Epstein Secrets

been exhausted. Edwards Aff. ¶ 25. On August 3, 2010, the court presiding over the case -- the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida — granted Edwards' Motion to Appoint a Commissioner in New York to take the deposition duces tecum of the Records Custodian of the Daily Ne

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

e marketing effort of the Ponzi scheme. EFTA00207314 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

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

e marketing effort of the Ponzi scheme. EFTA00612047 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

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

41 I 1 /Pfrbi E Skin j XE IDANT o096 5/Al COMMUNITY CONTROL VIOLATOR CFN 20080267522 OR BK 22760 PO 1081 RECORDED 07/17/2008 08:52:50 Pala Beach County, Florida Sharon R. flock, CLERK t COMPTROLLER Pg 1081; (1pg) DA' OF IRTH RACE PROBATION VIOLATOR GENDER SOCIAL SECURITY NUMBER JUDGMENT Th

cked jurisdiction on removal. Id. (citing Parks, The New York Times Co., 308 F.2d 474, 478 (5th Cir.1962); Cowart Iron Works, Inc.. Phillips Constr. Co., Inc., 507 F.Supp. 740, 744 (S.D. Ga. 1981)). Here, Defendants argue that removal is proper because Plaintiff cannot state a cause of action against Def

ght to the assistance of counsel in taking said appeal at the expense of the State upon showing of indigene . DONE ND ORDERED i Open 6 Court 4 at Palm Beach Count , Florida. this day of 'SO AS ,.e. , 2111•9 . brook EFTA00175570 Case 9:08-cv-c _-4-KAM Dootig 0 3 t?Rt,t . .-2 Entel. FLISD Do t 3.8/1b,

ked jurisdiction on removal. Id. (citing Parks'. The New York Times Co., 308 F.2d 474, 478 (5th Cir.1962); Cowan Iron Works, Inc.'. Phillips Constr. Co., Inc., 507 F.Supp. 740, 744 (S.D. Ga. 1981)). Here, Defendants argue that removal is proper because Plaintiff cannot state a cause of action against Def