EFTA00191264

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 4 of 9 
(ii) Court reporters (including persons operating video recording equipment at 
depositions) and person preparing transcripts of testimony to the extent necessary to prepare 
such transcripts, with the consent of counsel. 
(iii) Plaintiffs' attorneys who appear as counsel of record in this case, including the 
attached list of paralegals, clerical, secretarial and other staff employed or retained by such 
counsel, provided that such staff and employees also comply with the provisions of 
Paragraph 6 hereof. 
(iv) Retained consulting or testifying experts, advisors and consultants, including 
persons directly employed by such experts, advisors and consultants (collectively "experts") 
but only to the extent necessary to perform their work in connection with this Action. 
(I) Any additional persons as counsel for the parties and Intervenors shall consent to 
in writing before the proposed disclosures. 
b. 
All parties and their respective counsel, paralegals and employees and 
assistants of all counsel receiving the CDM shall take all steps reasonably necessary to 
prevent disclosure of the CDM other than in accordance with the terms of this Protective 
Order. 
c. 
Disclosure of the CDM other than in accordance with the terms of this 
Protective Order may subject the disclosing person to such sanctions and remedies as this 
Court may deem appropriate, including without limitation, contempt, injunctive relief and 
damages. 
-3-
EFTA00191324

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 5 of 9 
6. 
No copies of any CDM shall be made or delivered to any person other than 
those categories of persons referred to in paragraph 5 above, and even then only in 
accordance with paragraphs 7 and 8 herein. 
7. 
CDM may only be disclosed to persons who are not included in those 
categories referred to in paragraph 5.a. above, upon prior written consent of the Producing 
Party's and Intervenors' counsel. If either the Producing Party's counsel or the Intervenors' 
counsel refuses to give consent, the CDM shall not be disclosed. The Receiving Parties may 
apply to the Court for an order of relief, on notice to the Producing Party and Intervenors. 
8. 
Any person referred to in paragraphs 5.a.iii through 51 above who is 
furnished a copy of any CDM shall first be given a copy of this Protective Order and required 
to read it and be bound by its terms. 
9. 
At any time during this Action, the Receiving Parties may challenge the 
designation of CDM as confidential by written notice to the Producing Party's counsel and 
counsel for the Intervenors specifying by exact bates number the materials in dispute and the 
precise nature of the dispute with regard to each document or portion thereof. The parties 
and Intervenors shall have twenty (20) days from receipt of the written notice to determine 
if the dispute can be resolved without judicial intervention and, if not, the Receiving Parties 
amy move for an Order removing the confidential designation. The Receiving Parties shall 
have the burden of proof on such a motion to establish good cause for removing the 
confidential designation and treatment. 
-4-
EFTA00191325

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 6 of 9 
10. 
No party shall be obligated to challenge the propriety of any designation, and 
a failure to do so shall not preclude a subsequent challenge on the propriety of such 
designation and shall not constitute an admission that any information is, in fact, confidential. 
I I. 
In the event a party seeks to file any pleading, brief or memorandum or other 
document purporting to reproduce, paraphrase or summarize any CDM or portions thereof, 
that party shall take appropriate action to insure that the documents receive proper protection 
from public disclosure and shall seek leave of Court to file the document under seal in 
accordance with Local Rules of the United States District Court for the Southern District of 
Florida. 
12. 
a. 
In the event that a party intends to file CDM with the Court in support 
of, or in opposition to, a non-discovery motion (e.g. motion for summary judgment or any 
other dispositive or substantive motion), the filing party shall take appropriate action to 
insure that the documents receive proper protection from public disclosure and shall seek 
leave of Court to file the document under seal in accordance with the local rules. 
b. 
The non-discovery motion filing and briefing schedule shall be adjusted 
and tolled to provide sufficient time for the Court to consider and rule on the motion seeking 
permission to file the document(s) under seal. 
c. 
Once the matter has been resolved, the filing party may file the 
document(s) in accordance with the parties' and Intervenors' agreement and/or the Court's 
instructions, as applicable. 
-5-
EFTA00191326

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 7 of 9 
13. 
The CDM and/or other papers which are filed under seal shall be kept under 
seal until further order of the Court; however, said CDM and other papers filed under seal 
shall be available to the Court and counsel of record, and to all other persons entitled to 
receive the confidential information contained therein under the terms of this Protective 
Order. 
14. 
This Protective Order is intended to provide a mechanism for the handling of 
the CDM and is not intended to imply that any CDM is relevant or admissible in this Action 
or any other litigation. Any party may move for relief from, or general or particular 
modification of, the mechanism for maintaining confidentiality herein set forth, or the 
application of this Protective Order in any particular circumstance, and each party 
specifically reserves all rights to object to the relevance or admissibility of any information 
produced in accordance with this Protective Order on any grounds it may deem appropriate. 
15. 
If a party receiving CDM in accordance with the terms of this Protective Order 
is served with a subpoena or other process by any court, administrative or legislative body, 
or any other person or organization which calls for the production of any CDM, the party to 
whom the subpoena or other process is directed shall, within two business days of its service, 
notify the opposing party or parties and the Intervenors of the pendency of such subpoena or 
order and provide them with a copy of the subpoena or process and the date by which 
compliance is requested. Any party or the Intervenors opposing the production of the 
-6-
EFTA00191327

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 8 of 9 
information demanded in the subpoena or process shall notify the party served of its 
objections as early as possible prior to the requested compliance date. 
16. 
This Protective Order may be amended with leave of Court, by the agreement 
of counsel for the parties and intervenors in the form of a stipulation submitted to the Court 
for approval, or by the Court sua sponte after affording the parties and Intervenors the 
opportunity to be heard. If the parties and Intervenors cannot agree to an amendment, then 
a formal motion to amend must be filed with the Court. This Protective Order is intended 
to regulate the handling of CDM and documents during this litigation, but shall remain in full 
force and effect until modified, superseded or terminated on the record by agreement of the 
parties thereto or by order of the Court. 
17. 
All counsel of record in this Action shall make a good faith effort to comply 
with the provisions of this Protective Order and to ensure that their agents, employees and 
clients do so as well. In the event of a change of counsel, retiring counsel shall notify new 
counsel of their responsibilities under this Order. 
18. 
This Protective Order does not restrict or limit the use of CDM at any hearing 
or trial, which may be the subject of a further protective order and/or appropriate court 
orders. Prior to any hearing or trial at which the use of CDM is anticipated, the parties and 
Intervenors shall meet and confer regarding the use of the CDM. If the parties and 
Intervenors cannot agree, the parties and Intervenors shall request the Court to rule on such 
procedures. Notwithstanding, this Protective Order shall remain in full force and effect until 
-7-
EFTA00191328

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 9 of 9 
modified, superseded, terminated on the record by agreement of the parties and Intervenors 
or by order of the Court. 
19. 
Within sixty (60) days after the conclusion of this Action, whether by 
judgment, settlement or otherwise, including conclusion of any appeal, all CDM including 
but not limited to materials furnished to consultants and/or experts shall be returned to the 
Producing Party unless the parties stipulate to destruction in lieu of return; provided, 
however, that counsel of record in this case may retain for their files, copies of any of their 
work product, pleadings, court filings, brief, and exhibits, which incorporate or contain 
documents, information or material designated as "CONFIDENTIAL". 
20. 
Upon final termination of this Action, whether by judgment, settlement or 
otherwise, including all appeals, the Clerk of the Court shall return to counsel for the parties, 
or destroy, any materials filed under seal. Before destroying any document filed under seal, 
the Clerk of Court shall advise all parties of their option to accept return or destruction and 
shall allow no less than thirty (30) days from issuance of the notice for counsel to respond. 
In the absence of a response, the Clerk of Court may destroy documents filed under seal. 
DONE AND ORDERED in Chambers at West Palm Beach, Florida, this 
day of 
May, 2014. 
Kenneth Marra 
United States District Judge 
cc: 
All counsel 
-8-
EFTA00191329

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 1 of 22 
COMPOSITE EXHIBIT 2 
EFTA00191330

