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

man Lewis LLP, with offices at 228 East 45th Street, in Manhattan, New York. I submit this Affirmation in support of motion for an order pursuant to CPLR 3102(e) for production of a certain tape recording of an interview by George Rush, a Daily News reporter, of Jeffrey Epstein, a party to an action pending

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

passim N.Y. Civil Rights Law § 79-h(g) (McKinney 2010) 11, 14 iv EFTA00728065 PRELIMINARY STATEMENT Bradley Edwards seeks an order pursuant to CPLR 3102(e) for production of a tape recording of a conversation between a Daily News reporter and billionaire Jeffrey Epstein concerning Epstein's molestatio

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

2093 (S.C. Ct. Common Pleas July 20, 1994) 29 Yoder v. Adriatic°, 459 So.2d 449 (Fla. Dist. Ct. App. 1984) 18 STATUTES CPLR 3101(a)(4) passim CPLR 3102(e) 11, 1 2 MI Civil Rights Law § 79-h passim OTHER AUTHORITIES Carl C. Monk, Evidentiary Privilege for Journalists' Sources: Theory and Statutory