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lying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the first week of October, 2005. On October 18, 2
Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Re
Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration o
tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States , 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records . . . in the hands of an attorney—or
lying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the first week of October, 2005. On October 18, 2
Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Re
Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration o
tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. I United States , 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records . . . in the hands of an attorney—or
15 U.S. Dist. LEXIS 87203, * For Jeffrey Epstein, Intervenor: Jacqueline Perczek, Roy Eric Black, Black Srebnick Kornspan & Stumpf, Miami, FL. For Alan M. Dershowitz, Intervenor: Kendall Brindley r21 Coffey, LEAD ATTORNEY, Gabriel Groisman, Coffey Burlington, P.L., Miami, FL; Steven Russell Safra, Thomas E. Scot
bnick Kornspan & Stumpf, Miami, FL. For Alan M. Dershowitz, Intervenor: Kendall Brindley r21 Coffey, LEAD AT
lack Srebnick Kornspan & Stumpf, Miami, FL. For Alan M. Dershowitz, Intervenor: Kendall Brindley r21 C
_00059577 CONFIDENTIAL - PURSUANT TO FED. R.CCIN(F IDENTIAL DB-SONY-0022401 EFTA 00170127 EFTA01296795 Page 71 2015 U.S. Dist. LEXIS 87203, * Upjohn Co. v. United States, 449 U.S. 383, 402, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under c
ndrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and R
nce Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefko
ment, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00179727 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docke
/2013 Page 5 of 12 connection with the specific representation." Id. at 619. The Seventh Circuit found this letter brought the case squarely within Upjohn Co. v. United States 449 U.S. 383 (1981), "which explained that factual investigations performed by attorneys as attorneys fall comfortably within the
9102 pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of Epstein knew of the state investigation by the first week of October, 2005. On October 18, 2005, a search war
Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of Epstein kn
Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of
tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States, 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records ... in the hands of an attorney—or p
Entities connected to both Alan Dershowitz and Upjohn Co.

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Woody Allen
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION