Epstein Secrets

T C EFTA00207304 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH x No. 10 M8-85 (LMM) SUPPLEMENTARY AFFIDAVIT OF GEORGE RUSH STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) GEORGE RUSH, being duly sworn, depo

am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and Daily News journalist George Rush for an Order pursuant to Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe

reto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 17

hly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 1996). Gall

T C EFTA00612037 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH x No. 10 M8-85 (LMM) SUPPLEMENTARY AFFIDAVIT OF GEORGE RUSH STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) GEORGE RUSH, being duly sworn, depo

am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and Daily News journalist George Rush for an Order pursuant to Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe

reto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 17

hly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 1996). Gall

stantial punitive damages. In the fall of 2009, Michael Fisten, an investigator working for Edwards, heard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the recording for her and t

9 15 fn. 2 945 So.2d 1246 (Fla. 2006) 15 E.W. v. Epstein, Case No. 502008CA028XXXMBAB (Florida

pe was not protected by the journalist's privilege. (Judge McKenna's Opinion is attached as Ex. 5 to Lewis Aft). Applying Gonzales v. Nat 'I Broad. Co., Inc., 194 F.3d 29 (2d Cir. 1999) (Gonzales ///), the district court explained that a reporter's privilege extended even to non-confidential sources. The

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

2 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 disclosed

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

6 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 disclosed

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,

3 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 disclosed

mplaint in Razorback Funding, LLC, et aL v. Scott W. Rothstein, et aL, Case No. 09- 062943(19); see De

t Epstein, warranting Summary Judgment. 10 EFTA00799348 In Florida, "an action for malicious prosecution is a serious matter." Cent. Fla. Mach. Co., Inc. v. Williams, 424 So. 2d 201, 203 (Fla. 2d DCA 1983). Malicious prosecution actions are "not generally favored" in Florida. Id. at 202. There are si

However, the Plaintiff fails to discuss meaningfully the statute at issue or provide any authority relating to the claim Plaintiff seeks to assert. (W.) E. Negligence, wantonness and breach of fiduciary duty claims against BIC (Counts VIII-XI). BIC argues that the Plaintiffs negligence, wantonness

icited under these circumstances of confidence, Alabama courts will treat the statement as a fact reasonably relied upon. Id. Kaye v. Pawnee Const. Co., Inc., 680 F.2d 1360, 1367-68 (11th Cir. 1982) (footnote omitted); see Bryant Bank, 155 So. 3d at 239-40 (citing Kaye, 680 F.2d at 1368). As discussed ab

JANET E. GRAF, TRUSTEES 166 LAFAYETTE RD OF PLUM BUSH REAL SALISBURY. MA 01952-1507 19. DAVID J. HAR

urden under Rule 56(c) and, therefore, defendant is entitled to summary judgment on these claims. Travelers Cas. & Sur. Co. of Am. v. J.O.A. Const. Co., Inc., 479 Fed. Appx. 684, 692 (6th Cir. 2012) (citing Fed. R. Civ. P. 56(e)(2)-(3)). Accordingly, defendant's motion for summary judgment as to these cl

Rules of Civil Procedure. (Signed by Judge Robert W. Sweet on 9/29/2011) Filed In Associated Cases: 1

SAL WITH PREJUDICE x PLEASE TAKE NOTICE that the undersigned counsel for all parties hereby stipulate and agree that this action, Financial MG( Co., Inc. v. The Bear Stearns Cos. Inc., No. 10 Civ. 01226 (RWS), is hereby dismissed WITH PREJUDICE pursuant to Rule 41(a)(I )(A)(ii) of the Federal Rules o