4
Shared Docs
4
Same-Page
4 / 6
Mentions
Consider Secrecy of Plea Bargain (Fla.) SUN- SENTINEL, June 15, 2009 29 Dwr 1584534343 3970112-000042 EFTA00596454 Daily News, II, publisher of the New York Daily News, respectfully submits this memorandum of law in opposition to Bradley J. Edwards' motion to compel the Daily News to produce a tape recording that
accurate misdescription. Nowhere in his complaint in the Ponzi Scheme Action does Epstein allege that the sex abuse suits brought by Jane Doe,. and E.W. were fabricated. Instead, what the complaint actually alleges is that Rothstein used 9 DWI 1584534543 3970112.000042 EFTA00596463 these three le
minors); id. at 7 ("the evidence of Epstein's crimes is now clear"). Among the many other evidentiary sources listed by Edwards: • Jane Doe,.. and E.W. have all provided graphic eyewitness testimony that they were sexually abused by Epstein when minors. See SUF ¶ 2 ("Deposition of Jane Doe, Septemb
9:08-cv-80736-KAM Document 291-15 Entered on Fl.,SD? Docket 01/21/2 5 Page 32 of Case 09-34791-RBR Doc 160403 Filed 04/08/11 Page 31 10.1 Of 39 the New York Daily News about pending legal proceedings. In that interview, Epstein demonstrated an utter lack of remorse for his crimes (but indirectly admitted his crimes
an provide explanation. See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition Attachment # 7). 9. Epstein also sexually assaulted E.W., beginning when she was 14 years old and did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216. 10. Another of the minor girls Ep
did not notify E.W. and L.M. that a plea agreement had already been reached that would block federal prosecution of Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of the plea agreement. Nor did the FBI or other federal authorities confer with E.W. and L.M. about the plea. See id.
ood reason for defeating Brad Edwards' search for the truth. This case does not involve an issue relating to a confidential source. Accordingly, the Daily News possesses (at most) a qualified privilege, which can be overcome by Edwards making "a clear and specific showing that the [information]: (i) is high
UND 1. EPSTEIN'S SEXUAL ABUSE OF MINOR GIRLS AND HIS CRIMINAL PROSECUTION From approximately 2003 through approximately 2005, Jane Doe, L.M., and E.W. (all then minor girls) were repeatedly sexually abused by Jeffrey Epstein behind the walls of his gated mansion in Palm Beach, Florida. The acts of
PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM his current job, has returned S10,000 to'him because of the Palm Beach scandal, the New York Daily News has ’ reported. Rather than file charges, the state attorney’s office presented the case to a county grandjury. The panel indicted Epstein last-week
h to do so today. "It.is against public policy for these documents to be have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed," wrote former CircuitJudge Bill Berger, now in private practice-and representing one ofthe women. The P
Entities connected to both New York Daily News and E.W.

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONJack Goldberger
PERSON
United States
LOCATIONLeon Black
PERSONJane Doe
PERSONScott Rothstein
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATION
Scarlett Johansson
PERSONMaria Farmer
PERSON
Julie K. Brown
PERSON
New York
LOCATION