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— pais nor any of the other plaintiffs have been able to pabiigin even a single word of information ae a Epstein about tits abuse of minor girls. -~ : 25. “1 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 ‘own 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° a “stupid move” for Mr. Rush to play the tape or disclose the tape to other people as he likely waived any © _* an privilege. and that, as.a result of disclosing the tape, he was at risk of losing. his job. Lresponded that it. oo did not seem fair. that Mr..Rush lose his job or be. punished 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 RiBEE. of evidence. - - I declare under penalty of perjury that the Ae foraoings true and correct. fe * 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 8 BRAD EDWARDS, who iis personally known to me. oe : 2 we ee em oe aesocancctinl eramsnaais Soap eebaf ond attanan NUL Fe rermassou ne 1, 2012 Denes Aue UL. Sindee slimmer ene anes lleetee an { HOUSE_OVERSIGHT_013466