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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
Cir. 2006) 13 ii Dwr 15845345v) 3970112-000042 EFTA00596451 Flores v. Cooper Tire & Rubber Co., 178 P.3d 1176 (Ariz. CI. App. 2008) Flynn v. NYP Holdings, 235..2d 907, 652M.2d 833 (3d Dep't 1997) Fraser v. Park Newspapers Lawrence Inc., 257..2d 961, 684 .2d 332 (3d Dep't 1999) In re ABC, 189 Mis
served with a subpoena on Sept. 22 at 6:45 p.m. as she was leaving the Clinton Global Initiatives Conference at the Sheraton Hotel. Florida lawyer Brad Edwards, who represents three of the "Jane Does" who are suing Epstein, told Page Six that Maxwell would be questioned over her knowledge of how Epstein pro
t a building he owns, 301 E. 66th St. "Jeffrey rents several apartments there where he keeps his girls, alleged models for the MC2 agency he owns," Edwards said. "But Mark acts like he doesn't even know his brother. He was extremely angry and rude and cursed me out" NEW YORK POST Is e roguing Vidorriad
d. "But Mark acts like he doesn't even know his brother. He was extremely angry and rude and cursed me out" NEW YORK POST Is e roguing Vidorriadcc4 NYP Holdings, Mt NYPOST.COM . WPOSTONUNECOM . rid NEWYCRKFIDST.COM aro twig:narks of WP Whims. Ina Copyright 2009 NTP HiNcings, ID& MI rights rinonwl. Privacy I
more in- formation before deciding whether to quash a plea agreement that put Palm Beach billionaire Jeffrey Epstein be- hind bars for 18 months. Brad Edwards, a Hollywood attor- ney representing three girls who claim they were sexually abused by Epstein, appeared before U.S. District Judge Kenneth Marra
ctims not consulted in plea negotiations From Page Al County Jail, includes an agreement that the federal government will not prosecute Epstein. Edwards said his clients were not con- sulted when the plea deal was negotiated. The girls, each identified public- ly as a "Jane Doe," were about to be na
For Great CffilebRics W:V/`;,-M.CV:::.:1A1f TONIGHT 10/9C boys are brick! over lo gel psyched! Hate NEW YORK POST Is a registered trademark of NYP Holdings, Inc. NYPOST.COM, NYPOSTONLINE.COM, and NEWYORKPOST.COM we trademarks of NYP HoldIngS, Copyright 2007 NYP Holdings, Inc. All rights reserved. .
Entities connected to both Bradley Edwards and NYP Holdings

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONMartin Weinberg
PERSON
Bill Clinton
PERSONRobert C. Josefsberg
PERSON
Virginia Giuffre
PERSON