EFTA00596449Set 9
2008-08-0836p11,867w
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 news reporter George Rush ... efforts of journalists for their
private purposes, were routinely permitted.") (internal citations omitted).
Edwards' motion to compel must be denied for several reasons. First, the Court need not
even reach ... satisfy any one of the three prongs required to overcome the
qualified privilege. Edwards' motion to compel production of the Epstein interview should
therefore be denied. See Griffin
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596449.pdf