From: "Jeffrey E." <[email protected]>

From: "Jeffrey E." <[email protected]> To: Martin Weinberg Subject: Re: ATTORNEY-CLIENT PRIVILEGE Date: Sat, 02 May 2015 14:43:48 +0000 i dont think they can resist producing the interview? to us On Sat, May 2, 2015 at 10:07 AM, Martin Weinberg < > wrote: There are legal and practical issues involved with such a subpoena from Alan in the context of his defamation case. Legally, the media does not have an absolute privilege but a court will (upon a motion to quash) test the subpoena against a high standard of materiality, importance, whether its a fishing expedition, whether the same information is available from another source (eg a deposition of VR herself). See pgs 16-19 of attached (which is an overview, 7 yrs old, of how the media resists subpoenas). Practically, lets see what ABC decides. I emailed Hill without response yesterday. Alan will call Zucker with whom he has a relationship Monday. Martin G. Weinberg, Esq. Boston, MA 02116 ell This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. EFTA00857854 On Sat, 5/2/15, jeffrey E. <jeevacation®gmail.com> wrote: Subject: To: "Martin Weinberg" < >, "Kathy Ruemmler" Date: Saturday, May 2, 2015, 8:19 AM I assume that abc must have done some homework . we have heard nothing, yet. is there homework reachable by alan under a depo request of mr hill? please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00857855