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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA00208564: Privilege and Treat (DS9)

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Email correspondence dated August 6, 2013, between Paul Cassell and Jackie Perczek (with Brad Edwards copied) discussing legal arguments regarding attorney-client privilege and jurisdictional questions in a motion. The exchange addresses whether privilege applies to a motion to treat a motion to dismiss as equivalent to a jurisdictional matter, with Cassell arguing that privilege is central to both the jurisdictional and merits questions.

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Excerpt 1
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**.
Excerpt 2
So **privilege** is at the heart of the jurisdictional question you raise, and at the heart of the merits. They cannot be separated.
Excerpt 3
The Court needs to look at our merits arguments on **privilege** to determine the jurisdiction issue.

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