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any evidence to prove Epstein's lack of remorse for this abuse, a showing critical for securing substantial punitive damages. In the fall of 2009, Michael Fisten, an investigator working for Edwards, heard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexu
ard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the recording for her and two other persons. The author concluded: "You've got to get that tape." Fisten then called Rush. Rus
paper v. Lehrer McGovern Bovis, Inc., 300 A.D.2d 169, 752 N.Y.S.2d 642 (N.Y.A.D. 2002) 11 People v. Fentress, 103 Misc.2d 179, 425 N.Y.S.2d 485, (N.Y. Co. Sup. Ct. 1980) 13 People v. Osorio, 75 N.Y.2d 80, 84, 549 N.E.2d 1183 (N.Y. 1989) 10 United States v. Jacobs, 117 F.3d 82 (2d Cir. 1997) 13 i
" In re Steinhardt Partners, L.P., 9 F.3d 230, 235 (2d Cir. 1993) (internal quotation omitted). These general principles are operationalized in the New York's shield law. While the shield law provides certain protections for journalists, it also provides directly that the protection can be waived if infor
sexual abuse cases, during which Rush paraphrased aspects of the Epstein interview. Moving Affidavit of Michael Fisten, sworn to Sept. 14, 2010,1 8. Fisten also requested a copy of the Epstein interview, which request was likewise refused. Id. ¶ 10. The Daily News has not published any articles publicl
terview had been off-the-record and, moreover, would be of no help to his clients. Id. 8. Thereafter, on October 22, 2009, Rush also had a call with Michael Fisten, an investigator employed by Edwards on the sexual abuse cases, during which Rush paraphrased aspects of the Epstein interview. Moving Affidavit of
tion (whether Edwards participated in Rothstein's fraudulent Ponzi scheme, not whether Epstein sexually abused Jane Doe) and entirely different law (New York's stringent Shield Iaw, not the less protective federal reporter's privilege). And the unpublished Epstein interview, which was conducted months befo
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
estion' ") (citation omitted). Eagle Hosp. Physicians. LLC v. SRC Consulting, Inc., 561 F.3d 1298, 1303-05 (11th Cir. 2009). Brink's Inc. v. City of New York, 717 F.2d 700. 709-10 (2d Cir. 1983). Cablevision Systems Corp. v. DePalma. No. CV-87- 3528 (JLC), 1989 WL 8165, at *4-5 (E.D.N.Y. Jan. 17, 1989); se
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
estion' ") (citation omitted). Eagle Hosp. Physicians. LLC v. SRC Consulting, Inc., 561 F.3d 1298, 1303-05 (11th Cir. 2009). Brink's Inc. v. City of New York, 717 F.2d 700. 709-10 (2d Cir. 1983). Cablevision Systems Corp. v. DePalma. No. CV-87- 3528 (JLC), 1989 WL 8165, at *4-5 (E.D.N.Y. Jan. 17, 1989); se
f illegal activities, wire taps, and methods by the Rothstein firm while Mr. Edwards had basically been bringing these cases. The investigator, Mr. Fisten, who's mentioned in the Complaint, represented himself as an FBI agent, falsely represented himself as an FBI agent. BY MR. SCAROLA: Q. Do you ha
sition opsffrey Epstein, p. 25; lines 5-25. BY MR. SCAROLA: Q. Okay. What media did Mr. Edwards go to? A. I am aware of at least the Daily News in New York City. I have been told by other people that there were other media, local media. I've been told that the -- his investigator was sent to California to
Entities connected to both Michael Fisten and New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Marc Rich
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONDarren Indyke
PERSONFBI
ORGANIZATION
Prince Charles
PERSON
New York City
LOCATION
U.S. Virgin Islands
LOCATION