Epstein Secrets

paper v. Lehrer McGovern Bovis, Inc., 300 A.D.2d 169, 752 N.Y.S.2d 642 (N.Y.A.D. 2002) 11 People v. Fentress, 103 Misc.2d 179, 425 N.Y.S.2d 485, (N.Y. Co. Sup. Ct. 1980) 13 People v. Osorio, 75 N.Y.2d 80, 84, 549 N.E.2d 1183 (N.Y. 1989) 10 United States v. Jacobs, 117 F.3d 82 (2d Cir. 1997) 13 i

" In re Steinhardt Partners, L.P., 9 F.3d 230, 235 (2d Cir. 1993) (internal quotation omitted). These general principles are operationalized in the New York's shield law. While the shield law provides certain protections for journalists, it also provides directly that the protection can be waived if infor

102(E) ORDER TO PRODUCE TAPE RECORDING x I Index No. MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR CPLR 3102(E) ORDER TO PRODUCE TAPE RECORDING Robert Y. Lewis Freeman Lewis LLP 228 East 45th Street, 17th Floor New York. New York 10017 Tel: Fax: E-mail: Paul G. Cassell, Esq. (Motion for Pro Hac Vice A

ewsgathering process" and disclosures for any other reason. Instead, it simply says that if information is disclosed, then any privilege is waived. New York's shield law flatly provides: Notwithstanding the provisions of this section, a person entitled to claim the exemption provided under subdivision (b)

tes he did nothing wrong and went to jail for no reason. Fisten Aff. at 12. He further claims in the interview that if he had done the same abuse in New York, he would have only received a $200 fine. Id And — critical to the lawsuit involving Brad Edwards — Epstein remarkably blames Edwards for his proble

should order the Daily News to produce the recording. New York, New York November I I, 2010 Respectfully submitted, Freeman Lewis LLP '4/i By: Robert Y. Lewis 228 East 45" Street, 17'h Floor New York, New York 10017 Tel: Fax: Paul G. Cassell (Motion for Pro Hac Vice Admission Pending) (: " 4—'4 ;tel

eral is very concerned about assisting/helping the victims. She has taken a bold step; way ahead of the Attorney Generals of Florida, New Mexico and New York. (Even more so in that she is an appointed — not elected — AG. And the politics of bringing this lawsuit was tenuous.) I hope all of your will appla

reeman , "Jason P. Amala" Meredith Schultz , Brad Edwards , Nathan Goldbe , Diane Aldrich , Robert Glassman Si id McCawley "James R. Marsh" "Robert Y. Lewis" "Michael T. Pfau" Subject: RE: ['ate Law Firm - U.S. Virgin Islands - USVI Epstein Estate - Victims Dear Justice Warriors, I write to put many o

eral is very concerned about assisting/helping the victims. She has taken a bold step; way ahead of the Attorney Generals of Florida, New Mexico and New York. (Even more so in that she is an appointed — not elected — AG. And the politics of bringing this lawsuit was tenuous.) I hope all of your will appla

nifer Freeman "Jason P. Amala" Meredith Schultz , Nathan Goldbe Brad Edwards , Diane Aldrich Robert Glassman Si id McCawley "James R. Marsh" "Robert Y. Lewis" "Michael T. Pfau" >, Subject: RE: Pate Law Firm - U.S. Virgin Islands - USVI Epstein Estate - Victims Dear Justice Warriors, I write to put man

tion (whether Edwards participated in Rothstein's fraudulent Ponzi scheme, not whether Epstein sexually abused Jane Doe) and entirely different law (New York's stringent Shield Iaw, not the less protective federal reporter's privilege). And the unpublished Epstein interview, which was conducted months befo

sion to the Second Circuit. While the appeal was pending, the Jane Doe Action (as well as the ■. and E.W. suits) settled. See Moving Affirmation of Robert Y. Lewis, dated Sept. 15, 2010 ("Lewis Aff."), ¶ 7. The Daily News and Rush then moved the Second Circuit to vacate the District Court decision. 8 DWT 1511

eral is very concerned about assisting/helping the victims. She has taken a bold step; way ahead of the Attorney Generals of Florida, New Mexico and New York. (Even more so in that she is an appointed — not elected — AG. And the politics of bringing this lawsuit was tenuous.) I hope all of your will appla

rds , Diane Aldrich Robert Glassman Sigrid McCawley EFTA00074243 Jennifer Freeman I>, "Jason P. Amala" >, Meredith Schultz "James R. Marsh" "Robert Y. Lewis" "Michael T. Pfau" Subject: RE: Pate Law Firm - U.S. Virgin Islands - USVI Epstein Estate - Victims Dear Justice Warriors, I write to put many of

eral is very concerned about assisting/helping the victims. She has taken a bold step; way ahead of the Attorney Generals of Florida, New Mexico and New York. (Even more so in that she is an appointed — not elected — AG. And the politics of bringing this lawsuit was tenuous.) I hope all of your will appla

"Jason P. Amala" Meredith Schultz Wan Pottin , Nathan Goldbe Brad Edwards , Diane Aldrich Robert Glassman , Si id McCawley "James R. Marsh" "Robert Y. Lewis" , "Michael T. Pfau" Subject: RE: Pate Law Firm - U.S. Virgin Islands - USVI Epstein Estate - Victims Dear Justice Warriors, I write to put many

eral is very concerned about assisting/helping the victims. She has taken a bold step; way ahead of the Attorney Generals of Florida, New Mexico and New York. (Even more so in that she is an appointed — not elected — AG. And the politics of bringing this lawsuit was tenuous.) I hope all of your will appla

"Jason P. Amala" , Meredith Schultz Marti Hamilton < , Mariann Wang , Michael Maroko 1 'litany Henderson , Brian Panish , Sigrid McCawley , "Robert Y. Lewis" "Michael T. Pfau" Subject: RE: Pate Law Firm - U.S. Virgin Islands - USVI Epstein Estate - Victims here's the complaint. Robert Glassman, Esq.