Epstein Secrets

ommunication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States v. Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pr

easonable certainty that the privilege applies, the burden is not met." United States v. Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission v. TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United States v. Landof, , 591 F.2d 36, 38 (9th Cir

communication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pro

reasonable certainty that the privilege applies, the burden is not met." United States I Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission I TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United States I Landof, , 591 F.2d 36, 38 (9th Cir.

Its Applicability. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States v. Schaltenbrand, 930 F.2d 1554 (11th Cir. 1991); United '8For purposes of this discussion, the requested documents will be jointly referred to as "billing records.

easonable certainty that the privilege applies, the burden is not met." United States v. Blackburn, 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission v. TRW, Inc., 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz, 623 F.2d 122, 125 (2d Cir. 1980); United States v. Landof, 591 F.2d 36, 38 (9th Cir. 1