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

ge. In Re: Application to Quash Subpoenas to Daily News, L.P., and George Rush Daily News, L.P., George Rush, v. Jane Doe, Movants-Appellants, Real Party in Interest-Appellee. AMENDED ORDER Docket No. 10-2438 (L) 10-2573 (con) IT IS HEREBY ORDERED that the motion by Appellants Daily News L.P. and G

EY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees

ey Edwards whether he would withdraw them in exchange for an affidavit from Mr. Rush attesting to the fact that he had interviewed Mr. Epstein. Mr. Edwards said he would not. 10. On Friday, April 30, 2010, I received service of a subpoena from Doe's counsel requiring movant journalist George Rush to a

etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th

&gran of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name of party) Real Party In Interest Jane Doe , who issues or requests this subpoena, are: ion Pro Hac Vice Pending, 332 S. 1400 E.. Salt Lake City, UT 84112 EFTA0020733

EY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees

ey Edwards whether he would withdraw them in exchange for an affidavit from Mr. Rush attesting to the fact that he had interviewed Mr. Epstein. Mr. Edwards said he would not. 10. On Friday, April 30, 2010, I received service of a subpoena from Doe's counsel requiring movant journalist George Rush to a

etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th

Sinn* of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name of party) Real Party In Interest Jane Doe , who issues or requests this subpoena, are: on Pro Hac Vice Pending, EFTA00612063 AO 88 (Rev 06/09) Subpoena to Appear e

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

U.S. District Court for the Southern District of New York (the "Jane Doe Action"). 13. Annexed hereto as Exhibit "K" is a true and correct copy of Real Party In Interest Jane Doe's Response in Opposition to Motion of Daily News, L.P. to Quash Subpoenas, with exhibits, dated April 29, 2010, that was submi