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2 tel fax 1633 Broadway 10019-6708 Re: In re Application to Quash Subpoena to Daily News, L.P. and George Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist George Rush. They have moved to quash subpoenas for deposition testimony and docum
Ip Da ght Trevis maiWneri LLP May 3, 2010 VIA HAND DELIVERY Hon. Lawrence M. McKenna United States District Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Laura R. Handman Suite 2
- Jane Doe -- filed a proper subpoena for the tape in the U.S. District Court for the South District of New York. In June 2010, the District Court (McKenna, J.,) denied the Daily News' motion to quash the subpoena, finding that in view of its importance, the tape was properly discoverable despite the c
bers or under seal until any appeal from this decision is decided or the time to file a notice of appeal has expired. SO ORDERED. 14 ‘—`---- .4, Lawrence M. McKenna O.S.D.J. 3 Persons other than Jane Doe and Mr. Epstein are mentioned in the conversation. 6 EFTA00728466 EDWARDS AFF. EFTA00728467 SUPREME
cKenna reserved ruLng on whether the recording will be re'eased to atierneYs representing young women who were sexually abused by Epstein as mfrors. McKenna didn't Wen to the recanting tiring the hearing. Fon Lauderdale attorney Bald Edwards and Utah allomey and low professor Paul Casten ors flghtng to
ustody a tape•recorded conversation between veteran newspaper reporter George Rush and convicted sex offender Jerey Epstein But U S. District Judge Lawrence M. McKenna reserved ruLng on whether the recording will be re'eased to atierneYs representing young women who were sexually abused by Epstein as mfrors. McKenn
Entities connected to both McKenna and Lawrence M. McKenna

George W. Bush
PERSON
Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSONthe Southern District
LOCATIONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Anne B. Carroll
PERSON
New York Daily News
ORGANIZATION
Paul Cassell
PERSON
Lawrence Krauss
PERSON
Ghislaine Maxwell
PERSONMaria Farmer
PERSON
Alberto Gonzales
PERSON
Kenneth Marra
PERSONNat'l Broad.
ORGANIZATION
Bill Clinton
PERSONChambers
PERSON
Daniel Patrick Moynihan
PERSONRush Aff
ORGANIZATION