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

5=.2d 919 (Sup. Ct... Co. 2001) In re Application to Quash Subpoena to NBC 79 F.3d 346 (2d Cir. 1996) In re Behar, 779 F. Supp. 273 1991) In re CBS Inc., 232..2d 291, 648 In re Pennzoil Co.. 108.1.2d 666, 485 29 25 14,19 22,24 21,25 26 .2d 443 (1st Dep't 1996) .2d 533 (1st Dep't 1985) In

istrict of Florida, D.C. Docket No. 9:08-cv-80736-KAM Attorneys and Law Firms Paul Cassell, University of Utah College of Law, SALT LAKE CTY, UT, Bradley James Edwards, Edwards Pottinger, LLC, FORT LAUDERDALE, FL, for Petitioner. Richard Christian Komando, Bradley Garrison & Komando, ORANGE PARK, FL, for Amicus C

ted. During that meeting, however, the federal prosecutors and FBI agents still did not disclose the Agreement to Wild. Then, in mid-June of 2008, Bradley Edwards, the attorney for Wild and several of Epstein's other victims, discussed with AUSA Villafafia the possibility of federal charges being filed agains

18 months' imprisonment in the county jail. Having still not been informed of the resolution of Epstein's federal case, on July 3, 2008, attorney Edwards sent a letter to the U.S. Attorney's Office communicating the victims' wishes that federal charges be filed against Epstein. II. PROCEDURAL HISTOR

tion of Epstein's federal case, on July 3, 2008, attorney Edwards sent a letter to the U.S. Attorney's Office comm

v. Beck's Est., 129 F.2d 243, 245 (2d Cir. 1942))). Where, as here, the language Congress used is clear and unambiguous, our inquiry is complete. CBS Inc. it PrimeTime 24 Joint Venture, 245 F.3d 1217, 1222 (11th Cir. 2001). We are bound to "presume that Congress said what it meant and meant what it s

Page 9 of 20 sexual offenses against children, and the Court should therefore look to the specific statute of limitations covering such crimes. See Edwards. Shalala, 64 F.3d 601, 605 (I I th Cir. 1995) ("[I]t appears contrary to the Supreme Court's directives . . . to apply a statute [of limitations] of

A00210686 Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 19 of 20 DATED: February 6.2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for the victims This d

hile a claimant is "beyond the seas," as in 28 U.S.C. 2401(a), a court lacks the power to narrow the scope of the plain meaning of that phrase. See CBS Inc. I PrimeTime 24 Joint Venture, 245 F.3d 1217, 1228 (11th Cir. 2001) (cautioning against allowing "clearly expressed legislative decisions... [to] be

. Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id. The cases of U.S. I. Siegel, supra (I I's Cir. 1998), and U.S. . Edwards supra (3d Cir. 1998), also support Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of t

ture said what it means and means what it said, and not add language or give some absurd or strained interpretation. As stated in 2 EFTA00233491 CBS Inc. supra at 1228 — "Those who ask courts to give effect to perceived legislative intent by interpreting statutory language contrary to its plain and un