This document is a memorandum of law submitted by Davis Wright Tremaine LLP on behalf of Daily News, L.P. in opposition to Bradley J. Edwards' motion to compel the production of a tape recording of an unpublished interview with Jeffrey Epstein. The memorandum argues against the motion on the grounds of the reporter's privilege under New York's Shield Law, the lack of relevance of the interview to the Ponzi Scheme Action, and the availability of the information from other sources. It also addresses the issue of waiver of the reporter's privilege and the vacated status of a prior district court order related to the Jane Doe Action.
documents/EFTA00596449.pdf
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