Federal Court Filing: Subpoenas To Daily News, L.P (EFTA00207294)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x IN RE APPLICATION TO QUASH SUBPOENAS TO DAILY NEWS, L.P., AND GEORGE RUSH • • x No. 10 M8-85 (LMM) REPLY DECLARATION OF ANNE B. CARROLL Pursuant to 28 U.S.C. § 1746, Anne B. Carroll declares as follows: 1. I am Vice President and General Counsel of movant Daily News, L.P., publisher of the New York Daily News (the "Daily News"). I am admitted to practice before this Court. 2. I make this Declaration in further support of the motion of the Daily News and Daily News journalist George Rush for an Order pursuant to Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe in an action pending in the United States District Court for the Southern District of Florida captioned Doe v. Jeffrey Epstein, No. 08-cv-80893-1CAM, or in the alternative for a Protective Order pursuant to Fed. R Civ. Proc. 26(cXI). 3. Annexed hereto as Exhibit A is a true an