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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
UND 1. EPSTEIN'S SEXUAL ABUSE OF MINOR GIRLS AND HIS CRIMINAL PROSECUTION From approximately 2003 through approximately 2005, Jane Doe, L.M., and E.W. (all then minor girls) were repeatedly sexually abused by Jeffrey Epstein behind the walls of his gated mansion in Palm Beach, Florida. The acts of
LINK: I was just going to ask for -- since Mr. Epstein's deposition is so narrow and limited by this Court's order, may he appear by phone? He's in New York City, your Honor, or sometimes not in the country. MR. SCAROLA: We would request an opportunity to depose Mr. Epstein in person, your Honor. Mr. Epstei
r Shapiro present in the courtroom? MR. EDWARDS: Your Honor, I was informed that Mr. Paul Cassell was to call into this hearing on behalf of L.M., E.W. and S.R. THE COURT: I don't MR. EDWARDS: I don't know what arrangements he made. THE COURT: No such arrangements were made. So, we'll just -- on
R. CASSELL: Cassell is C-a-s-s-e-1-1. THE COURT: And who are you representing in this matter? MR. CASSELL: I represent putative intervenors L.M., E.W. and Jane Doe, who have a pending motion for leave to intervene. THE COURT: All right. Let me ask, is there any opposition to the motion to interve
goes for $556,500 The Associated hest NEW YORK - A rare copy of Benja- min Franklin's Poor Richard almanac has made somebody rich — selling at a New York City auction for more than half a million dollars. It's the second-highest price ever paid for a book printed in America. The Sotheby's auction house
re their plane struck a flock of Canada geese and lost thrust in both engines. Sullenberger told the board that he didn't at- tempt to return to New York's LaGuardia Airport because he thought, "I cannot afford to be wrong." and disabled would be exempt and cuts to Medicare would be sharply limit
th to do so today. "It is against public policy for these documents to have been sealed and hidden from public scrutiny. As a member of the public, E.W. has the right to have these documents unsealed," wrote former Circuit Judge Bill Berger, now in private practice and representing one of the women.
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
accurate misdescription. Nowhere in his complaint in the Ponzi Scheme Action does Epstein allege that the sex abuse suits brought by Jane Doe,. and E.W. were fabricated. Instead, what the complaint actually alleges is that Rothstein used 9 DWI 1584534543 3970112.000042 EFTA00596463 these three le
minors); id. at 7 ("the evidence of Epstein's crimes is now clear"). Among the many other evidentiary sources listed by Edwards: • Jane Doe,.. and E.W. have all provided graphic eyewitness testimony that they were sexually abused by Epstein when minors. See SUF ¶ 2 ("Deposition of Jane Doe, Septemb
ead them. Q And what did you do with them after you read them? A I left them on my desk. Q Which desk? A I don't remember exactly. I believe New York, as I said before. Q What happened to those documents after you left them on your desk? A After being informed by my counsel, I Palm Beach Repo
J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Shapiro Law uite 3000 ounse or ., . . an ane Doe Counsel for L.M., E.W. and Jane Niall T. McLachlan Carlton Fields Jorden Burt P.A. 200 °rinse or ow er nr e urnett, P.A. Isaac M. Marcushamer Ber er Sin erman LLP C
in Wasn't a Creep, by Ray Gustini, in The Wire (June 21, 201 I). Second, Jeffrey Epstein brazenly abused numerous girls in his Florida mansion, his New York mansion, and several other places that Dershowitz apparently admits he visited. See DE 282-1 at 1-3 (Dershowitz affidavit discussing visits to Epste
z] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexually abused, correct? 26 Of course, in a proceeding such as this one, the victims are entitled to an i
ead them. Q And what did you do with them after you read them? A I left them on my desk. Q Which desk? A I don't remember exactly. I believe New York, as I said before. Q What happened to those documents after you left them on your desk? A After being informed by my counsel, I Palm Beach Repo
ractice in this court set forth in Local Rule 2090-1(A). SHAPIRO LAW By: /s/ Peter E. ha it Peter E. Shapiro (FBN Attorneys for Intervenors L.M., E.W., and Jane Doe 10 EFTA00793508 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 11 of 165 Attorneys for Jeffrey Epstein SERVICE LIST Bradley J
York, and that no competent defense counsel negotiating in good faith with the prosecutors would have ever agreed to a deal back then that allowed New York prosecutors to indict for precisely the same conduct in the future, which, of course, is what happened. In addition, we have come up with very powe
h to do so today. "It.is against public policy for these documents to be have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed," wrote former CircuitJudge Bill Berger, now in private practice-and representing one ofthe women. The P
Entities connected to both New York and E.W.

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