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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
ld that a leak of confidential interview transcripts from CBS to the New York Daily News during the epic battle between 60 Minutes and whistleblower Jeffrey Wigand on one side and the Brown & Williamson Tobacco Company on the other, did nor waive CBS's privilege in the documents under the New York Shield Law e
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
96), a leak of confidential interview transcripts from CBS to the New York Daily News during the epic face-off between 60 Minutes and whistleblower Jeffrey Wigand on one side and the Brown & Williamson Tobacco Company on the other, did not waive CBS's privilege in the documents under the Shield Law except as t
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
96), a leak of confidential interview transcripts from CBS to the New York Daily News during the epic face-off between 60 Minutes and whistleblower Jeffrey Wigand on one side and the Brown & Williamson Tobacco Company on the other, did not waive CBS's privilege in the documents under the Shield Law except as t
Entities connected to both Bradley Edwards and Jeffrey Wigand

Jeffrey Epstein
PERSONJane Doe
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
New York
LOCATION
Harvey Weinstein
PERSON
Southern District of New York
ORGANIZATION
Bradley Cooper
PERSONSecond Circuit
ORGANIZATION
Bernie Sanders
PERSON
Sergey Brin
PERSON
New York Daily News
ORGANIZATION
Michael Fisten
PERSON
Alberto Gonzales
PERSON
The New York Times
ORGANIZATION
Clark
PERSON
Medina
PERSON
James Patterson
PERSON