Epstein Secrets

dentiary hearing served on them by plaintiff in an action pending in the United States District Court for the Southern District of Florida captioned Jane Doe v. Jeffrey Epstein, No. 08-cv-80893-KAM, based on the qualified reporter's privilege accorded by the First Amendment to the United States Constitut

affidavit and other papers must be served no later than May 4, 2010. Dated: New York, New York May 4, 2010 Respectfully submitted, ( -40414assie Laura R. Handman, Esq. Davis Wright Tremaine LLP oY rk, 0019 Anne B. Carroll (AC-5322) Deputy General Counsel New Yorl New York 10001 Attorneys for Movants Dail

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

N A FLORIDA LITIGATION OR IN THE ALTERNATIVE FOR A PROTECTIVE ORDER Anne B. Carroll, Esq. The Daily News L.P. 450 West 33rd Street N 10001-2631 Laura R. Handman, Esq. Davis Wright Tremaine LLP 1633 Broadway i rlia 10019 EFTA00207332 TABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT. 1

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

production of the Epstein interview recording should be denied. Dated: New York, New York November I, 2010 DAVIS WRIGHT TREMAINE LLP By: "II, - Laura R. Handman Robert D. Balin Victor Hendrickson 1633 Broadway — 27th Floor New York, NY 10019 Tel: (212) 489-8230 Attorneys for Daily News,.. Of Counsel: