Epstein Secrets

ed by counsel for the plaintiff in an action pending in the United States District Court for the Southern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plaintiff seeks to recover damages arising out of the defendant's alleged sexual abuse of her when she was a mino

endant's alleged sexual abuse of her when she was a minor. The subpoenas seek the production of "[ail' taped conversations between George Rush and Jeffrey Edward Epstein, including telephone recordings, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the t

a weekly columnist in the Daily News, that in the fall of 2009 he began to follow criminal and civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010, Ex. G) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of

outhern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plainti

d civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7,

EFTA00725412 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

ed by counsel for the plaintiff in an action pending in the United States District Court for the Southern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plaintiff seeks to recover damages arising out of the defendant's alleged sexual abuse of her when she was a mino

endant's alleged sexual abuse of her when she was a minor. The subpoenas seek the production of "(ail' taped conversations between George Rush and Jeffrey Edward Epstein, including telephone recordings, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the t

a weekly columnist in the Daily News, that in the fall of 2009 he began to follow criminal and civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010, Ex. G) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of

outhern District of Florida entitled Jane Doe v. Jeffrey Epstein (08 Civ. 80893 KAM), in which the plainti

d civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7,

EFTA00726066 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

3)(United States District Court, S.D. Fl.); v. Jeffrey Epstein (Case No. 502008CA028051XXXXMB AB)(Florida Circuit Court, 15th Judicial Circuit). v. Jeffrey Epstein (Case No. 502008CA028058XXXXMB ABXFlorida Circuit Court, 15th Judicial Circuit). 3. In December 2009, Epstein brought a vendetta action against me

itution in Florida. Subsequently, Bradley James Edwards, a Florida lawyer, brought civil actions on behalf of several girls alleging molestation by Epstein while they were minors. Jane Doe v. Jeffrey Epstein, (08- 80893)(United States District Court, S.D. Fl.); E v. Jeffrey Epstein (Case No. 502008CA

endant's alleged sexual abuse of her when she was a minor. The subpoenas seek the production of "(a)11 taped conversations between George Rush and Jeffrey Edward Epstein, including telephone recordings, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the t

n between George Rush, one of its reporters, and Jeffrey Epstein, and granting such other relief as the C

d civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7,

EFTA00728463 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

pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff Jane Doe has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this

prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[

on PACER. S.D. Fla. Civil Docket for Jane. Doe v. Jeffrey Epstein. Case # 9:08-cv- 80893-KAM ("Docket"), DE

on that any of those people . . . have spoken to Mr. Epstein about Jane Doe or any of the other specific victi

kind of evidence that would justify a burden- some incursion on the Daily News' and Rush's newsgathering. See In re Application to Ouash Subpoena to Nat'l Broad. Co., 79 F.3d at 353 (rejecting lower court's conclusion that "because the material contained in the out-takes sought by Graco is solely in the hands

ve Order pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this

prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[

found on PACER. S.D. Fla. Civil Docket for ME v. Jeffrey Epstein, Case # 9:08-cv- 80893-KAM ("Docket"), DE

on that any of those people . . . have spoken to Mr. Epstein about or any of the other specific victims," Edw

kind of evidence that would justify a burden- some incursion on the Daily News' and Rush's newsgathering. See In re Application to Ouash Subpoena to Nat'l Broad. Co., 79 F.3d at 353 (rejecting lower court's conclusion that "because the material contained in the out-takes sought by Graco is solely in the hands