Epstein Secrets

stantial punitive damages. In the fall of 2009, Michael Fisten, an investigator working for Edwards, heard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the recording for her and t

9 15 fn. 2 945 So.2d 1246 (Fla. 2006) 15 E.W. v. Epstein, Case No. 502008CA028XXXMBAB (Florida

102(E) ORDER TO PRODUCE TAPE RECORDING x I Index No. MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR CPLR 3102(E) ORDER TO PRODUCE TAPE RECORDING Robert Y. Lewis Freeman Lewis LLP 228 East 45th Street, 17th Floor New York. New York 10017 Tel: Fax: E-mail: Paul G. Cassell, Esq. (Motion for Pro Hac Vice A

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motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein.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ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

sion to the Second Circuit. While the appeal was pending, the Jane Doe Action (as well as the ■. and E.W. suits) settled. See Moving Affirmation of Robert Y. Lewis, dated Sept. 15, 2010 ("Lewis Aff."), ¶ 7. The Daily News and Rush then moved the Second Circuit to vacate the District Court decision. 8 DWT 1511

y in Interest-Appellee. AMENDED ORDER Docket No. 10-2438 (L) 10-2573 (con) IT IS HEREBY ORDERED that the motion by Appellants Daily News L.P. and George Rush to d ism i ss the consolidated appeals as moot and to vacate the district court orders of May 21,2010 and June 25, 2010 is GRANTED. FOR THE COURT,

e annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14, 2010, the Affirmation of Robert Y. Lewis dated September 15, 2010, the accompanying Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclai

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sition papers, if any, are to be served on or before October 1, 2010. Dated: September 16, 2010 New York, New York FREEMAN LEWIS LLP, /MN/ By: Robert Y. Lewis 228 East 451h Street 17i° Floor New York, New York 10016 (212) 980-4050 Attorneys for Petitioner EFTA00728884 SUPREME COURT OF THE STATE OF N

on: DAILY NEWS, L.P. Anne B. Carroll (AC-5322) Deputy General Counsel 450 West 33"I Street, 3n° Floor 10001 Attorneys for Daily News, L.P. and George Rush A copy was also sent via first-claim mail to Jack Alan Goldberger ATfERBURY GOLDBERG & WEISS, P.A. 250 Australian Avenue South, Suite 1400 FL 33

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 Admission Pending) (: " 4—'4 ;tel

deposition duces tecum, and at said deposition 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

e annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14, 2010, the Affirmation of Robert Y. Lewis dated September 15, 2010, the accompanying Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclai

: Pate Law Finn - U.S. Virgin Islands - USVI Epstein Estate - Victims Date: Thu, 16 Jan 2020 16:56:44 +0000 (USANYS)" Consider drinking more local bush tea made from Caribbean and African herbs, plants and trees? From: Sent: Thursday, January 16, 2020 11:54 AM To: (USANYS) Cc: Subject: RE: Pate

rds , Diane Aldrich Robert Glassman Sigrid McCawley EFTA00074243 Jennifer Freeman I>, "Jason P. Amala" >, Meredith Schultz "James R. Marsh" "Robert Y. Lewis" "Michael T. Pfau" Subject: RE: Pate Law Firm - U.S. Virgin Islands - USVI Epstein Estate - Victims Dear Justice Warriors, I write to put many of

deposition duces tecum, and at said deposition 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

e annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14, 2010, the Affirmation of Robert Y. Lewis dated September 15, 2010, the accompanying Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclai