Epstein Secrets

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

6, 7. The additional topics that Rush agrees may have been discussed with an investigator working with counsel which Rush has now recalled in his Supplementary Affidavit fl 2, 3, do not materially alter the contours of the issues before the Court with regard to waiver. But, in any event, with his recollecti

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

. The additional topics that Rush agrees may have been discussed with an investigator working with Doe's counsel which Rush has now recalled in his Supplementary Affidavit fl 2, 3, do not materially alter the contours of the issues before the Court with regard to waiver. But, in any event, with his recollecti

Annexed hereto as Exhibit "N" is a true and correct copy of the Amended Order, dated July 28, 2010, that was issued by the U.S. Court of Appeals for the Second Circuit in the appeal in the Jane Doe Action. 17. Annexed hereto as Exhibit "O" is a true and correct copy of the Judgment against Scott W. Rothstein tha

ith exhibits, dated April 29, 2010, that was submitted in the Jane Doe Action. 14. Annexed hereto as Exhibit "L" is a true and correct copy of the Supplementary Affidavit of George Rush, sworn to April 30, 2010, that was submitted in the Jane Doe Action. 15. Annexed hereto as Exhibit "M" is a true and corr