EFTA01102188

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): 
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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 
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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 
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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 
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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. 
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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; 
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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. 
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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 
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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... 
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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. 
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EFTA01102200

Jeffrey Epstein introduced woman to Prince Andrew, she tells London 'Daily Mail' 
Page 1 of 2 
PalmBeachDailyN,Ipnc,9m 
ig Punt 0-Is page• El Close 
Jeffrey Epstein introduced woman to Prince Andrew, she tells London 'Daily Mail' 
By MICHELE DARGAN 
DAILY NEWS STAFF WRITER 
Updated: 9:04 a.m. Tuesday. Mardi 1.2011 
Posted: 7:12 p.m. Monday, February 28, 2011 
The young woman previously known as Jane Doe 102 has gone public, detailing her life from age 15 as 
a paid sex slave for Jeffrey Epstein and his friends. 
Now a married 27-year-old mother of three living in Australia, Virginia Roberts spoke at length to 
London's Daily Mail in an interview published Sunday. 
Roberts spoke to the Mail after a photo recently surfaced of Epstein and Britain's Prince Andrew walking 
in Central Park. The photo was taken when the prince visited Epstein's Manhattan apartment in 
December. 
Roberts reveals to the Mail that she was in Prince Andrew's company three times at the behest of 
Epstein. An old photo, printed in the Mail, shows a smiling Andrew with his arm around Roberts' waist. 
The photo was taken at the London home of Epstein pal Ghislaine Maxwell. 
'There is no suggestion that there was any sexual contact between Virginia and Andrew or that Andrew 
knew that Epstein paid her to have sex with his friends," the Mail said. 
On that trip, which also included stops in Paris, Spain, Granada and Tangier, Roberts said Epstein paid 
her $15,000. 
Epstein, 58, received an 18-month sentence on state charges of soliciting a minor for prostitution and 
soliciting prostitution. He is now a lifelong registered sex offender. 
A deal with federal prosecutors revealed Epstein could have been charged with multiple federal counts of 
sexual exploitation of minors, resulting in much harsher penalties. But the feds deferred to the two state 
charges. 
Serving 13 months segregated in a vacant wing of the county stockade, Epstein was let out on work 
release six days a week for up to 16 hours a day. In addition, probation records reveal that while serving 
one year of house arrest, Epstein was given permission to travel out of state and spend hours outside his 
house, all with the blessing of either the court or his probation officer. Epstein retained some of the best 
lawyers in the country to get what many have described as a sweetheart deal. 
In December 2009, Roberts filed a lawsuit against Epstein as Jane Doe 102. She was one of nearly two 
dozen women who settled lawsuits against Epstein for undisclosed amounts, all alleging they were 
sexually abused by him as minors. The lawsuit says Maxwell recruited Roberts at The Mar-A-Lago Club, 
where Roberts was working as a changing room assistant. Maxwell told Roberts she could earn big 
money as a "traveling masseuse" to a wealthy Palm Beach man. 
All the lawsuits against the billionaire money manager said his modus operandi in the initial visit was the 
same: the minor girl was taken to Epstein's mansion on El Brillo Way and led upstairs to a spa room by 
one of Epstein's assistants, where he would ask the girl to perform massages and/or various sex acts, for 
which he would pay her. 
Roberts' lawsuit said she was sexually exploited by Epstein's adult male peers, which Included royalty, 
politicians, academicians, businessmen and others in various locations around the world. 
4 
• 
EXHIBIT 
2. 
hup://www.palmbeachdailynews.cominews/jeffrey-epstein-introduced-woman-to-prince-an... 
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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 
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News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page 1 of 3 
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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. 
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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 
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EXHIBIT 
3 
http://www.briefingwire.com/viewBriefing.aspx?id=24907 
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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 
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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 (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 
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5/2/2011 
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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-
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Duchess negotiated debt pay-off for several months 
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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 
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