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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
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 692 (III. App. Ct. 1980), rev d on o
offenses. The judge left open what the possible remedy could be.a3-9) Virginia Giuffre v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards and Paul G. Cassell meant for inclusion in the Crime Victims 59 Where are they pow? The Right-rAct lawsuit, Virginia _Giuffre (then known as 41.
n a December 2014 Florida court filing by Bradley Edwards and Paul G. Cassell meant for inclusion in the C
whilst she exceeded the prescribed concentration • of alcohol, reading being 0.050. Police At about 11.32 pm on Tuesday, 19th May, 2015, Police (O'Neill/While) were on mobile uniform patrol when they stopped the accused who was driving a Mitsubishi sedan south along The Terrace, Port Pixie for a ra
ellon Foundation," and Hazel Ruth EFTA00148339 Edwards, who chairs the Department of Architecture at How
gheta organized crime network." Another suspected drug trafficker, "Vincenzo Pasquino, was arrested along with" Morabito. The New York Post (5/25, O'Neill, 7.45M) and BBC World News (UK) (5/25, 6.59M) publish similar articles. OTHER FBI NEWS Senate Confirms Kristen Clarke As Head Of DO) Civil Rights
rity. The panel will be moderated by Safa Shahwan Edwards, Deputy Director of the Cyber Statecraft Initiat
zerova), NBC News (07/30, Sackur), USA TODAY (07/30, Bacon, Ortiz), The Hill (07/30, Sforza), Newsweek (07/30, Broadcast), the New York Post (07/30, O'Neill), and The Daily Beast (07/30, Quinn). West African Leaders Threaten Force Against Niger Plotters The Wall Street Journal (07/30, Hinshaw, Faucon) r
at the Andrew Mellon Foundation," and Hazel Ruth Edwards, who chairs the Department of Architecture at Ho
ngheta organized crime network." Another suspected drug trafficker, "Vincenzo Pasquino, was arrested along with" Morabito. The New York Post (5/25, O'Neill, 7.45M) and BBC World News (UK) (5/25, 6.59M) publish similar articles. EFTA00161572 OTHER FBI NEVidrs Senate Confirms Kristen Clarke As Head O
e Stewart Gloster, Deputy National Cyber Director for Technology and Ecosystem Security. The panel will be moderated by Safa Shahwan EFTA00164373 Edwards, Deputy Director of the Cyber Statecraft Initiative, Atlantic Council. We hope you can join us as we discuss the scope and strategy for unleashing A
zerova), NBC News (07/30, Sackur), USA TODAY (07/30, Bacon, Ortiz), The Hill (07/30, Sforza), Newsweek (07/30, Broadcast), the New York Post (07/30, O'Neill), and The Daily Beast (07/30, Quinn). West African Leaders Threaten Force Against Niger Plotters The Wall Street Journal (07/30, Hinshaw, Faucon)
London e . 0207-622 & 8738 (11) EFTA00191487 Edwards, Andrew & Tfti 9 ~ H uth 0 07-2354121 (h) p
00191531 O'Dora Mr Carletto 13 West Place tlisidon al 7-2100153 (h 02 7-4 ) 9 4939 (w) 0860 35 56 8 655Park Avenue Ne 001 pig ) (h) O'Neill, Louis 230 E. 15lh Street NY 10003 Ems t s Em . lumn .or (Hm)001 (w) Oates, Simon 0207-7241010 (w) Oates, Tom giersrat 1;1;4 O)ore, YInka
as friends. Or they are the kind who, like John Edwards, seem to be one thing but then turn out to have a
ote. The President talked of the election breaking the "fever" in Washington. "We didn't expect the floodgates would open and Boehner would be Tip O'Neill to our Reagan," Dan Pfeiffer, a senior adviser to the President, said. But reelection, he thought, had "liberated" Obama. The second Inaugural Addr
on Schwartz, Eric Client N N 6/9/2017 rtson Edwards Anker, Nina S. Client N N Douglas Robertson C
s Robertson Estate Of Abdel H Afghani Client Douglas Robertson Villani, Cynthia M. Client N Douglas Robertson Schoen, Pamela Client N rtson O'Neill, DiManno & Kelly Client Douglas Robertson Robert C.Doherty Irrevocable Trust 2/2017 Douglas Robertson Caymen Partners I LLC Client N Douglas
ent's charges, this Court assured both adequate notice of the allegations against the defendants and ample opportunity for a meaningful de- fense. Edwards, 430 A.2d at 1339-41. 4. Even in full-blown criminal trials, the Sixth Amendments Confrontation Clause poses the only constitutional objection to
) the strength of t e evidence upon which the pretrial detention was based." tired States Milian, 4 F.3d 1038, 1043 (2d Cir. 1993); United States O'Neill, 52 F. Supp. 2d 954, 960 (ED. Wis. 1999)(to get to first base on this issue, the defendant must show that either the prosecution or the court has u
Entities connected to both Bradley Edwards and O'Neill

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
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
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATION
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSONMartin Weinberg
PERSON