Epstein Secrets

e counsel a copy of the interview recording. (Id. 1 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C) 1 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, a

2 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III") .2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confidential: Mr. Rush disclosed

e counsel a copy of the interview recording. (Id. 1 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C) 1 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, a

6 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III") .2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confidential: Mr. Rush disclosed

e counsel a copy of the interview recording. (Id. I 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C] I 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, a

3 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III").2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confidential: Mr. Rush disclosed