Epstein Secrets

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

bpoenas. even without regard to privilege, have not been met. (ag Point 1, supra.) Second as a matter of law, absent publication of the Ig See also Altemose Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) (concluded that affidavits in the possession of television news staff ret

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

from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores v. Cooper Tire and Rubber Co., 178P.Id 1176, 1183 (Ariz. App.

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

bpoenas. even without regard to privilege, have not been met. (ag Point 1, supra.) Second as a matter of law, absent publication of the Ig See also Altemose Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) (concluded that affidavits in the possession of television news staff ret