Epstein Secrets

thin the bounds of reasonableness, 11 the Defendant is entitled to the information 12 contained in Interrogatory 19. 13 Now, with regard to the John Doe issue 14 relative to partners or Jane Doe, whoever may be 15 involved, I will permit, as did Judge Lewis in 16 her analysis, anyone who is name

s you get to 9 depose Mr. Epstein one time, all right. Already 10 Mr. Epstein's been deposed by Sid Garcia in the 11 State, he's been set by in B.B., which is one of 12 your cases, by Mr. Kuvin and the State, and Mr. 13 Berger and Mr. Edwards have started his 14 deposition, so this is kind o

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Motor Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E. Rule 6(e) —

e materials. The Government has already followed this procedure elsewhere and should do so here. See, e.g., Bates 000966-67 (materials about victim "B.B."). No Assertion of Privacy Rights by Other Victims. Several of the victims cited by the Government are represented by undersigned counsel and do no

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Moto• Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E Rule 6(c) —

e materials. The Government has already followed this procedure elsewhere and should do so here. See, e.g., Bates 000966-67 (materials about victim "B.B."). No Assertion of Privacy Rights by Other Victims. Several of the victims cited by the Government are represented by undersigned counsel and do no