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, [REDACTED] 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 Clew I 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-Y9rkttrOV910tAtinq 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-JeffreyzEstateirtto-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. [REDACTED] — 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 e Paul 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 convicted paedophile. I think that is a very good question to be asking." Kevin has been asking it for a while. Ho believes Epstein has in effect got away with most of his crimes because of his wealth and his connections with the powerful and well- connected across America and the world. lie's fine. He has a great life," he said of the man who spent less than two years in Jail after pleading guilty to child sex offences. That Is probably true. Florida law allows anyone to find out the whereabouts of a convicted sex offender via an online database. According to the website last week Epstein's location was St Thomas in the US Virgin Islands in the Caribbean. He owns a private island there: one that Prince Andrew has visited. "Epstein is probably sunning himself on a beach right now," Kevin said. The same cannot be said for the Duke of York. This weekend, as he considers the parlous state of his international reputation, he is likely to feeling a lot less comfortable than his one-time party friend. It was not meant to be this way for the prince. America is supposed to be a happy hunting ground for the British royal family. It Is a place where the people ace them es http://www.guardian.co.uk/u1c/2011/mar/13/prince-andrew-jeffrey-epstein/print EFTA01102211 Prince Andrew's link to sex offender Jeffrey Epstein taints royalty in US I UK news I The ... Page 2 of 3 exotic celebrities to be feted, admired and placed alongside the homegrown "royalty" of Hollywood. American citizens and politicians - freed from the burdens of paying for a civil list of their own — can indulge in the sort of innocent worship of monarchical "glam" that typified Britain in the teens. So recent headlines In the US media have come as a bit of a shock "Seen around town: Prince Andrew and Pery Billionaire," blared the New York Post. "Duchess of York apologises for accepting money from sex offender,' read the New York Daily News. So much for the eager anticipation of a slew of good publicity around the marriage of Prince William and Kate Middleton. It was not just the American tabloids. Even the Wall Street Journal ran a lengthy piece last week prompted by the fallout from Prince Andrew's long friendship and close relations with Epstein, 88, who served 18 months for sexual offences involving underage girls. No wonder New York Post columnist Andrea Peyser weighed in on the controversy about what she called a "bromance" between the pair. Prince Andrew, she concluded, was an "idiot prince". It is hard to fathom the depths of the PR disaster that continues to unfold around the prince because of his links to Epstein. After he was snapped walking side by side with Epstein through Central Park last December, Andrew has seen his entire globetrotting existence as a trade ambassador put under the microscope. It has not borne up well. Suddenly his life and times partying with Epstein have become public knowledge, complete with sordid details of being surrounded by young women and being Present at topless pool parties. A woman, [REDACTED], who provided sexual services for Epstein and his rich friends while underage, saw the photograph and decided to speak about her experiences. Another picture rapidly surfaced, of Roberts side by side with the prince. To cap it all, Andrew's links to a whole series of unpleasant developing world autocrats and dictators have also come under fresh examination. None of it has made a pretty picture and the royals — perhaps typically — have been slow to react in any meaningful way. First, the problem was ignored. Then it was dismissed. Only now, belatedly, have they begun to address it with reports that the Queen has talked to Andrew privately. It feels too little, too late. Like many Europeans, perhaps, Andrew enjoyed the US because of the freedom and opportunities it afforded. The social scone in glittering hotspots like Manhattan and Florida's Palm Beach allowed him to free himself from the stuffy world of aristocratic Britain. He was courted and won over by the rich elite and he repaid the compliment. No one knows why the prince carried on such a close friendship with a figure like Epstein for so long or why he refused to end it after Epstein went to jail. The facts alone should have been a warning sign. Epstein, a working class Brooklyn boy who became a super-wealthy money manager, was one of the world's most renowned playboys. But