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"Protected Material"
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EFTA00803986
Dataset 9
2017-04-27
6p
1,954w
…Protected Materials received from, the Client, any Covered Attorneys, Mr. Epstein and/or any other person acting at the direction or on the behalf of any of them: (collectively, the "
Protected Material
Sources"). Attorney-Client Privilege. The Company acknowledges that the Client is retaining the Company to provide the Services in connection with pending litigation and contemplated litigation involving Jeffrey Epstein and that, therefore, Protected Materials transmitted and communicated 2 381 Park Avenue South, Suite 1201 New York, NY 10016 …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00803986.pdf
EFTA00094794
Dataset 9
2016-02-26
10p
1,804w
…Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. Challenging Designations Of
Protected Material
(a) A Party shall not be obligated to challenge the propriety of any designation of Discovery Material under this Order at the time the designation is made, and a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094794.pdf
EFTA00084356
Dataset 9
2016-02-26
10p
1,804w
…Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. Challenging Designations Of
Protected Material
(a) A Party shall not be obligated to challenge the propriety of any designation of Discovery Material under this Order at the time the designation is made, and a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084356.pdf
EFTA00039416
Dataset 9
2019-11-25
3p
898w
…Re: United States v. Tova Noel and Michael Thomas, No. 19 Cr. 830 Dear Counsel: We write in response to your discovery request letters, dated January 29, 2020. This letter is designated as
Protected Material
pursuant to the Protective Order entered in this matter. Thomas Request. The Government refers to its prior response to this request, as stated at the November 25, 2019 pretrial conference. Noel Request No. 1-10, 12-13. With respect to your other requests, we note…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00039416.pdf
EFTA00204876
Dataset 9
2012-02-03
1p
451w
Subject:
Government Position
To:
Paul Cassell Brad Edwards
…two months, we would oppose a motion that the government file a redacted pleading in the open court file. I think we have a fundamental disagreement over the what constitutes protected Grand Jury material, and how readily such
protected material
can be segregated from non-protected information. As far as the information at page 32 n.20, of the government's reply, the government would need to obtain additional authorization from the Court under Fed.R.Cr.P. 6(e…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204876.pdf
EFTA00583454
Dataset 9
13p
3,972w
…not lie, the Mohawk Court concluded that postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney-client privilege. Appellate courts can remedy the improper disclosure of privileged material in the same way they remedy a host of other erroneous evidentiary rulings: by vacating an adverse judgment and remanding for a new trial in which the
protected material
and itsfruits are excludedfrom evidence. 2 EFTA00583455 Id. at 606-07 (emphasis added). This conclusion…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583454.pdf
EFTA00583780
Dataset 9
15p
4,660w
…would not lie, the Mohawk Court concluded that postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney-client privilege. Appellate courts can remedy the improper disclosure of privileged material in the same way they remedy a host of other erroneous evidentiary rulings: by vacating an adverse judgment and remanding for a new trial in which the
protected material
and its fruits are excludedfrom evidence. Id. at 606-07 (emphasis added). This conclusion…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583780.pdf
EFTA00209806
Dataset 9
2014-04-18
16p
7,014w
…609. The Supreme Court explained that an ap- peal from a final judgment suffices "to protect the rights of litigants and ensure the vitality of the attorney-client privilege" because ^[a]ppellate courts can remedy the improper disclosure of privileged material in the same way they remedy a host of other erroneous evidentiary rulings: by vacating an adverse judgment and remanding for a new trial in which the
protected material
and its fruits are excluded from evidence." Id. at…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209806.pdf
EFTA00029951
Dataset 8
2018-11-29
4p
2,283w
…Copy (2021) 4 The Government also argues that the Confidential Information covered by the Protective Order is not the sort of sensitive information that has been protected in the past, such as trade secrets. The fact that the
protected material
here is not of a specific type that has arisen in prior cases does not suggest that this case is extraordinary. End of Document O2021 Thomson Reuters. No claim to original U.S. Government Works. WESTLAW © 2021 Thomson Reuters…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029951.pdf
EFTA00015219
Dataset 8
2020-05-26
58p
17,292w
…Additionally, as contemplated by the FOIA Improvement Act of 2016, all of the
protected material
was created less than 25 years before the submission of Plaintiff's request. Deliberative Communications (56) The FBI asserted Exemption 5 to withhold deliberative communications. These communications contain or consist of material related to deliberations by DOJ employees who are making proposals and/or working to come to a consensus on final agency decisions. Specifically, this material includes FBI and the United States Attorney ("AUSA…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015219.pdf
EFTA00584603
Dataset 9
2008-07-11
21p
5,110w
