Epstein Secrets

ated June 23, 2010 (Stein, J.), and entered on June 25, 2010, adjudging them in civil contempt of the Memorandum and Order entered on May 21, 2010 (McKenna, J.) by reason of the Daily News Parties' refusal to consent to the production of certain newsgathering material that was ordered to be produced in

New York June 28, 2010 Respectfully submitted, DAVIS WRIGHT TREMAINE LLP By: 7_Atat Laura it Handman Robert D. Balin 1633 Broadway rk 10019 Anne B. Carroll Daily News, L.P. Deputy General Counsel 450 West 33rd Street, 3rd Floor DWT 141190929vI 3970112-000042 EFTA00723406 w k10001 Attorneys for A

2 tel fax 1633 Broadway 10019-6708 Re: In re Application to Quash Subpoena to Daily News, L.P. and George Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist George Rush. They have moved to quash subpoenas for deposition testimony and docum

equest for additional pages for the Movants' Reply. Thank you for your consideration in this matter. : Si rely yours, Si Laura R. !Landman cc: Anne B. Carroll, Esq. (via e-mail) Paul G. Cassell, Esq. (via e-mail) Anchorage New York Seattle Bellew. Portland:, Shanghai Los Arktelm San Franccco Was

nally required, or rooted in federal common law"); Persky v. Yeshiva Univ. No. 01 Civ. 4278 (LMM), 2002 WL 31769704, at *2 (S.D.N.Y. Dec. 10, 2002) (McKenna. J.) ("This circuit has long recognized the existence of a qualified privilege for journalistic information. This privilege is based. at least in p

LIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBPOENAS SERVED ON THEM IN A FLORIDA LITIGATION OR IN THE ALTERNATIVE FOR A PROTECTIVE ORDER Anne B. Carroll, Esq. The Daily News L.P. 450 West 33"I Street New York. NY 10001-2631 Laura R. Handman. Esq. Davis Wright Tremaine LLP 1633 Broadway New York

- Jane Doe -- filed a proper subpoena for the tape in the U.S. District Court for the South District of New York. In June 2010, the District Court (McKenna, J.,) denied the Daily News' motion to quash the subpoena, finding that in view of its importance, the tape was properly discoverable despite the c

ngs, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the testimony of George Rush and Anne B. Carroll, a Vice President and General Counsel of Daily News, L.P. (Carroll Decl., Apr. 7, 2010, Exs. A & B.) In the alternative, the subpoenaed parties see

called Edwards' investigator and said, "My god, you've [got to] get this tape. [Epstein] talks about the girls." Fisten Aft at I 3. Similarly, Judge McKenna — who had the benefit of listening to the recording' — specifically ruled that the recording contains statements that are "of likely relevance to a

copy of the foregoing Reply Memorandum of Law in Further Support of Motion for CPLR 3102(e) Order dated November 11, 2010 upon: DAILY NEWS, L.P. Anne B. Carroll (AC-5322) Deputy General Counsel 450 West 33"I Street, 3n° Floor 10001 Attorneys for Daily News, L.P. and George Rush A copy was also sent via

Y 10019-6708 tel fax [email protected] Re: In re Application to Quash Subpoena to Daily News, L.P. and Rush, No. 10-M8-85 (LMM) Dear Judge McKenna: I write as counsel to non-party Daily News, L.P. and journalist Rush. They have moved to quash subpoenas for deposition testimony and documents s

equest for additional pages for the Movants' Reply. Thank you for your consideration in this matter. : Si rely yours, Si Laura R. !Landman cc: Anne B. Carroll, Esq. (via e-mail) Paul G. Cassell, Esq. (via e-mail) Anchorage New York Seattle Bellew. Portland:, Shanghai Los Arktelm San Franccco Was

nally required, or rooted in federal common law"); Persky v. Yeshiva Univ. No. 01 Civ. 4278 (LMM), 2002 WL 31769704, at *2 (S.D.N.Y. Dec. 10, 2002) (McKenna. J.) ("This circuit has long recognized the existence of a qualified privilege for journalistic information. This privilege is based. at least in p

LIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBPOENAS SERVED ON THEM IN 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 EFTA

se in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District Court (McKenna, J.) did not accept Edwards' waiver argument; but, instead, ruled that, since Epstein was known to be the source for the interview, he was a non- co

Robert D. Balin Victor Hendrickson 1633 Broadway — 27th Floor New York, NY 10019 Tel: (212) 489-8230 Attorneys for Daily News,.. Of Counsel: Anne B. Carroll Deputy General Counsel Daily News, 450 West 33rd Street New York, NY 10019 Tel: (212) 210-2341 922 A.2d at 1275 (2007) (noting in dicta that no