in 20O8, after a three-year investigation into the young women he and his entourage procured, he wound up in jail. Nor was it an isolated incident. Epstein's case was ended via a plea bargain where he admitted guilt on a charge of felony solicitation of prostitution involving a minor. Yet as many as go young women had made allegations against him and, unusually, his plea deal allowed other accusers to sue him in civil court. So far at least sz of them have settled civil cases against him. The American drama is far from over for the prince. Instead the legal wranglings around Epstein and his exotic lifestyle threaten to drag the royal family right into the US court system. http://www.guardian.c o.uk/u1d201 1 /ma r/13/prince-andrew-jeffrey-epstein/print 5/2/2011 EFTA01102212 Prince Andrew's link to sex offender Jeffrey Epstein taints royalty in US I UK news I The ... Page 3 of 3 Epstein is now suing Brad Edwards, a lawyer for some of the girls from the original investigation. In turn Edwards is counter-suing Epstein, alleging that the billionaire is using his vast resources to pursue expensive legal cases and thus intimidate other victims and their legal representatives. Either way, Andrew could be pulled Into the mess as a witness. Edwards's lawyer, Jack Scarola, said last week that his team Intended to try and get a statement from the prince about what he may or may not have seen while attending parties with Epstein. Though the prince is likely to claim diplomatic immunity, that step will not keep his name out of the court papers or the headlines: it will just keep his presence out of the courtroom. The same thing goes for previous cases Involving Epstein. They amount toe potential source of PR torture for the royal family as media scrutiny continues. Recently released documents from a different case showed that two of Epstein's closest confidantes — his PA Sarah Ellen and an on-off girlfriend, Nadia Marcinkova - were repeatedly questioned by Kuvin about whether the prince had been involved in sexual acts with any of Epstein's entourage of young women. Both Ellen and Mareinkova declined to answer the questions and instead took the Fifth Amendment, which allows their legal silence. Of course, there is no evidence or suggestion that Andrew was Involved. But in PR terms there does not need to be. There is even a small chance that the FBI will use some of the new revelations emerging in the media to reopen the criminal rase against Epstein, though legal experts think it unlikely. Even the hint of a possibilty of a federal probe is another reason for the headline writers to start sharpening their pens for those with links to Epstein. Prince Andrew is not the only one. Epstein has partied in New York with numerous people since he left jail, Including big names and celebrities like Katie Couric, George Stephanopoulos and Woody Allen. Perhaps they too should have known better. ROYAL CONNECTIONS ■ Ghislaine Maxwell, 49, youngest daughter at Robert Maxwell, the former Daily Mirror proprietor, is considered one of Prince Andrew's more controversial friends. A decade ago, he was reported to have accompanied her to a **hookers and pimps" party in New York. Ghislalne moved to the US in 199i after the death of her father and became a fixture on the Manhattan party circuit, where she befriended Jeffrey Epstein. ■ Goga Ashkenazi, 31, a glamorous Kazakh oil tycoon, claims to be a "close friend" of Prince Andrew. Ashkenazi, an Oxford-educated socialite and entrepreneur, said: "Britain is very lucky to have him." She was introduced to Andrew In 2001 and they have been friends since. She was his guest at Ascot In 2ooy, although she denies rumours that they have ever been a couple. ■ Tank 1Caltunl, a convicted Libyan gun smuggler, is an old friend . In 2008 he and Andrew enjoyed a four-day holiday to Tunisia. Kaituni was convicted of buying a machine gun in 2005 and secretly attempting to transport it from Holland to France. g44/0aci.graelt 0 Gannon Mn., ato111eits Lino! ton http://www.guardian.co.uldulc/2011/mar/13/prince-andrew-jeffrey-epstein/print 5/2/2011 EFTA01102213 The Independent - Print Article Page 1 of 2 Independent.co.uk Duke of York's friend could be back in US courts Lawyers to question Prince Andrew's sex offender associate. By Jonathan Owen Sunday, 13 March 2011 The Duke of York's attempts to quell the furore surrounding his relationship with the billionaire sex offender Jeffrey Epstein appeared doomed this weekend when it emerged that more lurid details are to be aired In a US court within the next two weeks. Buckingham Palace was forced to deny that the Duke of York had postponed plans for a trip to Saudi Arabia next week, because of negative media coverage, amid reports in some media that the controversy had made him "toxic". A spokesman said: "Buckingham