Epstein Secrets

hat, in view of its importance. the tape was properly discoverable despite the claim of journalist privilege. The Daily News then took an appeal to the Second Circuit. While the appeal was pending, however, the underlying civil suit by Jane Does (as well as the other two girls) settled, leading to an automatic va

ry its burden of showing proper justification for refusing to produce these highly relevant tapes for two simple reasons. 2 EFTA00728067 First, the Daily News' reporter, George Rush, has waived whatever privilege might attach to the recording by playing a significant portion of the recording to three people

Id. This is unique and direct evidence of Epstein's lack of remorse that is not cumulative of anything else Edwards can present' 7 In its brief to the Second Circuit on the "Jane Doe" case, the Daily News claimed that Epstein's recording "shows little more than a defendant, charged in multiple actions with commit

prosecuted on behalf of ■. ARGUMENT I. THE DAILY NEWS HAS WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS. 6 The counterclaim is attached to the Daily News' Balin Aft: at Ex. B. 5 EFTA00729042 In his opening brief, Edwards' lead argument was that the Daily News has waived any privilege by disclosing

Annexed hereto as Exhibit "N" is a true and correct copy of the Amended Order, dated July 28, 2010, that was issued by the U.S. Court of Appeals for the Second Circuit in the appeal in the Jane Doe Action. 17. Annexed hereto as Exhibit "O" is a true and correct copy of the Judgment against Scott W. Rothstein tha

ounds for denying Edwards' motion are fully set forth in the accompanying memorandum of law. I submit this affirmation to annex exhibits relevant to the Daily News' opposition. 3. Annexed hereto as Exhibit "A" is a true and correct copy of the Complaint of Jeffrey Epstein, with Exhibits 1 and 2, that was file