Epstein Secrets

y Edwards, et al. (Case NO. 502009CA040800XXXXMBAG); and upon reading the Affirmation of Robert Y. Lewis dated September 15, 2010, the Affidavits of Bradley James Edwards and Michael Fisten both dated September 14, 2010, the Memorandum of Law dated September 16, 2010, and all the exhibits attached thereto, and it appe

APPLICATION FOR CPLR 3102(E) ORDER Index No. TO PRODUCE TAPE RECORDING x NOTICE OF MOTION PLEASE TAKE NOTICE that upon the annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14, 2010, the Affirmation of Robert Y. Lewis dated September 15, 2010, the

tein (Case No. 502008CA028058XXXXMBAB)(Florida Circuit Court, 15h Judicial Circuit). 3. In December 2009, Epstein brought a vendetta lawsuit against Edwards and others alleging abuse of process in connection with those civil actions. Jeffrey Epstein v. Bradley Edwards, et al. (Case No: 502009CA040800XXX

n and me, which at bottom concerns his sexual abuse of girls while they were minors, the very topic of the recorded conversation. Jeffrey Epstein v. Bradley Edwards, et al. (Case NO. 502009CA040800XXXXMBAG)(Florida Circuit Court, 15th Judicial Circuit). I. The Sexual Molestation Actions Against Epstein and His

IAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502009CA040800X)MMBAG JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually. BRALacpY J. EDWARDS, individually, and M., individually, Defendants. 17:3; t —CA c->"5-7, cn. % t 0 Cn -2 ° ! C' (n • • rn ORDER ON DEFENDANT'S MOTION TO A

t 0 Cn -2 ° ! C' (n • • rn ORDER ON DEFENDANT'S MOTION TO APPOINT COMMISSIONER r - THIS CAUSE, having come on before the Court upon Defendant Bradley J. Edwards's Motion to Appoint Commissioner, and the Court having heard argument of counsel, and being otherwise duly advised in the premises, it is, ORDERED an

that Epstein had apparently written about the case. 13. I have been extensively involved in the investigation attempting to support Jane Doe's and Brad Edwards's claims against Epstein. As part of my duties in investigating the cases, I have attempted to locate all recorded statements made by 3 EFTA0072847

ecorded call. 7. Rush had previously spoken to attorney Edwards (the attorney representing Jane Doe) and me conc

wis LLP for the purpose of taking the deposition duces tecum of the Records Custodian of the New York Daily News pursuant to a commission issued by the Circuit Court of the 15th Judicial Circuit In and For Palm Beach County, Florida for use in the case of Jeffrey Epstein v. Bradley Edwards, et al. (Case NO. 502009CA040800XX

roward Blvd., Ste. 700 Ft. Lauderdale, FL 33301 Bradley J. Edwards, Esq. 425 N. Andrews Ave., Ste. 2 Ft. Lauderdale, FL

is case arises from Plainfiffitounter-Defendant Jeffery Epstein's lawsuit against Defendants/Counter-Plaintiffs Bradley Edwards and Scott Rothstein. Edwards then countersued Epstein for malicious prosecution. Epstein voluntarily dismissed his initial suit On Augustin 2011, Epstein served an Offer of Jud

ger & 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esquire 1 East Broward Blvd. Suite 700 Ft. Lauderdale FL 301 Bradley J. Edwards Esquire Staftefil Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue Suite 2 Ft. Lauderdale, FL 33301 Fred ' de I Financial Plaza S

, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Btoward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradle J. Edwards Es . brad Fan a e eissing 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es . tnancta aza Suite 2612 Fort Lauderda

N, against Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, and are not part of the legal claims brought by Defendant/Counte•-Plaintiff, BRADLEY EDWARDS, individually, against Plaintiff/Counter-Defendant, JEFFREY EPSTEIN. However, this Proposal is intended to resolve all such claims if available.

tion entitled JEFFREY EPSTEIN v. SCOTT R0THSTEIN, individually, and BRADLEY J. EDWARDS, individually, Case No. 502009CA040800)OOaM13-AO, pending in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida ("the Action"). As further consideration, I agree not to disclose the details of this releas

N, against Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, and are not part of the legal claims brought by Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, against Plaintiff/Counter-Defendant, JEFFREY EPSTEIN. However, this Proposal is intended to resolve all such claims if available.

Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel, hereby serves this Proposal for Settlement upon Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ, P. 1.442: 1. This Proposal is being made pursuant to §768.79, Fla. Stat. and Fla. R

. SCOTT ROITHSTETN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DE

ction entitled JEFFREY EPSTEIN v. SCO7T ROTHSTEIN, individually, and BRADLEY J. EDWARDS, Individually, Case No 502009CA040800)OCOCMB-AG, pending in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida ("the Action"). As further consideration, I agree not to disclose the details of this releas

Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel, hereby serves this Proposal for Settlement upon Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ. P. 1.442: 1. This Proposal is being made pursuant to §768.79, Fla. Stat. and Fla. R

s Motion requesting that the Court enter an Order of entitlement to costs and attorneys' fees against Defendant/Counter- Plaintiff Bradley Edwards ("Edwards"). In support of thereof, Epstein states as follows: INTRODUCTION; On August 25, 2011, Epstein served an Offer of Judgment on Edwards in the amoun

ndant, JEFFREY EPSTEIN, against Defendant/Counter- Plaintiff, BRADLEY EDWARDS, individually, and the claims brought by Defendant/Counter- Plaintiff, BRADLEY EDWARDS, Individually, sinst Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, with prejudice, each party to bear its own costs and attorney's fees. The part

tion entitled JEFFREY EPSTEIN v. SCOT?' ROTHSTEIN, individually, and BRADLEY'. EDWARDS, individually, Case No. 502009CA040800,OOOCMB-AG, pending in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida ("the Action"). As further consideration, I agree not to disclose the details of this releas

ail: Paul G. Cassell, Esq. (Motion for Pro Hac Vice Admission Pending) 332 S. 1400 E. Salt Lake Ci Utah 84112 Tel.: Fax: E-Mail Counsel for Bradley James Edwards EFTA00728061 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 FACTUAL AND PROCEDURAL BACKGROUND 3 I. EPSTEIN'S SEXUAL ABUSE OF MINOR GIRLS AND HIS

EPSTEIN ABOUT HIS SEXUAL MOLESTATION AND ITS DISCLOSURE OF THE CONTENTS OF RECORED CONVERSATION TO THIRD PARTIES 5 IV. EPSTEIN'S ACTION AGAINST EDWARDS AND EDWARDS' COUNTERCLAIM 7 V. FEDERAL COURT ORDER FOR PRODUCTION OF THE RECORDING ? VI. EPSTEIN'S INVOCATION OF THE FIFTH IN THE EDWARDS ACTIO

atutes 18 U.S.C. § 2255 4 CPLR 3102(e) 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 E

ther leads to obtain this information in other ways have been exhausted. Edwards Aff. ¶ 25. On August 3, 2010, the court presiding over the case -- the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida — granted Edwards' Motion to Appoint a Commissioner in New York to take the deposition duces

N, against Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, and are not part of the legal claims brought by Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, against Plaintiff/Counter-Defendant, JEFFREY EPSTEIN. However, this Proposal is intended to resolve all such claims if available.

Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel, hereby serves this Proposal for Settlement upon Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ. P. 1.442: 1. This Proposal is being made pursuant to §768.79, Fla. Stat. and Fla. R

v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DE

Action entitled JEFFREY EPSTEIN v. SCOTT ROTHSTEIN, individually, and BRADLEY J EDWARDS, individually, Case No. 502009CA040800XXXXMB-AG, pending in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida ("the Action"). As further consideration, I agree not to disclose the details of this releas

N, against Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, and are not part of the legal claims brought by Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, against Plaintiff/Counter-Defendant, JEFFREY EPSTEIN. However, this Proposal is intended to resolve all such claims if available.

Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel, hereby serves this Proposal for Settlement upon Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ, P. 1.442: 1. This Proposal is being made pursuant to §768.79, Fla. Stat. and Fla. R

. SCOTT ROITHSTETN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DE

ction entitled JEFFREY EPSTEIN v. SCO7T ROTHSTEIN, individually, and BRADLEY J. EDWARDS, Individually, Case No 502009CA040800)OCOCMB-AG, pending in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida ("the Action"). As further consideration, I agree not to disclose the details of this releas