Palace has never announced any overseas visits for the Duke of York.' The issue refuses to die down, with two Lib Dem ministers breaking rank last night and privately suggesting they think Prince Andrew should quit as trade envoy. One said: "If he was a politician doing this, he would have gone by now, and rightly so." Another added: "That in the 21st century we should be putting up with this is obscene. it is incredibly difficult for the Government, more so the Tory side, but it cannot carry on." Even attempts by supporters to rally to his cause have been of mixed benefit. The Duchess of York's apology for a "gigantic error of judgement" in accepting money from Epstein only served to fuel reporting, as did reports of the Prince's links to Kazakhstan and the socialite Goga Ashkenazi, who is reported to have had been involved in the sale of the Duke's home to Kazakh oil billionaire Timur Kulibayev. There was also criticism last week when it emerged that the prince lobbied MP Mark Field this week to help to boost UK exports to oil-rich Azerbaijan, a country with a questionable human rights record. Now US lawyers hope to use a legal dispute between Epstein and Brad Edwards, a Florida attorney, to insist that Epstein reveal more about his relationship with the prince. Epstein will be questioned on allegations he procured sexual favours from minors for friends and forced to answer allegations that he abused up to 40 girls. Many of the most damaging recent headlines about the Duke of York have centred around a photograph of him with his arm around a girl who claims she was abused by Epstein. Jack Scarola, one of the lawyers close to the case, 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." Asked whether the duke was with Epstein when minors were present, he said: "The details of that relationship will be a subject of inquiry when Mr Epstein's testimony is taken.' The FBI Is said to be ready to reopen its criminal investigation into Epstein, convicted In 2008 for soliciting an underage girl for prostitution. A number of women are challenging a plea bargain deal which allowed the billionaire to avoid trial. Epstein, 58, was sentenced to 18 months in prison after admitting two sex offences. None of this will help Prince Andrew's attempts to damp down coverage questioning his judgement an his choice of associates as he travels the world as a commercial envoy for the UK. EXHIBIT http://www.independent.co.uldnews/uldhome-news/duke-of-yorks-friend-could-be-back-in-... EFTA01102214 The Independent - Print Article Page 2 of 2 Additional reporting by Andrew AfcCorkell, Emily Dugan and Matt Chorley tlndependent.co.uk http://www.independentico.u1c/news/ulc/home-news/duke-of-yorks-friend-could-be-back-in-... 5/2/2011 EFTA01102215 Victims of Sexual Abuse Demand Justice Page 1 of 2 Victims of Sexual Abuse Demand Justice Last week the Philadelphia archdiocese suspended 21 Roman Catholic priests who were named as child molestation suspects in a scathing grand jury report released last month. FOR IMMEDIATE RELEASE (Free-Press-Release.com) March 17, 2011 - Contact Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. (954) 524-2820 Kim Sailer, BARD Marketing/PR [email protected] Fort Lauderdale, FL -- Last week the Philadelphia archdiocese suspended 21 Roman Catholic priests who were named as child molestation suspects in a scathing grand jury report released last month. Regarding another sex scandal, over the last two weeks, hundreds of news articles have reported billionaire pedophile Jeffrey Epstein's close relationship with Britain's Prince Andrew. Farmer Jaffe Weissing 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. Edwards proved that Epstein and his international sex trafficking criminal enterprise exploited them and hundreds of other underage girls. Powerful organizations like the Catholic Church have been able to shelter accused priest and clergy as there continues to be no mention of penalties, censures, or removal from office for bishops who continue to hide and cover-up for the abusive priests. 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. 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. Sexual abuse and molestation cause great suffering for victims. Victims often deal with unimaginable humiliation and shame and it often leaves long-lasting emotional and psychological damage. F,dwards hopes that the media attention focused on the recent Philadelphia archdiocese sex scandal and on Epstein's sexual abuse will continue to "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." At Farmer Jaffe Weissing, our goal is to help sexual abuse victims obtain justice, counseling and compensation for their suffering. If you or a loved one has been abused by a • http://pressreleaser.org/victims-of-sexual-abuse-demand-justice/1347336 • EFTA01102216 Victims of Sexual Abuse Demand Justice Page 2 of 2 priest / clergy, a teacher, a scout leader or anyone else, please don't hesitate to contact Farmer Jaffe Weissing at 80o-40o-1098. 