“Tarte thes nor any of the other plaintiffs have been able to pabiigin even a single word of information aren .. Epstein about ci abuse of minor girls. -~ :
25. “| made a. good faith, -albeit unsuccessful, effort to resolve this: matter with ‘Anne B. Carroll, representing the Daily News: in order to’ avoid any court intervention. | explained. that we . needed ‘this tape for several reasons, including those cited by her. in her pleading. The tape is detrimental to. Epstein’s personal complaint against Mand me; the tape is evidence.of perjury. . ~~ : ; . committed’ by Epstein; the tape is the Best Evidence of his lack of remorse for his. actions and. will be |
presented in the punitive. damages. phase of the civil trials against him; and, perhaps most important, , the tape is the only way that the jury considering Jane Doe’s case will be able to hear Epstein’ 's voice and , “awn statements about his abuse of Jane. Doe and other minor girls. Without the tape, the jury will not have: the opportunity to hear Epstein give any substantive: information about Jane Doe’ s complaint. Indeed, they will not have the: ‘opportunity to‘even hear Epstein’ s voice utter any. ‘substantive words other than (in essence} “I take the Fifth.” ~ As part of our discussion, Ms. Carroll told me'thatitwasa° 4
“stupid move” for Mr. Rush to play the tape or disclose the tape. to other people as he likely waived any © ne pan privilege. and that, as.a result of disclosing the tape, he was at risk of losing. his job. Lresponded that it . oe did not seem fair. that Mr..Rush lose his job or be. punished i in any way, but that | had an absolute duty to. . represent my client and that | would be failing in that duty if | did not pursue this critical BIBER. of evidence. - -
I declare under penalty of perjury that the Ae forgoing true and correct. ie
FURTHER AFFIANT SAYETH NAUGHT.
- Dated this 23” day of April, 2010.
_ Brad Feats Esq..
“The fatagaite, instrument was acknowledged before me this 234 day of or, 2010 by BRAD _ EDWARDS, who i is ersonally, known to me. oe : 2 ee ee em oe
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HOUSE_OVERSIGHT_013466