Epstein Secrets

ricken. Finally, inadmissible and improper triple hearsay forms the basis of the "facts" set forth in ¶ 80, in which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Ru

n which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Rush. EDWARDS' "FACTS" PERTAINING TO OTHER PURPORTED ACTS OR WRONGS ARE NOT PROBATIVE AND ARE HIGH

7 So. 2d 355, 357 (Ha. 1s' DCA 1996); Albelo v. Southern Bell, 682 So.2d 1126, 1129 (Ha. 4'h DCA 1996). Finally, summary judgments are not favored. O'Connor v. Marston, 717 So. 2d 82 (Ha. 5th DCA, 1998). It is also necessary for the movant to authenticate the undisputed facts upon which its claim for s

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

4, 15, 16 McGarry v. University ojSan Diego, 64 Cal. Rptr. 3d 467 (Cal. Ct. App. 2007) 28, 29 iii D14'71584534593 3970112-000042 EFTA00596452 O'Connor v. Donaldson, 422 U.S. 563 (1975) 13 O'Neill v. Oakgrove Coast. Inc., 71 1.2d 521, 528 ad 1 (1988) 1, 2, 22 People ex reL Scott v. Silverstein

stigation? 11 A. Not that I'm aware of. 12 Q. Did he ever tell you that he had any 13 communications with Mr. Jenne, or Mr. Fandrey or 14 Mr. Fisten? 15 A. Not that fin aware of. 16 Q. And have you ever seen any note, report, 17 document, memorandum, e-mail or log entry in the Palm 18 Beac

12 A. It was actually even stated in the — that if 13 not preceded by — 13 she felt uncomfortable, to say so and Mr. Epstein would 14 ' (Ms. O'Connor exits the proceedings.) 14 stop pushing the issue. 15. MR. PIKE: Go ahead and finish the question, 15 Q. And she wasn't the tint person that to