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 Whistleblower Suits (qui tam). The firm is headquartered at 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301 and may be reached at (Boo) 400-1098 or (954) 524-282o. Additional information about Brad Edwards or Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. may be obtained from the firm's website at http://www.pathtojustice.com. #4* http://pressreleaser.org/victims-of-sexual-abuse-demand-justic,e/1347336 5/2/2011 EFTA01102217 Press Releases - Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL Page I of 5 Press Releases APRIL 2011 Former Jaffe Weissing Proudly Supports National Volunteer Week Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman supports National Volunteer Week (April 10.16). Our firm is very involved in giving back to our communities. Members of our firm support various charities, sit on non-profit boards, and do volunteer work with local schools and religious organizations. We are community-conscious and believe we have an obligation to give back o a society that has afforded so much to us and our families. Want to make a difference too? Visit the sites below for local volunteer opportunities: • Volunteer Broward: Fittp://www,volunteerbroward.org • Volunteer Match: http://www.volunteermatch.org MARCH 2011 Thank You Letter from the Alzheimer's Association, Southeast Florida Chapter Here is a wonderful linter we received from the Alzheimer's Association, Southeast Florida Chapter thanking attorney teven Jaffe for the $100,000 donation, which was a court approved payment of a settlement fund, as a result of the long• term care insurance class action law suit Ruderman v. Washington National Insurance Corporation. Brad Edwards Files Motion in Jeffrey Epstein Case - Violation of Crime Victim's Rights Act Attorney Brad Edwards filed a motion in Federal Court this week saying the U.S. Attorney's Office violated the Crime Victims' Rights Act by signing a nonprosecution agreement with sex offender Jeffrey Epstein without notifying his clients. News coverage included the Palm Beach Post and Main Justice. Join TEAM LINDSAY - Crohn's a Colitis Takes Step Walk Attorney Steven Jaffe's daughter Lindsay suffers from CROHN'S DISEASE...this is an incurable disease of the intestines. Each year we join other families to WALK FOR CROHN'S. This year's 1-mfle walk is Saturday, April 16, 2011, at 7pm at Hulzenga Plaza on the Las Olas Riverfront. Wont you please consider helping our TEAM LINSDAY, click here for details. We'd also love for you to walk with usl Gary M. Farmer, Sr. Joins The Elm, Farmer Jaffe Weissing Is pleased to announce that Gary M. Farmer, Sr., retired Fourth District Court of Appeal Judge, has joined the firm, as of-counsel and will provide litigation support and appellate representation in both civil and criminal cases. London Papers Quote Edwards in Recent Jeffrey Epstein / Prince Andrew Scandal London newspapers recently quoted attorney Brad Edwards regarding billionaire pedophile Jeffrey Epstelnl close relationship with Britain's Prince Andrew. Last year Edwards helped 10 women seek justice, who were sexually molested and abused by Epstein. National and local news coverage included London's The Telegraph, London's Daily Mail and South Florida's Palm Beach Daily News. Firm Sponsors Alzheimer's Association Gala Farmer Jaffe Weissing proudly supports The Times of Your Life Gala honoring the Alzheimer's Association. Click here for program. http://wv.rw.pathtojustice.com/media-center/press-releases/ EFTA01102218 Press Releases - Fanner, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL Page 2 of 5 FEBRUARY 2011 Lehrman Presents at Nova Southeastern University School of Law Attorney Seth Lehrman recently gave a lecture to law students at Nova Southeastern University Shepard Law Center on the Ethical Challenges Arising From a Law Firm's Sudden Dissolution. Weissing's Foster Care Success Story Attorney and Foster Parent Matt WeissIna was featured in the Junior League of Boca Raton's Winter 2011 magazine - The Bridge, discussing his experience with being a foster parent. JANUARY 2011 Jaffe Presents $100,000 Check to Alzheimer Association Attorney Steve Jaffe and Co-counsel Steven M. Dunn presented a $100,000 check to the Alzheimer's Association Southeast Chapter. The cy pres award (a court approved payment of settlement funds) was a result of a precedent setting long-term care Insurance class action law suit Ruderman v, Washington National Insurance Corporation. Jaffe Nominated Volunteer of the Year Attorney Steve Jaffe has been named Volunteer of the Year by the Florida Chapter of the Crohn's & Colitis