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ction by the Daily News of the recording. I attach the Rush declaration hereto as Ex. 3. 3 EFTA00728446 7. The Daily News then took an appeal to the Second Circuit. While the appeal was pending, however, the underlying civil suits by the three girls settled, leading to an automatic vacation of the district cou
molestation from discovery. It is for this reason, among others, that production of the tape on which he speaks about his molestation is critical. A. Epstein's Vicious Attacks on the Girls 5. Epstein's battery of attorneys have taken the girls' depositions, in which they have asked numerous questions sugg
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
ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear
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
ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear
Entities connected to both Second Circuit and A. Epstein's

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
Donald Trump
PERSON
Alan Dershowitz
PERSONFBI
ORGANIZATIONSouthern District
LOCATIONMaria Farmer
PERSONJack Goldberger
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
United States District Court
ORGANIZATIONEmmy Taylor
PERSON
Alexander Acosta
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Bill Clinton
PERSONWalker
PERSONHubbell
PERSONRoy Black
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