Epstein Secrets

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

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

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

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

the planet. • Riot-Makers-R-Us: Whether it's the Black Lives Matter rioters, the Occupy Wall Street rio

_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

-009112 Thru P-009113 11/26/2008 Email from Ro Black to and m Jeffrey Epstein (work release) [purs

"a far stronger showing of necessity and unavailability by other means" than is needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States 14 EFTA00086458 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 449 U.S. 383, 402 (1981));

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

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

sing the CM/ECF system. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 South Bi

enabling the client to conform his conduct to the dictates of the law and to present le- gitimate claims and dt enses f if litigation ensues. See Upjohn Co. I United States, O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. https://web2.westlaw.com/print/printstream.aspx?vi-2.0&mt=EleventhCircuit

820-8777 E-mail: [email protected] E-mail: ann.marie.c,[email protected] Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 JIBlackaroyblack.com Attorneys for Proposed Intervenor

/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