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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.
ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis , 636 F.2d at 1039. See also Nguyen v. Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States v. White , 950 F.2d 426, 430 (7t
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
Furthermore, blanket assertions are not proper, and the assertion must be made on a question-by-question and document-by-document basis. See, e.g., Nguyen v. Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States v. White , 950 F.2d 426, 430 (7
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.
ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis, 636 F.2d at 1039. See also Nguyen v. Excel Corp., 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat. Bank, 974 'In Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (en bane),
Entities connected to both Paul Lavery and Nguyen v. Excel Corp.

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSONSchaltenbrand
PERSONSouthern District
LOCATIONLavery
PERSONRiley
PERSON
United States
LOCATIONRoy Black
PERSONF.R.D. 251
ORGANIZATIONChristman
PERSONGerald Lefcourt
PERSONFBI
ORGANIZATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
Tony Blair
PERSONHawkins v. Stables
PERSONAcevedo
PERSONShelly Marchetti
PERSON
McKay
PERSON