Epstein Secrets

Case No. 502008CAOILUMOCXMB AB Epstein's Objections tW Request and Motion for Protective Order Page 15 of 22 39. This case is more analogous to Murphy and Gooey, where the court prohibited inspection because the plaintiffs could not demonstrate the how the inspection would be relevant to their res

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

d after the date of enactment,' " referenced in Landgraf, "unambiguously addresses the temporal reach of the statute" (citation omitted)); Lindh v. Murphy, 521 U.S. 320, 329 n. 4, 117 S.Ct. 2059, 2064 n. 4, 138 L.Ed.2d 481 (1997) (recognizing from Landgraf that statutory language such as, " `[This Act

o.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing., Hickman v. Taylor 329 U.S. 495, 501, 507 (1947). 15. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brand

or before a grand jwy. United States R. Nixon, supra; Kastigar R. United States, 406 U.S 441, 443444. S.Ct. 1653, 1f5-1616, 32 L.Ed.2d (1972); Murphy . Waterfront Comm'n, 8 U.S. 52, 93- 4, 84 S.Ct. 1594, 1610-1611, 12 L.Ed.2d 678 (1964) (White, .J., concurring). we recently ob- served in Unite

notes had in the first place before reaching the `waiver' issue. Accordingly, and because I do not believe that the ork-product *243 doctrine of Hickman Taylor, 329 U.S. 495, 67 S.Ct. 385, 91 L. . 451 (1947), can be extended wholesale from its historic role as a limita- tion on the nonevidentiary m