Epstein Secrets

claim of Fifth Amendment privilege and must be responded to within fifteen (15) days from the date hereof. DONE AND ORDERED this August 4, 2009, in Chambers, at West Palm Beach, Florida. LINNEA R. JOHIJ2UN UNITED STATES MAGISTRATE JUDGE CC: The Honorable Kenneth A. Marra All Counsel of Record 22 E

ation need not be admissible at trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id.; see also Hickman 12 EFTA00723247 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 13 of 22 v. Taylor, 329 U.S. 495, 507-508 (1947); Far

DENIED; and, (3) Plaintiffs Motion to Compel Answers to Interrogatories (D.E.#196 and #212) Is DENIED. DONE AND ORDERED this February 4, 2010, in Chambers, at West Palm Beach, Florida. o LINNEA R. J ON UNITED STA S MAGISTRATE JUDGE CC: The Honorable Kenneth A. Marra All Counsel of Record 14 E

nsidered the facts alleged in the Complaints, the elements needed to convict Epstein of ' Rule 26(b)(3) was adopted in 1970 to codify the holding in Hickman v. Taylor, 329 U.S. 495 (1947). 10 EFTA00592200 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 11 of 14 a crime, th

claim of Fifth Amendment privilege and must be responded to within fifteen (15) days from the date hereof. DONE AND ORDERED this August 4, 2009, in Chambers, at West Palm Beach, Florida. 0 eins.O-"-- LINNEA R. JOHNSON UNITED STATES MAGISTRATE JUDGE CC: The Honorable Kenneth A. Marra All Counsel of R

mation need not be admissible at trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id: see also Hickman I2 EFTA00728605 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 13 of 22 v. Taylor, 329 U.S. 495, 507-508 (1947);

D. 2. The stay of discovery pending ruling on the government's motion to dismiss entered November 8, 2011 [DE# 123] is LIFTED. DONE AND ORDERED in Chambers at West Palm Beach, Florida this 18th day of June, 2013. United States District Judge cc. All counsel 14 _SEALED /' NOT SEALED EFTA00177806

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman v. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to the days of se

notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. F

"work-product doctrine is distinct from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply