Epstein Secrets

ce in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confident

iosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?3 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out)

t fact that target letters and subpoenas were issued relating to certain financial offenses. See M·, DEs 282 and 283 submitted in camera and U.S. v. Zolin, 491 U.S. 554 ( 1989)( disclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing partie

luding alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. &2e generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in ones sexual matters and is not limi

fact that target letters and subpoenas were issued relating to certain financial offenses. Sse Lg., DEs 282 and 283 submitted in camera and U.S. v. Zolin, 491 U.S. 554 (1989Xdisclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing parties t

documents under seal for in camera review by a neutral and detached magistrate or by court-appointed special masters, see, e.g., United States v. Zolin, 491 U.S. 554, 570-71, 109 S.Ct. 2619, 2629-30, 105 L.Ed.2d 469 (1989); In re Grand July Proceedings, 867 F.2d 539, 540 (9th Cir.1989); In re Impou

ials. The proponent of the privilege bears the burden to establish its existence, United States v. (Under Seal), 748 F.2d 871, 876 (4th Cir.I 984); United States v. Covington & Burling, 430 F.Supp. 1117, 1122 (D.D.C.I 977), and absent the timely assertion of attorney-client privilege for each specific commun