwards filed a counterclaim, alleging Epstein filed a frivolous lawsuit to get him to back down from representing the victims. Epstein had filed a complaint with the Florida Bar against Edwards, raising allegations that Edwards and others were involved in Rothstein's wrongdoing. After investigating the claim, the Florida Bar dismissed the complaint. In July, Edwards received a letter from the U.S. Attorney's Office — the office responsible for prosecuting Rothstein — Identifying Edwards as a potential victim of Rothstein. Scarola wants the judge to sever the cases and fast-track Edwards' case. "This constitutes a very substantial cloud over Mr. Edwards' head," Scarola said. "Public allegations have been made against him that he was a participant in this major fraud, one of the largest in the history of South Florida, and we want, expeditiously, to have that cloud removed.' Epstein, 57, finished serving his one-year probation in July on state charges of soliciting prostitution and soliciting a minor for prostitution. More than two dozen underage girls were identified in federal documents as having been sexually abused by Epstein. A secret deal with federal prosecutors revealed Epstein could have been charged with multiple federal counts of sexual exploitation of minors, resulting in much harsher penalties. But the fads deferred to two state charges that got him an 18-month sentence. He served only 13 months in a vacant wing at the Palm Beach County Stockade. EXHIBIT http://www.palmbeachdailynews.cominewsklaim-epstein-filed-lawsuit-to-intimidate-attom... EFTA01102199 Claim: Epstein filed lawsuit to 'intimidate' attorney Edwards prosecuting sex abuse cases Page 2 of 2 In more than 62 pages of court documents, Scarola asserts the court should rule in Edwards' favor for at least two reasons: that Epstein has elected to invoke his Fifth Amendment privilege in depositions, and Epstein's claims are unsupported and contradicted by the evidence. "Under the well-established 'sword and shield' doctrine, Epstein cannot seek damages from Edwards while at the same time asserting a Fifth Amendment privilege to block relevant discovery," Scarola wrote in court papers. "Epstein's deposition was taken at least five times; court papers say. "During all of these depositions, Epstein refused to answer any substantive questions about his sexual abuse of minor girls." Ackerman said the Rothstein lawsuit is a different situation than Epstein taking the Fifth in depositions regarding the victims, because the allegations against Rothstein and Edwards look place outside of Epstein's personal knowledge. "This is not a case where Mr. Epstein has personal knowledge of what happened at the Rothstein firm In regard to these claims," Ackerman said. "These Investors went to the Rothstein firm and were shown case files for the L.M. litigation against our client for the purpose of putting investments in. The complaint is not based on whether our client is guilty or not guilty for the crimes for which he settled or pled guilty to. What he has said in the complaint is they took the cases against me ... to attempt to Inflate the value for the purpose of the investment." Scarola told Crow that Epstein has refused to answer any questions regarding his basis for claims against Edwards. "We have undertaken not only to demonstrate absence of any evidence to support any claims that have been made against Mr. Edwards, but to affirmatively and conclusively demonstrate his complete and total innocence with respect to these matters," Scarola said. Find this article at htlp://www.palmbeachdailynews.cominewskisen-epslein•filed-lawsuit-to•intimidate-attomey-ecvards-974565.html Print this page CI Close lutp://www.palmbeachdailynews.comMewsklaim-epstein-filed-lawsuit-to-intimidate-attom... 