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ANYS)" )is „cl F.,. el - - - Cc: "I Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Mon, 20 Apr 2020 21:53:59 +0000 USANYS Yes, the Jane Doe is From: (USANYS) Sent: Monday, April 20, 2020 17:52 To: (USANYS) (USANYS) ic ); , for sure — thanks and good point. •c > Cc: (USANYS) 1.S
ee also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dep't of Investigation of the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of infor
FLSD Docket 08/16/2013 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS THAT ARE NOT PRIVILEGED EFTA00208672 Case 9:08-cv-8
in which the public interest in nondisclosure must be balanced against the need of a particular litigant for access to the privileged information. Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo,
To: Kochevar, Steven (USANYS) 4 Cc: (USANYS) ) (USANYS) dc ); Subject: RE: Jeffrey Epstein-Related Touhy Requests 1 take it we fully know that Jane Doe is Maria Lacerda? I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a
see also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dept of Investigation of the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of infor
PM To: Kochevar, Steven (USANYS) (USANYS) •ca; Cc: (USANYS) > Subject: RE: Jeffrey Epstein-Related Touhy Requests I take it we fully know that Jane Doe is Maria Lacerda? I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a
ee also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dep't of Investigation of the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of infor
ated Touhy Requests I take it we fully know that Jane Doe isa? I had a little pause on handing out the GJ
ee also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dep't of Investigation of the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of infor
020 5:52 PM To: (USANYS) (USANYS) dc ); (USANYS) Cc: < M> < Subject: RE: Jeffrey Epstein-Related Touhy Requests I take it we fully know that Jane Doe is I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a problem disclos
ee also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dep't of Investigation of the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of infor
FLSD Docket 08/16/2013 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also refe
in which the public interest in nondisclosure must be balanced against the need of a particular litigant for access to the privileged information. Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo,
Entities connected to both Jane Doe and Tuite

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATIONRoy Black
PERSONMartin Weinberg
PERSON
the University of Utah
ORGANIZATION
Dexter Lee
PERSON
S.J. Quinney College of Law
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
New York
LOCATION
Alfredo Rodriguez
PERSON
David Boies
PERSON
George Mitchell
PERSON