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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.
s or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn v. United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Co
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.
s or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn I United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Cou
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.
or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn v. United States, 449 U.S. 383 (1981), the Supreme Court made clear that an -18- EFTA00179117 attorney cannot create a "zone of silence" over fact
Entities connected to both Paul Lavery and Upjohn

Jeffrey Epstein
PERSONLeon Black
PERSONRoy Black
PERSONRiley
PERSON
Alexander Acosta
PERSON
United States
LOCATIONSouthern District
LOCATIONSchaltenbrand
PERSONGerald Lefcourt
PERSON
Tony Blair
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONF.R.D. 251
ORGANIZATIONFBI
ORGANIZATIONE.D. Mich. 2004
ORGANIZATION
Palm Beach Police Department
ORGANIZATION
Vince Foster
PERSON
FedEx
ORGANIZATION
Guy Lewis
PERSONBarrett
PERSON