This document is a reply memorandum of law submitted by Daily News, L.P., and journalist George Rush in support of their motion to quash subpoenas served on them in a Florida litigation or, alternatively, for a protective order. The document argues that the plaintiff, Jane Doe, has not met the burden of showing that the Epstein interview tape sought through the subpoenas can be compelled under the reporter's privilege or federal rules. It discusses the relevance, materiality, and absence of alternative sources for the information sought, and argues against the need for an evidentiary hearing. The document also addresses the issue of whether the reporter's privilege was waived.
documents/EFTA00207332.pdf
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