Epstein Secrets

RK, • App. Div. No. 6081 Respondent, • On Appeal from New York Supreme Court, • New York County, Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM OF LAW IN SUPPORT OF MOTION TO UNSEAL APPELLATE BRIEFS DAVIS WRIGHT TREMAINE LIP Robert D. Balin John M.

iction for Sex Crimes and Designation as a Level Three Sex Offender 3 B. Media Interest in New York and Florida Prosecutors' Lenient Handling of Epstein's Case 5 C. The Post's Efforts to Obtain the Appellate Briefing Filed with the First Department 8 ARGUMENT 9 I. THE POST HAS THE RIGHT TO M

had never spoken to the federal investigators in Florida who had reached the conclusion that Epstein was a serial abuser of underage girls. Id Ex. C. Epstein subsequently commenced this Appeal, seeking to overturn the trial court's ruling that he is a level three sex offender. The appellate briefs submitt

Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM

Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM O

008), available at https://nypost.com/2008/06/30/jeffrey-epstein-pleads-guilty-to-prostitution-chargest Mother se

n on the disclosure of the appellate briefs. Id. Mr. Epstein's lawyer stated that he would not take a positio

6 N.Y.S.3d 19 (1st Dep't 2015) 10 Danco Labs., Ltd v. Chem. Works of Gideon Richter, Ltd, 274 A.D.2d 1, 711 N.Y.S.2d 419 (1st Dep't 2000) 11, 13 Globe Newspaper Co. v. Superior Court, 457 U.S. 596 (1982) 11, 13 In re Application of National Broad Co., 635 F.2d 945 (2d Cir. 1980) 11, 13 In re Associated Pres

Post, moyes pursuant to Fla, R. Civ. P. 1.510(a) for Summary Judgment and states: I. INTRODUCTION The material facts in this case are not in dispute. Jeffrey Epstein was an extraordinarily wealthy, influential, and serial pedophile. It is indisputable that the State failed or refused to use the tools available to

therwise available in the public record-to inform the public as to whether the then State Attorney for Palm Beach County presented truncated evidence ofEpstein’s criminal wrongdoing to the 2006 grand jury in a manner that precluded Epstein’s indictment for the serious crimes he committed, including sex traff

effrey Epstein, till when he had been informed of Mr. Epstein’s reputation and his wealth, and I just thought t

e material facts in this case are not in dispute. Jeffrey Epstein was an extraordinarily wealthy, influenti

ntly, public access to trials acts as an important check, akin in purpose to the other checks and balances i that infuse our system of government.”); Globe Newspaper Co. v. Superior Courtfor Norfolk County, 457 U.S. 596, 606 (1982) (“the right of access to criminal trials plays a particularly significant role in the f

pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff Jane Doe has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this

prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[

on PACER. S.D. Fla. Civil Docket for Jane. Doe v. Jeffrey Epstein. Case # 9:08-cv- 80893-KAM ("Docket"), DE

on that any of those people . . . have spoken to Mr. Epstein about Jane Doe or any of the other specific victi

r. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996) 18 Bruno v. Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil

ve Order pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this

prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[

found on PACER. S.D. Fla. Civil Docket for ME v. Jeffrey Epstein, Case # 9:08-cv- 80893-KAM ("Docket"), DE

on that any of those people . . . have spoken to Mr. Epstein about or any of the other specific victims," Edw

r. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996) 18 Bruno v. Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil

pted suicide of his former and now-late cellmate Jeffrey Epstein. Id. at 1-2. The Government submitted a s

n a sealed The right of access is an affirmative, enforceable public right, and the standing of the press to enforce it is well settled. See, e.g., Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 609 n.25 (1982); Hanford Courant Co. v. Pellegrino, 380 F.3d 83, 91 (2d Cir. 2004). EFTA00017095 --- PAGE BREAK

ors to seek death penalty for ex-cop in quadruple homicide, New York Post (Mar. 21, 2019) httos://bitivam7aloL. See, e.g., William K. Rashbaum et al.,Jeffrey Epstein Is Found Injured in Jail Cell, New York Times (July 25, 2019) htips://nyti.ms/2kbOXbe. 9 See, e.g., Emily Saul, Jail guards threatening former Epste

e Lugosch, 435 F.3d at 124. 5 EFTA00017099 --- PAGE BREAK --- charges against him and the prosecutors' decision to seek the death penalty.? Mr. Epstein's attempted suicide, which occurred while Mr. Tartaglione was his cellmate, roused even greater interest in his case! Put simply, the public is wat

e remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The origins of thi

ffrey Epstein's Conviction and the CVRA Suit The origins of this case lie in a decade-old criminal proceeding against financier Jeffrey Epstein ("Epstein"). On June 30, 2008, Epstein pleaded guilty to Florida state charges of soliciting, and procuring a person under the age of eighteen for, prostitu

e remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The orig

its] claim of functioning as surrogates for the public."J9 48 Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cly., 457 U.S. 596, 606, 102 S.Ct. 2613, 73 L.Ed.2d 248 (1982)). 49 Richmond Newspapers, Inc. v. Virginia, 448 U.S.

remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The origins of this

Jeffrey Epstein's Conviction and the CVRA Suit The origins of this case lie in a decade-old criminal proceeding against financier Jeffrey Epstein ("Epstein"). On June 30, 2008, Epstein pleaded guilty to Florida state charges of soliciting, and procuring a person under the age of eighteen for, prostitut

remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The origi

lize this crucial qualification to the litigation privilege. " Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cty., 457 U.S. 596, 606 (1982)). 49 Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572-73 (1980) (plurality op

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTFIS LIN, etc., et al., Defendant(s). ORDER ON COUNTER-PLAINTIFF EDWARDS' RENEWED MOTION FOR LEAVE TO ASSERT CLAIM F

IL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTFIS LIN, etc., et

NTY CIVIL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTFIS LIN, e

damages, the Plaintiff must make a showing through proffer of a "reasonable basis for recovery of such damages." See Fla. Stat. § 768.72. See also, Globe Newspaper Co. a King, 658 So.2d 518, 520 (Fla. 1995). While the burden is upon the party seeking punitive damages to make such an evidentiary proffer, the standa

ugh his undersigned counsel, hereby submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein’s Motion for Summary Judgment. Epstein seeks Summary Judgment on the claims of abuse of process and malicious prosecution set forth in Brad Edwards’ Fourth Amended Counterclaim. Each of th

Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Depos

al complaint with obstruction of justice in eanneetinn with trying to obtain $50,000 from civil attorneys pursuing civil sexual assault cases against Rpatein as payment for producing the book to the attorneys. See Criminal Complaint at 4, US. v. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit “G

, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOT

, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOTI

written by Rebecca Rosenberg and Danika Fears, which was published by the Post on January 7, 2015, entitled “DA’s office ‘went easy’ on sex offender Epstein.” 4840-5788-8644v. 1 3930033 -000039 HOUSE_OVERSIGHT_016424 --- PAGE BREAK --- os Annexed hereto as Exhibit C is a true and correct copy of an ar

ement about sexual assault — and a decade before the fall of Harvey Weinstein, Bill Cosby and U.S. Olympic gymnastics doctor Larry Nassar — there was Jeffrey Edward Epstein. Epstein, a multimillionaire hedge fund manager whose friends included a constellation of entertainers, politicians, business titans and royalty, fo