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motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein.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ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R

Doe Action as the basis for his argument that he too is similarly entitled to production of the Epstein interview for use in the Ponzi Scheme $ As Pennzoil and Sheehan illustrate, where (as here) a party files a New York proceeding seeking discovery of newsgathering material from a New York news organiz

by “Jim” Jiminez, an upbeat guy I liked. | don’t think he took the red-ink problems home with him as Cap Balfour had. He reported to my half-brother George at corporate headquarters in Los Angeles, and George reported to my father in London. George had earned his job as president by outstanding performan

erence”; we value satisfactions now over foreseen ones later. This is not quite the same as the difference between birds in the hand and birds in the bush. That says that we value certainties over probabilities. Time preference also values Chapter 3: Foundations 1/11/16 3 HOUSE_OVERSIGHT_010974 pres

over the company. The required public disclosure of this, on top of the tripartite agreement and co-trustee lawsuit before, was blood in the water. Pennzoil launched a hostile takeover bid in December. My concern was that the trust should not be locked in a minority position. | met with Pennzoil in New Yo

By: /s/ Deputy Clerk Copies to: Hon. Geoffrey W. Barnard Gregory H. Hodges, Esq. Maria Tankenson

t purposely availed itself of the privilege of conducting business within the forum State, thus invoking the protection and benefits of its laws.'" Pennzoil Prods. Co. v. Colelli & Assocs., Inc., 149 F.3d 197, 203 (3d Cir. 1998). A plaintiff can meet this burden in one of two ways: by establishing spec