Case 9:08-cv-80736-KAM Document 247.2 Entered on FLSD Docket 05/02/2014 Page 2 of 22 
Attorneys Say Miami Prosecutes Violated cam Metals' RIghtS Act I Main Justice 
JEGOTIATING WITH THE DOJ: N1MAw JUSTICE 
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orneys Say Miami Prosecutors Violated Crime Victims' Rights Act 
'rename Arno/how I March 22. 2011 11:52 am 
we attorneys for two girls who wand they ant eattultal by bilhonolre end 
Mae sex °Render Jeffrey Epstein Mod cowl gapers on Monday canting PO 
I U S Attorneys Once Mol sled the Cure Vlalme' RION. An by scan • ronprosecubon Kreitman, et' Elmeln 
ut nothing them Me Pete Beach oily News mooned 
ww• Printable Voltam 
thgrasikepdnle 
i Epstein served 13 months In Jail tom June 2004 to My 2003 a one stele count of &Magna 
en unchrego go for prosbamo Aa • town he Is maned to register es a set oftener 
he wan" proteada foe edadonal chops mote then 40 glee under the ego of 16 ssy tag 
tame to He home and gave him manages During thorium/men they say he masirbeted 
and away esstaied them 
Bred Edwards and Paul Cased. Hamra representen woof hn alleged Mcdms. My In 
the nog that tie U B Attaney's ofce for the Southern Ol sat of %doe of tieutwaotohr 
r falai f' •i 
misled the stares by tang them there wee en ongoing Imrnagelten Into their clans 
However. May say. the once was emceeing the tact Mat they needy herd signed • 
osoeman deal MT Epstein 
-Ong to Me modem the U S Attomays *Mat In Janata 2008 and May 2000 sent Us* notecotton' 'mania to 
ins Mined Maims laying 'Pas Carl Hanna under Investlgean ' HINiever. Si. taco had signed the agreement 
!par In September 2007 
Montoya weal a court heeded during which ltwr NI) ask MN ma agreement be onviralsted hawse N Nano the 
is' rights In the motion at attorneys clakn the egnawat Is Ono, because me government Old not rimed the 
pessienady mandated rights of maims before n entered Mrs agreement' 
Ogg mints the request. Epskin add be charged by the U.S Altman office if he were charged sal ocartted on 
al charges. he could be sentenced to 10 years to Me for nth Omega 
'MC to the meat 'The CO/ reason that the (U 9 Morsels splice) concealed the existence of me non-pro socutIon 
event from the Maim* was nol to cony)/ with 001710 opal reselcion dA newt lo men a firestorm of pima 
nay that would have Masted II ths sweetheart plea deal rim • pancally connected billonalre had been revealed' 
I Volk, special counsel for me U S Attorneys Office Southern 19selet re Fronde. In en oral to the newspaper that the 
anceneYs ace wall respond in court flings 
ever. le we staled more then two years ago in July 2009 In our 'itemise to the prelritiffa than-emergency imam lot 
cement of the Cane Viclin Rights Ad. the CVFtA was not tiOlstorl becthise no federal charges wore ever gad In tea 
iern Memo of Florae.' Vale said 'Because the menet remains pending In cowl. It would be Inappromfata at Ms time 
note 000110nel comment on Me merits d the current motion 
aeon pnCITC 
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Page 1or 2 
EFTA00191331

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 3 of 22 
Monkeys Say Miami Prosecutors Violated Crime Victims' Eights Mi I Main JuMkt 
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Copyright CI 201' WDC Medle Lie 
Page 2 of 2 
EFTA00191332

