Epstein Secrets

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losure of the attorney's identification of some occasional wheat among the chaff."); In re Shell Oil, 125 F.R.D. at 134 ("it is highly unlikely that Shell will be able to discern the PLC's `theory of the case' or thought processes simply by knowing which 65,000 out of 660,000 documents have been selec

)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "protected zone"

rcuits reaching the same conclusion. Jones, 471 F.3d at 538-39 (citing United States v. Griffith, 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor, 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum, 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton, 456 F.2d 171, 173 (

d Epstein that she had just turned 18 (although she was really 15). Epstein paid JD#3 $200 for that first massage and then had her dropped off at a Shell gas station near Okeechobee Blvd. and the Turnpike. Prior to leaving Epstein's house, JD#3 gave her telephone number to one of Epstein's assistants.