Epstein Secrets

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

New York Shield Law would then apply. Ste In re Application to Ouash Subpoena to National Broadcasting Co., 79 F.3d 346. 351. 352 (2d Cir. 1996) ("Graco") (applying New York Shield Law to state claims pending in Massachusetts federal court, noting the relevant standards of that law and the federal pr

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

New York Shield Law would then apply. Ste In re Application to Ouash Subpoena to National Broadcasting Co., 79 F.3d 346. 351. 352 (2d Cir. 1996) ("Graco") (applying New York Shield Law to state claims pending in Massachusetts federal court, noting the relevant standards of that law and the federal pr

mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat

alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were

made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar

d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi

poena must show that the information sought is ... unobtainable from other sources") (emphasis added); In re Application to Quash Subpoena to NBC ("Graco"), 79 F.3d 346, 353 (2d Cir. 1996) (rejecting lower court's conclusion that "because the material contained in the out-takes sought by Graco is sole