Epstein Secrets

happened. 3 as importantly, both aides are adequately prepared 5 when the trustee took over the tiles, there 6 so that, as I mentioned in this Pollard case, no 4 wan an understanding by Hr. Edwards and his firm 7 ono is unduly surprised by something that cones 7 that [hove would to about 5,000

e I' today and that have been flied as a matter of se done. But it will be ordered that it be done post in record. I• trial. 19 KR. CASSELL: Gould they also be directed to 20 Any other remedies that are ➢ought as you go 20 make a representation as to who they have 21 along -- I understand

happened. 3 as importantly, both aides are adequately prepared 5 when the trustee took over the tiles, there 6 so that, as I mentioned in this Pollard case, no 4 wan an understanding by Hr. Edwards and his firm 7 ono is unduly surprised by something that cones 7 that [hove would to about 5,000

URT: I don't think chat I have that 78 80 I reserving on that as will. I ability. 2 MR. CASSELL: But related to that is the 2 KR. CASSELL: Gould I be heard on that issue 1 distribution. Tho cat is now wandering out of the 3 then? I believe that you do have -- all right. 4 bag, so sloe is

result in more limited waiver, as to the materials actually produced. This concept was clari- fied further y the Court in Martin Mari- etta Corp. . Pollard, 856 F.2d 619, 626 i (4th Cir.19 ), where it stated: irst and most generally, opinion work product is to be accorded great protection by the cou

those original documents, the defendant does not have possession of them. The necessary predicate does not exist, and Sporck is not triggered. See Gould, 825 F.2d at 680 ("the equities may not favor the application of the Sporck exception if the files from which the documents had been culled . . . w