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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
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
E.W./L.M.: "What the evidence is really going to show is that Mr. Epstein — at least dating back as completely irrelevant r subject matter of the Civil EFTA00795603 Epstein v. RRA, et al. Page 17 far as our investigation and resources have permitted, back to 1997 or '98 — has every single day o
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
r says. May I quote Judge Marra. 'If a specific tangible need arises in a civil case the relief should be sought in that case.' In other words, the Civil cases which are in front of Judge Hafele is one forum that Judge Marra said go to it. Judge Marra did not say that this Court does not have Jurisdic
ATE OF FLORIDA, E.W., THE PALM BEACH POST, B.B, Respondents. E.W.'S SEALED REQUEST TO DISMISS THE PETITION FOR LACK OF JURISDICTION Respondent, E.W., would show the Court as follows: 1. This Court lacks jurisdiction to hear this petition. The order under review is a non-final order for which no
Entities connected to both Civil and E.W.

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJane Doe
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONJack Scarola
PERSONMaria Farmer
PERSONRobert D. Critton
PERSON
Paul Cassell
PERSON
United States
LOCATION
Donald Trump
PERSON
Scarlett Johansson
PERSONMichael J. Pike
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Palm Beach County
LOCATIONLuttier & Coleman
ORGANIZATION