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

passim N.Y. Civil Rights Law § 79-h(g) (McKinney 2010) 11, 14 iv EFTA00728065 PRELIMINARY STATEMENT Bradley Edwards seeks an order pursuant to CPLR 3102(e) for production of a tape recording of a conversation between a Daily News reporter and billionaire Jeffrey Epstein concerning Epstein's molestatio

and Jeffrey Epstein, executed by Epstein on September 24, 2007. 12. Annexed hereto as Exhibit "J" is a true and correct copy of the Affidavit of George Rush, sworn to April 6, 2010, that was submitted in the proceeding entitled In re 2 DWT 15631739v2 3970112-000042 EFTA00596486 Application to Quash S

e and correct copy of the Judgment against Scott W. Rothstein that was entered June 9, 2010 in the cr

rneys for Daily News, L.P. ("Daily News"). I submit this affirmation in opposition to the motion of Bradley James Edwards for an order, pursuant to CPLR 3102(e), compelling the Daily News to produce a certain audio recording. 2. The grounds for denying Edwards' motion are fully set forth in the accompanyi

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motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein.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ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

2093 (S.C. Ct. Common Pleas July 20, 1994) 29 Yoder v. Adriatic°, 459 So.2d 449 (Fla. Dist. Ct. App. 1984) 18 STATUTES CPLR 3101(a)(4) passim CPLR 3102(e) 11, 1 2 MI Civil Rights Law § 79-h passim OTHER AUTHORITIES Carl C. Monk, Evidentiary Privilege for Journalists' Sources: Theory and Statutory

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,

man Lewis LLP, with offices at 228 East 45th Street, in Manhattan, New York. I submit this Affirmation in support of motion for an order pursuant to CPLR 3102(e) for production of a certain tape recording of an interview by George Rush, a Daily News reporter, of Jeffrey Epstein, a party to an action pending

ersation, incorrectly described in motion papers as an "interview," between one Jeffrey Epstein and New York Daily News, LP (Daily News)' reporters George Rush and Martin Dunn, for use in a Florida action. In the underlying Florida action, Epstein (Epstein) sues lawyer Bradley James Edwards (Edwards) asser

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK I.A.S. PART 17 X In the Matter of the Application of BRADLEY JAMES EDWARDS SEEKING CPLR 3102(e) ORDER FOR DAILY NEWS, ■. TO PRODUCE TAPE RECORDING X Index No. 112345/10 EMILY JANE GOODMAN, J.S.C.: Bradley, a Florida lawyer, moves pursuant