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IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
JEFFREY EPSTEIN, 
Plaintiff, 
VS. 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, 
individually, and L.M., individually, 
Defendants. 
Complex Litigation, Fla. R. Civ. Pro. 1201 
Case No. 50 2009 CA 040800XXXXMBAG 
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION 
FOR PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND 
DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRA-JUDICIAL 
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 Motion for Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff 
From Making Extra-Judicial Statements and Commentary to the Media and Press, and, as 
grounds therefor, states: 
1. 
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 1]. The source for much of that Article's 
information is Jack Scarola, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. 
Edwards. 
2. 
In fact, Mr. Scarola is quoted to have said the following: 
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CASE NO. 50 2009 CA 040800 XXXXMB AG 
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 
children." 
[Exhibit I]. 
3. 
That same day, the Palm Beach Daily News published an article entitled "Jeffrey 
Epstein address book 'Holy Grail' of famous manes." [Exhibit 2]. 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." [Exhibit 2]. 
4. 
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 3]. 
5. 
Any published comments by Mr. Scarola are clearly generating other articles 
about EPSTEIN. All statements and comments by Mr. Scarola to the press and media must 
therefore stop immediately. 
6. 
This Court has the undeniable discretion to control and prohibit such extra-
judicial commentary in order to insure that Plaintiff/Counter-Defendant EPSTEIN receives a fair 
trial. See State ex. rd. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 
1976). Courts in Florida may take steps to protect against pretrial publicity. See Shepnard v. 
- 2 - 
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CASE NO. 50 2009 CA 040800 XXXXMB AG 
Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); Sentinel Communications 
Co. v. Watson, 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limitations imposed by the 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 State ex. rel. Miami I Jerald Publishing Co. v. 
McIntosh, 340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers, Inc. v. 
McCrary 520 So. 2d 32, 35 (Fla. 1988). 
7. 
The Florida Supreme Court in McIntosh recognized that restrictions on extra-
judicial comment are within the power of the trial judge when it said: 
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. 
State ex rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d at 910. Thereafter, the 
Supreme Court in McCrary stated: "Prohibition on comment is an acceptable alternative to prior 
restraint." Florida Freedom Newspapers, Inc. v. 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 was proper preventive measure where prejudicial publicity threatened to 
impair the right to a fair trial). 
8. 
Any communications by Mr. Jack Scarola and Mr. Bradley J. 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," 
states: 
(a) Prejudicial Extrajudicial Statements Prohibited. 
A lawyer shall not make an extrajudicial statement 
that a reasonable person would expect to be 
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CASE NO. 50 2009 CA 040800 XXXXMB AG 
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 
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." 
9. 
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, i 11 S. Ct. 2720, 2745, 115 L. Ed. 
2d 888 (1991). 
10. 
On March 
, 2011, in an effort to conserve this Court's time and resources, 
EPSTEIN's counsel asked Mr. Scarola to enter into a written agreement guaranteeing that Mr. 
Scarola, Mr. Edwards, and their respective agents and employees will not engage in any extra-
judicial commentary concerning MR. EPSTEIN's alleged sexual abuse of or being with minor 
females. 
11. 
The undersigned's efforts have not, unfortunately, been successful. 
WHEREFORE, Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, respectfully requests 
this Court, pursuant to the foregoing authorities and consistent with 4.3-6 of the Rules 
Regulating the Florida Bar, to issue a Protective Order barring Mr. Jack Scarola, 
Defendant/Counter-Plaintiff Mr. Bradley J. Edwards, and their respective agents and employees, 
from participating, encouraging, assisting, or abetting in the dissemination of any out-of-court 
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CASE NO. 50 2009 CA 040800 XXXXMB AO 
publicity or extra-judicial statements and commentary to the media and press concerning MR. 
EPSTEIN's alleged sexual abuse of or being with minor females. 
Respectfully submitted, 
By: 
Joseph L. Ackerman, Esq. 
Fla. Bar No. 235954 
FOWLER WHITE BURNETT P.A. 
901 Phillips Point West 
777 South Flagler Drive 
West Palm Beach, Florida 33401 
Telephone: 
Facsimile: 
Attorneys ore 
y pstein, Plaintiff 
and 
Christopher E. Knight 
Fla. Bar. No. 607363 
FOWLER WHITE BURNETT P.A. 
Espirito Santo Plaza, 14th Floor 
1395 Brickell Avenue 
Miami, Florida 33131 
Telephone: 
Facsimile: 
Attorneys for Je rey pstern, Plaintiff 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 
day of March, 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 
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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 
By: 
Joseph L. Ackerman, Esq. 
