Epstein Secrets

that Rush had waived sa applicable reporter's privilege by disclosing brief portions of the Epstein interview to third parties (Balin Aff. Ex. K (Jane Doe's Response in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District

F.3d 62 (2d Cir. 1994) 13 Baxter v. Palmigiano, 425 U.S. 308 (1976) 21 Buttner v. Berg & Dorf, 138 ad 439, 525 MI.2d 858 (2d Dep't 1988) 19 Branzburg v. Hayes, 408 U.S. 665 (1972) 23 Brown & Williamson Tobacco CS E. v. Wigand, 1996 WL 350827 (Sup. Ct. OS Co. Feb. 28, 1996), affd, 228 ..2r1187,

Merriam-Webster Online (2010), /off-the-record ("`off-the-record': given or made in confidence and not for publication <off-the-record comments>"); Branzburg v. Hayes, 408 U.S. 665, 728 (1972) (Stewart J., dissenting) (defining "confidentiality" as "the promise or understanding that names or certain aspects of co

udge Netburn's Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently,

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00077710 supervision

udge Netburn's Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently,

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00039525 supervision

dge Netburn's Order On or about April 9, 2019, the Government advised Judge Netburn, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. 1). Subsequently,

ons, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 102 Boyd v. United States, 116 U.S. 616 (1886) 101 iv EFTA00095071 Branzburg v. Hayes, 408 U.S. 665 (1972) 78 Bridges v. United States, 346 U.S. 209 (1953) 38 Bronston v. United States, 409 U.S. 352 (1973) 121 Bryson

INIMIIIIM the definfrOn the defendant's motion for summary judgment. (See 15 Civ. 7443 (LAP), Dkt. No. 542-4). Giuffre has since self-identified as Jane Doe #3. (See id., Dkt. No. 23 n.2). 117 EFTA00095209 As described in the preceding section, in the fall of 2015, Giuffre sued the defendant for defa

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the lon

udge Netburn's Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently,

s v. Calandra, 414 U.S. 338, 343 (1974)). "Wide latitude in gathering evidence is vital to the grand jury's investigative function." Id. at 422; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the 78 EFTA00103103 supervision

im to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carroll Reply Dec1.1 6). Further bolstering Doe's claims in the underlying case is the fact that evidence of sexual abu

to non-party subpoenas in private civil disputes. Lee v. Department of Justice. 413 F.3d 53, 58 (D.C. Cir. 2005) (limiting "the applicability of the Branzburg precedent to the circumstances considered by the court in Branzburg-that is. the context of a criminal proceeding, or even more specifically, a gra

a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et al. ("Jane Doe"), 17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A. Background As desc

such investigations it may compel the production of documentary evidence or the testimony of witnesses, as it deems necessary." Id. at 421-22; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the longstanding

the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et aL ("Jane Doe"), 17 Civ. 616 (

such investigations it may compel the production of documentary evidence or the testimony of witnesses, as it deems necessary." Id. at 421-22; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the lon