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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
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
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
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
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
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 Rush Supp and Carroll Decl

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
ORGANIZATIONCounts IV & V
ORGANIZATIONNat'l Broad.
ORGANIZATIONCo., Inc.
ORGANIZATIONNat'l Broad. Co., Inc.
ORGANIZATION
the Daily News
ORGANIZATION
Lawrence Krauss
PERSONLawrence M. McKenna
PERSONThe Second Circuit
ORGANIZATION