Epstein Secrets

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

ed on April 13.2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in favor") (see other examples Carroll Reply

tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (- Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of statement

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

for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and "[y]ou digitally penetrated Plaintiff when she was a minor," SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of

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

d on April 13, 2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carr

tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (Doe's Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of state

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

tein's silence in the face of such confrontational Requests for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of