Epstein Secrets

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

poena must show that the information sought is ... unobtainable from other sources") (emphasis added); In re Application to Quash Subpoena to NBC ("Graco"), 79 F.3d 346, 353 (2d Cir. 1996) (rejecting lower court's conclusion that "because the material contained in the out-takes sought by Graco is sole

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

New York Shield Law would then apply. Ste In re Application to Ouash Subpoena to National Broadcasting Co., 79 F.3d 346. 351. 352 (2d Cir. 1996) ("Graco") (applying New York Shield Law to state claims pending in Massachusetts federal court, noting the relevant standards of that law and the federal pr

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

New York Shield Law would then apply. Ste In re Application to Ouash Subpoena to National Broadcasting Co., 79 F.3d 346. 351. 352 (2d Cir. 1996) ("Graco") (applying New York Shield Law to state claims pending in Massachusetts federal court, noting the relevant standards of that law and the federal pr