EFTA00207294.txt

"I am Vice President and General Counsel of movant Daily News, L.P."

"Daily News journalist George Rush"

"Doe v. Jeffrey Epstein, No. 08-cv-80893-1CAM"

"Michael Fisten, private investigator for Doe's attorney Bradley Edwards"

"taped interview with Jeffrey Epstein"

"motion of Daily News, L.P., and myself to quash subpoenas served on us in this action"

"motion of Daily News, L.P., and myself to quash subpoenas served on us in this action"

"Plaintiff, JEFFREY EPSTEIN... files this action against Defendants, SCOTT ROTHSTEIN... This is an action for damages in excess of $15,000.00"

"Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A."

"Russell Adler (another named partner in RRA)"

"Magistrate Judge Linnea Johnson wrote in a discovery order dated September 15, 2009 (DE 299 in Federal Case #08-80119)"

"Ms. Mellon, formerly a newspaper reporter in Knoxville, currently resides in Houston"

"the Daily News publisher did not 'kill' my story -- in fact my article about the Epstein case was subsequently published in the paper."

"my conversation with Mr. Fisten took place on or about that date [October 22, 2009]"

"After EDWARDS was recruited and joined RRA in the spring of 2009"

"times you went to Mr. Epstein's home? A. I don't know. Like 17."

"After EDWARDS joined RRA"

"Non-Prosecution Agreement (NPA) between Epstein and USAO"

"attorneys Martha McCampbell and Gary Prince appeared on behalf of the defendants"

"attorneys Martha McCampbell and Gary Prince appeared on behalf of the defendants"

"Gary M. Prince and P. Alexander Vogel, of O'Neil, Parker & Williamson, Knoxville, for defendants"

"Charles W. Pope Jr... for plaintiffs"

"Heather G. Hacker... for plaintiffs"

"Nathan W. Kellum and Jonathan Scruggs... for plaintiffs"

"Nathan W. Kellum and Jonathan Scruggs... for plaintiffs"

"Attorney Richard Hollow appeared on behalf of Ms. Mellon"

"L.W., a minor, by and through his parents SAMUEL and TINA WHITSON v. KNOX COUNTY BOARD OF EDUCATION"

"L.W., a minor, by and through his parents SAMUEL and TINA WHITSON v. KNOX COUNTY BOARD OF EDUCATION"

"an affidavit from Mr. Rush attesting to the fact that he had interviewed Mr. Epstein"

"RRA and its attorneys in the Civil Actions against EPSTEIN may have compromised their clients' interests"

"the individual who first brought ■. to EPSTEIN's home"

"ROTHSTEIN... had EDWARDS demand excessive money from EPSTEIN in the Civil Actions"

"representations of RRA, and Defendants, ROTHSTEIN, EDWARDS and ■. as to how he conducted and defended the Civil Actions"

"representations of RRA, and Defendants, ROTHSTEIN, EDWARDS and ■. as to how he conducted and defended the Civil Actions"

"representations of RRA, and Defendants, ROTHSTEIN, EDWARDS and ■. as to how he conducted and defended the Civil Actions"

"with EDWARDS and RRA as her attorneys"

"hired ROTHSTEIN, EDWARDS and RRA"

"Mr. Epstein — at least dating back as far as our investigation and resources have permitted, back to 1997 or '98 - has every single day of his life, m"

"Jeffrey Epstein coerced, induced, or enticed .the then minor Plaintiff to commit various acts of sexual misconduct"