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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
has held that, when faced with a combination of federal claims and pendent state law claims, federal common law controls under Rule 501. Hancock v. Dodson, 958 F.2d 1367, 1372-73 (6th Cir. 1992) ("Since the instant case is a federal question case by virtue of the appellant's section 1983 claim, we hold
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
has held that, when faced with a combination of federal claims and pendent state law claims, federal common law controls under Rule 501. Hancock v. Dodson, 958 F.2d 1367, 1372-73 (6th Cir. 1992) ("Since the instant case is a federal question case by virtue of the appellant's section 1983 claim, we hold
] to be as gracious in defeat as was George H.W. Bush in 1992, the last time an incumbent was defeated.
ump] to be as gracious in defeat as was George H.W. Bush in 1992, the last time an incumbent was defe
son "says the police department in conjunction with the FBI Drug Task Force executed two coordinated simultaneous search warrants Thursday morning. Dodson says the warrants are in relation to an on-going drug-trafficking investigation inside the city of Centralia." According to WJBD-AM, "The Centralia
) to be as gracious in defeat as was George H.W. Bush in 1992, the last time an incumbent was defeated.
ump) to be as gracious in defeat as was George H.W. Bush in 1992, the last time an incumbent was defe
son "says the police department in conjunction with the FBI Drug Task Force executed two coordinated simultaneous search warrants Thursday morning. Dodson says the warrants are in relation to an on-going drug-trafficking investigation inside the city of Centralia." According to WJBD-AM, "The Centralia
) to be as gracious in defeat as was George H.W. Bush in 1992, the last time an incumbent was defeated.
ump) to be as gracious in defeat as was George H.W. Bush in 1992, the last time an incumbent was defe
son "says the police department in conjunction with the FBI Drug Task Force executed two coordinated simultaneous search warrants Thursday morning. Dodson says the warrants are in relation to an on-going drug-trafficking investigation inside the city of Centralia." According to WJBD-AM, "The Centralia
tice requires." Id.; see also Logitech Cargo v. J.W. Perry, 817 So. 2d 1033 (Fla. 3d DCA 2002). 15.
void costly litigation, and to achieve a balanced search for the truth to ensure a fair trial." Elkins v. Syken, 672 So. 2d 517 (Fla. 1996) (citing Dodson v. Pend!, 390 So. 2d 704 (Fla. 1980); Suif Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970)). -"S ,r‘ II. In Elkins, the Florida Supreme Court
ers' website. Holdings: The District Court, Paul W. Grimm, United States Magistrate Judge, held tha
and finding that "it also would be impractical to apply two different rules of priv- ilege to the same evideny before a single jury."); Hancock . Dodson, 958 F.2d 1367, 1373 (6 Cir.1992) (holding that the existence of pen- dent state claim did not relieve the Court of its obligation to apply the
Entities connected to both George W. Bush and Dodson

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