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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
erent power beyond the literal wording of Rule 6(e)(3) to disclose grand jury material" and has properly exercised that power here. United States v. Aisenberg, 358 F.3d 1327, 1347 (11th Cir. 2004). Victims Have Properly Petitioned for the Release of Grand Jury Materials — A litigant can petition for rele
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
grand jury materials. • The Court has "inherent power beyond the literal wording of Rule 6(e)(3) to disclose grand jury material," United States. Aisenberg, 358 F.3d 1327, 1347 (11th Cir. 2004), and has properly exercised that power here. • A litigant can petition for release of grand jury materials.
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
erent power beyond the literal wording of Rule 6(e)(3) to disclose grand jury material" and has properly exercised that power here. United States v. Aisenberg, 358 F.3d 1327, 1347 (11th Cir. 2004). Victims Have Properly Petitioned for the Release of Grand Jury Materials — A litigant can petition for rele
Entities connected to both Bogle and Aisenberg

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSONLeon Black
PERSONMartin Weinberg
PERSONRoy Black
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
United States
LOCATION
the University of Utah
ORGANIZATION
Jay Lefkowitz
PERSON
Dexter Lee
PERSONFISTOS & LEHRMAN
ORGANIZATIONKirkland & Ellis
ORGANIZATION
San Diego
LOCATION
Jackie Perczek
PERSONSubpoena Duces Tecum
PERSON