Epstein Secrets

aiWneri LLP May 3, 2010 VIA HAND DELIVERY Hon. Lawrence M. McKenna United States District Judge Daniel

2 tel fax 1633 Broadway 10019-6708 Re: In re Application to Quash Subpoena to Daily News, L.P. and George Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist George Rush. They have moved to quash subpoenas for deposition testimony and docum

appeal has expired. SO ORDERED. 14 ‘—`---- .4, Lawrence M. McKenna O.S.D.J. 3 Persons other than Jane D

- Jane Doe -- filed a proper subpoena for the tape in the U.S. District Court for the South District of New York. In June 2010, the District Court (McKenna, J.,) denied the Daily News' motion to quash the subpoena, finding that in view of its importance, the tape was properly discoverable despite the c

ura" Subject: Re Doe v. Epstein - letter to Hon. Lawrence McKenna, USDC - SDNY Date: Mon, 03 May 2010 17:2

01 +0000 Importance: Normal Attachments: DN_Epsteinn Itr to_Hon._McKenna_5-3-10.pdf Please see the attached - thank you! «DN Epstein - kr to Hon. McKenna 5-3-10.pdf>> Steve Parker I Davis Wright Tremaine LLP Anchorage I Bellevue I Los Anodes I New York I Porasnd I San Francisco I Seattle I Shanghai I

x offender Jerey Epstein But U S. District Judge Lawrence M. McKenna reserved ruLng on whether the recordin

cKenna reserved ruLng on whether the recording will be re'eased to atierneYs representing young women who were sexually abused by Epstein as mfrors. McKenna didn't Wen to the recanting tiring the hearing. Fon Lauderdale attorney Bald Edwards and Utah allomey and low professor Paul Casten ors flghtng to

d 833 (3d Dep't 1997) Fraser v. Park Newspapers Lawrence Inc., 257..2d 961, 684 .2d 332 (3d Dep't 1999)

se in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District Court (McKenna, J.) did not accept Edwards' waiver argument; but, instead, ruled that, since Epstein was known to be the source for the interview, he was a non- co