Epstein Secrets

cco Corp., 529 U.S. 120 (2000) 8 Hudson Valley Black Press v. I.R.S., 409 F.3d 106 (2d Cir. 2005) 8

h., 464 U.S. 89 (1983) 8 Burrage v. United States, 571 U.S. 204 (2014) 15 Commit. v. Clark, 489 U.S. 726 (1989) 15 Food and Drug Admin. v. Brown & Williamson Tobacco Corp., 529 U.S. 120 (2000) 8 Hudson Valley Black Press v. I.R.S., 409 F.3d 106 (2d Cir. 2005) 8 Kaiser Aluminum & Chem. Corp. v. Bonjorno, 494 U.S.

s Co. v. United States, 403 U.S. 713, 717 (1971) (Black, J. concurring). In short, the appellate briefs

USE EXISTS TO UNSEAL THE APPELLATE BRIEFS 10 CONCLUSION 14 4811-3721-9459v.2 3930033-000039 EFTA00805349 TABLE OF AUTHORITIES Page(s) Cases Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165 (6th Cir. 1983) 13 Daily News, L.P. v. Wiley, 126 A.D.3d 511, 6 N.Y.S.3d 19 (1st Dep't 2015) 10 Danco Labs., Ltd v. Chem.

team of attorneys began 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 o

ot pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ( "For communications between an attorney and client . . . to be privileged, they must be

team of attorneys began 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 o

not pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., I Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ( "For communications between an attorney and client . . . to be privileged, they must be

was excused from appearing before the grand jury and that Mr. Riley did not flout the subpoena by failing to appear. AUSA agreed with Attorney Mr. Black that Mr. Riley would not have to appear and produce the disputed items if a motion to quash all aspects of the subpoenas was filed. Neither party's

t pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp., 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ("For communications between an attorney and client . . . to be privileged, they must be c