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

ep. 1413 (S.D.N.Y. 2004) 2 iii EFTA00728011 Eagle Hosp. Physicians. LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) 7 Gonzales v. National Broad. Co., 194 F.3d 29 (2d Cir. 1999) 2, 3 Hill v. Federal Trade Comm'n, 124 F.2d 104 (5th Cir. 19431) 13 In re Aoplication to Ouash Subpoena to Nat'

tions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in Epstein v. Rothstein, Edwards No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/23947743/121

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defendants. 50 2009 cAo 03 (JUI0X04B COMPLAINT COPY RECEIVED FOR FILING

eeks are (1) highly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 19

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

ep. 1413 (S.D.N.Y. 2004) 2 iii EFTA00207334 Eagle Hosp. Physicians. LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) 7 Gonzales v. National Broad. Co., 194 F.3d 29 (2d Cir. 1999) 2, 3 Hill v. Federal Trade Comm'n, 124 F.2d 104 (5th Cir. 19431) 13 In re Aoplication to Ouash Subpoena to Nat'

tions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in Epstein v. Rothstein, Edwards & L.M. No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/2394774

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defendants. 50 2009 cAo 03 (JUI0X04B COMPLAINT COPY RECEIVED FOR FILING

eeks are (1) highly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 19