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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 (LLM) REPLY MEMORANDUM OF LAW OF DAILY NEWS, L.P., AND DAILY NEWS JOURNALIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBP

nt of Justice 413 F.3d 53 (D.C. Cir. 2005) 2 L.W. ex rel. Whitson v. Knox County Bd. of Educ. 36 M

giano 425 U.S. 308 (1976) 7 Bellefonte Re Ins. Co. v. Argonaut Ins. Co. 757 F.2d 523 (2d Cir. 1985) 12 Best Canvas Products & Supplies. Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618 (II th Cir. 1983) 12 Brink's Inc. v. City of New York 717 F.24 700 (2d Cir. 1983) 7 Drown & Williamson Tobacco Coro. v. Wiga

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 (LLM) REPLY MEMORANDUM OF LAW OF DAILY NEWS, L.P., AND DAILY NEWS JOURNALIST GEORGE RUSH IN SUPPORT OF THEIR MOTION TO QUASH SUBP

nt of Justice 413 F.3d 53 (D.C. Cir. 2005) 2 L.W. ex rel. Whitson v. Knox County Bd. of Educ. 36 M

giano 425 U.S. 308 (1976) 7 Bellefonte Re Ins. Co. v. Argonaut Ins. Co. 757 F.2d 523 (2d Cir. 1985) 12 Best Canvas Products & Supplies. Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618 (II th Cir. 1983) 12 Brink's Inc. v. City of New York 717 F.24 700 (2d Cir. 1983) 7 Drown & Williamson Tobacco Coro. v. Wiga

av , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagl

merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation

av , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagl

merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation

av , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagl

merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation

ay , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orsecic, P.A. 25 West Flag

merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation

av , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagl

merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation