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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
96), a leak of confidential interview transcripts from CBS to the New York Daily News during the epic face-off between 60 Minutes and whistleblower Jeffrey Wigand on one side and the Brown & Williamson Tobacco Company on the other, did not waive CBS's privilege in the documents under the Shield Law except as t
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
96), a leak of confidential interview transcripts from CBS to the New York Daily News during the epic face-off between 60 Minutes and whistleblower Jeffrey Wigand on one side and the Brown & Williamson Tobacco Company on the other, did not waive CBS's privilege in the documents under the Shield Law except as t
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
ld that a leak of confidential interview transcripts from CBS to the New York Daily News during the epic battle between 60 Minutes and whistleblower Jeffrey Wigand on one side and the Brown & Williamson Tobacco Company on the other, did nor waive CBS's privilege in the documents under the New York Shield Law e
Entities connected to both Jeffrey Epstein and Jeffrey Wigand

George W. Bush
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
New York
LOCATION
Bradley Cooper
PERSONScott Rothstein
PERSON
Sergey Brin
PERSON
Harvey Weinstein
PERSON
Bernie Sanders
PERSON
Southern District of New York
ORGANIZATIONNicholas
PERSON
Alberto Gonzales
PERSON
J. Robert Oppenheimer
PERSONSecond Circuit
ORGANIZATION
New York Daily News
ORGANIZATION
The New York Times
ORGANIZATION
James Patterson
PERSON
Clark
PERSON