Re: ATTORNEY-CLIENT PRIVILEGE - JE

Spoke at length with the OGIS assistance group re FOIA. They actually think the FBI is one of the more responsive agencies. They do what I have been doing with the Liaison - extracting "estimates" of when a batch will be produced. They will then communicate with me on your behalf and close the file when that batch is produced thus requiring us to make serial applications if we want them to be a second voice pushing for compliance. I will trigger this process (without a lot of faith it will help).

Ultimately, going to court is the only way to create an enforceable schedule. OGIS told me that they are familiar with schedules urged by DOJ OIP which are just ignored due to agency resource limits.

Just spoke with Kendall about the basis for VR to be listed. He agrees he has the better shot of discovering that info which could also help Alan (clearly if there is another witness rather than just a plane log that witness did not ID Alan). He will make the call. Confirms he is helping Alan identify a Broward lawyer.which will then lead to an investigator. I have seen inserts from Alan so I know that he is pushing the writing/filing of a response to the Motion by Boies for Protection/Limits

she is a believer he shouldstress that allowing her to lies so much is a real harm to truevicitms

can kenedall talk to
marie?

I ve asked. He agrees

Sent from my
iPhone

He will make that case from Alan's rights as a wrongly accused person - that if there is another person that made her a "victim" with sufficient detail to put on her the "victim list" for reparations than the other person could potentially testify to statements JD3 made, people she claimed to have massaged, etc. If this other person - again, if there was one - had named Alan they never would have allowed him into a negotiating session after JD 3 was interviewed as a potential witness. Otherwise, maybe its just a plane record but Kendall has the best chance of finding out from the perspective of his need to represent Alan Martin G. Weinberg, Esq.

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