Epstein Secrets

submits this memorandum of law in opposition to Bradley J. Edwards' motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillary discovery proceeding, a civil litigant —

ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

cGarry v. University ojSan Diego, 64 Cal. Rptr. 3d 467 (Cal. Ct. App. 2007) 28, 29 iii D14'71584534593 3970112-000042 EFTA00596452 O'Connor v. Donaldson, 422 U.S. 563 (1975) 13 O'Neill v. Oakgrove Coast. Inc., 71 1.2d 521, 528 ad 1 (1988) 1, 2, 22 People ex reL Scott v. Silverstein, 412 II2d 6

-attacked-knife-I> (11/23, Mordock, 492K) reports W. Samuel Patten, who was "a key witness" in special

Bloomberg <https://www.bloomberg.coin/news/articles/2020-11-23/u-k-weighs-huawei-installation-ban-next- year-to-sway-lawmakers?smd=premium> (11123, Donaldson, Seal, 4.73M) reports the UK "is considering a ban on the installation of Huawei Technologies Co. 50 equipment as soon as next year to appease lawma

e Washington Times (11/23, Mordock, 492K) reports W. Samuel Patten, who was "a key witness" in specia

k had been captured on an FBI wiretap." EFTA00149126 CYBER DIVISION UK Said To Be Considering Huawei Installation Ban In 2021. Bloomberg (11/23, Donaldson, Seal, 4.73M) reports the UK "is considering a ban on the installation of Huawei Technologies Co. 5G equipment as soon as next year to appease lawm

ch are clearly related to his injury." Dr. Scott W. Sautter, neurospsychologist, evaluated the claima

111. Accord Ed Schory & Sons, Inc. v. Society Natl. Bank (1996), 75 Ohio St. 3d 433, 440, 1996 Ohio 194, 662 N.E.2d 1074; Natl. City Bank, Akron v. Donaldson (1994), 95 Ohio App.3d 241, 244-245, 642 N.E.2d 58. "'Generally, the parol evidence rule prohibits the admission of evidence to contradict or add t

an, J.L. & Loftus, E.F. (1974). Retrieval of words from well-learned sets. Journal of Experimental Psychology, 102, 1085-1091. Loftus, E.F. & Cole, W. (1974). Retrieving attribute and name information from semantic memory. Journal of Experimental Psychology, 102, 1116-1122. Loftus, E.F., Wiksten,

c better than paper? I can't remember. Psychological Methods. 11, 119-122. Davis, D., & Loftus, E.F. (2006) Psychologists in the forensic world. in Donaldson, S. I., Berger, D.E. & Pezdek, K. (Rig.). Applied psychology: New frontiers and rewarding careers. Mahwah, NJ: Erlbaum., p 171-200. Loftus, E.F.,

urtroom # West Palm Bea U So. Co. Complex 200 W. Atlantic Avenue Room # Delray Beach No. Co. Co

ghter's friends. They told her they heard she was handing hanging around with Mr. Byron Elrod in an area known as 'The Cut" which is located off Old Donaldson and Highway 140. "The Cut" is a known drug area in the county. I completed a missing person's checklist and obtained a recent picture of the juveni