Epstein Secrets

the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc

xpression for 13 EFTA00071572 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 20 of 30 which the protection is claimed." United States v. Schwinanzer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government co

the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc

xpression for 13 EFTA00075455 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 20 of 30 which the protection is claimed." United States v. Schwinanzer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government co

the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc

xpression for 13 EFTA00088689 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 20 of 30 which the protection is claimed." United States v. Schwinanzer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government co