Epstein Secrets

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

10 EXHIBIT E EFTA00207311 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defenda

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

43 EXHIBIT E EFTA00612044 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defenda

gators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters with George Rush of the NY Daily News regarding the Epstein matter, he would not be answering any questions regarding what Fisten specifically discussed with Mr. Rush because that was w

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M.,

gators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters with George Rush of the NY Daily News regarding the Epstein matter, he would not be answering any questions regarding what Fisten specifically discussed with Mr. Rush because that was w

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M.,

round town: Prince Andrew and Pert Billionaire," blared the New York Post. "Duchess of York apologises for accepting money from sex offender," read the New York Daily News. So much for the eager anticipation of a slew of good publicity around the marriage of Prince William and Kate Middleton. It was not just the Amer

NTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendants. Complex Litigation, Fla. R. Civ. Pro. 1201 Case No. 50 2009 CA 040800XXXXMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PRECLUDE O