Epstein Secrets

d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00728026 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her

to the defendant's continued newsgathering effectiveness of preserving the source's confidentiality." Id. at 596-98.5 Even in Circuits that, unlike the Second Circuit, have not recognized a federal reporter's privilege, the standards applicable under Rules 26 and 45 have resulted in rejection of private litigants

d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00207349 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her

to the defendant's continued newsgathering effectiveness of preserving the source's confidentiality." Id. at 596-98.5 Even in Circuits that, unlike the Second Circuit, have not recognized a federal reporter's privilege, the standards applicable under Rules 26 and 45 have resulted in rejection of private litigants

witnesses to this action, as is standard practice by their office and others in this jurisdiction. See, e.g., Securities and Exchange Commission v. Carroll, 19 Civ. 7199 (AT), 2020 WL 1272287, at *1 (S.D.N.Y. Mar. 17, 2020); Securities and Exchange Commission v. Abraaj Investment Management Limited, 19

have been incorrect remains to be litigated; Ms. Maxwell is not asking this Court to decide that question today. But Ms. Maxwell is seeking in both the Second Circuit and before Judge Preska that the status quo be maintained until the issue can be litigated. If, for example, without the benefit of this informatio