Epstein Secrets

herefore fell within the federal qualified privilege that governs non-confidential news material in the Second Circuit. Dist. Ct. Op. at 4 (quoting Gonzales v. NBC, 194 F.3d 29, 36 (2d Cir. 1999)). Applying the federal qualified privilege standard (which is significantly less demanding than the more rigo

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

3, 4 & 7). 3 EFTA00725412 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III") .2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confi

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

3, 4 & 7). 3 EFTA00726066 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III") .2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confi

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

ngle v. Liggett Group, Inc., 9 15 fn. 2 945 So.2d 1246 (Fla. 2006) 15 E.W. v. Epstein, Case No. 502008CA028XXXMBAB (Florida Circuit Court) 4 Gonzales v. Nat? Broad Co., Inc., 194 F.3d 29 (2d Cir. 1999) 7 In re Horowitz, 482 F.2d 72 (2s Cir. 1973) 12 In re Steinhardt Partners, L.P., 9 F.3d 2

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

3, 4 & 7). 3 EFTA00728463 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III").2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confid

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