Epstein Secrets

Page 2 2013 U.S. Dist. LEXIS 40263, * LOADMAN GROUP, L.L.C., et al., PLAINTIFFS, vs. BANCO POPULAR NORTH AMERICA, DEFENDANT. CASE NO. 4:10cv1759 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO, EASTERN DIVISION 2013 U.S. Dist. LEXIS 40263 March 19, 2013, Decided March 19, 2013, Filed PRIOR HISTORY: Loa

urden under Rule 56(c) and, therefore, defendant is entitled to summary judgment on these claims. Travelers Cas. & Sur. Co. of Am. v. J.O.A. Const. Co., Inc., 479 Fed. Appx. 684, 692 (6th Cir. 2012) (citing Fed. R. Civ. P. 56(e)(2)-(3)). Accordingly, defendant's motion for summary judgment as to these cl

ile blaming them for the abuse. 1 EFTA00728066 Several months ago, one of the three girls -- Jane Doe -- filed a proper subpoena for the tape in the United States District Court for the South District of New York. In response, on April 7, 2010, Rush and the Daily News filed a motion to quash, claiming that the tape recording

pe was not protected by the journalist's privilege. (Judge McKenna's Opinion is attached as Ex. 5 to Lewis Aft). Applying Gonzales v. Nat 'I Broad. Co., Inc., 194 F.3d 29 (2d Cir. 1999) (Gonzales ///), the district court explained that a reporter's privilege extended even to non-confidential sources. The

ael Fisten, both dated September 14, 2010, as well as a review of the files and records in an earlier proceeding for production of the recording in the United States District Court, Southern District of New York. 2. The Court should issue the order for the production of the recording pursuant to CPLR 3102(e) because (i) a Flor

3 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III").2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confidential: Mr. Rush disclosed

Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe in an action pending in the United States District Court for the Southern District of Florida captioned Doe v. Jeffrey Epstein, No. 08-cv-80893-1CAM, or in the alternative for a Protective Order pursuant

hly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 1996). Gall

Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe in an action pending in the United States District Court for the Southern District of Florida captioned Doe v. Jeffrey Epstein, No. 08-cv-80893-1CAM, or in the alternative for a Protective Order pursuant

hly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 1996). Gall

minal prosecution. According to a pleading recently filed by the federal government in a case which Edwards is litigating against the government in the United States District Court for the Southern District of Florida under the Crime Victims Rights Act: When asked whether Epstein "pulled you closer to him in a sexual way," [LM

and Summary Judgment against Edwards is therefore mandated. In Florida, "an action for malicious prosecution is a serious matter." Cent. Fla. Mach. Co., Inc. v. Williams, 424 So. 2d 201, 203 (Fla. 2d DCA 1983). Malicious prosecution actions are "not generally favored" in Florida. Id. at 202. There are si