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Epstein File EFTA01111901: Privilege and Session (DS9)

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This document is a transcript of a phone conference session between parties in a civil case (Case 1:15-cv-07433-RWS, Document 79) dated April 4, 2016. The discussion centers on resolving privilege matters and scheduling additional material submissions. The parties agreed to defer certain issues pending resolution of privilege questions to avoid potential exposure, and the plaintiff agreed to proposed protective measures for a phone conference session.

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you to submit any additional materials and I think 4 that submission should be on the schedule that we have already 5 determined with respect to the **privilege**
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So, it seems to me it is sensible to 22 put that over. 23 So, assuming that we can resolve the **privilege** matters 24 and anything else you want to bring
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I do agree and it was part of our papers 17 that we wanted to get the **privilege** issues resolved so that we 18 would not be subjecting ourselves, potentially

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