Epstein Secrets

uant to 28 U.S.C. § 1746, Anne B. Carroll declares as follows: 1. I am Vice President and General Counsel of movant Daily News, L.P., publisher of the New York Daily News (the "Daily News"). I am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and

rial in a Cir0 Action UNITED STATES DISTRICT COURT for the Southern District of New York In Re: Application to Quash Subpoenas Plaintiff v. to Daly News, L.P. and George Rush Defendant Civil Action No. 10 MB-85 SUBPOENA TO APPEAR AND TESTIFY AT A HEARING OR TRIAL EN A CIVIL ACTION To: George Rush

. Annexed hereto as Exhibit A is a true and correct copy of E & J Gallo Winery v. Encana Energy Servs.. Inc. 33 Med. L. Rptr. 1413 (S.D.N.Y. 2005) (Preska, J.). 4. Annexed hereto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 1721 (E.D. Tenn. 2008). 5.

uant to 28 U.S.C. § 1746, Anne B. Carroll declares as follows: 1. I am Vice President and General Counsel of movant Daily News, L.P., publisher of the New York Daily News (the "Daily News"). I am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and

ial in a Cir0 Action UNITED STATES DISTRICT COURT for the Southern District of New York In Re: Application to Quash Subpoenas Plaintiff v . to Daly News, L.P. and George Rush Defendant Civil Action No. 10 MB-85 SUBPOENA TO APPEAR AND TESTIFY AT A HEARING OR TRIAL EN A CIVIL ACTION To: George Rush

. Annexed hereto as Exhibit A is a true and correct copy of E & J Gallo Winery v. Encana Energy Servs.. Inc. 33 Med. L. Rptr. 1413 (S.D.N.Y. 2005) (Preska, J.). 4. Annexed hereto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 1721 (E.D. Tenn. 2008). 5.

rnment Works. 8 EFTA00100692 . Dershowitz, 410 F.Supp.3d 564 (2019) alleges that in 2018 and 2019, he gave interviews to the Miami Herald, CNN, the NY Daily News, Local 10 News, RawStory.com, Law & Crime, The Crimson, and Vanity Fair. (Compl. Exs. 1.6). As alleged, these are clearly new audiences even if, a

ing that she was forced to engage in sexual activity with him. Defendant moved to dismiss and to disqualify law firm Holdings: The District Court, Loretta A. Preska, Senior District Judge, held that: III single publication rule did not apply to bar claim on limitations grounds; (2) plaintiffs allegations were

ressively prosecuting officers accused of wrongdoing as California's attorney general." Floyd Hologram To Tour US And Replace Confederate Statues. The New York Daily News <https://news.yahoo.com/george-floyd-hologram-tour-u- 191300300.html> (7/29, Braine, 2.52M) reported that a "hologram effigy" of George Floyd "will

2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two

amson Tobacco Corp. v. Wigand No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996), 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, d

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);

amson Tobacco Corp. v. Wigand No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996), 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, d

g Petroleum Products standard to confidential materials): E Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413. 1414 (S.D.N.Y. 2005) (Preska, J.) (applying petroleum Products standard to both confidential sources and confidential materials) (copy annexed as Ex. A to Carroll Reply Decl.);

ressively prosecuting officers accused of wrongdoing as California's attorney general." Floyd Hologram To Tour US And Replace Confederate Statues. The New York Daily News (7/29, Braine, 2.52M) reported that a "hologram effigy" of George Floyd "will tour the US, traveling roughly along the route of the 1961 Freedom Rid

015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two

cuting officers accused of wrongdoing as California's attorney general." Floyd Hologram To Tour US And Replace Confederate Statues. EFTA01658256 The New York Daily News (7/29, Braine, 2.52M) reported that a "hologram effigy" of George Floyd "will tour the US, traveling roughly along the route of the 1961 Freedom Rid

015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's attorneys two days to seek a stay from an appeals court on two