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nfidential source and his unpublished interview therefore fell within the federal qualified privilege that governs non-confidential news material in the Second Circuit. Dist. Ct. Op. at 4 (quoting Gonzales v. NBC, 194 F.3d 29, 36 (2d Cir. 1999)). Applying the federal qualified privilege standard (which is signific
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
hat, in view of its importance. the tape was properly discoverable despite the claim of journalist privilege. The Daily News then took an appeal to the Second Circuit. While the appeal was pending, however, the underlying civil suit by Jane Does (as well as the other two girls) settled, leading to an automatic va
for three persons not involved in any Daily News reporting effort: a filmmaker, a social activist, and an attorney who had been following the case. Rush Aff. ¶ 6. Shortly after that meeting, one of the participants went to an investigator for Edwards' clients -- Michael Fisten -- and said, "My god, you'v
ction by the Daily News of the recording. I attach the Rush declaration hereto as Ex. 3. 3 EFTA00728446 7. The Daily News then took an appeal to the Second Circuit. While the appeal was pending, however, the underlying civil suits by the three girls settled, leading to an automatic vacation of the district cou
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] II 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste
Entities connected to both Second Circuit and Rush Aff

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
New York
LOCATION
Paul Cassell
PERSON
Kenneth Marra
PERSON
Bradley Cooper
PERSON
the United States District Court
ORGANIZATION
Alberto Gonzales
PERSON
Lawrence Krauss
PERSONScott Rothstein
PERSON
New York Daily News
ORGANIZATION
McKenna
PERSONFlorida Bar
ORGANIZATION
the Daily News
ORGANIZATION
Anne B. Carroll
PERSON
Michael Fisten
PERSON