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 4 of 22 
Attorneys want Jeffrey Epstein agreement thrown out 
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Attorneys want Jeffrey Epstein agreement thrown out 
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Court papers Ned Monday say the U.S. Attorneys Office violated 
tho Crime Violins' Rights Mt by signing a nonprosecution 
agreement with sex offender Jeffrey Epstein without notifying his 
victims 
Attorneys Bad Edwards and Paul Cane, representing Jane Doe 
1/1 and Jane Doe fr2, went a court hearing, where they will ask that 
the agreement be invalidated because, they say, the victims' nghts 
were violated II that happens, it could open up the 93-year•td 
Palm Beath billionaire toe slew ol federal charges involving sex 
crimes with minors that were set 05100 by the agreement. 
The motion. Nod Monday in federal court In West Palm Beach. 
accuses the U.S Attorney's Office ol deliberately misleading the 
victims by taloa them the Investigation was ongoing. wheal 
concealing they had already sgnod a deal with Epstein 
According to the motion, the U S Attorneys Office sent 'false 
letters In January 2008 and May 2008 to the victims 
saying lIthlIS case is currently under investigation' after the 
government had signed the agreement w.lh Epstein In September 
2007 
'The only reason that the (U S Attorneys Office) concealed the 
existence of the nonprosocut/on agreement from the victims was 
not to comply w.th some legal restriction, but rather to avoid a 
firestorm of public Conyovorsy that would have erupted If Me 
sweetheart area deal with a po Ideally connected billionaire had been 
revealed.' the motion says.
II Epstein were found Diary on federal charges. statutory pona'tles 
ranged from 10 years to We 
Instead the sealed pact was part and parcel of Epsleln's 
acceptance of a stale plea deal where he received en IBmonth 
Sentence for sorolling a minor for prostitution and soliciting 
prostaulOn He served 13 months segregated In a vacant wing of 
the county stockade and was lel out on work rtease six days a 
week for up to 16 haws a day 
Edwards and other attorneys fought In court for a year before 
successfully gelling the agreement unsealed In September 2009 
More Man 30 minor gins ware klentified as Easton s victims in the 
nara 
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It 
Page 1 of 3 
EFTA00191333

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 5 of 22 
Attorneys want Jeffrey Epstein agreement thrown out 
417111 3 37 PM 
Almon 4 
Doe I and 2, who were 14 and 13. respectively. al the limo of the 
Incidents, received monetary settlements in civil cases. They am 
among more than two-dozen underage girls who Plod lawsuits or 
settled claims against Epstein. alleging they wore lured to his Palm 
Beach mansion to gem him sexually charged massages and/or sex 
In exchange for money. 
The motion feed Monday says the agreement Is illegal because the 
government did not protect the tongressIonatly mandeled rights of 
victims before it entered this agreement' 
Aticia Valle, special counsel for the U.S. Attorney's Office Southern 
District of Florida. sald in on e•mall that the U.S. Attorneys Ofece 
will respond In court feings. 
'However, as we slated more than two years ago in July 20O8 in our 
response to the plaintiffs' thenemergency petition for enforcement 
of the Crime Victim Rights Act, the CVRA was not violated because 
no federal charges were ever filed in the Southern District of 
Florida.' Valle said. 'Because the matter remains pending In coon, it 
would be Inappropriate allies lime to provide additional comment on 
the merits of the current motion' 
The attorneys reference e-mells and letters from the federal office in 
Epsteins lawyers acknowledging the government's legal obligation 
to Inform victims about the pact The entails are redacted In the 
motion because they are under set The attorneys filed a separate 
motion Monday to unseal the correspondence.
'The reasonable Inference from the evidence Is that the U S 
Attorney's Office wanted to keep the agreement a secret to avoid 
intense criticism that would surely ensued had the victims and the 
public learned that a billionaire sex offender with political 
connections had arranged to avoid federal prosecution for numerous 
felony sex offenses against manor girls.' the motion says 'As part of 
this pattern of deception, the U.S. Attorney's Office discussed victim 
notification with the defendant sex offender and. niter he raised 
objections. slopped making notilleatIons.* 
Epstein sought 'a higher level of review' within the Department of 
Justice the motion says. 'A reasonable inference Irons the evidence 
is that Epstein used his sirlicani pol.lical and social connections to 
kitty the Justice Department to avoid significant federal 
prosecution' the motion states 
shed this article. 
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Page a of 3 
EFTA00191334

' Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 6 of 22 
Attorney% want Jeff ray fpsDin agreement throw" out 
4O/11 1 37 PM 
Coppgret 0 Thu Apr 07 13 33 34 EDT 7011 M ogles reserved By tory PekreeechOelgtferte con. you accept the leans el out Pella ogeeerneof Plans° Joao N 
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Page 3 al 3 
EFTA00191335

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 7 of 22 
News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi. . Page I of 3 
BRIEFINGWIRE 
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News Reports about 
Billionaire Pedophile Jeffrey 
Epstein Highlight the 
Importance of Victims Rights 
Hundreds or news articles have reported 
billionaire pedophile Jeffrey Epstein's 
close relationship with Britain's Pr rce 
Andrew Attorney Brad Edwards has 
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by Epstein 
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close relationship with Britain's Prince 
Andrew. Attorney Brad Edwards has 
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EFTA00191336

