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too close to persons associated with the victims. 4. Request No. 18--Documents Concerning Recusal of the United States Attorney's r33] Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted
, the "work-product privilege applies to . discussions between prosecutors and investigating ri7] agents, both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing FTC v. Grolier Inc., 462 U.S. 19, 103 S. Ct. 2209, 76 L. Ed. 2d 387 (1983)). The work-product privilege
ng.' (DE 212-1 at 21-22); (see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted
eys, the "work-product privilege applies to ... discussions between prosecutors and investigating agents, both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing FTC v. Grolier Inc., 462 U.S. 19 (1983)). The work-product privilege extends only to documents that an a
n, which she is likely to refuse to give or provide, on the matters about which she may be interrogated before the United States District Court for the Southern District of Florida, including a Grand Jury impaneled therein, as well as subsequent proceedings or trial, and respectfully alleges as follows: 1. That ==.
s, the "work-product privilege applies to . . . discussions between prosecutors and investigating agents, both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing FTC v. Grolier Inc., 462 U.S. 19 (1983)). The work-product privilege extends only to documents that an a
ing.' (DE 212-1 at 21-22); see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted
eys, the "work-product privilege applies to ... discussions between prosecutors and investigating agents, both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing FTC v. Grolier Inc., 462 U.S. 19 (1983)). The work-product privilege extends only to documents that an a
Entities connected to both the Southern District and Zingsheim

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONLeon Black
PERSON
Southern District of New York
ORGANIZATION
Paul Cassell
PERSON
Donald Trump
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Supreme Court
ORGANIZATION
Michael Jackson
PERSONEmmy Taylor
PERSON
West Palm Beach
LOCATION
United States Department of Justice
ORGANIZATION
Michael Douglas
PERSONKuyrkendall
PERSONWright
PERSON