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motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein.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ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

sclosing brief portions of the Epstein interview to third parties (Balin Aff. Ex. K (Jane Doe's Response in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District Court (McKenna, J.) did not accept Edwards' waiver argument; but, i

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

Mr. Rush's interview of Mr. Epstein. (Fisten Aff., Apr. 23, 2010 [Real Party in Interest Jane Doe's Resp. in Opp'n to Mot. of Daily News, L.P., to Quash Subpoena, Ex. B] 1 3.) Mr. Rush paraphrased the interview relatively thoroughly. (Id. 1 7.) 4. As noted above, the present motion has been argued on the

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

about Mr. Rush's interview of Mr. Epstein. (Fisten Aff., Apr. 23, 2010 [Real Party in Interest Jane Doe's Resp. in Opp'n to Mot. of Daily News, to Quash Subpoena, Ex. B] 1 3.) Mr. Rush paraphrased the interview relatively thoroughly. (Id. 1 7.) 4. As noted above, the present motion has been argued on the

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,

Mr. Rush's interview of Mr. Epstein. (Fisten Aff., Apr. 23, 2010 [Real Party in Interest Jane Doe's Resp. in Opp'n to Mot. of Daily News, L.P., to Quash Subpoena, Ex. B] 1 3.) Mr. Rush paraphrased the interview relatively thoroughly. (Id. 1 7.) 4. As noted above, the present motion has been argued on the

of normal adolescent ideals." (Emphasis Added). W. Epstein is also entitled to know, among other thi

4/13/2009 32 ENDORSED ORDER granting (73) Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order and to Quash Subpoena for Deposition of Jane Doe No. 3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of Law in Support in case 9:08