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motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein.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ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R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

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
New York
LOCATIONScott Rothstein
PERSON
Harvey Weinstein
PERSON
Bradley Cooper
PERSON
Bernie Sanders
PERSON
J. Robert Oppenheimer
PERSON
Southern District of New York
ORGANIZATION
Sergey Brin
PERSON
Alberto Gonzales
PERSON
New York Daily News
ORGANIZATION
The New York Times
ORGANIZATION
Murphy
PERSON
Clark
PERSON
James Patterson
PERSONSecond Circuit
ORGANIZATION