5/2/2011 EFTA01102200 Jeffrey Epstein introduced woman to Prince Andrew, she tells London 'Daily Mail' Page 1 of 2 PalmBeachDailyN,Ipnc,9m ig Punt 0-Is page• El Close Jeffrey Epstein introduced woman to Prince Andrew, she tells London 'Daily Mail' By MICHELE DARGAN DAILY NEWS STAFF WRITER Updated: 9:04 a.m. Tuesday. Mardi 1.2011 Posted: 7:12 p.m. Monday, February 28, 2011 The young woman previously known as Jane Doe 102 has gone public, detailing her life from age 15 as a paid sex slave for Jeffrey Epstein and his friends. Now a married 27-year-old mother of three living in Australia, Virginia Roberts spoke at length to London's Daily Mail in an interview published Sunday. Roberts spoke to the Mail after a photo recently surfaced of Epstein and Britain's Prince Andrew walking in Central Park. The photo was taken when the prince visited Epstein's Manhattan apartment in December. Roberts reveals to the Mail that she was in Prince Andrew's company three times at the behest of Epstein. An old photo, printed in the Mail, shows a smiling Andrew with his arm around Roberts' waist. The photo was taken at the London home of Epstein pal Ghislaine Maxwell. 'There is no suggestion that there was any sexual contact between Virginia and Andrew or that Andrew knew that Epstein paid her to have sex with his friends," the Mail said. On that trip, which also included stops in Paris, Spain, Granada and Tangier, Roberts said Epstein paid her $15,000. Epstein, 58, received an 18-month sentence on state charges of soliciting a minor for prostitution and soliciting prostitution. He is now a lifelong registered sex offender. A deal with federal prosecutors revealed Epstein could have been charged with multiple federal counts of sexual exploitation of minors, resulting in much harsher penalties. But the feds deferred to the two state charges. Serving 13 months segregated in a vacant wing of the county stockade, Epstein was let out on work release six days a week for up to 16 hours a day. In addition, probation records reveal that while serving one year of house arrest, Epstein was given permission to travel out of state and spend hours outside his house, all with the blessing of either the court or his probation officer. Epstein retained some of the best lawyers in the country to get what many have described as a sweetheart deal. In December 2009, Roberts filed a lawsuit against Epstein as Jane Doe 102. She was one of nearly two dozen women who settled lawsuits against Epstein for undisclosed amounts, all alleging they were sexually abused by him as minors. The lawsuit says Maxwell recruited Roberts at The Mar-A-Lago Club, where Roberts was working as a changing room assistant. Maxwell told Roberts she could earn big money as a "traveling masseuse" to a wealthy Palm Beach man. All the lawsuits against the billionaire money manager said his modus operandi in the initial visit was the same: the minor girl was taken to Epstein's mansion on El Brillo Way and led upstairs to a spa room by one of Epstein's assistants, where he would ask the girl to perform massages and/or various sex acts, for which he would pay her. Roberts' lawsuit said she was sexually exploited by Epstein's adult male peers, which Included royalty, politicians, academicians, businessmen and others in various locations around the world. 4 • EXHIBIT 2. hup://www.palmbeachdailynews.cominews/jeffrey-epstein-introduced-woman-to-prince-an... EFTA01102201 Jeffrey Epstein introduced woman to Prince Andrew, she tells London 'Daily Mail' Page 2 of 2 Epstein attorney Joseph Ackerman did not return a call for comment. Roberts — who spent four years with Epstein — refers to him as 'a monster who paid her lavishly to satisfy his and his friends sexual whims — although Roberts doesn't identify the friends. Roberts says she would meet one of Epstein's friends on his private island in the Caribbean or at his ranch in New Mexico, both of which were Isolated, and she was 'given to men ranging in age from their 40s to their 60s." To detach herself from reality, Roberts said, she began taking Xanax —"up to eight pills a day." Other revelations by Roberts in the Mail: Epstein and Maxwell told her they wanted her to have his child. That, she told the Mail, was "a wake-up call" to get out of the situation. Fort Lauderdale attorney Brad Edwards has represented several of Epstein's underage victims. In addition, Epstein and Edwards have filed lawsuits against each other. Epstein alleges Edwards was involved in false claims made by Ponzi schemer Scott Rothstein, while Edwards alleges Epstein filed a frivolous lawsuit to get him to back down from representing the victims. "I feel terrible for Virginia and all of the other girls that were sexually abused, but I was not surprised at all by the story," Edwards said. "I represented several girls that, similar to Virginia, were very young and vulnerable and were badly abused by Epstein. These