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 against the plaintiff's claims that the Epstein interview tape is necessary for her case, citing the reporter's privilege and the lack of relevance and materiality of the tape to the plaintiff's claims. The memorandum also addresses the standards under Federal Rules of Civil Procedure 26 and 45, the reporter's privilege, and the lack of waiver of this privilege.
documents/EFTA00728009.pdf
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