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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.)
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 seek a protective order barring disclosure under Fed. R. Civ. P. 26(c). C
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
themselves to be Jeffrey Epstein," and the testimony of George Rush and Anne B. Carroll, a Vice President and General Counsel of Daily News, IIII (Carroll Decl., Apr. 7, 2010, Exs. A & B.) In the alternative, the subpoenaed parties seek a protective order barring disclosure under Fed. R. Civ. P. 26(c). C
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
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 seek a protective order barring disclosure under Fed. R. Civ. P. 26(c). CC
Entities connected to both Jane Doe and Carroll Decl

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.
ORGANIZATIONCounts IV & V
ORGANIZATIONGonzales v. Pierce
PERSON
McKENNA
LOCATIONLawrence M. McKenna
PERSON