Epstein Secrets

unsel responded that they would do so only if movants would stipulate to the accuracy of all facts alleged in the subpoenas of Brad- ley Edwards and Michael Fisten submitted in support of Doe's opposition to movants' motion to quash or for a protective order. I declined. 1 declare under penalty of perjury that

interview with Jeffrey Epstein but whom I did not identify in my prior affidavit. Hearing that refreshed my memory that in fact I did speak to Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein must have occurred prior to October 22, 2009, because my conv

. Annexed hereto as Exhibit A is a true and correct copy of E & J Gallo Winery v. Encana Energy Servs.. Inc. 33 Med. L. Rptr. 1413 (S.D.N.Y. 2005) (Preska, J.). 4. Annexed hereto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 1721 (E.D. Tenn. 2008). 5.

unsel responded that they would do so only if movants would stipulate to the accuracy of all facts alleged in the subpoenas of Brad- ley Edwards and Michael Fisten submitted in support of Doe's opposition to movants' motion to quash or for a protective order. I declined. I declare under penalty of perjury that

interview with Jeffrey Epstein but whom I did not identify in my prior affidavit. Hearing that refreshed my memory that in fact I did speak to Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein must have occurred prior to October 22, 2009, because my conv

. Annexed hereto as Exhibit A is a true and correct copy of E & J Gallo Winery v. Encana Energy Servs.. Inc. 33 Med. L. Rptr. 1413 (S.D.N.Y. 2005) (Preska, J.). 4. Annexed hereto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 1721 (E.D. Tenn. 2008). 5.

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

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);

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

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);