This memorandum supports a motion for a CPLR 3102(e) order to produce a tape recording of a conversation between a Daily News reporter and Jeffrey Epstein regarding his sexual abuse of minor girls. The document outlines the background of Epstein's criminal prosecution and civil actions against him, the recorded conversation with the Daily News, and the legal arguments for why the tape should be produced. It argues that the Daily News has waived any journalist's privilege by disclosing the tape's contents to third parties and that the tape is critical evidence for ongoing litigation involving Bradley Edwards, who is counter-suing Epstein for malicious prosecution.
documents/EFTA00728061.pdf
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