Epstein Secrets

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

passim N.Y. Civil Rights Law § 79-h(g) (McKinney 2010) 11, 14 iv EFTA00728065 PRELIMINARY STATEMENT Bradley Edwards seeks an order pursuant to CPLR 3102(e) for production of a tape recording of a conversation between a Daily News reporter and billionaire Jeffrey Epstein concerning Epstein's molestatio

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

man Lewis LLP, with offices at 228 East 45th Street, in Manhattan, New York. I submit this Affirmation in support of motion for an order pursuant to CPLR 3102(e) for production of a certain tape recording of an interview by George Rush, a Daily News reporter, of Jeffrey Epstein, a party to an action pending

ourt Southern District of New York, found sufficient relevance to order the tape released, but the case was settled first, mooting the action, and, the Second Circuit thereafter vacated Judge McKenna's decision. EFTA00595560 young women who, as minors, were allegedly sexually abused and/or exploited by Epstein

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK I.A.S. PART 17 X In the Matter of the Application of BRADLEY JAMES EDWARDS SEEKING CPLR 3102(e) ORDER FOR DAILY NEWS, ■. TO PRODUCE TAPE RECORDING X Index No. 112345/10 EMILY JANE GOODMAN, J.S.C.: Bradley, a Florida lawyer, moves pursuant

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

rneys for Daily News, L.P. ("Daily News"). I submit this affirmation in opposition to the motion of Bradley James Edwards for an order, pursuant to CPLR 3102(e), compelling the Daily News to produce a certain audio recording. 2. The grounds for denying Edwards' motion are fully set forth in the accompanyi

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

2093 (S.C. Ct. Common Pleas July 20, 1994) 29 Yoder v. Adriatic°, 459 So.2d 449 (Fla. Dist. Ct. App. 1984) 18 STATUTES CPLR 3101(a)(4) passim CPLR 3102(e) 11, 1 2 MI Civil Rights Law § 79-h passim OTHER AUTHORITIES Carl C. Monk, Evidentiary Privilege for Journalists' Sources: Theory and Statutory