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D.Me.2001) federal courts apply federal law when ad ressing the work product doctrine, even in di- versity cases lacking any federal ques- tion); 8 Wright, Miller & Marcus, Feder- al Practice and Procedure: Civil 2d. § 2023 (2d ed. 1994) ("At least since the adoption of Rule 26(13)(3) in 1970, it has
e complained mightily that Rosenbaum has already made unauthorized disclosures, Garfinkel and Katzman have not identified for this Court which of Rosenbaum's statements in the Request for Judicial Inquiry, or at the April 16 healing, they claim are privileged. Moreover, Katzman's assertion of privileg
and has led to litigation between the former law partners. The motions now before this Court arise, in large measure, from heated disputes between Rosenbaum on the one hand, and Garfinkel and Katz- man on the other. Immediately following the breakup of KGR, Rosenbaum's law firm, RMJS, en- tered appeara
nd responsibilities whatsoever.'" CNN <https://www.cnn.com/2020/11/19/politics/biden-harris-classified-intelligence-gap/index.html> (11/19, Cohen, Wright, Herb, 83.16M) reports, "there's a world of difference between what Biden can learn from outside EFTA00137254 experts and the depth of knowledge h
inst Protesters Dismissed In Court. • Federal Lawsuit Against Chicago Police Alleges "Brutal Attacks On Protesters." • WPost Analysis: Rittenhouse, Rosenbaum's Encounter "Divided The Nation." Counter-Terrorism • Syrian IS Suspect Arrested By Greek Police After Migrant Camp Fight. • Watchdog: EU Relying
saying Trump was willing to help prosecutors expose Epstein as a child predator. Additional reporting on the story was provided by ABC News (09/07, Wright), Newsmax (09/07, Fitzgerald), Tampa Free Press (09/07, Shockey), and USA Today (09/07, Bagchi). EFTA00163821 EFTA00163822 EFTA00163823 EFTA0
, Vaillancourt), HuffPost (09/06, O'Connor), The Independent (09/06, Evans), The Intercept (09/05, Aaronson), Fox News (09/06, Miller), NPR (09/06, Rosenbaum), Rolling Stone (09/06, Legaspi, Suebsaeng), and Telegraph (09/06, Millward). MSNBC (09/06, Video) published broadcast coverage of the story. House
gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern I. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA00210143 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead
ely separate from her role as the Vice President- Elect. There is no co-mingling of those roles and responsibilities whatsoever." CNN (11/19, Cohen, Wright, Herb, 83.16M) reports, "there's a world of difference between what Biden can learn from outside experts and the depth of knowledge he would gain fr
inst Protesters Dismissed In Court. • Federal Lawsuit Against Chicago Police Alleges "Brutal Attacks On Protesters." • WPost Analysis: Rittenhouse, Rosenbaum's Encounter "Divided The Nation." COUNTER-TERRORISM • Syrian IS Suspect Arrested By Greek Police After Migrant Camp Fight. • Watchdog: EU Relying
gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O'Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within pleading to decide application of work product privilege). The Court will therefore evaluate each claim of
gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA_R1_01293439 EFTA02335901 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 P
gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA00086448 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead
saying Trump was willing to help prosecutors expose Epstein as a child predator. Additional reporting on the story was provided by ABC News (09/07, Wright), Newsmax (09/07, Fitzgerald), Tampa Free Press (09/07, Shockey), and USA Today (09/07, Bagchi). DEA Breaks Down International Drug Conspiracy Affe
, Vaillancourt), HuffPost (09/06, O'Connor), The Independent (09/06, Evans), The Intercept (09/05, Aaronson), Fox News (09/06, Miller), NPR (09/06, Rosenbaum), Rolling Stone (09/06, Legaspi, Suebsaeng), and Telegraph (09/06, Millward). MSNBC (09/06, Video) published broadcast coverage of the story. House
gh "[s]ome older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipatio
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA01657755 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead
Entities connected to both Wright and Richard M. Rosenbaum

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATION
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSONEmmy Taylor
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Michael Jackson
PERSONJane Doe
PERSON
Eric Trump
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
Marc Rich
PERSON
Michael Douglas
PERSON
George Mitchell
PERSON