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tober 13, 2010, an wunarked, unaddressed and unpostmarked envelope was discovered in the mailbox at Mr. Epstein's vacation home at 9 East 7O Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of vide
lbox at Mr. Epstein's vacation home at 9 East 7O Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Ex. A, Aff. Richard Barnett
ober 13, 2010, an unmarked, unaddressed and unpostmarked envelope was discovered in the mailbox at Mr. Epstein's vacation home at 9 East 71g Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of vide
box at Mr. Epstein's vacation home at 9 East 71g Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (A ff. Richard Barnett). 3.
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 And the unpublished Epstein interview, which was conducted months befo
vance to a significant issue in the case, and are not reasonably obtainable from other available sources" (quoting Gonzales, 194 F.3d at 36)) with.. Civil Rights Law § 79-h(c) (to overcome state Shield Law privilege for non-confidential material, party must make "a clear and specific showing" that the
Entities connected to both New York and Civil

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONDarren Indyke
PERSONFBI
ORGANIZATION
John F. Kennedy
PERSON
New York City
LOCATION
Prince Charles
PERSON
Samantha Power
PERSON