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

uct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

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

ry Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege

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

ury Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States I Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege

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.

Jury Matter No. 91-01386, 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City, 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileg