Epstein Secrets

stantial punitive damages. In the fall of 2009, Michael Fisten, an investigator working for Edwards, heard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the recording for her and t

9 15 fn. 2 945 So.2d 1246 (Fla. 2006) 15 E.W. v. Epstein, Case No. 502008CA028XXXMBAB (Florida

ry its burden of showing proper justification for refusing to produce these highly relevant tapes for two simple reasons. 2 EFTA00728067 First, the Daily News' reporter, George Rush, has waived whatever privilege might attach to the recording by playing a significant portion of the recording to three people

and Jeffrey Epstein, executed by Epstein on September 24, 2007. 12. Annexed hereto as Exhibit "J" is a true and correct copy of the Affidavit of George Rush, sworn to April 6, 2010, that was submitted in the proceeding entitled In re 2 DWT 15631739v2 3970112-000042 EFTA00596486 Application to Quash S

e and correct copy of the Judgment against Scott W. Rothstein that was entered June 9, 2010 in the cr

ounds for denying Edwards' motion are fully set forth in the accompanying memorandum of law. I submit this affirmation to annex exhibits relevant to the Daily News' opposition. 3. Annexed hereto as Exhibit "A" is a true and correct copy of the Complaint of Jeffrey Epstein, with Exhibits 1 and 2, that was file

on: 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 first-claim mail to Jack Alan Goldberger ATfERBURY GOLDBERG & WEISS, P.A. 250 Australian Avenue South, Suite 1400 FL 33

prosecuted on behalf of ■. ARGUMENT I. THE DAILY NEWS HAS WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS. 6 The counterclaim is attached to the Daily News' Balin Aft: at Ex. B. 5 EFTA00729042 In his opening brief, Edwards' lead argument was that the Daily News has waived any privilege by disclosing