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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
New York Shield Law would then apply. Ste In re Application to Ouash Subpoena to National Broadcasting Co., 79 F.3d 346. 351. 352 (2d Cir. 1996) ("Graco") (applying New York Shield Law to state claims pending in Massachusetts federal court, noting the relevant standards of that law and the federal pr
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
New York Shield Law would then apply. Ste In re Application to Ouash Subpoena to National Broadcasting Co., 79 F.3d 346. 351. 352 (2d Cir. 1996) ("Graco") (applying New York Shield Law to state claims pending in Massachusetts federal court, noting the relevant standards of that law and the federal pr
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
poena must show that the information sought is ... unobtainable from other sources") (emphasis added); In re Application to Quash Subpoena to NBC ("Graco"), 79 F.3d 346, 353 (2d Cir. 1996) (rejecting lower court's conclusion that "because the material contained in the out-takes sought by Graco is sole
Entities connected to both Scott Rothstein and Graco

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
George W. Bush
PERSON
Michael Fisten
PERSON
Department of Justice
ORGANIZATION
New York
LOCATION
Bernie Sanders
PERSON
Julie K. Brown
PERSON
Harvey Weinstein
PERSON
New York Daily News
ORGANIZATION
Bradley Cooper
PERSON
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATION
The New York Times
ORGANIZATION
Sergey Brin
PERSON
Alberto Gonzales
PERSON
Johns
PERSON
James Patterson
PERSON
McKenna
PERSON