Epstein Secrets

eral law are "identical" to those under the applicable New York statute.— See Persky, supra. 2002 WL 31769704, at *3 (McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to

d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00728026 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her

eral law are "identical" to those under the applicable New York statute.— See Persky. supra. 2002 WL 31769704, at *3 (McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to

d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00207349 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her

: told George : o 16. oe Mr. Rush indicated that he taped the. conversation between him and: Mr. Epstein, _ 5, Se Mr. “Rush also spoke at length to Michael Fisten, an investigator with: my'fi firm that. was - . assisting with the investigation of the case... Mr. Fisten reported to: me * shortly after the conver

Mr. “Rush also spoke at length to Michael Fisten, an investigator with: my'fi firm that. was - . assisting with the investigation of the case... Mr. Fisten reported to: me * shortly after the conversation with Mr. Rush that he: had such a conversation. . pclae tpi vale HOUSE_OVERSIGHT_013464 --- PAGE

‘opportunity to‘even hear Epstein’ s voice utter any. ‘substantive words other than (in essence} “I take the Fifth.” ~ As part of our discussion, Ms. Carroll told me'thatitwasa° 4 “stupid move” for Mr. Rush to play the tape or disclose the tape. to other people as he likely waived any © ne pan privilege.