…would not lie, the Mohawk Court concluded that 7 EFTA00584609 postjudgment appeals generally suffice to protect the rights of litigants and ensure the vitality of the attorney-client privilege. Appellate courts can remedy the improper disclosure ofprivileged material in the same way they remedy a host of other erroneous evidentiary rulings: by vacating an adverse judgment and remanding for a new trial in which the
protected material
and itsfruits are excludedfrom evidence. Id. at 606-07 (emphasis added). This conclusion…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584603.pdf
EFTA00209741
Dataset 9
2014-04-18
23p
5,318w
…judgment suffices "to protect the rights of litigants and ensure the vitality of the attorney-client privilege" because "[a]ppellate courts can remedy 15 EFTA00209755 Case: 13-12923 Date Filed: 04/18/2014 Page: 16 of 23 the improper disclosure of privileged material in the same way they remedy a host of other erroneous evidentiary rulings: by vacating an adverse judgment and remanding for a new trial in which the
protected material
and its fruits are excluded from evidence." Id…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209741.pdf
EFTA00070830
Dataset 9
2018-11-29
7p
2,189w
…by the Protective Order is not the sort of sensitive information that has been protected in the past, such as trade secrets. The fact that the
protected material
here is not of a specific type that has arisen in prior cases does not suggest that this case is extraordinary. 6 EFTA00070835 The subject matter of the Government's investigation is obviously serious. But to pierce the Protective Order, the Government must demonstrate not that this investigation is an extraordinary circumstance…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00070830.pdf
EFTA00622043
Dataset 9
2016-03-09
12p
2,821w
…have "access to" the material. Subsection (h)(3) further muddies Plaintiff's murky swamp of disclosure. If Plaintiff or her lawyers have a "good. basis to conclude" that someone has either "received" (and apparently not looked at) or "seen" (which would imply receipt followed by viewing) Plaintiff or her lawyers can disseminate
Protected Material
to that person. Seemingly, if either Plaintiff or her lawyers are tricked by someone in the press or otherwise and have a "good ." but 6 EFTA00622051…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622043.pdf
EFTA00657039
Dataset 9
2011-09-27
12p
3,759w
…1073, 1081 (4th Cir. 1981): "to effect a forfeiture of work product protection by waiver, disclosure must occur in circumstances in which the attorney cannot reasonably expect to limit the future use of the otherwise
protected material
." Doe thus established reasonableness of the disclosing party's expectation of confidentiality as the touchstone for determining whether work product privilege was waived. 'In Nobles, the Court determined that, when defense counsel elected to put his investigator on the witness stand at trial…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00657039.pdf
EFTA00068378
Dataset 9
2019-07-18
5p
1,716w
…suggestion. E-mail us. at
[email protected]
with your comments or questions. 0 1095 777o Miami Harald The information you receive on-linc from The Miami Herald is protected by the copyright !can ofthe United States. The copyright lawsprohibit any copying, redistributing. retransmitting. or repurposing ofany copyright-
protected material
. The Miami Herald archives are stored on a SAVE (tm) newspaper library systemfrom MediaStream Inc.. a Knight- Ridder Inc. company tile://C: \America Online 4.01abbieWROBEFIIM 01/08/2000 EFTA00068382
https://www.justice.gov/epstein/files/DataSet%209/EFTA00068378.pdf
EFTA00209236
Dataset 9
2011-03-21
20p
5,563w
…questions. See DE 247-1 at 3, 1 12(b) (after filing of pleading with
protected material
, the "motion filing and briefing schedule shall be adjusted and tolled to provide sufficient time for the Court to consider and rule on the motion seeking permission to file the document(s) under seal."). All these ambiguities are sure to create abundant litigation — as a just a quick perusal of Epstein's litigation tactics in this case in the past will attest. And…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209236.pdf
EFTA00209632
Dataset 9
2014-04-18
24p
5,766w
…judgment suffices "to protect the rights of litigants and ensure the vitality of the attorney-client privilege" because "[a]ppellate courts can remedy 15 EFTA00209646 Case: 13-12923 Date Filed: 04/18/2014 Page: 16 of 23 the improper disclosure of privileged material in the same way they remedy a host of other erroneous evidentiary rulings: by vacating an adverse judgment and remanding for a new trial in which the
protected material
and its fruits are excluded from evidence." Id…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209632.pdf
EFTA01084188
Dataset 9
2011-06-06
7p
2,982w
…of the Client 14. To & effective, any modifications to this Agreement shall be in writing and signed by each of the parties. 15. Inadvertent or unauthorized disclosure of information or material covered by this Agreement shall not operate as a waiver with respect to any other
protected material
under this Agreement. 16, All parties agree that irreparable damage would result from any party's breach of this Agreement and that, in the event of a breach, specific performance and/or…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084188.pdf
EFTA00800866
Dataset 9
2018-03-02
9p
2,944w
…Edwards, and attorney Mark Nurik — was revealed in Epstein's recent March 2 filing at Exhibit C, page 1 (identifying email by Bates number 1527). That email quotes anticipated statements from one the three victims. Id. ("she will say ... [recounting anticipated testimony].").2 This is core attorney-client
protected material
. As another straightforward illustration, consider an email on October 23, 2009, between the victims' attorney, Bradley J. Edwards, and other attorneys (Fistos' et al.) — again revealed in Epstein's recent…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800866.pdf
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