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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
es > U.S. District Courts, New York > E&J Gallo Winery v. Encana Energy Services Inc., 33 Med.L.Rptr. 1413 (S.D.N.Y. 2005) 33 Med.L.Rptr. 1413 EL) Gallo Winery v. Encana Energy Services Inc. U.S. District Court Southern District of New York No. M8-85 January 12, 2005 EPO GALLO WINERY, a California corpo
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
es > U.S. District Courts, New York > E&J Gallo Winery v. Encana Energy Services Inc., 33 Med.L.Rptr. 1413 (S.D.N.Y. 2005) 33 Med.L.Rptr. 1413 EL) Gallo Winery v. Encana Energy Services Inc. U.S. District Court Southern District of New York No. M8-85 January 12, 2005 EPO GALLO WINERY, a California corpo
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
re Natural Gas Commodities Litigation. 235 F.R.D. 241, 242, 246 (S.D.N.Y. 2006) (applying 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 s
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
re Natural Gas Commodities Litigation. 235 F.R.D. 241, 242, 246 (S.D.N.Y. 2006) (applying 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 s
Entities connected to both Michael Fisten and Gallo Winery

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJane Doe
PERSON
Kenneth Marra
PERSONRussell Adler
PERSONthe Southern District
LOCATION
Bill Richardson
PERSON
Rosenfeldt
PERSONWilliam Berger
PERSON
Marc Rich
PERSONBerger
PERSON
New York Daily News
ORGANIZATIONComplex Litigation
ORGANIZATION
Palm Beach County
LOCATIONAdler, P.A.
ORGANIZATION
the United States District Court
ORGANIZATION
South Florida
LOCATION
Johns
PERSON