Epstein Secrets

3)(United States District Court, S.D. Fl.); v. Jeffrey Epstein (Case No. 502008CA028051XXXXMB AB)(Florida Circuit Court, 15th Judicial Circuit). v. Jeffrey Epstein (Case No. 502008CA028058XXXXMB ABXFlorida Circuit Court, 15th Judicial Circuit). 3. In December 2009, Epstein brought a vendetta action against me

itution in Florida. Subsequently, Bradley James Edwards, a Florida lawyer, brought civil actions on behalf of several girls alleging molestation by Epstein while they were minors. Jane Doe v. Jeffrey Epstein, (08- 80893)(United States District Court, S.D. Fl.); E v. Jeffrey Epstein (Case No. 502008CA

endant's alleged sexual abuse of her when she was a minor. The subpoenas seek the production of "(a)11 taped conversations between George Rush and Jeffrey Edward Epstein, including telephone recordings, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the t

n between George Rush, one of its reporters, and Jeffrey Epstein, and granting such other relief as the C

d civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7,

man Lewis LLP, with offices at 228 East 45th Street, in Manhattan, New York. I submit this Affirmation in support of motion for an order pursuant to CPLR 3102(e) for production of a certain tape recording of an interview by George Rush, a Daily News reporter, of Jeffrey Epstein, a party to an action pending

1 FACTUAL AND PROCEDURAL BACKGROUND 3 I. EPSTEIN'S SEXUAL ABUSE OF MINOR GIRLS AND HIS CRIMINAL PROSECUTION 3 II. THE CIVIL ACTIONS AGAINST EPSTEIN FOR SEXUAL MOLESTATION OF MINOR GIRLS AND ASSERTION OF THE FIFTH AMENDMENT BY EPSTEIN AND OTHERS 4 III. THE DAILY NEWS' RECORDED CONVERSATON WIT

in Detail to Others 11 II. ANY QUALIFIED JOURNALIST'S PRIVILEGE OF THE DAILY NEWS IS OVERCOME BY JANE DOE'S CLEAR AND COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE AND LACK OF REMORSE 13 i EFTA00728062 A. The Epstein Interview is Highly Material and Relevant to Edwards' De

MIGHT OTHERWISE ATTACH TO THE TAPE RECORDING OF JEFFREY EPSTEIN BY PLAYING THE TAPE TO THREE PEOPLE AND

cluded in the first full paragraph attributed to Mr. Epstein at page 15 of the transcript." Id. at 5. 7 EFTA

passim N.Y. Civil Rights Law § 79-h(g) (McKinney 2010) 11, 14 iv EFTA00728065 PRELIMINARY STATEMENT Bradley Edwards seeks an order pursuant to CPLR 3102(e) for production of a tape recording of a conversation between a Daily News reporter and billionaire Jeffrey Epstein concerning Epstein's molestatio

mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat

alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were

made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar

d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi

2093 (S.C. Ct. Common Pleas July 20, 1994) 29 Yoder v. Adriatic°, 459 So.2d 449 (Fla. Dist. Ct. App. 1984) 18 STATUTES CPLR 3101(a)(4) passim CPLR 3102(e) 11, 1 2 MI Civil Rights Law § 79-h passim OTHER AUTHORITIES Carl C. Monk, Evidentiary Privilege for Journalists' Sources: Theory and Statutory

(e) to compel production of an audio tape of an off-the-record conversation, incorrectly described in motion papers as an "interview," between one Jeffrey Epstein and New York Daily News, LP (Daily News)' reporters George Rush and Martin Dunn, for use in a Florida action. In the underlying Florida action, Eps

ein and New York Daily News, LP (Daily News)' reporters George Rush and Martin Dunn, for use in a Florida action. In the underlying Florida action, Epstein (Epstein) sues lawyer Bradley James Edwards (Edwards) asserting claims based on purported involvement in a Ponzi scheme including fraud, civil rack

in motion papers as an "interview," between one Jeffrey Epstein and New York Daily News, LP (Daily News)

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK I.A.S. PART 17 X In the Matter of the Application of BRADLEY JAMES EDWARDS SEEKING CPLR 3102(e) ORDER FOR DAILY NEWS, ■. TO PRODUCE TAPE RECORDING X Index No. 112345/10 EMILY JANE GOODMAN, J.S.C.: Bradley, a Florida lawyer, moves pursuant

Exhibit "I" is a true and correct copy of the Non-Prosecution Agreement between the United States Attorney for the Southern District of Florida and Jeffrey Epstein, executed by Epstein on September 24, 2007. 12. Annexed hereto as Exhibit "J" is a true and correct copy of the Affidavit of George Rush, sworn to

rect copy of the Non-Prosecution Agreement between the United States Attorney for the Southern District of Florida and Jeffrey Epstein, executed by Epstein on September 24, 2007. 12. Annexed hereto as Exhibit "J" is a true and correct copy of the Affidavit of George Rush, sworn to April 6, 2010, that

" is a true and correct copy of the Complaint of Jeffrey Epstein, with Exhibits 1 and 2, that was filed De

rneys for Daily News, L.P. ("Daily News"). I submit this affirmation in opposition to the motion of Bradley James Edwards for an order, pursuant to CPLR 3102(e), compelling the Daily News to produce a certain audio recording. 2. The grounds for denying Edwards' motion are fully set forth in the accompanyi