Epstein Secrets

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

bpoenas. even without regard to privilege, have not been met. (ag Point 1, supra.) Second as a matter of law, absent publication of the Ig See also Altemose Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) (concluded that affidavits in the possession of television news staff ret

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

bpoenas. even without regard to privilege, have not been met. (ag Point 1, supra.) Second as a matter of law, absent publication of the Ig See also Altemose Constr. Co. v. Building & Constr. Trades Council 443 F. Supp. 489 (E.D. Pa. 1977) (concluded that affidavits in the possession of television news staff ret

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

from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores v. Cooper Tire and Rubber Co., 178P.Id 1176, 1183 (Ariz. App.