Epstein Secrets

ocuments subject to privacy rights of victims who are not parties to this litigation Box #1 P-003553 Thru P-0035558 Printout of filenames from Federal Express subpoena response with Attorney notations Work product 6(e) Box #1 P-003556 Thru P-003562 Document entitled "Identified Numbers" with accomp

not parties to this litigation File folder entitled from Fed Ex Records" cor.stisin handwritten and typed attorney ( notes and screen shots of FedEx subpoena response electronic file Box #1 P-001057 thru P-001959 File folder entitled "Colonial Bank Records" containing records received in re

"a far stronger showing of necessity and unavailability by other means" than is needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States 14 EFTA00086458 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 449 U.S. 383, 402 (1981));

ttorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express. This document was not filed using CM/ECF because it is being filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Sub

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States , 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records . . . in the hands of an attorney—or

ttorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express. This document was not filed using CM/ECF because it is being filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Sub

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. I United States , 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records . . . in the hands of an attorney—or

ach. 401 Telephone: Facsimile: E-mail: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August ? a 2007, the foregoing document was served via Federal Express on Attorney Roy Black and Attorney William Richey. This document was not filed using CIvI/ECF because it is being filed under seal. Assistant U.S.

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States, 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records ... in the hands of an attorney—or p