EFTA00725457.pdf PDF
PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION MEMORANDUM TO: Jeffrey Epstein FROM: Darren K. Indyke DATE: August 12, 2009 RE: Discovery in Jane Doe No. 2 Case EFTA00725457 Requests to Produce The excerpt fro…
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EFTA01206912.pdf PDF
NEW YORK the privilege being personal, the consequences are limited to the witness that invokes it (id. at 45, 427 N.Y.S.2d 961, 405 N.E.2d 205). Thus, where the privilege is asserted by a nonparty witness…
EFTA01733753.pdf PDF
THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Roy Black From: William Riley Date: October 9, 2005 Re: Jeff Epstein File: 8577R On October 7…
EFTA00157111.pdf PDF
From: IMatealLEM To: au= Cc: Subject Epstein terms for privilege review Date: Tuesday, Mardi 31, 2020 11:20:19 AM Yep! I got them. Our network is back up and running, so I'll be playing with that stuff over…
EFTA00367181.pdf PDF
From: Richard Joslin -4 To: jeffrey E. Subject: FW: PRIVILEGED & CONFIDENTIAUATTORNEY-CLIENT COMMUNICATION Date: Wed, 02 Jul 2014 12:11:05 +0000 Please let me know if you would like to participate and if so, whether the time below are…
EFTA00762577.pdf PDF
From: "Martin Weinberg" To: "Jeffery Edwards" Subject: ATTORNEY-CLIENT PRIVILEGE Date: Tue, 16 Mar 2010 01:53:52 +0000 Attachments: search memo3.doc See attached Major contradictions between affidavit/taped statement are at 2-9, and between…
EFTA00101078.pdf PDF
From: To: ' Cc:' )" < Subject: RE: Epstein search materials for upload and privilege review Date: Wed, 12 Feb 2020 18:22:00 +0000 Attachments: Epstein_Priv_terms.doex Whe…
EFTA00674612.pdf PDF
From: "Martin Weinberg" To: "Jeffrey Epstein" Cc: Subject: ATTORNEY-CLIENT PRIVILEGE Date: Fri, 27 May 2011 18:44:37 +0000 A far more plausible slot than as a foreclosure clerk for a local court given cyber background…
EFTA00334260.pdf PDF
From: Darren Indyke To: Lesley Groff Cc: Martin Weinber < Subject: Re: ATTORNEY-CLIENT PRIVILEGE Date: Mon, 30 Nov 2015 18:12:14 +0000 Hey, Les. Marty will let me know when things are ready and where Brice must…
EFTA00932860.pdf PDF
From: "jeffrey E." To: Melanie Spinella la> Subject: Fwd: PRIVILEGED & CONFIDENTIAL Date: Wed, 06 Dec 2017 22:46:17 +0000 please read the whole page Forwarded message From: Bronstein, Richard J Date: Sat, Dec 12, 2015 at…
EFTA00586224.pdf PDF
…for all years from 2002 through the present. Response to Request Numbers : Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit…
EFTA01377949.pdf PDF
Page 13 2009 U.S. Dist. LEXIS 139535, * require Epstein "to surrender the very protection which the privilege is designed to guarantee." Hoffman, 341 U.S. at 479. As such, no more particularized showing than that offered by Epstein in…
EFTA01387844.pdf PDF
…Dist. LEXIS 139535, * knowledge of the cases at issue. On this basis the Court finds rm the privilege raised as to these interrogatories valid, and asserted by Epstein only with reference to "genuinely threatening questions." United States v. Goodwin, 625…
EFTA01377945.pdf PDF
…Dist. LEXIS 139535, * knowledge of the cases at issue. On this basis the Court finds rm the privilege raised as to these interrogatories valid, and asserted by Epstein only with reference to "genuinely threatening questions." United States v. Goodwin, 625…
EFTA00725590.pdf PDF
…constitutional privileges in declining at present to respond to this request for production based on advice from my counsel that I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth Amendment and…
EFTA00222963.pdf PDF
THE SUBPOENA FOR THE CONTENTS OF EPSTEIN'S COMPUTERS, EVEN IF CONSIDERED "PURELY PRIVATE PAPERS," DOES NOT VIOLATE EPSTEIN'S FIFTH AMENDMENT PRIVILEGE. Lastly, Epstein argues that the subpoena seeks "purely private papers," and that a subpoena demanding those papers…
EFTA00729515.pdf PDF
…for all years from 2002 through the present. Response to Request Numbers : Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit…
EFTA02104614.pdf PDF
…contents of this e-mail message and any attachments are confidential and are intended solely for addressee. The informabon may also be legally privileged. This transmission is sent in trust for the sole purpose of delivery to the intended recipient…
EFTA00139445.pdf PDF
…08:12 PM Subject: BOP OFFICIAL - LEGAL HOLD NOTICE for (INMATE DEATH) CustodianDocSearchCheckList LHN-CIV-2019-00204 JOSEPH N COLUMBO rtf Subject: BOP OFFICIAL - LEGAL HOLD NOTICE for (INMATE DEATH) Legal Hold Notice: Record Custodians Privileged and Confidential …
EFTA00139736.pdf PDF
…OF THE GENERAL COUNSEL' Sent: Wed 8/14/2019 3:08:22 PM Subject: BOP OFFICIAL - LEGAL HOLD NOTICE for INMATE DEATH CustodianDocSearchCheckList LHN-CIV-2019-00204 Subject: BOP OFFICI Legal Hold Notice: Record Custodians Privileged and Confidential …
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