Epstein Secrets

nsel have had access to the subpoenaed computers since at least October 2005, when they were removed from Epstein's home, and they have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investig

n had standing to assert these challenges, the subpoenas are not unreasonable and do not violate any act of production privilege. For these reasons, the United States asks the Court to deny the Motion to Quash and to order the prompt production of the requested items and the witnesses' appearances before the Grand

papers of any kind. The notion that the Fifth Amendment rotects the privacy of papers originated in Boyd I United States , . . but our decision in Fisher United States , . .. sounded the death knell for Boyd . Several of Boyd 's express or implicit declarations [had] not stood the test of time, . . . and its privac

ds of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff I Davis Polk & Wardwell , 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any other rule would permit a

nsel have had access to the subpoenaed computers since at least October 2005, when they were removed from Epstein's home, and they have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investig

n had standing to assert these challenges, the subpoenas are not unreasonable and do not violate any act of production privilege. For these reasons, the United States asks the Court to deny the Motion to Quash and to order the prompt production of the requested items and the witnesses' appearances before the Grand

ands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff v. Davis Polk & Wardwell , 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any other rule would permit a

ckup withholding rules, 31% of the gross proceeds payable to a stockholder or ot=er payee pursuant to the Offer must be withheld and remitted to the United Sta=es Treasury, unless the stockholder or other payee provides his or her taxpaye= identification number (employer identification number or social sec

to their customers. 16. Miscellaneous. The Offer is not being made to, nor will the Company accept tenders from, holders of Shares in any state of the United States or any foreign jurisdiction in which the Offer or the acceptance thereof would not be in compliance with the laws of such state or foreign jurisdict

Contingent Stock Redemption Agreement. With the advice of Lazard Freres & Co.lic, the Company's financial advisor =ith respect to this matter, and Davis Polk & Wardwell, its legal advisor, t=e Board concluded that, although the Company's rights under the Contingen= Stock Redemption Agreement (which are not exercisab

at the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn I United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Court wrote: the at

hands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff. Davis Polk & Wardwell , 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any other rule would permit a