Epstein Secrets

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

Y EDWARDS, individually, , going to hoar? boranciants/countor -Plaintiffs. 10 THE COURT: Yes. My understanding as I left / 11 Was going to be Edwards' Second Supplement to TRANSCRIPT OF PROCEEDINGS 12 Motion in Lunine Addressing Scope of Admissible I) Evidence, and of course in that same vein

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

le used not only in 2 And ono of the factors hero is a very wall- 2 describing certain part➢ of the task that was 3 recognised principle of the Bigelow case, which la 3 as➢igned to Dr. Jan➢en or in our argument regarding 4 a V.S. Supreme Court case, that says that ono of 4 the nature of the dama

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

last wok just 4 and Any Reference to Docunenta Containing 4 So my suggestion to your Honor is that wo deal 5 Privileged Materials, Listed on Edwards' Privilege o first with the procedural issue because, as I said, 4 Log. 4 that will narrow issue. significantly. And then / MR. SCAROER: Yes,

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

le used not only in 2 And ono of the factors hero is a very wall- 2 describing certain part➢ of the task that was 3 recognised principle of the Bigelow case, which la 3 as➢igned to Dr. Jan➢en or in our argument regarding 4 a V.S. Supreme Court case, that says that ono of 4 the nature of the dama

eutsche Asset Mgmt, Inc. v. Callaghan, No. 01 Civ 4426 CBM, 2004 WL 758303 16 Dillon v. City of New York, 704 N.Y.S.2d 1, 5 (1st Dep't 1999) 8,18 Edwards v. Great Northern Ins. Co., No. 03 CV 2947 (NG) (RML), 2006 WL 2053717, (E.D.N.Y. July 21, 2006) 18 Foretich v. Capital Cities/ABC, Inc., 37 F.3d

my defense, or fairly arises out of the charges he has made against me." William Blake Odgers, A Digest of the Law of Libel and Slander (1st Am. ed. Bigelow 1881). New York, along with numerous other jurisdictions6 and the Restatement (Second) of Torts, recognizes a qualified privilege to respond in sel