Epstein Secrets

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

eeks are (1) highly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 19

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

eeks are (1) highly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 19

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

ep. 1413 (S.D.N.Y. 2004) 2 iii EFTA00728011 Eagle Hosp. Physicians. LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) 7 Gonzales v. National Broad. Co., 194 F.3d 29 (2d Cir. 1999) 2, 3 Hill v. Federal Trade Comm'n, 124 F.2d 104 (5th Cir. 19431) 13 In re Aoplication to Ouash Subpoena to Nat'

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

ep. 1413 (S.D.N.Y. 2004) 2 iii EFTA00207334 Eagle Hosp. Physicians. LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) 7 Gonzales v. National Broad. Co., 194 F.3d 29 (2d Cir. 1999) 2, 3 Hill v. Federal Trade Comm'n, 124 F.2d 104 (5th Cir. 19431) 13 In re Aoplication to Ouash Subpoena to Nat'