Foundation of America iCaak. DECEMBER 2010 Clan Action Settlement Creates $8 Million Fund For Elderly Floridians Judge James I. Cohn of the U. S. District Court for the Southern District of Florida has granted final approval of a class action settlement which creates an $8 million fund for elderly class members with home healthcare Insurance policies issued by Washington National Insurance Company (WNIC). The agreement also places all those elderly Insured's back on claim, meaning the insurance company will now be responsible for the cost of care of our clients. Attorneys Steve Jaffe and Mark Fistos also received court approval that required WNIC to make a $100,000 cy pres award (donation) to a charity whose mission is to serve the needs of the elderly — the court approved the Alzheimer Association as recipient of the donation. Mowat, et al v. DJSP Enterprises, Inc., et al. Attorneys Gary Farmer Mark Fistos, Seth Lehrman and co-counsel, who are representing former employees of the law firm of David J. Stern and a related company, have filed a federal class action lawsuit asking for back wages and benefits because they claim that hundreds of employees were fired without 60 days' advance notice, as required under federal law. The suit charges that Stems law firm and Its publicly traded processing unit DJSP Enterprises didn't follow the Worker Adjustment and Retraining Notification Act or WARN Act requirement to give employees 60 days' warning — plus pay and benefits — before a mass layoff. Local news coverage included South Florida Business Journal, Sun-Sentinel, Miami Herald, Palm Beach Post, and CBS4 Miami. OCTOBER 2010 Weissing Nominated 2010 Most Effective Lawyer Attorney Matt Weissing was selected as a ;010 Most Effective lawyers semi-finalist by the editorial staff of the Daily !tuskless Review. http://www.pathtojustice.conilmedia-center/press-releases/ 4/15/2011 EFTA01102219 Press Releases - Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL Page 3 of 5 AUGUST 2010 United States of America v. Scott W. Rothstein Attorney $eth Lehrman prevailed in the firm's prosecution of criminal forfeiture and restitution claims on behalf of thirty- seven former Rothstein Rosenfeldt Adler (lIRK) clients who sought to recover more than one million dollars of settlement monies that had been deposited into a trust account of the RAA law firm prior to Scott Rothstein's widely publicized theft of those monies. After the implosion of RRA, our firm agreed to represent these individuals free of charge. The courts order detailed the monies owed to them. Outside the courthouse, Mr. Lehrman commented, `This is full justice for good and deserving people.* Mr. Lehrman's victory has been the subject of several media reports, Including, the Sun Sentinel Bloomberg South Florida_Business Journal, and Law.com. Gelco Indemnity Co. v. Physicians Group, LLC, a/a/o Paul Androski Attorney Gary Farmer drafted the winning brief in Geico Indemnity Co. v. Physicians Group, LLC, alalo Pout Androski, In which the Second District Court of Appeal confirmed on August 13, 2010, that the fee schedule amendments to the Florida Motor Vehicle No-Fault Law, 5 627.736, Fla. Stat. (2008) ("PIP") effective January 1, 2008, do not apply retroactively. The courts ruling settles an issue which has been hotly contested in lower courts. JULY 2010 Mercedes Iota, et at v. Lighthouse Intracoastal Inc., et al. Attorney Matt Weissing's case, Mercedes Iota, et of v. Lighthouse Intracoastal Inc., et at, was the subject of an article in the Daily Business Review. JUNE 2010 Farmer Named FJA Treasurer Attorney Gary Farmer is being sworn in as Treasurer of the Florida Justice Association. Gary has served as Secretary of the Florida Justice Association since June 2009 and served on its Board of Directors since 2005. $10,800,000 Verdict Attorney Matt Weissing received a jury verdict of S10.800.00 on behalf of a client who sustained brain Injuries when she fell and struck her head while working at a construction site. MAY 2010 $735,000 Verdict Attorney Drad Edwards won a $735,000 jury verdict in a case brought on behalf of truck driver who lost three toes due to a warehouse accident. Class Certification Upheld The United States Court of Appeals for the Seventh Circuit issued an opinion upholding the trial court's order certifying a multi-state class In 5oltzman v. Pena. Case No. 06 C 4481, which Is pending In the United States District Court for the Northern District of Illinois. Attorneys Steve Jaffe and Mark Fistos are handling the case. Edwards Prevails on Key Rulings in Epstein Case Attorney Brad Edwards succeeded in convincing a federal judge that billionaire Jeffrey Epstein must disclose specific fiaures_showing his net worth. Brad also received a favorable ruling allowing his client access to a recording and transcript of a recording of a reporters off-the-record interview with Epstein. The reporter's newspaper had sought to have the materials protected from disclosure based on a 'qualified reporters privilege.