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 8 of 22 
News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of VI... Page 2 of 3 
at Epstein's Paim Beach Mansion, private 
Caribbean island and his Jet. But 
Epstein's heinous sexual abuse of these 
victims Is no fiction. 
Edwards successtuny represented these 
women, obtaining Justice for each of 
them, by proving that Epstein end his 
internettonal 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 
vest 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 
then 83,000 substantiated reports of 
sexually abused children were made In 
2006 stone. The actual number of 
incidents of sexual abuse is likely much 
higher because II 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 beaarthat victims 
rights cases can effectively protect their 
rights, maintain their anonymity, and hold 
predators accountable.' 
Farmer, Jaffe, Waging, Edwards, Piste's 
Lehman, P.L , a Fort Lauderdale 
Litigation firm, focuses on Consumer 
Class Actions, Sexual Abuse Cases as 
well as other significant Personal inlury, 
Wrongful Death, and Whistlebiower Suits 
(qul tem). The firm is headquartered at 
425 N. Andrews Avenue, Suite 2, Fort 
http://www.briefingwirc.com/viewBriefing.aspeid-24902 
5/2/2011 
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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 (964) 624-
2820 Additional information about Brad 
Edwards or Farmer, Jaffe, Welssing, 
Edwards, Fistos 8 Lehrman. P.L. may be 
obtained from the fires webalte at 
swAv palhlotustIce com. 
FAQ4 I Contact Us I Terme 8 Conditions I 
Privacy Policy 
O NOD OdeingVAte LLC 
httpl/www.briefingwire.comiviewBriefing.asmaid=24907 
5(2/201) 
EFTA00191338

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Palm Beach Dilly News (FL) 
JUDGE RECEIVES EPSTEIN TAPE 
RULING PENDING 
MICHELE OARGAN, Daily News Staff Writer 
Published' May 5, 2010 
NEW YORK — A Manhattan federal 
Way Wok Into custody • lapsrocorted conversation 
between veteran newts 
rter 
Rush end convicted sex offender Jeffrey Epstein. 
But U S DINO Judge. 
eons reserved ruling on whether the recording wet be released to 
Wormy* representing 
n who were sexually abused by Epstein as rNnors. McKenna Sin', 
Ils/en to the recording dung the hearing. Fort Lauderdale °Homey Bred Edwards arid Utah attorney and 
law professor Pail Cassel are fIghtng lo obtain the 22.mlnLie tape on behalf of Epstein victim Jane Doe. 
She has Ned one of • dozen pending off cases in fedora! court In West Palm Beech egstral Epstein. 
A status check Is sat for Thursday In those cases baton U.S. District Judge Kenneth Mena. 
Doe could have sallied the lawsuit for 150.000 but is asking for S50 miler, In damages. Cassel said 
Tuesday. 'Jane Doe was repeatedly sexually esseulled over a lengthy period of erne by this wealthy and 
powerful man,' Cassell said. 
Epstein, 57, Is cunently under house arrest n his Palm Beach horns eller seMng 13 months of en 18. 
model stale sentence for soliciting a minor tor proOlulion and scatting prostitution. Nearly Iwo dozen 
young women have filed lawsuit. against the b IllonaVe money manager •• some already aided — el 
alleging Epstein sexually abused them et minors al Ns El Brio Way home.
Cites mponeffs protected erioffiEN 
Rush. of the New York Deity News, was present in the courtroom, but did not haw to Ms* Tuesday. 
Neither did Fort Lauderdale private Investigator Michael Flsten, also In the courtroom. Working on belief 
of Epstein victims, Fitton discovered the existence of ihe tape and had e conversation with Rush ebout its 
contents. 
Representing Rush and the newspaper. Washington ettomey Laura Hindman and New York Daly News 
ettomey Ame Carroll argued the tape florid !VI be retested under any circumstances, citing reporter's 
protected pdvilege. Rush told Epstein the conversation wee 'off the record' end has never published any 
gallon 04 leer conversation. But even If portions had been printed. the unpublished portions would still be 
protected, Mondrian bid. 
Hindman cited cases where Interviews were conducted in the presence of other people and ladelilige was 
not waned 
In addition. Handmen argued that Rush should not have to testify In court. 
The Willy for fanners pelvises to be protected is crucial In culling semis' and gathering information tor 
news Correa Hindman said Reporting is all about give and take between the reporter end the source. 
Mars what reporter, have to do, Hardman said. 
This a so critical to news gathering.' Hardman said. 'Mr. Rush OWN And himself testifying In !many) 
cases psi because he hid the temerity 10 do some reporting an • yew Imperial slory.' 
There a nothing helpful to Does case on the tape and 'lane Doe Is not referred to once In that Npe.' 
Hardman said. 
Caned argued that the laps Is %Nicer in showing Epstelne lack el remorse,' 
Cassell described Epstein as a pitiless sexual abuser to Janet/co siva al least 30 other minor gins Even 
though Jane Doe Is not mired to by name on the laps Epstein miens to ass victims as 'the girls' and 
makes disparaging remarks about them on Ihe laps. Cassell said. 
Tope played for others 
Cassel said privilege does not apply because It was waived when Rush played the tape for three people 
and verbally divulged Its contents to two others, Including li sten and Edwards. who also represents two 
other victims. But even if them is 'qualified NM age,' Cowell Gays II a outweighed by Doe's Mobility to 
obtain the information anywhere else and the Nile need to hear Epstein's own words about Ms lack of 
remorse. 
Since Epstein has exercised Ns Fifth Amendment right during questioning by victims' attorneys. the jury 
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EFTA00191339

