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the Government (Bates 0001-04), court pleadings filed by the victims themselves or other victims, by Epstein, or by news media organizations (e.g., Bates 00142-88, 00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g., Bates 0008-10, 0012-14. 0036-86, 00190-228), public
cuments apply to which of the victims' document production requests. Instead, the Government has simply taken more than 13,000 pages of documents, Bates stamped them in no particular order (or at least no order that the victims can discern), and then asserted that they are all privileged for various
ccess to information against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging ci
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
ccess to information against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging ci
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
ccess to information against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging ci
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
ccess to information against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging ci
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
ccess to information against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citi
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
eged information. Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Wor
Entities connected to both Bates and Frankenhauser

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
United States
LOCATIONMaria Farmer
PERSONJane Doe
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
S.J. Quinney College of Law
ORGANIZATION
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
the University of Utah
ORGANIZATION