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ew York by the attorney for the plaintiff in an action pending in the United States District Court for the Southern District of Florida, Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which plaintiff Jane Doe ("Doe") alleges that she was sexually abused by defendant Jeffrey Epstein when she was a minor (th
(the "Doe Action"); and WHEREAS the subpoenas sought a recording that reporter Rush had made of a 22-minute telephone interview he had conducted of Epstein and recorded on a digital hand-held device (the "Epstein Recording"), which the Daily News Parties assert is confidential material and which Jane D
for the Southern District of Florida, Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which plaintiff
es now believe in good faith that the May 20 Order is a final appealable order under 28 U.S.C. § 1291 and the doctrine set forth in United States v. Cuthbertson, 651 F.2d 189 (3d Cir. 1981) (the "Cuthbertson Doctrine"); and WHEREAS, in the alternative, if the Second Circuit does not find the May 20 Order t
erations omitted)). In order to initiate a proceeding with the Epstein Victims Compensation Fund, a victim must articulate a claim "directed against Epstein." (Indep. Epstein Victims' Compensation Program Protocol, Def. Mot. Ex. 1 Attachment A Ex. 1 at 3 (emphasis added)). And in that context, it would
d be treated identically to the specific requests for them, as discussed above. EFTA00090229 Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For
erations omitted)). In order to initiate a proceeding with the Epstein Victims Compensation Fund, a victim must articulate a claim "directed against Epstein." (Indep. Epstein Victims' Compensation Program Protocol, Def. Mot. Ex. 1 Attachment A Ex. 1 at 3 (emphasis added)). And in that context, it would
Page: EFTA00010122 →ally to the specific requests for them, as discussed above. EFTA00010124 --- PAGE BREAK --- Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For
Page: EFTA00010125 →Entities connected to both Jeffrey Epstein and Cuthbertson

Marc Rich
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Lawrence Krauss
PERSON
Department of Justice
ORGANIZATION
David Boies
PERSON
Audrey Strauss
PERSON
Chris Tucker
PERSONSecond Circuit
ORGANIZATIONChambers
PERSONReyes
PERSON
Alison J. Nathan
PERSON
Cynthia Nixon
PERSON
Brady
PERSON
Giglio
PERSON
McKenna
PERSONUlbricht
PERSONSkelos
PERSON