Epstein Secrets

I am a member of Davis Wright Tremaine LLP, attorneys for Daily News, L.P. ("Daily News"). I submit this affirmation in opposition to the motion of Bradley James Edwards for an order, pursuant to CPLR 3102(e), compelling the Daily News to produce a certain audio recording. 2. The grounds for denying Edwards' motio

James Edwards for an order, pursuant to CPLR 3102(e), compelling the Daily News to produce a certain audio recording. 2. The grounds for denying Edwards' motion are fully set forth in the accompanying memorandum of law. I submit this affirmation to annex exhibits relevant to the Daily News' oppositi

miss, dated January 26, 2010, that was issued in the Ponzi Scheme Action. 6. Annexed hereto as Exhibit "D" is a true and correct copy of Defendant Bradley J. Edwards's Motion to Appoint Commissioner that was filed July 19, 2010 in the Ponzi Scheme Action. 7. Annexed hereto as Exhibit "E" is a true and correct cop

ith exhibits, dated April 29, 2010, that was submitted in the Jane Doe Action. 14. Annexed hereto as Exhibit "L" is a true and correct copy of the Supplementary Affidavit of George Rush, sworn to April 30, 2010, that was submitted in the Jane Doe Action. 15. Annexed hereto as Exhibit "M" is a true and corr

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

6, 7. The additional topics that Rush agrees may have been discussed with an investigator working with counsel which Rush has now recalled in his Supplementary Affidavit fl 2, 3, do not materially alter the contours of the issues before the Court with regard to waiver. But, in any event, with his recollecti

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

. The additional topics that Rush agrees may have been discussed with an investigator working with Doe's counsel which Rush has now recalled in his Supplementary Affidavit fl 2, 3, do not materially alter the contours of the issues before the Court with regard to waiver. But, in any event, with his recollecti