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ised of the scope of the federal grand jury investigation, which is broader than the state investigation. The federal investigation, as conducted by the Federal Bureau of Investigation ("FBI"), is broader both in terms of the crimes being investigated and the number of victims identified. F2 Epstein's counsel is correct, however, i
ommunication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States v. Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pr
ised of the scope of the federal grand jury investigation, which is broader than the state investigation. The federal investigation, as conducted by the Federal Bureau of Investigation ("FBI") is broader both in terms of the crimes being investigated and the number of victims identified. fi Epstein's counsel is correct, however, in
durally and legally. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States' Schaltenbrand , 930 F.2d 1554 (11th Cir. 1991); United States' Muiioz , 233 F.3d 1117 (9th Cir. 2000); Hawkins I Stables , 148 F.3d 379 (4th Cir. 1998); Motley I
ised of the scope of the federal grand jury investigation, which is broader than the state investigation. The federal investigation, as conducted by the Federal Bureau of Investigation ("FBI"), is broader both in terms of the crimes being investigated and the number of victims identified. F2 Epstein's counsel is correct, however, i
communication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pro
sed of the scope of the federal grand jury investigation, which is broader than the state investigation. The federal investigation, as conducted by the Federal Bureau of Investigation ("FBI"), is broader both in terms of the crimes being investigated and the number of victims identified' Epstein's counsel is correct, however, in
Its Applicability. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States v. Schaltenbrand, 930 F.2d 1554 (11th Cir. 1991); United '8For purposes of this discussion, the requested documents will be jointly referred to as "billing records.
Entities connected to both FBI and Schaltenbrand

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Alexander Acosta
PERSONLeon Black
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONJane Doe
PERSON
Scarlett Johansson
PERSONSouthern District
LOCATION
Palm Beach Police Department
ORGANIZATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSONGerald Lefcourt
PERSON
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONEmmy Taylor
PERSON
Stephen Hawking
PERSONRoy Black
PERSONAnn Sanchez
PERSON