Epstein Secrets

ty's] belief that the papers are those described in the subpoena. Doe, 465 U.S. at 612, quoting Fisher, 425 U.S. at 410; see also United States v. Hubbell, 530 U.S. 27, 40 (2000) (compelled testimony "is not to be found in the documents produced in response to the subpoena" but is instead "the testimon

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor,. 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modem work- product doctrine, holding that: (flu performing his various duties, how

rty's] belief that the papers are those described in the subpoena. Doe, 465 U.S. at 612, quoting Fisher, 425 U.S. at 410:see also United States v. Hubbell, 530 U.S. 27, 40 (2000) (compelled testimony "is not to be found in the documents produced in response tip the subpoena" but is instead "the testimo

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

TA00179122 1991) (Fifth Amendment does not protect the contents of voluntarily prepared documents, whether business or personal); United States v. Hubbell, 167 F.3d 552, 567 (D.C. Cir. 1999) (same), aff'd on other grounds, 530 U.S. 27 (2000); In re Grand Jury Proceedings, 759 F.2d 1418, 1419 (9th Cir.

ain hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re