3
Shared Docs
3
Same-Page
5 / 3
Mentions
ovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the United States Attorneys, United States Department of Justice, http://www.justice.gov/usao/eousa/mission-and-functions (last visited June 19, 2015). The internal documents that Petitioners seek relate to the p
w to proceed in the Epstein matter given the initiation of CVRA litigation by Petitioners. These communications are solely between attorneys within the United States Department of Justice. The communications do not constitute the commission of crime, fraud, or misconduct, but rather simply advise how to proceed given that allegations
ket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication I. Grolier, Inc., that "the literal language o
ovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the United States Attorneys, United States Department of Justice, http://www.justice.gov/usaoThousa/mission-and-functions (last visited June 19, 2015). The internal documents that Petitioners seek relate to the p
w to proceed in the Epstein matter given the initiation of CVRA litigation by Petitioners. These communications are solely between attorneys within the United States Department of Justice. The communications do not constitute the commission of crime, fraud, or misconduct, but rather simply advise how to proceed given that allegations
07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language o
d as a possible victim of Epstein's sex offenses. The term "Government" means the federal government, including all employees of and components of the United States Department of Justice (such as, the Office of the Attorney General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of Professional Respons
icipation of litigation, and certainly not litigation about the Crime Victims' Rights Act. See, e.g., Southern Union Co. v. Southwest Gas Corp., 205 F.R.D. 542, 549 (D. Ariz. 2002) (documents not protected by work product because not prepared in connection with case at hand). II. Specific Responses to
Entities connected to both United States Department of Justice and F.R.D.

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Ghislaine Maxwell
PERSON
Southern District of New York
ORGANIZATION
Bradley Edwards
PERSON
George W. Bush
PERSONFBI
ORGANIZATION
Prince Andrew
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONLeon Black
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
Jay Lefkowitz
PERSONJack Goldberger
PERSONMartin Weinberg
PERSON