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E. The Present Motion to Compel I0 ARGUMENT 11 I. EDWARDS MAY NOT RELY ON THE VACATED DISTRICT COURT ORDER FROM THE JANE DOE ACTION 12 II. EDWARDS FAILS TO MEET THE REQUIREMENTS FOR DISCOVERY OF A NON-PARTY UNDER CPLR 3101(a) 14 A. The Epstein Interview Does Not Have Heightened Relevance to
a deposition in one of the now-settled suits by implying that "he did not recognize" reporter Rush. Moving Br. at 17; see also Moving Affidavit of Bradley James Edwards, sworn to Sept. 14, 2010 ("Edwards Aft"), ¶ 22. Besides being farfetched and factually unsupported, Edwards' apparent desire to attack Epstein's cr
pstein sex abuse litigation, as even a quick Google search reveals. See. e.g., Heiress Quizzed in Sex Suits. M. POST, Oct. 12, 2009 ("Florida lawyer Brad Edwards. who represents three of the 'Jane Does' who are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how
lawyers and others close to the case — including attorney Edwards — who could provide tips and information to assi
't 2006) 22 Tannenbaum v. City of New York, 30..3d 357, 819 Eig2d 4 (1st Dep't 2006) 15, 19 US. v Burke, 700 F.2d 70 (2d Cir. 1983) 26 U.S v. Marcos, 1990 WL 74521 ( June I, 1990) 26 U.S. v. Munsingwear, 340 U.S. 36 (1950) 13 Ulrich v. Coast Dental Servs., Inc., 739 So.2d 142 (FIa. Dist. C
me highflying societies in Manhattan and Palm Beach - socialized together in the past." Another report from The Daily Caller (7/8, News, 716K) says Bradley Edwards, a lawyer who represented Epstein's victims, "stated in court documents that Trump had barred Epstein" from Mar-A-Lago "because Epstein sexually as
The Daily Caller (7/8, News, 716K) says Bradley Edwards, a lawyer who represented Epstein's victims, "st
add the controversial citizenship question to the Census." Pelosi: Citizenship Question's Purpose Is To "Make America White Again." The Hill (7/8, Marcos, 2.98M) reports House Speaker Pelosi "argued Monday that...Trump's push to include a citizenship question on the 2020 census is an effort to 'make A
S BRIEFING FRIDAY, NOVEMBER 1, 2019 5:00 AM EDT Wray Discusses Threats To 2020 Election Security At House Committee Hearing. ExecutiveGov (10/31, Edwards) reports, "FBI Director Christopher Wray said he expects threat actors from countries like Russia and China to cause possible interference in the U.
ensures] Trump's right to participate in the latter stage of the proceedings unless he tries to block witnesses from testifying." The Hill (10/31, Marcos, 2.98M) reports House Speaker Pelosi "presided over the chamber during the vote, a step meant to underscore the significance of the moment. During h
06:58 I Levy. 18/02/10 16. hammas terror 07:06 I mike. 18/02/10 17. No, it's not troubling 07:15 I David. 18/02/10 18. What lessons? 07:26 I Edward. 18/02/10 19. #11 David 07:58 l Walter. 18/02/10 20. Dubai's vaunted police Mork 07:59 I Cipora Julienne 18/02/10 Kohn. 21. If Mosso(' isn't r
ns from London. 10:12 David Nigel 18/02/10 Graham.. 31. Martin #21 _ yes, that is my take also 10:121dana. 18/02/10 32. bye bye Israel! 10:521 Marcos. 18/02/10 33. To all cringers here : 2 Brits bombed 10:561Absolute 18/02/10 cofee shop "Mike" in TA Sweden_ "does the response require endange
insists he is a "third-party owner," claiming he purchased the Lamborghini for $150,000. Two Arrested After Impersonating FBI Agents Patch (08/06, Edwards) reported that New York State Police have arrested Wei Baoguo, 34, and Yu Sheng Gui, 38, both of Brooklyn, for impersonating FBI agents as part of a
President Donald Trump said, The entire nation is praying for the victims and their families!' He called the suspect 'horrible The Guardian (08/06, Marcos) reported that an FBI spokesperson said that their Savannah satellite office "is aware of the incident at Fort Stewart and is coordinating with Army
Entities connected to both Bradley Edwards and Marcos

Jeffrey Epstein
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
Donald Trump
PERSON
Salt Lake City
LOCATION
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Alexander Acosta
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSONDarren Indyke
PERSON