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T C EFTA00207304 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH x No. 10 M8-85 (LMM) SUPPLEMENTARY AFFIDAVIT OF GEORGE RUSH STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) GEORGE RUSH, being duly sworn, depo
am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and Daily News journalist George Rush for an Order pursuant to Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe
reto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 17
int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, ■. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual
T C EFTA00612037 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH x No. 10 M8-85 (LMM) SUPPLEMENTARY AFFIDAVIT OF GEORGE RUSH STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) GEORGE RUSH, being duly sworn, depo
am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and Daily News journalist George Rush for an Order pursuant to Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe
reto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 17
int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual mi
ch, FL 33401 VIA U.S. MAIL The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixi
e like this one, "a case where the case had never been at issue." Serban, 148 So. 3d at 1291(quoting Labor Ready). Furthermore, Epstein's operative Second Amended Complaint, which had neither been answered nor defaulted, contained a "brand-new" count alleged in response to the trial court's order dismissing the prior a
nited States in United States of America v. Scott W. Rothstein Case No. 09-60331CR-Cohn, United State
aint in April 2009, after EDWARDS joined RRA, the allegations against EPSTEIN in <SL7 complaint became even more salacious. In paragraph 12 of .'s Second Amended Complaint, L.M. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu
ccident that young girls like his clients L. , E.W. and Jane Doe ended up in EPSTE1N's mansion where
and prosecute against El) ARDS and the pending, closely related counterclaims. FACTUAL BACKGROUND Plaintiff/Counterdefendant, EPSTEIN has filed a Second Amended Complaint against ED ARDS. The complaint challenges EDWARDS' professionalism as an attorney rep enting girls who had been sexually abused. In particular,
nited States in United States of America v. Scott W. Rothstein, Case No. 09-60331CR-Cohn, United Stat
int In April 2009, after EDWARDS Joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, II. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu
Entities connected to both George W. Bush and Second Amended Complaint

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Charles
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSONJack Goldberger
PERSONMaria Farmer
PERSONDarren Indyke
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Stephen Hawking
PERSON
Richard Kahn
PERSON
Condoleezza Rice
PERSON
Scarlett Johansson
PERSON