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worked for Defendant Epstein during portions of the Palm Beach Police Department’s months’ long investigation which spanned from Ma
201 F.R.D. 272 (D.D.C. 2001); See also, Salter v. Upjohn Co., 593 F.2d 649, 651 (5th Circ. 1979)(It is very u
ctims identified. F2 Epstein's counsel is correct, however, in asserting that Epstein's criminal conduct first came to the attention of the FBI when the City of Palm Beach Police Department became concerned about the manner in which the Palm Beach County State Attorney's Office was handling the state prosecution. The investigation of t
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
ctims identified. F2 Epstein's counsel is correct, however, in asserting that Epstein's criminal conduct first came to the attention of the FBI when the City of Palm Beach Police Department became concerned about the manner in which the Palm Beach County State Attorney's Office was handling the state prosecution. The investigation of t
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
nvolved use of means of interstate commerce (i.e., a telephone) and travel in interstate commerce. Both Jane Does were initially identified through the Palm Beach Police Department's investigation of Epstein. 76. Confirming the fact that the Government had identified Jane Doe No. 1 as a victim in this case, on about June 7, 200
/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
Entities connected to both Palm Beach Police Department and Upjohn Co.

Jeffrey Epstein
PERSON
United States
LOCATIONFBI
ORGANIZATIONthe Southern District
LOCATION
Alexander Acosta
PERSONGerald Lefcourt
PERSONJack Goldberger
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Palm Beach County
LOCATION
George W. Bush
PERSONRoy Black
PERSON
the United States District Court
ORGANIZATION
Bradley Edwards
PERSONAnn Sanchez
PERSON
West Palm Beach
LOCATION