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y News filed a motion to quash, claiming that the tape recording is somehow protected by a journalist's privilege. In June 2010, the District Court (McKenna, J.,) rejected that argument, finding that, in view of its importance. the tape was properly discoverable despite the claim of journalist privilege
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 journalist's privilege
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
- 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
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
n application for recusal. 'In a separate unreported case Poe v. Epstein in which a young woman sued Epstein in connection with underage sex, Judge McKenna of the New York District Court Southern District of New York, found sufficient relevance to order the tape released, but the case was settled first
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK I.A.S. PART 17 X In the Matter of the Application of BRADLEY JAMES EDWARDS SEEKING CPLR 3102(e) ORDER FOR DAILY NEWS, ■. TO PRODUCE TAPE RECORDING X Index No. 112345/10 EMILY JANE GOODMAN, J.S.C.: Bradley, a Florida lawyer, moves pursuant
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
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
Entities connected to both McKenna and CPLR 3102(e

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONSecond Circuit
ORGANIZATIONJane Doe
PERSONthe Southern District
LOCATION
New York Daily News
ORGANIZATION
Bradley Cooper
PERSONScott Rothstein
PERSON
Anne B. Carroll
PERSON
New York
LOCATION
Ghislaine Maxwell
PERSON
Paul Cassell
PERSON
Michael Fisten
PERSON
Alberto Gonzales
PERSON
the United States District Court
ORGANIZATION
Goldman Sachs
ORGANIZATIONRobert Y. Lewis
PERSON
Lawrence Krauss
PERSON
Kenneth Marra
PERSON