Epstein Secrets

ORDER TO PRODUCE TAPE RECORDING Robert Y. Lewis Freeman Lewis LLP 228 East 45th Street, 17th Floor New York. New York 10017 Tel: Fax: E-mail: 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

ork. New York 10017 Tel: Fax: E-mail: Paul G. Cassell, Esq. (Motion for Pro Hac Vice Admission Pendin

y News filed a motion to quash, claiming that the tape recording is somehow protected by a journalist's privilege. In June 2010, the District Court (McKenna, J.,) rejected that argument, finding that, in view of its importance. the tape was properly discoverable despite the claim of journalist privilege

recording was somehow protected by a journalist's privilege. Jane Doe responded, and the U.S. District Court for the Southern District of New York (McKenna, J.) held a hearing and listened to the tape in camera. The district court then ruled that the tape was not protected by the journalist's privilege

nd George Rush TO: Bradley James Edwards FARMER WESSING EDWARDS FISTOS & LEHRMAN P.L. 425 N. Andrews Avenue, Suite 2 n a 1d ale Florida 33301 Paul G. Cassell 332 South 1400 East, Room 101 Salt Lake City, Utah 84112-730 Attorneys for Appellee Jane Doe Jack Alan Goldberger ATTERBURY GOLDBERGER & WEISS,

enue, Suite 2 n a 1d ale Florida 33301 Paul G. Cassell 332 South 1400 East, Room 101 Salt Lake City, U

ated June 23, 2010 (Stein, J.), and entered on June 25, 2010, adjudging them in civil contempt of the Memorandum and Order entered on May 21, 2010 (McKenna, J.) by reason of the Daily News Parties' refusal to consent to the production of certain newsgathering material that was ordered to be produced in

Movants' Reply. Thank you for your consideration in this matter. : Si rely yours, Si Laura R. !Landman cc: Anne B. Carroll, Esq. (via e-mail) Paul G. Cassell, Esq. (via e-mail) Anchorage New York Seattle Bellew. Portland:, Shanghai Los Arktelm San Franccco Washington O.C. •C0at, et www.0wt.com

cc: Anne B. Carroll, Esq. (via e-mail) Paul G. Cassell, Esq. (via e-mail) Anchorage New York Seattl

2 tel fax 1633 Broadway 10019-6708 Re: In re Application to Quash Subpoena to Daily News, L.P. and George Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist George Rush. They have moved to quash subpoenas for deposition testimony and docum

ew York FREEMAN LEWIS LLP By: Robert Y. Lewis 228 East 45th Street 17th Floor New York, New York 10017 Tel. (212) 980-4084 Fax: 212 980-4055 PAUL G. CASSELL, ESQ. (Mo Pro Hac Vice Admission Pending) 332 S. 1400 E. Salt Lake City, Utah 84112 Tel.: 801-585-5202 Fax: 801-585-6833 E-Mail Counsel fo

Tel. (212) 980-4084 Fax: 212 980-4055 PAUL G. CASSELL, ESQ. (Mo Pro Hac Vice Admission Pending) 332

- Jane Doe -- filed a proper subpoena for the tape in the U.S. District Court for the South District of New York. In June 2010, the District Court (McKenna, J.,) denied the Daily News' motion to quash the subpoena, finding that in view of its importance, the tape was properly discoverable despite the c

ORDER TO PRODUCE TAPE RECORDING Robert Y. Lewis Freeman Lewis LIP 228 East 45th Street, 1711 Floor New York, New York 10017 Tel: Fax: E-mai Paul G. Cassell, Esq. (Motion for Pro Hac Vice Admission Pending) 332 S. 1400 E. Salt Lake Cit Utah 84112 Tel.: Fax: E-Mail Counsel for Bradley James &Avon&

York, New York 10017 Tel: Fax: E-mai Paul G. Cassell, Esq. (Motion for Pro Hac Vice Admission Pendin

called Edwards' investigator and said, "My god, you've [got to] get this tape. [Epstein] talks about the girls." Fisten Aft at I 3. Similarly, Judge McKenna — who had the benefit of listening to the recording' — specifically ruled that the recording contains statements that are "of likely relevance to a

Movants' Reply. Thank you for your consideration in this matter. : Si rely yours, Si Laura R. !Landman cc: Anne B. Carroll, Esq. (via e-mail) Paul G. Cassell, Esq. (via e-mail) Anchorage New York Seattle Bellew. Portland:, Shanghai Los Arktelm San Franccco Washington. O.C. •C0at, et www.0wt.co

cc: Anne B. Carroll, Esq. (via e-mail) Paul G. Cassell, Esq. (via e-mail) Anchorage New York Seattl

Y 10019-6708 tel fax [email protected] Re: In re Application to Quash Subpoena to Daily News, L.P. and Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist Rush. They have moved to quash subpoenas for deposition testimony and documents s

Me see of I B say they came to Na home and gave him ma wart Curl/ the massages. they say. he rhialutbalad and Suety assaulted rem Brad Edwards and Paul Cassell, allomem represantei two of Na raged steams. say In Meting than the U S Attorneys eke for the Southern Cleric' of Florida of OMNIrattly misled the

or Thursday in those cases before U.S. Claim Judge Kennel Marra. Dog mad have welled the lawsuit for 550.000 but b asking for $50 ratan ter damages. Cassell said Tuesday. -Jane Doe was repeatedly sexually assaulted over a lengthy period of Urne by this wealthy and powerful man,' Cassell said. East*. 57

cKenna reserved ruLng on whether the recording will be re'eased to atierneYs representing young women who were sexually abused by Epstein as mfrors. McKenna didn't Wen to the recanting tiring the hearing. Fon Lauderdale attorney Bald Edwards and Utah allomey and low professor Paul Casten ors flghtng to