Epstein Secrets

by Playing It for Three People and Describing It in Detail to Others 11 II. ANY QUALIFIED JOURNALIST'S PRIVILEGE OF THE DAILY NEWS IS OVERCOME BY JANE DOE'S CLEAR AND COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE AND LACK OF REMORSE 13 i EFTA00728062 A. The Epstein In

ry its burden of showing proper justification for refusing to produce these highly relevant tapes for two simple reasons. 2 EFTA00728067 First, the Daily News' reporter, George Rush, has waived whatever privilege might attach to the recording by playing a significant portion of the recording to three people

girls) had happened in New York, he (Epstein) would have received only a $200 fine (id); • Epstein made very negative and derogatory comments about Jane Doe's attorney Brad Edwards and that Edwards was the one causing all of Epstein's problems (i.e., the civil suits brought by Jane Doe and other girls) (i

prosecuted on behalf of ■. ARGUMENT I. THE DAILY NEWS HAS WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS. 6 The counterclaim is attached to the Daily News' Balin Aft: at Ex. B. 5 EFTA00729042 In his opening brief, Edwards' lead argument was that the Daily News has waived any privilege by disclosing

the Southern District of New York (the "Jane Doe Action"). 13. Annexed hereto as Exhibit "K" is a true and correct copy of Real Party In Interest Jane Doe's Response in Opposition to Motion of Daily News, L.P. to Quash Subpoenas, with exhibits, dated April 29, 2010, that was submitted in the Jane Doe Act

ounds for denying Edwards' motion are fully set forth in the accompanying memorandum of law. I submit this affirmation to annex exhibits relevant to the Daily News' opposition. 3. Annexed hereto as Exhibit "A" is a true and correct copy of the Complaint of Jeffrey Epstein, with Exhibits 1 and 2, that was file