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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
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
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
ourt conclude that "Epstein made no material admissions regarding the young women suing him for sexual abuse." Daily News Memo. of Law at 6 (citing Rush Supp. Aff. 7 4-5) (emphasis in original). This conclusory assertion is flatly inaccurate, as others who have listened to the recording have explained. On
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
on a digital recording device. Id. During the interview, Epstein made no material admissions regarding the young women suing him for sexual abuse. Rush Supp. Aff. ¶¶ 4-5. So too, because the interview took place months before Epstein filed the Ponzi Scheme Action (and before Rothstein was even publicly
Entities connected to both Ghislaine Maxwell and Rush Supp

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
New York
LOCATIONJane Doe
PERSON
Paul Cassell
PERSONSecond Circuit
ORGANIZATION
Lawrence Krauss
PERSONJack Goldberger
PERSON
Bradley Cooper
PERSONScott Rothstein
PERSON
New York Daily News
ORGANIZATION
Alberto Gonzales
PERSON
the Daily News
ORGANIZATIONThe Second Circuit
ORGANIZATIONFlorida Bar
ORGANIZATION
Michael Fisten
PERSONRobert Y. Lewis
PERSON