girls will never completely heal from what they went through. What is most troublesome though is that these serious crimes went virtually unpunished. I currently represent several victims that want Epstein prosecuted for the crimes he committed against them, which is why we filed a claim under the Crime Victim's Rights Act In an effort to overturn the illegal plea deal and get true justice for these victims." Find this article at: hltp.ilvivive.palmbeachdaitynews.continews/jeffrey-epstein-introducee-woman-to-prince-andrew-she-1288718.html Ji Print this pace 9 Close http://www.palmbeachdailynews.com/news/jeffrey-epstein-introduced-woman-to-prince-an... 5/2/2011 EFTA01102202 News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page 1 of 3 BRIEFING WIRE A Free Press Release Website Briefing Search Keyword: Category: I ClewI Search Submit Your Press Release Biz Directory RSS Feed 0 SEC Tips Questions? :t Author Details pARU Marketing WNW oardriarketine (AM' O SHARE 13 News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Victims Rights Hundreds of news articles have reported billionaire pedophile Jeffrey Epstein's close relationship with Britain's Prince Andrew. Attorney Brad Edwards has pursued victim rights cases on behalf of ten women who were sexually molested by Epstein. Ask a Lawyer Online Now 12 Lawyers Are Online. Current Wait Time: 14 Minutes. Law.JustAnswer.com ri Ack by C.00gle priefingWire.com 3/08/2011 - Contact Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. (954) 524-2820 Kim Sailer, BARD Marketing/PR (561) 637-2575 Fort Lauderdale, FL -- In the last week, hundreds of news articles have reported billionaire pedophile Jeffrey Epstein's close relationship with Britain's Prince Andrew. Attorney Brad Edwards has pursued victim rights cases on behalf of ten women who, between 12 and 15 years of age, were sexually molested and abused by Epstein. The stories of their abuse have all the trappings of a Hollywood movie, including posh settings of I in 'Ads by COO* Find a Lawyer - Free, Free, Confidential Lawyer Locator. Save Time - Describe Your Case Now! www.Lo`rjaIMatcii.COM Ask a Lawyer Online Now 27 Lawyers Online Now Answer Your Questions In Minutes. canswer.c.anuLaw Sexual Abuse Allegations We wrote the book on defending false molestation allegations www.FalscAbubo.com Local 1-Day Couoone Up to 90% Off the Best Stuff To Do! Restaurants, Spas, Events and More. www.Livii igSociel.com The Diana Screen Employment screening tool. Help prevent child molestation. dianascreen.corn • EXHIBIT 3 http://www.briefingwire.com/viewBriefing.aspx?id=24907 EFTA01102203 News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page 2 of 3 at Epstein's Palm Beach Mansion, private Caribbean island and his Jet. But Epstein's heinous sexual abuse of these victims is no fiction. Edwards successfully represented these women, obtaining justice for each of them, by proving that Epstein and his international sex trafficking criminal enterprise exploited them and hundreds of other underage girls. This recent wave of news coverage highlight the importance of the victims rights work that Attorney Edwards does on behalf of victims of sexual molestation and other sexual abuse. Edwards conducts extensive Investigations and pursues civil lawsuits against sexual predators to protect the rights of his victim clients and to hold sexual predators, like Epstein, accountable. Many sexual predators, like Epstein, are wealthy and powerful and able to focus vast resources and high profile legal teams in an attempt to deflect attention, avoid criminal liability, and deny justice to their victims. Speaking of his work on the Epstein cases, Edwards says 'we took on powerful people and sought to level the playing field to protect victims." Representing these women has made Edwards aware that child sexual abuse is extremely prevalent. According to a U.S. Health and Human Services study, more than 83,000 substantiated reports of sexually abused children were made in 2005 alone. The actual number of incidents of sexual abuse is likely much higher because it is believed that sexual abuse, especially amongst children, is significantly underreported. Edwards hopes that the media attention focused on Epstein's sexual abuse will "inspire victims to report these crimes" and will convey his belief "that victims rights cases can effectively protect their rights, maintain their anonymity, and hold predators accountable.' Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., a Fort Lauderdale Litigation firm, focuses on Consumer Class Actions, Sexual Abuse Cases as well as other significant Personal Injury, Wrongful Death, and Whlstleblower Suits (qui tam). The firm is headquartered at 425 N. Andrews Avenue, Suite 2, Fort http://www.briefingwire.com/viewBriefing.aspx?id=24907 5/2/2011 EFTA01102204 News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page 3 of 3 Lauderdale, Florida 33301 and may be reached at (800)400-1098 or (954) 624- 2820. Additional information about Brad Edwards or Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. may be obtained from the firm's website at wpm.pathtojustice.com. fAias i Contact Us I Terms & Conditions privacy Policy O 2009 BtlefinaVAre US http://www.briefingwire.comNiewBriefing.aspx/id=24907 5/2/2011 EFTA01102205 Convicted paedophile Jeffrey Epstein is facing a new criminal investigation and is involv... Page 1 of 3 Cate Crekorai* Convicted paedophile Jeffrey Epstein is facing a new criminal investigation and is involved in a civil suit with a lawyer The Duke of York could be asked to give evidence in two separate legal cases involving Jeffrey Epstein, his paedophile friend, The Daily Telegraph has learnt. Jeffrey Epstein and Ghisleine Maxwell stayed at Sandringham as guests of the Duke Photo: ALBANPIX/GEOFF PUGH By 409 Slvain!.(http:/fwww,telegraph.co.uk4oumaliatsaon-swain/, In Palm Beath, Florida 10:00PM GMT 10 Mar 2011 5?!IS".v 4cfl§wPine an TtiltelatIttPV.N.I.PS90V199sWain) Lawyers for a Florida attorney who Is being sued by Epstein have disclosed that they want to take a statement from the Duke because they believe he may be able to shed fresh light on Epstein's alleged sex offences. Meanwhile the FBI has Indicated that It will reopen Its criminal investigation Into Epstein after receiving new information. He was convicted In 2008 for soliciting an under-age girl for prostitution. Sources in America have said the FBI could ask the Duke to give evidence as part of the new Investigation. Epstein, 58, was sentenced to 18 months in prison after admitting two sex offences as part of a plea bargain deal. But allegations were made against him by as many as 40 girls, of whom 17 have settled civil claims they brought against the billionaire. hup://www.telegraph.co.ukinews/ulcnews/theroyalfamily/8374911/Convicted-paedophile-Je.. • EFTA01102206 Convicted paedophile Jeffrey Epstein is facing a new criminal investigation and is involv... Page 2 of 3 Epstein is himself suing Brad Edwards, a lawyer for several of the girls. Epstein alleges that Mr Edwards was inked to a fraud committed by a former colleague — a claim dismissed by the local bar association - and that his clients' cases against Epstein were therefore Invalid. Princess Beatnceapd .p.dricess Euganiepatprice for row over Duke of York's trade rob fhttp://www telegrapkco.ukinewsfuknewsithemyalfamilyi_8408879/PrIncess-Beatrickand-Pripceskgegenjelpy- PPc8.-fPf5PW:.9vW:P4k -91-Y9rkttrOV9 10tAtinq Further scrutinyon Duke of York over lobbying thitgfiwww.telemaph.co.uldnewsklmewsAheroyalfamily18372507IFuither-scrutinton-Dulce-of-York-over- lobbying:him(' Timeline: the Duke of York's questionable friends (httpillwww.telegrash.co.ukinews/uknewsttheroyallamily/8388227fTimeline-the-Duke-of-Yorks-questionable- IriengOltre0 _abourAleiPrinceNierewICen emberrassmerteittp:/Nrww.telegraph.co.ukinewsinewsvideoiuk-politics- YAPS4A§§ 2?0,1409Yr7MF -P.rilntet, EPP#FrasPiTient h!aiD Duchess negotiated debt pay-off for several months Inttp/twwwjelesraph.cb.ukinnitysitiknewstthergyallerni npfglellpuchess-pf-York-s_p_ent-ntne-morithe-nagetiating: with:convictee:plasidephile-Jeffrey zEstateirtto-patoff-her-debte.ntml" Mr Edwards, meanwhile, claims Epstein is abusing the legal system by seeking to intimidate other lawyers and girls, and is counter-suing the financier for substantial damages. He Is seeking to prove to the court that Epstein did sexually abuse dozens of children, allegedly at his Florida mansion in most cases, where the Duke enjoyed holidays and massages. Jack Scarola, the lawyer representing Mr Edwards. told The Daily Telegraph: 'We would be very keen to speak with Prince Andrew, given his relationship with Jeffrey Epstein. 