* Brad is representing several young women in civil suits In which they allege Mr. Epstein sexually assaulted them when they were tens. Trial is set to begin July 14, 1010. Intp://wsinv.pathtojustice.corn/media-center/press-releases/ 4/15/2011 EFTA01102220 Press Releases - Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL Page 4 of 5 Lehrman Represents Football Great, Warren Sapp, and Others In Forfeiture Proceedings Attorney Seth Lehrman has filed papers in forfeiture proceedings in bankruptcy court on half of Warren Sappand others to recover monies they lost in trust funds held by Ponzi schemer, Scott Rothstein which were never accounted for. April 2010 $520 million Vihistieblower Recovery Attorney Gary Farmer resolved a Wh stieblower sultagainst pharmaceutical giant AstraZeneca, which will pay $520 million in civil fines and restitution to state and federal entities. The firm disseminated a press release on the case. The U.S. Attorney General Issued remarks about the settlement. The federal Department of Justice also announcedthe settlement. The settlement agreement is available on our site. March 2010 Law School Presentation Firm Attorney Seth Lehrman gave a presentation on law practice management at Nova Southeastern University Shepard Broad Law Center in Ft. Lauderdale, Florida. February 2010 Firm Hosts FJA Event Farmer, Jaffe, WelssIng, Edwards, Fistos & Lehrman, P.L. hosted a Florida Justice Association member appreciation reception on the rooftop of the firm's ft, Lauderdale offices. Photos were taken of the event. Qui Tam Presentation Firm attorney Gary Farmer was a presenter at the Florida Justice Association's Workhorse Seminar in Orlando. He spoke on Dui Tarn litigation, which has been the focus of much of his law practice. Qui Tam suits are also commonly known has whistleblower suits. Gary was one of the originating attorneys in the Qui Tam settlement involving Ell Lilly and the drug Zyprexa that resulted in a record $1.42 billion dollar settlement for illegal off-label marketing of drugs. Gary has handled notable class actions and other Qui Tam settlements. January 2010 Class Certification Granted in Long Term Health Insurance Case The firm won a contested class certification ruling for the class action plaintiffs in one the firm's long term health insurance cases, Ruderman, et al., v. Washington Notional Insurance Company filed in the United States District Court for the Southern District of Florida, Case No. 08-0/.23401-COHN/ROSENBAUM. Attorneys Steve Jaffe and Mark Fistos are representing the injured parties as Plaintiffs' counsel in this class action case. The defendant's petition to appeal the order was denied on March 4, 2010. The case has been stayed pending settlement discussions. Jaffe Sworn in as BCJA President Attorney Steve Jaffe commenced his tenure as President of the Broward County Justice Association with his Inaugural message to BCJA members. November 2009 Nova Presentation Attorney Seth Lehrman was a presenter a law office management workshop at at Nova Southeastern University Sheparrt road Law Center in Ft. Lauderdale, Florida. hup://www.pathtojustice.cortilmedia-center/pre.ss-releases/ 4/15/2011 EFTA01102221 Press Releases - Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL Page 5 of 5 October 2009 Attorney Brad Edwards assisted with a vktim's rights workshop In Orlando. September 2009 Jaffe Appointed CCFA Board Member Attorney Stevo Jaffe was appointed to the Board of Trustees of the Crohn's and Colitis Foundation of America (Florida Chapter). Crohn's and Colitis Foundation of America is a nonprofit, volunteer•driven organization dedicated to %incline the cure for Crohn's disease and ulcerative colitis. June 2009 Clan Certification Granted in Pella Windows Case With their co-counsel, attorneys ;tel.,/ Jaffe and Mark Fistosprevalled for the Injured victims named as plaintiffs on a contested multistate class action certification motion pending In the United States District Court for the Northern District of Illinois in the class action case Saltzman v. Pella. Case No. 06 C 4481. February 2009 NationsRent Administrative Fee Class Action Settled With their co•counsel, firm attorneys Steve Jaffe and Mark Fistos won for the class action plaintiffs a contested nationwide class certification in in Re NationsRent Fee Litigation Case No. 06-60924-CIV-BROWN, filed in the United States District Court for the Southern District of Florida. A settlement has been reach for the class. The court entered an order finally approving the settlement on March 31, 2010. January 2008-Present Weissing Continues to Serve Foster Care Community Attorney