Epstein Secrets

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN MATTER OF APPLICATION OF BRADLEY JAMES EDWARDS SEEKING CPLR 3102(E) ORDER FOR DAILY NEWS, L.P. TO PRODUCE TAPE RECORDING Index No. 112345/10 REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF MOTI

stein has ulterior motives and purposes in exercising such illegal, improper, and perverted use of process. His real purpose was to put pressure on Edwards„ and other victims by publishing what amounts to nothing more than a press release issued under the cloak of protection of the litigation privilege."

gation about that very subject in Florida. Movant Bradley J. Edwards is involved in a hotly contested lawsuit, in whi

dmission Pending) (: " 4—'4 ;telte) 332 S. 1400 E. Salt Lake City UT 84112 Telephone: Facsimile: E-Mail: cassel 1 DOlaw. utah.ed u Counsel for Bradley James Edwards 13 EFTA00729050 AFFIRMATION OF SERVICE As agreed in advance with counsel for the Daily News, I HEREBY AFFIRM that on November 11, 2010, I cause

prosecuted on behalf of ■. ARGUMENT I. THE DAILY NEWS HAS WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS. 6 The counterclaim is attached to the Daily News' Balin Aft: at Ex. B. 5 EFTA00729042 In his opening brief, Edwards' lead argument was that the Daily News has waived any privilege by disclosing

ail: Paul G. Cassell, Esq. (Motion for Pro Hac Vice Admission Pending) 332 S. 1400 E. Salt Lake Ci Utah 84112 Tel.: Fax: E-Mail Counsel for Bradley James Edwards EFTA00728061 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 FACTUAL AND PROCEDURAL BACKGROUND 3 I. EPSTEIN'S SEXUAL ABUSE OF MINOR GIRLS AND HIS

EPSTEIN ABOUT HIS SEXUAL MOLESTATION AND ITS DISCLOSURE OF THE CONTENTS OF RECORED CONVERSATION TO THIRD PARTIES 5 IV. EPSTEIN'S ACTION AGAINST EDWARDS AND EDWARDS' COUNTERCLAIM 7 V. FEDERAL COURT ORDER FOR PRODUCTION OF THE RECORDING ? VI. EPSTEIN'S INVOCATION OF THE FIFTH IN THE EDWARDS ACTIO

atutes 18 U.S.C. § 2255 4 CPLR 3102(e) passim N.Y. Civil Rights Law § 79-h(g) (McKinney 2010) 11, 14 iv EFTA00728065 PRELIMINARY STATEMENT Bradley Edwards seeks an order pursuant to CPLR 3102(e) for production of a tape recording of a conversation between a Daily News reporter and billionaire Jeffrey E

ry its burden of showing proper justification for refusing to produce these highly relevant tapes for two simple reasons. 2 EFTA00728067 First, the Daily News' reporter, George Rush, has waived whatever privilege might attach to the recording by playing a significant portion of the recording to three people

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

ounds 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' opposition. 3. Annexed hereto as Exhibit "A" is a true and correct copy of the Complaint of Jeffrey Epstein, with Exhibits 1 and 2, that was file