EFTA00596449Set 9
2008-08-0836p11,867w
News to
produce a tape recording that news reporter George Rush made of a confidential unpublished
interview of Jeffrey Epstein.
PRELIMINARY STATEMENT
In this ancillary discovery proceeding, a civil litigant ... Shield Law
mandates before a litigant may compel the press to disclose non-confidential, unpublished
material — namely, he does not meet his heavy burden under the Shield Law of demonstrating ... absolute privilege from compelled production;
and, under Section 79-h(c), all non-confidential "unpublished news" is subject to a stringent
qualified privilege that imposes a "very heavy burden
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596449.pdf