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

bpoenas. even without regard to privilege, have not been met. (ag Point 1, supra.) Second as a matter of law, absent publication of the Ig See also Altemose Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) (concluded that affidavits in the possession of television news staff ret

Id. This is unique and direct evidence of Epstein's lack of remorse that is not cumulative of anything else Edwards can present' 7 In its brief to the Second Circuit on the "Jane Doe" case, the Daily News claimed that Epstein's recording "shows little more than a defendant, charged in multiple actions with commit

from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores v. Cooper Tire and Rubber Co., 178P.Id 1176, 1183 (Ariz. App.

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

bpoenas. even without regard to privilege, have not been met. (ag Point 1, supra.) Second as a matter of law, absent publication of the Ig See also Altemose Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) (concluded that affidavits in the possession of television news staff ret