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motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein.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ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

5=.2d 919 (Sup. Ct... Co. 2001) In re Application to Quash Subpoena to NBC 79 F.3d 346 (2d Cir. 1996) In re Behar, 779 F. Supp. 273 1991) In re CBS Inc., 232..2d 291, 648 In re Pennzoil Co.. 108.1.2d 666, 485 29 25 14,19 22,24 21,25 26 .2d 443 (1st Dep't 1996) .2d 533 (1st Dep't 1985) In

and indispensable party. See, e.g., Hon. William W. Schwarzer et al., Federal Civil Procedure Before

v. Beck's Est., 129 F.2d 243, 245 (2d Cir. 1942))). Where, as here, the language Congress used is clear and unambiguous, our inquiry is complete. CBS Inc. it PrimeTime 24 Joint Venture, 245 F.3d 1217, 1222 (11th Cir. 2001). We are bound to "presume that Congress said what it meant and meant what it s

-W- C. e-pecli lay Robert r Jose e g Katherine W. Ezell Attorneys or Plaintiff Podhurst Orseck, P

ture said what it means and means what it said, and not add language or give some absurd or strained interpretation. As stated in 2 EFTA00233491 CBS Inc. supra at 1228 — "Those who ask courts to give effect to perceived legislative intent by interpreting statutory language contrary to its plain and un