Epstein Secrets

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

ngs, all emails to and from Jeffrey Edward Epstein or someone representing 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 see

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

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

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

Robert D. Balin Victor Hendrickson 1633 Broadway — 27th Floor New York, NY 10019 Tel: (212) 489-8230 Attorneys for Daily News,.. Of Counsel: Anne B. Carroll Deputy General Counsel Daily News, 450 West 33rd Street New York, NY 10019 Tel: (212) 210-2341 922 A.2d at 1275 (2007) (noting in dicta that no