Matt Weissing continues to volunteer for 4Kids of South Florisk which provides Safe Place intake services for every dependent child which is taken into care In Broward County, serves children and those providing Foster Care, Adoption, Crisis Pregnancy, and provides stability for kids who are aging out of the foster care system. Matt and his family first became involved with the organization in 1996, when they accepted responsibility for a foster son. Seeing the needs of foster children throughout our community, Matt became an advocate for foster children making numerous appearances on local radio stations, speaking before community organizations, In churches, etc. In 2008, 4Kids was recognized by the White House as the model for Foster Care in the United States. http://www.pathtojustice.com/media-conter/press-releases/ 4/15/2011 EFTA01102222 ef mfr.! le1e Vitzvng rel - o - ..4....L.....nnoyabiaminIssimb ag teal* mee RI Env 1.11•11. in ii.riyel meek kale. el mem .se. hew env ti Mine reegeab NtinvItalestkrtoneS• 4 0*CfmaiisPrilir Aram,.. Mare. and Ctiwak PCB rilinivitilfrf anent okikatens -Lean% Tbe Telt:Grit hedereally Mele1 ale Peiaeia Day Nee t yea Sivas hsed W en mik ;Jib:v. S• T) An e "email mksa-el ablebesed by EPsteit re ik'm :.14 C•-,t..lanZ., C CT:1 EFTA01102223 00001 IN THE CIRCUIT COURT, 15TH JUDICIAL CIRCUIT; IN AND FOR 2 PALM BEACH COUNTY, FLORIDA 3 CASE NO.: 562010CA000161 4 JEFFREY EPSTEIN, 5 Plaintiff, 6 vs. 7 SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, 8 And L.M., individually, 9 Defendants. 10 11 12 HEARING BEFORE: HONORABLE DAVID F. CROW 13 DATE TAKEN: March 31, 2011 14 TIME: 8:32 a.m. to 8:53 a.m. 15 PLACE: Palm Beach County Courthouse 205 N. Dixie Highway, Room 9C 16 West Palm Beach, Florida 33401 17 REPORTED BY: Kathleen M. Ames, RPR 18 19 20 21 22 23 24 25 ( EXHIBIT 03/31/11 Reconsid on discov orders Page 1 EFTA01102224 00005 1 allegations. 2 THE COURT: Okay. Well, I thought I — well, 3 never mind. Go ahead. 4 MR. SCAROLA: What Your Honor will see, when you 5 have a chance to take a look at that amendment to the 6 complaint, is that there has been an effort to try to 7 remove from the complaint any assertion that Mr. Epstein 8 was not guilty of the underlying crimes and torts that 9 resulted in his criminal prosecution and the civil claims 10 against him. However, in spite of that effort - because 1 I what they have attempted to state, as they describe it in a 12 very recent submission to Your Honor, the case management 13 report - is an abuse of process claim against Mr. Edwards. 14 And the theory of the abuse of process claim is that IS Mr. Epstein is an innocent man who was falsely targeted as 16 a serial pedophile who openly victimized young children in 17 the presence of his high profile friends. Falsely 18 targeted, with those allegations, for the sole purpose of 19 attempting to enhance the marketability of Ponzi scheme 20 interests in those claims. That's the Plaintiffs theory. 21 Still hasn't been able to articulate how he is damaged by 22 that because it's not a defamation claim because the last 23 thing they want to do is put Mr. Epstein's reputation in 24 contention in this litigation but that's what they claim. 25 Mr. Edwards' theory of this case is that Mr. Epstein 03/31/11 Reconsid on discov orders Page 5 EFTA01102225 00006 1 was and is an incorrigible pedophile who victimized scores 2 of children internationally and openly in the presence of 3 his high profile friends. And that among the victims of 4 his RICO activities, because in the underlying case there 5 were RICO claims, among the victims of his RICO activities 6 were the particular individuals that Mr. Edwards was 7 representing before he ever joined the Rothstein Law Firm. 8 And that all of his efforts to investigate and prosecute 9 those underlying claims were good faith efforts conducted 10 in total ignorance of anything that was going on, as far as 11 Mr. Rothstein was concerned. And that the sole purpose of 12 the lawsuit filed against Mr. Edwards and one of his 13 clients, while those cases were still pending, was to 14 intimidate Mr. Edwards to abandon his very vigorous IS investigation and prosecution of those claims. 16 So whether we look at it from the perspective of the 17 Plaintiffs theory of the case or whether we look at it 18 from the perspective of the Defendant's theory of the case, 19 what Mr. Edwards -- excuse me -- what Mr. Epstein was, in 20 fact, doing is relevant and material. Clearly it's 21 relevant and material from the counterclaim perspective 22 because we allege a motive to cover-up an extensive pattern 23 of international crime. That's why he's trying to scare 24 Mr. Edwards off, intimidating him through this abusive 25 process because he doesn't want the details of his 03/31/11 Reconsid on discos, orders Page 6 EFTA01102226