Epstein Secrets

y or for a party to the subsequent litigation," Underwriters Ins. Co. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication I. Grolier, Inc., that "the literal language of [Rule 26(b)(3)] protects materials prepared for ars litigation

ket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication I. Grolier, Inc., that "the literal language o

ch governs, the law must be obeyed.... United States t Schooner Peggy, 5 U.S. (1 Cranch) 102, 9, 2 L.Ed. 49 (1801). This principle is embodied in the Supreme Courts holding that a new law applies to a case in progress unless applying it "would result in manifest injustice or there is stat- utory direction or il

vernment is required to demonstrate that there are grounds for a hearing under the specific provisions of either 3142(f)(1) or (f)(2)." Butler, 165 F.R.D. at 71. "When there exists one or more grounds for holding a hearing under those provisions, the government may proceed on the theory of risk of fli

r for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language of [Rule 26(b)(3)] protects materials prepared for ars litigation

07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language o

re, .'s treatment records from the Parent-Child Center, Inc. and Dr. Serge Thys are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee'. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00182846 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009

ere, preventing Epstein from identifying Plaintiffs' in subpoenas and other type discovery overwhelmingly inhibits discovery. Ees Doe v. Evans, 202 F.R.D. at 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing De

tlement agreement constituted Page 10 an "implied waiver" of this privilege. Id at 622-26. The court began its analysis with a con- sideration of the Supreme Court's decision in Nobles, noting that that decision held that an attempt to make testimonial use of work product resulted in an implied waiver of the p

to Orig. US Gov. Works. https://web2.westlaw.contrint/printstream.aspers=WLW11.07&pbc=8C6E23F9,Sidecti n ObAPIAI EFTA00177915 Page 10 of 25 183 F.R.D. 458,51 Fed. R. Evid. Serv. 35 (Cite as: 183 F.R.D. 458) L . way that the attorney client priv- ilege can. Whether the information involved is fac