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uant to 28 U.S.C. § 1746, Anne B. Carroll declares as follows: 1. I am Vice President and General Counsel of movant Daily News, L.P., publisher of the New York Daily News (the "Daily News"). I am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and
rial in a Cir0 Action UNITED STATES DISTRICT COURT for the Southern District of New York In Re: Application to Quash Subpoenas Plaintiff v. to Daly News, L.P. and George Rush Defendant Civil Action No. 10 MB-85 SUBPOENA TO APPEAR AND TESTIFY AT A HEARING OR TRIAL EN A CIVIL ACTION To: George Rush
with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three
uant to 28 U.S.C. § 1746, Anne B. Carroll declares as follows: 1. I am Vice President and General Counsel of movant Daily News, L.P., publisher of the New York Daily News (the "Daily News"). I am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and
ial in a Cir0 Action UNITED STATES DISTRICT COURT for the Southern District of New York In Re: Application to Quash Subpoenas Plaintiff v . to Daly News, L.P. and George Rush Defendant Civil Action No. 10 MB-85 SUBPOENA TO APPEAR AND TESTIFY AT A HEARING OR TRIAL EN A CIVIL ACTION To: George Rush
with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three
ky sex scandal—will work his powerful connections to get Epstein excused of the charges. STARR TURN Ken Epstein (a past Radar investor with the New York Daily News's Mort Zuckerman) arrived in Palm Beach yesterday on his private 727 to face charges of transporting minors across state lines for prostitution. He w
ber one girl" - described his genitalia as being deformed and "egg-shaped", according to a police record. Attorneys, including former Cirucit Judge William Berger, sought the release of the sealed deal as part of their legal strategy in those civil suits. Epstein has repeatedly invoked his right to remain sil
Entities connected to both New York Daily News and William Berger

Jeffrey Epstein
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
George W. Bush
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Bradley Edwards
PERSON
Stephen Hawking
PERSON
Julie K. Brown
PERSON
Scarlett Johansson
PERSON
New York
LOCATION
Prince Charles
PERSON
Chris Tucker
PERSONFBI
ORGANIZATION
Les Wexner
PERSON