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from an author that Daily News reporter George Rush had made a tape recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the tape for her and two other persons. The author concluded: "You've got to get that tape." Fisten then called Rush. Rush des
Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon
ION FOR CPLR 3102(E) ORDER ORDER TO PRODUCE TAPE RECORDING Pursuant to CPLR 3102(e) Index No. x An Application having been made by Petitioner Freeman Lewis LLP for the purpose of taking the deposition duces tecum of the Records Custodian of the New York Daily News pursuant to a commission issued by the Cir
CORDING x NOTICE OF MOTION PLEASE TAKE NOTICE that upon the annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14, 2010, the Affirmation of Robert Y. Lewis dated September 15, 2010, the accompanying Memorandum of Law and all exhibits attached
Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon
RECORDING NOTICE OF MOTION PLEASE TAKE NOTICE that upon the annexed Affidavit of Bradley James Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14, 2010, the Affirmation of Robert Y. Lewis dated September 15, 2010, the accompanying Memorandum of Law and all exhibits attached
Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his Ncw York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon
Entities connected to both Michael Fisten and Freeman Lewis LLP

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONJane Doe
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
Ghislaine Maxwell
PERSON
Paul Cassell
PERSON
New York Daily News
ORGANIZATIONSecond Circuit
ORGANIZATIONRobert Y. Lewis
PERSON
McKenna
PERSON
Anne B. Carroll
PERSONRush Supp
ORGANIZATION