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or related transactions." July Letter at 2-3. The scope of these requests is outlandishly overbroad. EFTA00016596 --- PAGE BREAK --- established Second Circuit law, and they are beyond the scope of this Office's disclosure obligations in this case. We expect to take all necessary steps to comply with our o
Page: EFTA00016597 →or the Southern District of New York (or FBI agents working therewith) by the United States Attorney's Office for the Southern District of Florida, the Middle District of Florida, and/or the Northern District of Georgia (or FBI agents working therewith). We will produce materials consistent with our Obligations t
Page: EFTA00016597 →would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United
80); United States v. Landof, , 591 F.2d 36, 38 (9th Cir. 1978); In re Grand flay Proceedings , 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn , the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd , the court found tha
would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United
980); United States I Landof, , 591 F.2d 36, 38 (9th Cir. 1978); In re Grand flay Proceedings , 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn , the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd , the court found tha
ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF
. 1980); United States v. Landof, 591 F.2d 36, 38 (9th Cir. 1978); In re Grand Jury Proceedings, 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn, the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd, the court found that
t 1313. Hoffenberg suggests that United States v. Leonard, 50 F.3d 1152, 1158 (2d Cir.I995), suggests a high- er standard of proof. In Leonard, the Second Circuit instructed that "the district court should consider any evidence with a significant degree of probative value, and should rest its finding on evid
61. Jan. 21, 1986. In prosecution for violations of the Racketeer Influ- enced and Corrupt Organizations Act, the United States District Court for the Middle District of Flor- ida, Hodges, Chief Judge, dismissed indictment against defendant, concluding that nonprosecu- tion agreement entered into by the Government
o dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a defe
the investigation and potential prosecution, relating to Jeffrey Epstein’s alleged sexual activities with minor females,” and assigned the matter to the Middle District of Florida U.S. Attorney’s Office for further consideration. The records included a declination of the matter due to the NPA. 7. U.S. Attorney’s Offi
Entities connected to both Second Circuit and the Middle District

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Michael Cohen
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSON
Donald Trump
PERSONFBI
ORGANIZATION
Southern District of New York
ORGANIZATIONMartin Weinberg
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSON
New York
LOCATION