Epstein Secrets

e 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 thereto, Bradley James Edwards, as defendant and counterclai

ngs, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the testimony of George Rush and Anne B. Carroll, a Vice President and General Counsel of Daily News, L.P. (Carroll Decl., Apr. 7, 2010, Exs. A & B.) In the alternative, the subpoenaed parties see

should order the Daily News to produce the recording. New York, New York November I I, 2010 Respectfully submitted, Freeman Lewis LLP '4/i By: Robert Y. Lewis 228 East 45" Street, 17'h Floor New York, New York 10017 Tel: Fax: Paul G. Cassell (Motion for Pro Hac Vice Admission Pending) (: " 4—'4 ;tel

copy of the foregoing Reply Memorandum of Law in Further Support of Motion for CPLR 3102(e) Order dated November 11, 2010 upon: DAILY NEWS, L.P. Anne B. Carroll (AC-5322) Deputy General Counsel 450 West 33"I Street, 3n° Floor 10001 Attorneys for Daily News, L.P. and George Rush A copy was also sent via

sion to the Second Circuit. While the appeal was pending, the Jane Doe Action (as well as the ■. and E.W. suits) settled. See Moving Affirmation of Robert Y. Lewis, dated Sept. 15, 2010 ("Lewis Aff."), ¶ 7. The Daily News and Rush then moved the Second Circuit to vacate the District Court decision. 8 DWT 1511

Robert D. Balin Victor Hendrickson 1633 Broadway — 27th Floor New York, NY 10019 Tel: (212) 489-8230 Attorneys for Daily News,.. Of Counsel: Anne B. Carroll Deputy General Counsel Daily News, 450 West 33rd Street New York, NY 10019 Tel: (212) 210-2341 922 A.2d at 1275 (2007) (noting in dicta that no