Epstein Secrets

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

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

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

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

ber 1, 2010. II . Annexed hereto as Exhibit "I" is a true and correct copy of the Non-Prosecution Agreement between the United States Attorney for the Southern District of Florida and Jeffrey Epstein, executed by Epstein on September 24, 2007. 12. Annexed hereto as Exhibit "J" is a true and correct copy of the Aff

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

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

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