3
Shared Docs
3
Same-Page
8 / 3
Mentions
ts, the following data is for information purposes only and is not an official record. Certified copies may be obtained from that individual state's Department of State. Your DPPA Permissible Use is: Debt Recovery/Fraud Your GLBA Permissible Use is: Legal Compliance Copyright@ 2017 LexisNexis, a division of Reed E
t--closed their inquiry r32] into the matter by noting that the OPR has jurisdiction to investigate allegations of misconduct involving only current Department of Justice attorneys. (See P-O13937;' see also P-0013946). The OPR did not investigate the matter further, and it issued no factual determinations on whether a
" (DE 266 at 11). Specifically, it requests "all documents, correspondence, and other information regarding the potential conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral For internal use only SDNY_GM_00059581 CONFIDENTIAL - PURSUANT TO FED.
_00059577 CONFIDENTIAL - PURSUANT TO FED. R.CCIN(F IDENTIAL DB-SONY-0022401 EFTA 00170127 EFTA01296795 Page 71 2015 U.S. Dist. LEXIS 87203, * Upjohn Co. v. United States, 449 U.S. 383, 402, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under c
e 102. Some of the correspondence that is being withheld by the Government under the deliberative process privilege concerns an investigation that the Justice Department's Office of Professional Responsibility (OPR) opened with' regard to the Epstein case. This investigation was undertaken at the request of the victim
de: a) All documents, correspondence, and other information collected by the Office of Professional Responsibility (OPR) and any other component of the Justice Department (including the FBI) in response to the victims' letter; b) All documents, correspondence, witness statements, and other information collected as pa
tment accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the pote
/2013 Page 5 of 12 connection with the specific representation." Id. at 619. The Seventh Circuit found this letter brought the case squarely within Upjohn Co. v. United States 449 U.S. 383 (1981), "which explained that factual investigations performed by attorneys as attorneys fall comfortably within the
RANSMISSION OK TX/RX. NO 2683 CONNECTION TEL 6592380 SUBADDRESS CONNECTION ID ST. TIME 09/06 14:62 USAGE T 01'00 PGS. SENT 2 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Facsimile . FACSIMILE CO
counsel upon lift of stay by 11d' Circuit Box #2 P-008364 Thru P-008382 File folder entitled Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P
"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));
Entities connected to both Department of Justice and Upjohn Co.

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Alexander Acosta
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATIONFBI
ORGANIZATIONLeon Black
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Virginia Giuffre
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSON
Jay Lefkowitz
PERSON