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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
passim N.Y. Civil Rights Law § 79-h(g) (McKinney 2010) 11, 14 iv EFTA00728065 PRELIMINARY STATEMENT Bradley Edwards seeks an order pursuant to CPLR 3102(e) for production of a tape recording of a conversation between a Daily News reporter and billionaire Jeffrey Epstein concerning Epstein's molestatio
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
man Lewis LLP, with offices at 228 East 45th Street, in Manhattan, New York. I submit this Affirmation in support of motion for an order pursuant to CPLR 3102(e) for production of a certain tape recording of an interview by George Rush, a Daily News reporter, of Jeffrey Epstein, a party to an action pending
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
2093 (S.C. Ct. Common Pleas July 20, 1994) 29 Yoder v. Adriatic°, 459 So.2d 449 (Fla. Dist. Ct. App. 1984) 18 STATUTES CPLR 3101(a)(4) passim CPLR 3102(e) 11, 1 2 MI Civil Rights Law § 79-h passim OTHER AUTHORITIES Carl C. Monk, Evidentiary Privilege for Journalists' Sources: Theory and Statutory
Entities connected to both Ghislaine Maxwell and CPLR 3102(e

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
New York
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONSecond Circuit
ORGANIZATION
Lawrence Krauss
PERSON
Bradley Cooper
PERSON
the United States District Court
ORGANIZATIONScott Rothstein
PERSON
New York Daily News
ORGANIZATION
Goldman Sachs
ORGANIZATION
Alberto Gonzales
PERSONFlorida Bar
ORGANIZATION
Michael Fisten
PERSONE.W.
PERSONRobert Y. Lewis
PERSON