'We want to obtain additional details on the scope of Mr Epstein's alleged sexual abuse of children — when, where, how frequently and the extent to which it involved the transport of children inside and outside the United Slates for sex. 'We have reason to believe that Prince Andrew has been in the company of Mr Epstein while Mr Epstein has been in the company of under-aged children.' Asked whether he had any reason to suspect the Duke had been present while under-age girls were abused, Mr Scarola said: "That's not something I can publicly comment on. We have an ongoing investigation and an ongoing prosecution of a civil case. These are not matters of public record and I am restricted in what I can say on the public littp://www.telegraph.co.uldnews/ulcnews/theroyalftunily/8374911/Convicted-paedophile-Jen. 5/2/2011 EFTA01102207 Convicted paedophile Jeffrey Epstein is facing a new criminal investigation and is involv... Page 3 of 3 There is no allegation that the Duke had sexual contact with any of the girls or that he was aware of any wrongdoing by Epstein. Mr Scarola added: 'Deposition testimony has been taken generally concerning Mr Epstein's association with many high -profile people' Documents filed in the case so far Include Epstein's private phone directory —which included numerous contact details for the Duke, along with masseuses and dozens of other prominent friends. They also include flight logs for Epstein's private Jet, which detailed a trip the Duke took with him In 2000 and a 1998 meeting between Epstein, the Duchess of York and Princesses Beatrice and Eugenie. Mr Sterols said he anticipated 'significant procedural Impediments" in obtaining sworn deposition from the Duke, due to his ability to claim diplomatic immunity. He said he may be forced to turn to international law. 'The Hague Convention specifically outlines procedures that must be followed for the citizen of one country to be compelled to give testimony regarding a case pending in another," he said. A Buckingham Palace spokesman declined to comment. C Copyright of Telegraph Media Group Limbed 2011 http://www.telegraph.co.uk/news/uknews/theroyalfamily/8374911/Convicted-paedophile-Je... 5/2/2011 EFTA01102208 Jeffrey Epstein address book 'Holy Grail' of famous names Page 1 of 2 PalmBeachDailyNpy,Thcpn Jeffrey Epstein address book 'Holy Grail' of famous names By MICHELE DARGAN DAILY NEWS STAFF WRITER P•otthts nage 0 Close Updated: 7:58 p.m. Friday, March 11, 2011 Posted: 7:57 p.m. Friday, March 11, 2011 When talking about the personal address book of billionaire sex offender Jeffrey Epstein, the term "little black book" takes that phrase to a whole new level. Manhattan money manager Epstein's book reads like a laundry list of the world's richest and most powerful people, including some Palm Beachers. Referred to as "The Holy Grail" by Epstein's former house manager — now serving time for trying to sell it to attorneys — the 97-page address book details multiple addresses, phone numbers, e-mails and other contact information for former President Bill Clinton, Britain's Prince Andrew and Sarah Ferguson, Donald Trump, Sen. John Kerry, various members of the Kennedy clan and former British Prime Minister Tony Blair, among many others. The British press has been having a field day digging up new details about Epstein's friendship with Prince Andrew. Virginia Roberts — known only as Jane Doe 102 in court papers — has been dishing her story to London's Daily Mail. Details include Roberts having been in the company of the prince three times at Epstein's behest. Roberts also recounted meeting Clinton on Epstein's private Caribbean island, according to the Mail. But Roberts made no suggestion of sexual relations with Prince Andrew or with Clinton, the Mail reported. Similarly, there is no suggestion of anything salacious with any of the Palm Beachers listed among the money manager's contacts. Roberts — who spent four years with Epstein — refers to him as "a monster' who paid her lavishly to satisfy his and his friends sexual whims — although Roberts doesn't identify the friends. British papers also have reported that Ferguson accepted £15,000 from Epstein. The money was paid to her former assistant, who claimed Ferguson owed him unpaid wages and other bills. Ferguson has since told the Mail and other British papers that she made "a gigantic