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22 
PAT Beach Daily News: Archives 
wet hive no odor way to hew Cps.In's words In his &snooks, Cassell said. 
Deadline for discovery In the Doe rose le May 31. with the plat sal * July t4. 
mdergenapbdellynews.com 
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Pain Desch Daily News (FL) 
LAWYER: EPSTEIN MADE ADMISSIONS ON TAPE 
MICHELE (MADAN, Daily News Staff Witter 
Published: Apdi 29. 2010 
A tape recorded interview between a reporter and convicted sex offender Jeffrey Epste'n contains 
'damning admIeslone by Epstein,' which Includes rotten saying he had come "dose to crossing a one' 
concerning sex with underage girls. 
Those and other revelations about the 22-trinute Interview by New York Day News reporter 
RULi 
with Epstein are contained in a 24-page court Ping by **may* Brad Edwards and POW Cast* on 
hail 
of Jane Doe. Edwards represents Doe and Pave other Epstein victims. Edwards and Cassell are lIghting to 
obtain the tape to further the, cane of sexual abut* by Epstein when Dos was a minor 
Epstein, 57. was released from Jell in July alter *Wog 13 mono., of an Igrnonth slate sentence for 
soliciting • mho: for 020abiu••• and stliktting prostIttlon Nearly two dozen young women have Mod 
lewsults against Epstein — some already settled -• as alleging Epstein sexually abused them as mince, el 
his El Brill° Way home, where he b now serving house west 
The New York Daily News is seeking to keep the tope confidential, citing reporlans protected privilege. 
In response, Cassell says the newspaper waived Ks protected privilege when Rush played the recording 
for three people and daunted its contents to two others, Including Edward. 
In addition. Cattail writes that pnviege cant be app led In this situation because It doesn't Involve an 
Issue misled Ia e conildentai source The pent* on the tape is Epstein. 
Evan If there Is 'outlined privilege.' Cased maintains It Is outweighed by Doe's insblity lo obtain the 
information anywhere else and her 'compel:nu need loobten Jeffrey EpsteIn's own words about his 
sexual abuse end tack of remorse' 
When reached by phone Wednesday, Anne Cant seamy for the New York Dent News. said she will 
answer Cassait In a coon Ming. Both the New Your Daly News and Doe have asked a ladeni court lodge 
In Manhattan to listen to the tape In chambers to help determine whether *Niter applies 
Epstein and others who heeped him procure minor gins for massages end sex acts have taken the Fifth 
Amendment In the r deposition,. stymieing Doe and the other victim suing Epstein. the document, say. 
Michael Fitters. tut Investigator worlong for Doe, discovered the ultimo, of the tape in fall 2009. An 
author who had listened to the tape told Fisten that Rush had a tape retorting of Epstein 'discussing the 
sexual ribose of minor gins' 
According to a sworn affidavit by Ratan. he cared Rush. who confirmed he Interviewed Epsleen end made 
a tape. Actonling to Amen. Rush toad him that he compiled negative Information from Epstein about his 
exploits with underage ohs and how he eluded the justka system But Fitton said that Rush told him Mal 
his publisher, who knows Epstein. Used II after receiving a cal from Epstein 
FIslen sold Rush told rim. among other things. that the following Information was contained on the tape 
That Ewa n said he went to Jail in Florida for no reason end • the sexual abuse of minors had happened 
In New York, he would have oily received a 2200 Ara 
That L.M., one of Edwards' clients who sued Epstein for sexual abuse as e minor, crone to h.m es a 
