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ree computers were his private papers. As set forth in the Recarey Declaration, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act of production doctrine would not have protected Epstein from producing the computers if they had rem
n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act o
, the [attorney-client] privilege does not bar revelation of the original location or conduction of the evidence in question." Hunter at *3 (quoting Meredith at 54). While the investigator could not testify about the substance of any communications with the attorney, he had to tell the jury where the wall
n it over to the prosecution. Therefore, introduction of the evidence did not implicate the privilege. Hunter at *2 (citing Clutchette at 1472). In Meredith , a murder suspect informed his attorney that the murder victim's wallet was in the garbage can behind the suspect's house and the attorney sent a p
United States hereby opposes Epstein's motion and moves for an order to compel the appearance of witnesses and production of the requested items. 'Sarah is one of Epstein's personal assistants. -5- EFTA00179104 ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The
the [attorney- client] privilege does not bar revelation of the original location or conduction of the evidence in question." Hunter at *3 (quoting Meredith at 54). While the investigator could not testify about the substance of any communications with the attorney, he had to tell the jury where the wall
e defendant in Hunter, the defendant argued that the anomey-client privilege precluded admission of the receipts against him at trial. Similarly, in Meredith, the defense investigator found the murder victim's wallet based on information obtained from the defendant and turned it over to defendant's attorn
c) Johnson, Loretta (Cnty Court) Johnson, Nide (Gun Club) Johnson, H. Quinn (DOVE-TD) Jones, Jeffery (Set Team) Jordan, Damaris (DOVE) Jordan, Ellen (HOM) Katz Jon Kay, Steven Kalman, Rachel Kenneway, Deborah King, Angela King., Mercedes Kinsey, Charles (So Cnty) (Exec) (Appeals) (INTA
y,' and Epstein was told never to come back." CONTRIBU' Homi Furthermore, the parent of one of Epstein's youngest victims is outraged that he R Sarah aymond, t could walk without registering as a sex offender and tells Radar, "What this man others did to my daughter was horrible. He thinks that
(Fel X) McRoberts, Aleather (Info Res) McWatters, Carey (Juv) Mendel, Ruth Ann (Exec) Mendelsberg, Jerry (CAC) Mercuro, Mario (JirnmyRyce) Meredith, Lourdes (Fel X) Meyer, Steve (Felony) Mighdoll, Preston (INVEST) Miller, Angela (ASA) (Fel )01 Miller, Leigh (INTAKE) Miller, Michelle (F
Entities connected to both Sarah Kellen and Meredith

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
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Marc Rich
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Alan Dershowitz
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Prince Andrew
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Kenneth Marra
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSONDarren Indyke
PERSON
Bill Clinton
PERSONMaria Farmer
PERSON
Palm Beach
LOCATION
Alexander Acosta
PERSON