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egan approaching the State Attorney's Office, applying 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 t
f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.
ommunication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States v. Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pr
egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. F4 At some time after the possibility of obtaining a search warrant was discussed, Epstein hired th
attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.
durally and legally. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States' Schaltenbrand , 930 F.2d 1554 (11th Cir. 1991); United States' Muiioz , 233 F.3d 1117 (9th Cir. 2000); Hawkins I Stables , 148 F.3d 379 (4th Cir. 1998); Motley I
egan approaching the State Attorney's Office, applying 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 t
f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.
communication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pro
d solicitation offense is a felony. -3- EFTA00179102 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
attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.'
Its Applicability. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States v. Schaltenbrand, 930 F.2d 1554 (11th Cir. 1991); United '8For purposes of this discussion, the requested documents will be jointly referred to as "billing records.
Entities connected to both Jack Goldberger and Schaltenbrand

Jeffrey Epstein
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
Alexander Acosta
PERSONSouthern District
LOCATIONRoy Black
PERSON
United States
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATION
Sarah Kellen
PERSONGerald Lefcourt
PERSON
United States District Court
ORGANIZATIONAnn Sanchez
PERSON
Palm Beach Police Department
ORGANIZATION
Stephen Hawking
PERSON