Epstein Secrets

IDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SDNY-0022405 EFTA_OOPOI31 EFTA01296799 Page 75 2015 U.S. Dist. LEXIS 87203, * that was made to Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be i

_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

lose to persons associated with the victims. 21 EFTA00086465 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 22 of 51 Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be in

"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));

lose to persons associated with the victims. 21 EFTA01657772 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 22 of 51 Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be in

"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 EFTA01657765 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));

ntial conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that EFTA00179731 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 3

/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