Epstein Secrets

o: Jackie Peraek Cc: M, (USAFLS); (USAFLS); Brad Edwards Subject: RE: Position on Motion to Treat MTD as Equivalent to Jurisdictional Question Hi Jackie, Thanks for getting back to us so quickly. We have always appreciated your collegiality on these issues as well (and we know that your firm has qui

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

o: Jackie Perczek Brad Edwards ([email protected]) Subject: RE: Position on Motion to Treat MID as Equivalent to Jurisdictional Question Hi Jackie, Thanks for getting back to us so quickly. We have always appreciated your collegiality on these issues as well (and we know that your firm has qui

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris

209322 Cc USAFLS); Brad Edwards ([email protected]) Subject: RE: Position on Motion to Treat MTD as Equivalent to Jurisdictional Question Hi Jackie, Thanks for getting back to us so quickly. We have always appreciated your collegiality on these issues as well (and we know that your firm has qui

the problem with the alternative that you propose is that the jurisdictional issue and the merits issues overlap. You argue as to jurisdiction that Perlman does not apply because there is no privilege. And our argument on the merits is that there is a privilege. So privilege is at the heart of the juris