Epstein Secrets

nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. Kam incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing req

more so in light of Epstein's admission in his lawsuit against M. and others that he that he was "one of M's many `Johns.— See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co.. Dec. 7, 2009) at 146(a), pertinent pages annexed as Ex. E to the C

LIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBPOENAS SERVED ON THEM IN A FLORIDA LITIGATION OR IN THE ALTERNATIVE FOR A PROTECTIVE ORDER Anne B. Carroll, Esq. The Daily News L.P. 450 West 33"I Street New York. NY 10001-2631 Laura R. Handman. Esq. Davis Wright Tremaine LLP 1633 Broadway New York

CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502009CA040800X)MMBAG JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually. BRALacpY J. EDWARDS, individually, and M., individually, Defendants. 17:3; t —CA c->"5-7, cn. % t 0 Cn -2 ° ! C' (n • •

0X)MMBAG JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually. BRALacpY J. EDWARDS, individually

ngs, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the testimony of George Rush and Anne B. Carroll, a Vice President and General Counsel of Daily News, L.P. (Carroll Decl., Apr. 7, 2010, Exs. A & B.) In the alternative, the subpoenaed parties see

nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. 1° Doe incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing

ges in his complaint against M. 13 12 The document is available online at http://www.scribd.com/doc/23947743/121009-epstein. "Complaint, Epstein v. Rothstein et al., II 42(h)(i) ("M. testified that she ... worked at various strip clubs; is an admitted prostitute and call girl; has a history of illegal dru

LIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBPOENAS SERVED ON THEM IN A FLORIDA LITIGATION OR IN THE ALTERNATIVE FOR A PROTECTIVE ORDER Anne B. Carroll, Esq. The Daily News L.P. 450 West 33rd Street N 10001-2631 Laura R. Handman, Esq. Davis Wright Tremaine LLP 1633 Broadway i rlia 10019 EFTA

ifferent litigation in which he himself — not Jane Doc — is a party. Specifically, in January 2010 the managing partner of Edwards' former law firm, Scott Rothstein, pled guilty and was sentenced to 50 years in prison for a massive "Ponzi" scheme in which he defrauded investors of $1.2 billion by convincing the

brought a civil lawsuit against Edwards in Florida state court in which he alleges that Edwards was involved in, or knew or should have known about, Rothstein's Ponzi scheme, and pleads claims against Edwards for fraud and violation of Florida's racketeering statute as well as an abuse of process claim al

Robert D. Balin Victor Hendrickson 1633 Broadway — 27th Floor New York, NY 10019 Tel: (212) 489-8230 Attorneys for Daily News,.. Of Counsel: Anne B. Carroll Deputy General Counsel Daily News, 450 West 33rd Street New York, NY 10019 Tel: (212) 210-2341 922 A.2d at 1275 (2007) (noting in dicta that no