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LIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBPOENAS SERVED ON THEM IN A FLORIDA LITIGATION OR IN THE ALTERNATIVE FOR A PROTECTIVE ORDER Anne B. Carroll, Esq. The Daily News L.P. 450 West 33"I Street New York. NY 10001-2631 Laura R. Handman. Esq. Davis Wright Tremaine LLP 1633 Broadway New York
McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to attach the memo to his affidavit. - 8 - EFTA00728021 As to the supposed "damning admission," Rush attests that neither
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
d portions of the tape immediately called Edwards' investigator and said, "My god, you've [got to] get this tape. [Epstein] talks about the girls." Fisten Aft at I 3. Similarly, Judge McKenna — who had the benefit of listening to the recording' — specifically ruled that the recording contains statements t
LIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBPOENAS SERVED ON THEM IN A FLORIDA LITIGATION OR IN THE ALTERNATIVE FOR A PROTECTIVE ORDER Anne B. Carroll, Esq. The Daily News L.P. 450 West 33rd Street N 10001-2631 Laura R. Handman, Esq. Davis Wright Tremaine LLP 1633 Broadway i rlia 10019 EFTA
McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to attach the memo to his affidavit. - 8 - EFTA00207344 As to the supposed "damning admission," Rush attests that neither
Entities connected to both Anne B. Carroll and Fisten Aft

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
McKenna
PERSON
New York Daily News
ORGANIZATIONJane Doe
PERSONSecond Circuit
ORGANIZATION
Alberto Gonzales
PERSONLaura R. Handman
PERSONNat'l Broad.
ORGANIZATION
New York
LOCATION
Bradley Cooper
PERSONAltemose Constr
PERSONTrades Council
ORGANIZATION
Michael Fisten
PERSONScott Rothstein
PERSONTremaine LLP
ORGANIZATIONBranzburg v. Hayes
PERSON
Burke
PERSONMovants Daily News
ORGANIZATION