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,

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon

ION FOR CPLR 3102(E) ORDER ORDER TO PRODUCE TAPE RECORDING Pursuant to CPLR 3102(e) Index No. x An Application having been made by Petitioner Freeman Lewis LLP for the purpose of taking the deposition duces tecum of the Records Custodian of the New York Daily News pursuant to a commission issued by the Cir

WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS 5 11. THE QUALIFIED JOURNALIST PRIVILEGE IS OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MINOR GIRLS AND HIS LACK OF REMORSE 8 A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil

Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores

S OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MI

le sources" since "the record is quite clear that Mr. Epstein has regularly been asserting, and will continue

foregoing reasons, the Court should order the Daily News to produce the recording. New York, New York November I I, 2010 Respectfully submitted, Freeman Lewis LLP '4/i By: Robert Y. Lewis 228 East 45" Street, 17'h Floor New York, New York 10017 Tel: Fax: Paul G. Cassell (Motion for Pro Hac Vice Admissi

position to produce a certain audio tape in Daily News, L.P.'s custody and control of a conversation between George Rush, one of its reporters, and Jeffrey Epstein, and granting such other relief as the Court deems just. EFTA00601997

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

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

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon

position to produce a certain audio tape in Daily News, L.P.'s custody and control of a conversation between George Rush, one of its reporters, and Jeffrey Epstein, and granting such other relief as the Court deems just. EFTA_R1_02212437 EFTA02725013

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

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

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his Ncw York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon