This document is a reply memorandum of law filed by Bradley James Edwards in the Supreme Court of the State of New York, County of New York. It supports a motion for a CPLR 3102(E) order to compel the Daily News, L.P. to produce a tape recording of Jeffrey Epstein. The memorandum argues that the Daily News has waived any journalist privilege by disclosing the contents of the recording and that the qualified journalist privilege is overcome by Edwards' need for Epstein's statements to defend against Epstein's civil suit and pursue a counterclaim for damages. The document includes arguments about the relevance and necessity of the recording, the waiver of privilege, and the lack of alternative sources for Epstein's statements.
documents/EFTA00729035.pdf
{}