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s to maybe cross the line a little too closely (Fisten Aff. ¶ 8); • Telling Fisten that Epstein said he was very upset that Edwards had subpoenaed Ghisline Maxwell, referring to her as a good person that did nothing wrong (i.e., had done nothing wrong even though she helped procure young girls to satisfy Epstei
very upset that Edwards had subpoenaed Ghisline Maxwell, referring to her as a good person that did nothi
y News filed a motion to quash, claiming that the tape recording is somehow protected by a journalist's privilege. In June 2010, the District Court (McKenna, J.,) rejected that argument, finding that, in view of its importance. the tape was properly discoverable despite the claim of journalist privilege
recording was somehow protected by a journalist's privilege. Jane Doe responded, and the U.S. District Court for the Southern District of New York (McKenna, J.) held a hearing and listened to the tape in camera. The district court then ruled that the tape was not protected by the journalist's privilege
ly thing he might have done wrong was maybe to cross the line a little too closely. Rush advised that Epstein was very upset that Edwards subpoenaed Ghisline Maxwell. 9. At no point during this phone call was I told that the discussion was "off the record" or otherwise "confidential". I was never told that ther
n was very upset that Edwards subpoenaed Ghisline Maxwell. 9. At no point during this phone call was I to
- 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
fied as a co-defendant of Edwards in the Epstein vs. Edwards lawsuit. 3 EFTA00729040 • Epstein said he was very upset that Edwards had subpoenaed Ghisline Maxwell, referring to her as a good person that did nothing wrong (i.e., had done nothing wrong even though she helped procure young girls to satisfy Epste
vely use initials, Jane Doe or other anonymous designations . .. [as] a key element of the fraudulent scheme." Complaint 123. 3 Edwards subpoena to Maxwell appears to form one of the grounds for the Epstein vs. Edwards lawsuit. See Epstein Complaint at 141. 4 See Doe No. 102 v. Epstein, No. 9:09-CV-806
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 that are "of likely relevance to a
n Sex Suits. M. POST, Oct. 12, 2009 ("Florida lawyer Brad Edwards. who represents three of the 'Jane Does' who are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how Epstein procured many of the girls.") (bold in original); Susan Spencer-Wendel, Judge Agrees
are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how Ep
se in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District Court (McKenna, J.) did not accept Edwards' waiver argument; but, instead, ruled that, since Epstein was known to be the source for the interview, he was a non- co
t the federal government does not intervene in sex-assault cases, except if we're deal- ing with a serial rapist or it crosses jurisdictional lines," Maxwell said. "It's either not a big enough case or not atrocious enough for them? Epstein, 56, served 13 months of his 18-month sentence at the Palm Beach
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
United States v. GNI.bine Maxwell 20 Cr. 330 IAM) Nen.Testifying Witness Material 11/6/2021 3501.000 Genaml Date Descriptban Attorney Produced to Defense 3501000 031 2021.0
Monism/ 302 3501.142-01 2020.0x15 nternew notes 3501.10-01 2019.11.01 Intones" 301 3501.10-000 2019.11.01 Intoning Notes 3501.148 eatrkk McKenna DM Dosciptkes 39)1 148 0)1 2006.11.11 Florida DAVID. indnidual summary page for Patoct McKenna 3501148 032 2006.11.11 Florida DAY.I.D.IndhIdu
Entities connected to both Ghislaine Maxwell and McKenna

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Newark
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
Marc Rich
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSON
New York
LOCATIONMaria Farmer
PERSONFBI
ORGANIZATION
Denver
LOCATION