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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
ed. In re Venezia, 922 A.2d 1263, 1275 a 2007) (emphasis added). To take but two of many other on-point examples, in McGarry v. University of San Diego, 64 Cal. Rptr. 3d 467 (Cal. Ct. App. 2007), the plaintiff— like Edwards here — argued that the journalist had waived his confidential reporter's pri
position. It's in the 3 criminal complaint. The truth is different from 4 what's in both the criminal complaint and in that FBI 5 affidavit, and in Brad Edward's own statements on the 6 subject. 7 The truth is that Alfredo Rodriguez was 8 deposed twice, once in July and once in August. And 9 in the
RICO investigation 16 for that entire time, creating fake evidence in 17 Epstein's case. 18 And she had just filed hidden secret using 19 Edwards to overturn the NPA by filing the -- this 20 CVRA case, that sole purpose was to overturn it. And 21 so when he approached her with the list, this w
ormally asking questions of 14 Ms. Maxwell, I'm going to put on the record everybody 15 that's in this room, in addition to me, starting with 16 you, Diego. 17 DIEGO PESTANA: Diego Pestana, Associate 18 Deputy Attorney General. 19 TODD BLANCHE: And then you heard from 20 Special A
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Entities connected to both Bradley Edwards and Diego

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONMartin Weinberg
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON