4
Shared Docs
4
Same-Page
4 / 4
Mentions
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
former Southern District of Florida U.S. Attorney Guy Lewis and former Southern District of Florida Assistant U.S. Attorneys Lilly Ann Sanchez and Michael Tien. FSThe wires and peripheral devices were present but the central processing units ("CPUs") were gone. is one of Epstein's personal assistants. E7A
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
former Southern District of Florida U.S. Attorney Guy Lewis and former Southern District of Florida Assistant U.S. Attorneys Lilly Ann Sanchez and Michael Tien. FSThe wires and peripheral devices were present but the central processing units ("CPUs") were gone. Sarah Kellen is one of Epstein's personal ass
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
former Southern District of Florida U.S. Attorney Guy Lewis and former Southern District of Florida Assistant U.S. Attorneys Lilly Ann Sanchez and Michael Tien. SThe wires and peripheral devices were present but the central processing units ("CPUs") were gone. -4- EFTA00179103 home (at Epstein's invitat
/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
defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President
Entities connected to both Upjohn Co. and Michael Tien

Jeffrey Epstein
PERSONLeon Black
PERSONRoy Black
PERSONJack Goldberger
PERSON
Alexander Acosta
PERSON
Alan Dershowitz
PERSONGerald Lefcourt
PERSONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSON
Guy Lewis
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSONMain Justice
ORGANIZATION
Bradley Edwards
PERSONAnn Sanchez
PERSON