3
Shared Docs
3
Same-Page
3 / 3
Mentions
e counsel a copy of the interview recording. (Id. 1 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C) 1 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, 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
e counsel a copy of the interview recording. (Id. 1 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C) 1 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, 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
e counsel a copy of the interview recording. (Id. I 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C] I 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, a
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 Rush Supp and Counts IV & V

Anne B. Carroll
PERSON
New York Daily News
ORGANIZATIONJane Doe
PERSON
George W. Bush
PERSON
Jeffrey Epstein
PERSONRush Aff
ORGANIZATION
Alberto Gonzales
PERSONthe Southern District
LOCATIONQuash Subpoena
PERSON
McKENNA
LOCATIONGonzales v. Pierce
PERSONReal Party
ORGANIZATIONNat'l Broad.
ORGANIZATIONCo., Inc.
ORGANIZATIONNat'l Broad. Co., Inc.
ORGANIZATIONCarroll Decl
PERSON
the Daily News
ORGANIZATION
Lawrence Krauss
PERSONLawrence M. McKenna
PERSONThe Second Circuit
ORGANIZATION