Epstein Secrets

purposely availed itself of the privilege of conducting business within the forum State, thus invoking the protec- tion and benefits of its laws.'" Pennzoil Prods. Co. F Colelli & Assocs., Inc., 149 F.3d 197, 203 (3d Cir.1998). A plaintiff can meet this burden in one of two ways: EFTA00187468 568 2

lan... 5/14/2007 EFTA00187439 $DNY CM/ECF Version 3.0L - Docket Report Page 1 of 5 CLOSED U.S. District Court United States District Court for the Southern District of New York (Foley Square) CIVIL DOCKET FOR CASE #: 1:02-cv-05332-SITS Citibank, N.A.I Epstein, et al Assigned to: Judge Sidney H. Stein Demand:

t purposely availed itself of the privilege of conducting business within the forum State, thus invoking the protection and benefits of its laws.'" Pennzoil Prods. Co. v. Colelli & Assocs., Inc., 149 F.3d 197, 203 (3d Cir. 1998). A plaintiff can meet this burden in one of two ways: by establishing spec

11 11-13.) On June 11, 2002, the plaintiffs filed their complaint in this Court. One month later on July 11, 2002, Citibank sued the plaintiffs in the Southern District of New York, alleging that they had defaulted on both the loan at issue here and a second $10 million loan.' See Citibank, N.A. v. Epstein, Index N

Doe Action as the basis for his argument that he too is similarly entitled to production of the Epstein interview for use in the Ponzi Scheme $ As Pennzoil and Sheehan illustrate, where (as here) a party files a New York proceeding seeking discovery of newsgathering material from a New York news organiz

f. Ex. M (Memorandum & Order dated May 18, 2010 ("Dist. Ct. Op.")), at 1. Thereafter, the Daily News and Rush instituted an ancillary proceeding in the Southern District of New York to quash the subpoenas on the ground (among others) that Jane Doe could not overcome the federal reporter's privilege. In opposition to