Epstein Secrets

me is hereby granted. A commissioner shall be appointed in New York for the purpose of taking the deposition duce tecum of the Records Custodian of The New York Daily News. Said commissioner to be: Metro Attorney Service, Inc., 305 Broadway, 14th Floor, New York, NY 10007. DONE and ORDERED in Chambers at West Palm Bea

meone representing themselves to be Jeffrey Epstein," and the testimony of George Rush and Anne B. Carroll, a Vice President and General Counsel of Daily News, L.P. (Carroll Decl., Apr. 7, 2010, Exs. A & B.) In the alternative, the subpoenaed parties seek a protective order barring disclosure under Fed. R

columnist in the Daily News, that in the fall of 2009 he began to follow criminal and civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010, Ex. G] II 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste

Consider Secrecy of Plea Bargain (Fla.) SUN- SENTINEL, June 15, 2009 29 Dwr 1584534343 3970112-000042 EFTA00596454 Daily News, II, publisher of the New York Daily News, respectfully submits this memorandum of law in opposition to Bradley J. Edwards' motion to compel the Daily News to produce a tape recording that

s among various lawyers and others close to the case — including attorney Edwards — who could provide tips and information to assist his reporting. Rush Aff. ¶¶ 3, 6-7. In October 2009, Rush obtained a telephone interview with Epstein to talk about the status of the civil cases against him. See Rush Aff

Rush Aff. ¶¶ 3, 6-7. In October 2009, Rush obtained a telephone interview with Epstein to talk about the status of the civil cases against him. See Rush Aff. ¶ 4; Balin Aff. Ex. L (Supplementary Affidavit of George Rush, sworn to April 30, 2010 ("Rush Supp. Aff.")), ¶ 2. Epstein and Rush agreed at the o

meone representing themselves to be Jeffrey Epstein," and the testimony of George Rush and Anne B. Carroll, a Vice President and General Counsel of Daily News, L.P. (Carroll Decl., Apr. 7, 2010, Exs. A & B.) In the alternative, the subpoenaed parties seek a protective order barring disclosure under Fed.

columnist in the Daily News, that in the fall of 2009 he began to follow criminal and civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010, Ex. G) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste

meone representing themselves to be Jeffrey Epstein," and the testimony of George Rush and Anne B. Carroll, a Vice President and General Counsel of Daily News, IIII (Carroll Decl., Apr. 7, 2010, Exs. A & B.) In the alternative, the subpoenaed parties seek a protective order barring disclosure under Fed.

columnist in the Daily News, that in the fall of 2009 he began to follow criminal and civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7, 2010, Ex. G) 11 1-2), and that in November of 2009 he was able to arrange a telephone interview of Mr. Epste

ood reason for defeating Brad Edwards' search for the truth. This case does not involve an issue relating to a confidential source. Accordingly, the Daily News possesses (at most) a qualified privilege, which can be overcome by Edwards making "a clear and specific showing that the [information]: (i) is high

for three persons not involved in any Daily News reporting effort: a filmmaker, a social activist, and an attorney who had been following the case. Rush Aff. ¶ 6. Shortly after that meeting, one of the participants went to an investigator for Edwards' clients -- Michael Fisten -- and said, "My god, you'v