Epstein Secrets

Companies, 166 A.D.2d 223, 224 (1st Dept. 1990) Cooper Indus., Inc. v. Leatherman Tool Group, Inc., 532

any evidence to prove Epstein's lack of remorse for this abuse, a showing critical for securing substantial 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 sexu

ard 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 two other persons. The author concluded: "You've got to get that tape." Fisten then called Rush. Rus

845345v) 3970112-000042 EFTA00596451 Flores v. Cooper Tire & Rubber Co., 178 P.3d 1176 (Ariz. CI. App.

sexual abuse cases, during which Rush paraphrased aspects of the Epstein interview. Moving Affidavit of Michael Fisten, sworn to Sept. 14, 2010,1 8. Fisten also requested a copy of the Epstein interview, which request was likewise refused. Id. ¶ 10. The Daily News has not published any articles publicl

terview had been off-the-record and, moreover, would be of no help to his clients. Id. 8. Thereafter, on October 22, 2009, Rush also had a call with Michael Fisten, an investigator employed by Edwards on the sexual abuse cases, during which Rush paraphrased aspects of the Epstein interview. Moving Affidavit of

25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N

ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid

S.D. Fla. 2001); Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid

he ANN VON ALLMEN LIVING TRUST, DEAN KRETSCHMAR, COOPER MANAGEMENT, ANTHONY DEGENNARO as Trustee of the

the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. Michael Fisten d. Kenneth Jenne e. David Boden f. Deborah Villegas g. Andrew Barnett 9 EFTA00722468 h. Bradley Edwards 15. All documents related to o

. LLC 652 F. Supp. 2d 1252 (M.D. Fla. 2009) 12 Cooper Industries. Inc. v. Leatherman Tool Group. Inc.,

eral law are "identical" to those under the applicable New York statute.— See Persky, supra. 2002 WL 31769704, at *3 (McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to

ANN VON ALLMEN LIVING TRUST, DEAN KRETSCHMAR, COOPER MANAGEMENT, ANTHONY DEGENNARO as Trustee of th

the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. Michael Fisten d. Kenneth Jenne e. David Boden f. Deborah Villegas g. Andrew Bamett 6 EFTA00731276 Case 09-34791-RBR Doc 1063 Filed 10/13/10 Page 7 o

. LLC 652 F. Supp. 2d 1252 (M.D. Fla. 2009) 12 Cooper Industries. Inc. v. Leatherman Tool Group. Inc.,

eral law are "identical" to those under the applicable New York statute.— See Persky. supra. 2002 WL 31769704, at *3 (McKenna. J.). " Notably. Mr. Fisten claims he "wrote up a report memorializing what Rush had told me" shortly after his conversation with Mr. Rush (Fisten Aft*" I I) but chooses not to

ANN VON ALLMEN LIVING TRUST, DEAN KRETSCHMAR, COOPER MANAGEMENT, ANTHONY DEGENNARO as Trustee of th

the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. Michael Fisten d. Kenneth Jenne e. David Boden f. Deborah Villegas g. Andrew Barnett h. Bradley Edwards i. A.J. Discala j. Christina ICitterman k. D