Epstein Secrets

Ip Da ght Trevis maiWneri LLP May 3, 2010 VIA HAND DELIVERY Hon. Lawrence M. McKenna United States District Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Laura R. Handman Suite 200 1919 Pennsylvania Avenue NW Washington, DC 20006-3

2 tel fax 1633 Broadway 10019-6708 Re: In re Application to Quash Subpoena to Daily News, L.P. and George Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist George Rush. They have moved to quash subpoenas for deposition testimony and docum

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, in the City of New York, on the 28i° day of July, two thousand and ten. Before: Dennis Jacobs, Chief

- Jane Doe -- filed a proper subpoena for the tape in the U.S. District Court for the South District of New York. In June 2010, the District Court (McKenna, J.,) denied the Daily News' motion to quash the subpoena, finding that in view of its importance, the tape was properly discoverable despite the c

Ip Da ght Trevis maiWneri LLP May 3, 2010 VIA HAND DELIVERY Hon. M. McKenna United States District Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Laura R. Handman Suite 200 1919 Pennsylvania Avenue NW Washington, DC 20006-3

Y 10019-6708 tel fax [email protected] Re: In re Application to Quash Subpoena to Daily News, L.P. and Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist Rush. They have moved to quash subpoenas for deposition testimony and documents s