3 computers that were taken wires - pool cabana

I was Epstein's I was

Dalia was still the attorney when the first discussion of search warrant occurred Hard files"-massages"-ranging files w/ "models" contents removed

EFTA00179234

$\textcircled{1}$ what does act of production priv cover?

production of items tending to incriminate

- if the act of producing establishes link in chain

$ \textcircled{2} $ only protects person making th production unless stands in shoes of Epstein

Fifth Amendment only bars compulsion of testimonial evidence -hardwriting samples, blood, DNA, breath, fingerprint

Break discussion into two parts

-computer equipment (requests

1 and 2)

-other items

-> no act of production privilege for these

$ \textcircled{1} $ What does act of production privilege cover a)production of items that tend to incriminate the subpoenaed party

EFTA00179235

Does the Attorney - Client privilege apply?

-privilege is not favored

-criteria for applying privilege

-Allen v. McGraw, 106 F.3d 582, 600 (4th Cir. 1997)

-the privilege protects only the attorney-client communication, not the underlying facts. Id. at 604 (citing Upjohn, 449 US at 395)

Party asserting work product doctrine or attorney-client privilege as a bar to discovery has the burden of establishing that either or both is applicable. Barclays American Corp. v. Kane, 746 F.2d 653, 656 (10th Cir. 1984) (extensive citations omitted)