prosUrate and a drug user (mean rig she cane to NM for sex, rather than him purstAng her) 
That all the g de suing Nm era only hying to get a meal ticket. 
That me only thing he mole have done wrong was to maybe cross the Ina a *tie too closely. 
In a sworn deposition. Edwards states that Rush **dosed much of the information contained on the tape 
to tdm In e conversation 
Edwards said in his statement that the Rush Interview Is 'on quo end not otherwise obtainable from other 
witnesses beaus* a can be used to Men Potion 
a Nen' atm& 
Edwards saki Epstein Intik* in o deposition that he did not recognize ins name 
Rush from the 
New York Deily News 'despite the fact that ha gave a personal Interview that we ag.now to have 
bean tape recorded.' 
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22 
Palm Beach Daly News Archives 
4/7/11 1 32 PM 
Epstein 
Hee mme close to crossing e 
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Page 2 of 
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Page I 
LexisNexis" 
6 of II DOCUMENTS 
Copyright 2009 ProQuest Information and Learning 
All Rights Reserved 
ProQuest SuperText 
Copyright 2009 Palm Beach Post 
Palm Beach Daily News 
September 20, 2009 Sunday 
Dn I Edition 
SECTION: A SECTION; Pg. A.1 
LENGTH: 1126 words 
HEADLINE: ATTORNEY FOR EPSTEIN VICTIMS: 'I HAVE NEVER SEEN A STRANGER CASE' 
BYLINE: MICHELE DARGAN, MICHELE DARGAN, Daily News Staff Writer 
BODY: 
Sex offender Jeffrey Epstein could have been charged with multiple counts of five federal offenses involving sex 
acts with minors and faced a life sentence, but, instead, the government agreed not to prosecute him or his procurers if 
he spent 18 months in the county jail on two state charges. 
Those were the details unsealed Friday in a nine-page federal non- prosecution agreement that lets Epstein and 
co-conspirators Sarah Kellen, Adrian& Ross, Lesley Groff and Nadia Marcinkova off the hook for any of those past 
crimes. 
"He could have gone to prison for life and somehow he's getting immunity in exchange for nothing? said Fon 
Lauderdale attorney Brad Edwards, who represents three Epstein victims. "I have never seen a stranger case. To me, it's 
more spectacular what's not in it. It's the U.S. Attorney's Office saying we'll do everything in our power to see he doesn't 
get punished." 
Edwards has been fighting for a year in federal and state court to unseal the agreement. 
"The non-prosecution agreement raises more questions than it answers," said Miami attorney Adam Horowitz, who 
represents seven victims. "Why did all the co-conspirators receive immunity? Why were the victims not consulted re-
garding the sentence? Why did he receive such a minimal sentence? 
The federal deal has remained sealed in Epstein's state court file since he pleaded guilty in June 2008 to state 
charges of procuring a minor for prostitution and soliciting prostitution. 
U.S. Attorney's Office does not comment 
The federal charges he could have faced were: conspiracy to persuade minor females to engage in prostitution, 
conspiracy to travel to engage in illicit sexual conduct with minor females, persuading minor females to engage in pros-
titution, traveling to engage in illicit sexual conduct with minor females and causing a person under 18 years to engage 
in sex for money while knowing they are underage. 
The charges carry various statutory penalities ranging from 10 years to life, with a minimum mandatory of at least 
10 years. 
Alicia Valle, spokeswoman for the U.S. Attorney's Office in Miami, declined comment. 
Expert: Feds take few sex-assault cases 
EFTA00191343