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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
inal intercourse. With the possible exception of one girl, none of the minors had any training in massage therapy, and, as shown by Attachment E to the Black Affidavit, Epstein was receiving professional chiropractic services from a licensed chiropractor, Dr. Thomas Rofrano. Epstein's counsel misstates the state c
durally and legally. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States' Schaltenbrand , 930 F.2d 1554 (11th Cir. 1991); United States' Muiioz , 233 F.3d 1117 (9th Cir. 2000); Hawkins I Stables , 148 F.3d 379 (4th Cir. 1998); Motley I
inal intercourse. With the possible exception of one girl, none of the minors had any training in massage therapy, and, as shown by Attachment E to the Black Affidavit, Epstein was receiving professional chiropractic services from a licensed chiropractor, Dr. Thomas Rofrano. Epstein's counsel also misstates the st
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
inal intercourse. With the possible exception of one girl, none of the minors had any training in massage therapy, and, as shown by Attachment E to the Black Affidavit, Epstein was receiving professional chiropractic services from a licensed chiropractor, Dr. Thomas Rofrano. Epstein's counsel misstates the state c
Entities connected to both Schaltenbrand and the Black Affidavit

Jeffrey Epstein
PERSONF.R.D. 251
ORGANIZATIONHubbell
PERSONSouthern District
LOCATION
United States
LOCATIONPaul Lavery
PERSON
Alexander Acosta
PERSONLeon Black
PERSONRiley
PERSONGrand Jury Proceedings
ORGANIZATIONFisher
PERSONMorganroth
PERSON
Scarlett Johansson
PERSONSubpoena No
ORGANIZATIONGerald Lefcourt
PERSON
United States District Court
ORGANIZATIONWilliam Riley's
PERSONChristman
PERSON
FedEx
ORGANIZATION
Guy Lewis
PERSON