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ly News, II, publisher of the New York Daily News, respectfully submits this memorandum of law in opposition to Bradley J. Edwards' motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT
s among various lawyers and others close to the case — including attorney Edwards — who could provide tips and information to assist his reporting. Rush Aff. ¶¶ 3, 6-7. In October 2009, Rush obtained a telephone interview with Epstein to talk about the status of the civil cases against him. See Rush Aff
Rush Aff. ¶¶ 3, 6-7. In October 2009, Rush obtained a telephone interview with Epstein to talk about the status of the civil cases against him. See Rush Aff. ¶ 4; Balin Aff. Ex. L (Supplementary Affidavit of George Rush, sworn to April 30, 2010 ("Rush Supp. Aff.")), ¶ 2. Epstein and Rush agreed at the o
CATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH McKENNA, D.J., M8-85 MEMORANDUM AND ORDER 1. Daily News, L.P., the publisher of the Daily News, and George Rush, a Daily News reporter, move, pursuant to Fed. R. Civ. P. 45(c) (3)(A)(iii), for an order quashing subpoenas issued by counsel fo
columnist in the Daily News, that in the fall of 2009 he began to follow criminal and civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010, Ex. G) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste
APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, AND GEORGE RUSH McKENNA, D.J., M8-85 MEMORANDUM AND ORDER 1. Daily News, III., the publisher of the Daily News, and George Rush, a Daily News reporter, move, pursuant to Fed. R. Civ. P. 45(c) (3)(A)(iii), for an order quashing subpoenas issued by counsel fo
columnist in the Daily News, that in the fall of 2009 he began to follow criminal and civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010, Ex. G) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste
Entities connected to both the Daily News and Rush Aff

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
New York
LOCATIONthe Southern District
LOCATION
New York Daily News
ORGANIZATIONJane Doe
PERSON
Lawrence Krauss
PERSON
Kenneth Marra
PERSON
Alberto Gonzales
PERSONScott Rothstein
PERSON
Bradley Cooper
PERSONSecond Circuit
ORGANIZATION
Paul Cassell
PERSON
Anne B. Carroll
PERSONRush Supp
ORGANIZATIONQuash Subpoena
PERSON
Michael Fisten
PERSONCo., Inc.
ORGANIZATION