error of judgment" in accepting the money from Epstein and that she will pay him back. The entire "Grail" was made public as part of a pending civil court case in which Epstein is suing attorney Brad Edwards, who represented several underage girls who sued Epstein. Epstein sued Edwards, alleging he was involved in false claims made by Ponzi schemer Scott Rothstein; Edwards countersued Epstein, saying he filed a frivolous lawsuit to get him to back down from representing the young women. All the lawsuits against Epstein said his modus operandi in the initial visit was the same: The girls were taken to Epstein's Palm Beach mansion and led upstairs to a spa room by one of Epstein's assistants, where he would ask the girls to perform sexually charged massages and/or various sex acts, for which he would pay them. Other high-profile names in Epstein's book Include Special Envoy for Middle East Peace George Mitchell, New York City Mayor Michael Bloomberg, New York Gov. Andrew Cuomo, Barbara Walters, Alec Baldwin, Ralph Fiennes, George Hamilton, Dustin Hoffman, Kevin Spacey, Liz Hurley, Lauren Hutton, Janice Dickinson, Naomi Campbell, Christy Turlington, Henry Kissinger, Joan Rivers, Courtney • 5 http://www.palmbeachdailynews.cominews/jeffrey-epstein-address-book-holy-grail-of-fam... EFTA01102209 Jeffrey Epstein address book 'Holy Grail' of famous names Page 2 of 2 Mick Jagger, Comelia Guest, Phil Collins, ltzhak Perlman, Simon LeBon, Charlie Rose, Richard Branson, playwright Candace Bushnell, designers Tom Ford and Vera Wang, soap opera actress Nadla Bjorlin and erotic film star Koo Stark, who once dated Prince Andrew. Among the high-powered Palm Beachers listed in the money manager's address book are Catherine and Fred Adler, Samantha and Serena Boardman, Jimmy and Jane Buffett, Pepe Fanjul, Conrad and Barbara Black, Gerry Goldsmith, Marjorie Gubelman, Dana Hammond, David Koch, Henry Kravis, Frayda and George Lindemann Sr., Bob and Todd Meister, Alfred Taubman, Stanley, Bea and Brett Tollman, and Martin Trust. Gaston Cantens, a spokesman for Florida Crystals Corp., said Fanjul and Epstein "obviously knew each other and had some contact in the past. But there isn't any ongoing business or social relationship with Mr. Epstein.- Reached by phone at his Palm Beach home, media mogul Black said he knew Epstein as "a friend of my colleague Mr. Wexner." Les Wexner, CEO of The Limited Brands, was reported to have been Epstein's biggest client and close friend. Wexner replaced Epstein as his money manager, according to recent reports. Some of the names in Epstein's book are sub-listed under geographic locations. The heading "massage" is notated under many of Epstein's locations. Names and phone numbers, most of them first names only, are listed under the massage entries. Registered as a level 3 sex offender, Epstein pleaded guilty to soliciting underage girls for sex at his El Brillo Way home in Palm Beach. In addition to serving 13 months of an 18-month jail sentence, Epstein has settled at least two dozen lawsuits with young women for undisclosed amounts. Find this article at: htlp://www.palmbeachdailynems.cominewejeffrerepalein-address-Cook-holpgrail-orfamous-1315130.hlmi Print Ns page El Close http://vrww.palmbeachdailynews.com/news/jeffrey-epstein-address-book-holy-grail-of-fam... 5/2/2011 EFTA01102210 Prince Andrew's link to sex offender Jeffrey Epstein taints royalty in US I UK news I The ... Page 1 of 3 guardianco.uk TheCtiserver Pinang sucencess by: Ito** All-In-One Piers Prince Andrew's link to sex offender Jeffrey Epstein taints royalty in US The Duke of York's friendship with billionaire convicted paedophile Jeffrey Epstein has put him on American front pages ePaul Hanle Is New York not Otnener,Suadey IS ?throb anti ; A tual.",” Trbwe Aud ttn. la Cairn hls hieneltuips under Inlenuiliuunl eamItalloo. Pbelotreph. raccedo Arrimbolno/FPA The British press has a new admirer. Spencer Kuvint a Florida lawyer who has fought several cases for young women alleging sexual abuse by the disgraced billionaire Jeffrey Epstein, is delighted — and relieved — that newspapers are now examining Prince Andrew's relationship with the convicted paedophile. "lam glad the British press has picked this up," Kuvin told the Observer. "The British . people have a right to ask why he [Prince Andrew) is hanging out with a co