Fla. Bar No. 235954 
W:1807431MTNPRO29-to prechade opposing counsel extrajudicial statcmcnts.EEG docx 
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Convicted paedophile Jeffrey Epstein is facing a new criminal investigation and is involv... 
Page I of 3 
The Telegraph 
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 Ghislaine Maxwell stayed at Sandringham as guests of the puke Photo: ALF3ANPIX/GEOFF PUGH 
By Jon Swaine (http://www.telegraph.co.uk/joumalists/jon-swaine0  , in Palm Beach, Florida 
10:00PM GMT 10 Mar 2011 
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. 
EXHIBIT 
http://www.telcgraph.co.uk/news/uknews/theroyalfamily/8374911 /Convicted-paedophile-J... 3/11/2011 
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Convicted paedophile Jeffrey Epstein is facing a new criminal investigation and is involv... 
Page 2 of 3 
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. 
Epstein is himself suing Brad Edwards, a lawyer for several of the girls. Epstein alleges that Mr Edwards 
was linked 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. 
Further scrutiny on Duke of York over lobbying 
(http://wwwieleg raph.co.uk/news/uknews/theroyalfamily/8372507/Further-scrutiny-on-Duke-of-York-over
-lobbying.html) 
Timeline: the Duke of  York's questionable friends 
(http://www.telegraph.co.uldnews/uknews/theroyalfamily/8366227/Timeline-the-Duke-of-Yorks-
questionable-friends.html) 
Labour MP: Prince Andrew is 'an embarrassment' (http://www.telegraph.co.uldnews/newsvideo/uk-
politics-video/8366220/Labour-MP-Princ,e-Andrew-is-an-embarrassment.html) 
Duchess negotiated debt pay-off for several months 
(http://www.tele.graph.co.ukinews/uknews/theroyalfamily/8366981/Duchess-of-York-spent-nine-months-
negotiating-with-convicted-paedophile-Jeffrey-Epstein-to-pay-off-her-debts.htmll 
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 States 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.* 
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Convicted paedophile Jeffrey Epstein is facing a new criminal investigation and is involv... Page 3 of 3 
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 record." 
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 Scarola 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. 
Copyright of Telegraph Media Group Limited 2011 
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Jeffrey Epstein address book 'Holy Grail' of famous names 
Page I of 2 
PalmBeachDailyNpyyj,cpsp 
Jeffrey Epstein address book 'Holy Grail' of famous names 
By MICHELE DARGAN 
DAILY NEWS STAFF WRITER 
Updated: 7:56 p.m. Friday, March 11, 2011 
Posted: 7:57 p.m. Friday, March 11, 2011 
Print this page 
Close 
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. 
— known only as Jane Doe 102 in court papers — has been dishing her 
story to London's al y al 
e ails 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 Love, 
EXHIBIT 
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Jeffrey Epstein address book 'Holy Grail' of famous names 
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Mick Jagger, Cornelia Guest, Phil Collins, Itzhak Perlman, Simon LeBon, Charlie Rose, 
son, 
playwright Candace Bushnell, designers Tom Ford and Vera Wang, soap opera actress 
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: 
hitp://www.palmtteachdailynews.cominews/jeffrey-epstein-address-book-holy-grail-of-famous-1315130.html 
Print this page 
Close 
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Prince Andrew's link to sex offender Jeffrey Epstein taints royalty in US I UK news I The ... Page 1 of 3 
guardian.co.uk TheObserver 
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 
Paul Harris In New York 
11w Observer. Sunday t3 March 2011 
A ssac leader 
Prince Andrew is 
finding his friendships under international examination. Photograph: Facundo 
Arrizabalaga/EPA 
The British press has a new admirer. Spencer Kuvin, &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 ?Eno 
Andrew's relationship with the convicted paedophile. 
'I am glad the British press has picked this up," Kuvin told the Observer. 'he 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." 
Kuvin has been asking it for a while. He 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. 
"He'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," Kuvin 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 see them as 
t 
EXHIBIT 
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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 posos. 
So recent headlines in the US media have come as a bit of a shock. "Seen around town: 
Prince Andrew and Pert 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, $8, who served a 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, 
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 scene 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 
2008, 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 4o 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 iy 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. 
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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 rages involving Epstein. They amount to a potential 
source of PR torture for the royal family as media scrutiny continues. Recently released 
documents from a different case showed that two of E stein's closest confidantes - his 
PA 
and an on-off girlfriend, 
- 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 
and 
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 case 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 of 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. Ghislaine moved to the US in 1991 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 zoo7, although she denies rumours that 
they have ever been a couple. 
■ Tarek Kaituni, 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. 
ruardiandonk ("Quantum News and Wad Limited 2011 
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