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volving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant's assertions regarding her relationship to each of these individuals. Defendant hired Jaffe, th
3, 2014) (internal quotation marks omitted)). Moreover, at least one New York court has found that British privilege law is "apparently similar" to New York's. Aetna Cas. & Sur. Co. v. Certain Underwriters at Lloyd's London, 4 "Where there is no attorney involved in the communication ..., there can be no
uffre v. Maxwell, No. 15 CIV. 7433 (RWS), 2016 WL 831949, at *2 n.2 (S.D.N.Y. Feb. 29, 2016) ("Because New York has the most significant interest, New York law applies."). The potential litigation for which Defendant sought Barden's advice never came to frOition and no • pending issues in or relating
from the Constitution's Article III requirement that the jurisdiction of the federal courts be limited to actual cases and controversies." Elend v. Basham, 471 F.3d 1199, 1204-05 (11th Cir. 2006). "'The ripeness doctrine keeps federal courts from deciding cases prematurely,' Beaulieu v. City of Alabast
tion of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered ' New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05. 2 EFTA00076069 Case 1:19-cr-00490-RM
from the Constitution's Article III requirement that the jurisdiction of the federal courts be limited to actual cases and controversies." Elend v. Basham, 471 F.3d 1199, 1204-05 (11th Cir. 2006). "'The ripeness doctrine keeps federal courts from deciding cases prematurely,' Beaulieu v. City of Alabast
tion of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered ' New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05. 2 EFTA00095872 Case 1:19-cr-00490-RM
Entities connected to both Basham and New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Marc Rich
PERSONFBI
ORGANIZATION
Samantha Power
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSONJane Doe
PERSONEmmy Taylor
PERSON
Scarlett Johansson
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Colorado
LOCATION
Geoffrey S. Berman
PERSONMartin Weinberg
PERSONDoug Band
PERSON
Atlanta
LOCATION