Epstein Secrets

submits this memorandum of law in opposition to Bradley J. Edwards' motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillary discovery proceeding, a civil litigant —

ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

on a digital recording device. Id. During the interview, Epstein made no material admissions regarding the young women suing him for sexual abuse. Rush Supp. Aff. ¶¶ 4-5. So too, because the interview took place months before Epstein filed the Ponzi Scheme Action (and before Rothstein was even publicly

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH McKENNA, D.J., M8-85 MEMORANDUM AND ORDER 1. Daily News, L.P., the publisher of the Daily News, and George Rush, a Daily News reporter, move, p

e counsel a copy of the interview recording. (Id. 1 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C) 1 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, a

EXHIBIT M EFTA00726063 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, AND GEORGE RUSH McKENNA, D.J., M8-85 MEMORANDUM AND ORDER 1. Daily News, III., the publisher of the Daily News, and George Rush, a Daily News reporter, move, p

e counsel a copy of the interview recording. (Id. 1 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C) 1 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, a

y in Interest-Appellee. AMENDED ORDER Docket No. 10-2438 (L) 10-2573 (con) IT IS HEREBY ORDERED that the motion by Appellants Daily News L.P. and George Rush to d ism i ss the consolidated appeals as moot and to vacate the district court orders of May 21,2010 and June 25, 2010 is GRANTED. FOR THE COURT,

e counsel a copy of the interview recording. (Id. I 8.) Mr. Rush subsequently corrected the date of the interview to "prior to October 22, 2009." (Rush Supp. Aff., Apr. 30, 2010 [Carroll Reply Decl., May 3, 2010, Ex. C] I 2.) At the outset of the interview, Mr Epstein said that it was off-the-record, a

on: DAILY NEWS, L.P. Anne B. Carroll (AC-5322) Deputy General Counsel 450 West 33"I Street, 3n° Floor 10001 Attorneys for Daily News, L.P. and George Rush A copy was also sent via first-claim mail to Jack Alan Goldberger ATfERBURY GOLDBERG & WEISS, P.A. 250 Australian Avenue South, Suite 1400 FL 33

ourt conclude that "Epstein made no material admissions regarding the young women suing him for sexual abuse." Daily News Memo. of Law at 6 (citing Rush Supp. Aff. 7 4-5) (emphasis in original). This conclusory assertion is flatly inaccurate, as others who have listened to the recording have explained. On