Epstein Secrets

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[Tjhe United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

ernment which may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand here. Interesting, the Standing Discovery Order — and asso

rative process is at issue) that have not been proven by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown' City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privile

ies, Inc. I. Carpenter, 130 S. Ct. 599 (2009) passim Nat'l Super Spuds, Inc.' N.Y. Mercantile Exch., 591 F.2d 174, 178 (2d Cir.1979) 13 Perlman I United States, 247 U.S. 7 (1918) passim United States'. Copar Pumice Co., Inc., 714 F.3d 1197, 1207 (10th Cir. 2013). 17, 19 Wilson'. O'Brien, 621 F.3d 641, 64

create the necessary factual support from which this Court could find that he will be injured if the correspondence is provided to the victims. See Bogle. McClure, 332 F.3d 1347, 1358 (1 1 th Cir. 2003) (noting privilege holder not "excused from meeting their burden of proving the communication confi

andatory for wire fraud only if the government exercises its discretion to seek such forfeiture. See 28 U.S.C. § 2461(c); Fed. R. Crim. P. 32.2(a); United States v. Liquidators of European Fed. Credit Bank, 630 F.3d 1139, 1144 (9th Cir. 2011) (describing procedure for forfeiture). "[T]he Government retains b

e Government has not provided factual material identifying who is the attorney, who is the client, and how the communications were confidential. See Bogle v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). 13. Deliberative Process Privilege Privilege Not Properly Invoked - Any deliberative process pri