Epstein Secrets

f. Ex. M (Memorandum & Order dated May 18, 2010 ("Dist. Ct. Op.")), at 1. Thereafter, the Daily News and Rush instituted an ancillary proceeding in the Southern District of New York to quash the subpoenas on the ground (among others) that Jane Doe could not overcome the federal reporter's privilege. In opposition to

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

45(c) (3)(A)(iii), for an order quashing subpoenas issued by counsel for the plaintiff in an action pending in the United States District Court for the Southern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plaintiff seeks to recover damages arising out of the defendant's

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) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste

45(c) (3)(A)(iii), for an order quashing subpoenas issued by counsel for the plaintiff in an action pending in the United States District Court for the Southern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plaintiff seeks to recover damages arising out of the defendant's

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) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste

motion to quash, claiming that the recording was somehow protected by a journalist's privilege. Jane Doe responded, and the U.S. District Court for the Southern District of New York (McKenna, J.) held a hearing and listened to the tape in camera. The district court then ruled that the tape was not protected by the j

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

5(c) (3)(A) (iii), for an order quashing subpoenas issued by counsel for the plaintiff in an action pending in the United States District Court for the Southern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plaintiff seeks to recover damages arising out of the defendant's

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