Epstein Secrets

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

one in confidence. "The burden of proving that a communication falls under the attorney-client privilege rests on the proponent of the privilege." Hawkins v. Stables , 148 F.3d 379, 383 (4th Cir. 1998) (citation omitted). The party invoking the attorney-client privilege has the burden of proving that an attorney-

June 6, 2007 VIA FACSIMILE Robert I. Targ, Esq. Diaz Reus Rolff & Targ LLP 100 S.E. Second Street, Suite 2600 Miami, FL 33131 Re: Subpoena to Paul Lavery Dear Mr. Targ: Thank you for your letter of June 4, 2007. Following receipt of your letter, I conducted some additional research regarding your bl

applicability. See, e.g., United States v. Schaltenbrand , 930 F.2d 1554 (11th Cir. 1991); United States v. MuRoz , 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables , 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co. , 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty Advisors, Inc. , 185 F.R.D.

have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

done in confidence. "The burden of proving that a communication falls under the attorney-client privilege rests on the proponent of the privilege." Hawkins v. Stables, 148 F.3d 379, 383 (4th Cir. 1998) (citation omitted). The party invoking the attorney-client privilege has the burden of proving that an attorney