3
Shared Docs
3
Same-Page
5 / 3
Mentions
ubpoenas issued by counsel for the plaintiff in an action pending in the United States District Court for the Southern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plaintiff seeks to recover damages arising out of the defendant's alleged sexual abuse of her
ounsel to Jane Doe, who had heard from a third party about Mr. Rush's interview of Mr. Epstein. (Fisten Aff., Apr. 23, 2010 [Real Party in Interest Jane Doe's Resp. in Opp'n to Mot. of Daily News, L.P., to Quash Subpoena, Ex. B] 1 3.) Mr. Rush paraphrased the interview relatively thoroughly. (Id. 1 7.)
claims under Florida common law (Counts I s III), one claim under federal law (18 U.S.C. § 2255) (Count II), and two claims under Florida statutes (Counts IV & V); federal subject matter jurisdiction is premised on diversity of citizenship, Jane Doe being alleged to be a resident of Florida, and Mr. Epstein
ubpoenas issued by counsel for the plaintiff in an action pending in the United States District Court for the Southern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plaintiff seeks to recover damages arising out of the defendant's alleged sexual abuse of her
ounsel to Jane Doe, who had heard from a third party about Mr. Rush's interview of Mr. Epstein. (Fisten Aff., Apr. 23, 2010 [Real Party in Interest Jane Doe's Resp. in Opp'n to Mot. of Daily News, to Quash Subpoena, Ex. B] 1 3.) Mr. Rush paraphrased the interview relatively thoroughly. (Id. 1 7.) 4. A
claims under Florida common law (Counts I s III), one claim under federal law (18 U.S.C. § 2255) (Count II), and two claims under Florida statutes (Counts IV & V); federal subject matter jurisdiction is premised on diversity of citizenship, Jane Doe being alleged to be a resident of Florida, and Mr. Epstein
he maintenance of his claims. Indeed, Judge McKenna, in ordering production, has already found that the evidence was relevant to one of the girl's (Jane Doe's) claims. In view of Epstein's invocations of the Fifth Amendment — both during past discovery and his promised invocation during the upcoming trial
claims under Florida common law (Counts I & III), one claim under federal law (18 U.S.C. S 2255) (Count II), and two claims under Florida statutes (Counts IV & V); federal subject matter jurisdiction is premised on diversity of citizenship, Jane Doe being alleged to be a resident of Florida, and Mr. Epstein
Entities connected to both Jane Doe and Counts IV & V

Jeffrey Epstein
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Lawrence Krauss
PERSON
Alberto Gonzales
PERSON
New York Daily News
ORGANIZATION
the Daily News
ORGANIZATIONThe Second Circuit
ORGANIZATIONCo., Inc.
ORGANIZATIONQuash Subpoena
PERSON
Anne B. Carroll
PERSONReal Party
ORGANIZATIONRush Supp
ORGANIZATIONRush Aff
ORGANIZATIONNat'l Broad.
ORGANIZATIONNat'l Broad. Co., Inc.
ORGANIZATIONCarroll Decl
PERSONGonzales v. Pierce
PERSON
McKENNA
LOCATIONLawrence M. McKenna
PERSON