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motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein.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ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

in's complaint alleges claims against Rothstein and Edwards for fraud, violation of Florida's civil racketeering statute and violation of Florida's Civil Remedies for Criminal Practices Act. Ponzi Scheme Complaint ¶¶ 26, 54-68, 73-78.4 The complaint also pleads an abuse of process claim alleging that after the thrce sex abuse suits were

o deposition), and Mr. Edwards' clients (L.M., E.W. and Jane Doe). Source: Florida Standard Jury In

and engaging in improper litigation tactics in order to promote and sustain that Ponzi scheme. Epstein brought claims for violations of Florida 's Civil Remedies for Criminal Practices Act, violations of Florida's Racketeer Influenced and Corrupt Organization (RICO), abuse of process, fraud and conspiracy to commit fraud. Rothstein di

d others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (herei

three defendants -7- EFTA00612489 including: Edwards, and his then partner Scott Rothstein. The four counts alleged: (1) violations of Florida's Civil Remedies for Criminal Practices Act; (2) violations of Florida's Racketeering Influenced and Corrupt Organization Act; (3) abuse of process; and (4) fraud. Epstein's complaint set for