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

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon

ION FOR CPLR 3102(E) ORDER ORDER TO PRODUCE TAPE RECORDING Pursuant to CPLR 3102(e) Index No. x An Application having been made by Petitioner Freeman Lewis LLP for the purpose of taking the deposition duces tecum of the Records Custodian of the New York Daily News pursuant to a commission issued by the Cir

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

foregoing reasons, the Court should order the Daily News to produce the recording. New York, New York November I I, 2010 Respectfully submitted, Freeman Lewis LLP '4/i By: Robert Y. Lewis 228 East 45" Street, 17'h Floor New York, New York 10017 Tel: Fax: Paul G. Cassell (Motion for Pro Hac Vice Admissi

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

that upon the annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michae

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon

RE APPLICATION FOR CPLR 3102(E) ORDER Index No. TO PRODUCE TAPE RECORDING 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

that upon the annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michae

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his Ncw York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon