Epstein Secrets

rative process is at issue) that have not been proven by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle v. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown v. City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert pri

process privilege would be a qualified privilege, which would be overridden by the victims' compelling need to obtain the materials here. See, e.g., Newport Pac., Inc. v. County of San Diego, 200 F.R.D. 628, 638-41 (S.D. Cal. 2001) (in action charging county Board of Supervisors with violating Federal Fair

Government has not provided factual material identifying who is the attornex, who is the client, and how the communications were confidential. See Bogle I McClure, 332 F.3d 1347, 1358 (11th Cir. 2003) (noting privilege holders not As the Court is aware, the victims have alleged that U.S. Attorney's

rocess privilege would be a qualified privilege, which would be overridden by the victims' compelling need to obtain the materials here. See, e.g., Newport Pac., Inc.' County of San Diego, 200 F.R.D. 628, 638-41 (S.D. Cal. 2001) (in action charging County with violating the Federal Fair Housing Act, the pl

e Government has not provided factual material identifying who is the attorney, who is the client, and how the communications were confidential. See Bogle v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). 13. Deliberative Process Privilege Privilege Not Properly Invoked - Any deliberative process pri

process privilege would be a qualified privilege, which would be overridden by the victims' compelling need to obtain the materials here. See, e.g., Newport Pac., Inc. v. County of San Diego, 200 F.R.D. 628, 638-41 (S.D. Cal. 2001) (in action charging county Board of Supervisors with violating Federal Fair