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

, 3rd Floor New York, New York 10001 }am ali__ Laura R. Handman, Esq. Davis Wright Tremaine LLP 1633 Broadway New York, NY 10019 Attorneys for Movants Daily News, L.P. and George Rush -19- EFTA00207355

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

0 West 33rd Street, 3rd Floor , ,bki,J2 d/2 Åa-- IIS Laura R. Handman, Esq. Davis Wright Tremaine LLP 1633 Broadway New Y 9 Attorneys for Movants Daily News, LP. and George Rush -19- EFTA00728032

ring served on them by plaintiff in an action pending in the United States District Court for the Southern District of Florida captioned Jane Doe v. Jeffrey Epstein, No. 08-cv-80893-KAM, based on the qualified reporter's privilege accorded by the First Amendment to the United States Constitution and federal comm

istrict of Florida captioned Jane Doe v. Jeffrey Epstein, No. 08-cv-80893-KAM, based on the qualified repo

outhern District of Florida captioned Jane Doe v. Jeffrey Epstein, No. 08-cv-80893-KAM, based on the quali

a R. Handman, Esq. Davis Wright Tremaine LLP oY rk, 0019 Anne B. Carroll (AC-5322) Deputy General Counsel New Yorl New York 10001 Attorneys for Movants Daily News, L.P. and George Rush TO: Bradley James Edwards FARMER WESSING EDWARDS Fort Lauderdale. Florida 33301 Paul G. Cassell S.J. QUINNEY COLLEGE OF