Epstein Secrets

ference must have specified -the purpose for which the computers were seized and delineated the limits of their subsequent search". United States v. Hunter, 13 F.Supp.2d 574, 584 (D.Vt. 1998) Given these principles, the Requests contained in ¶'s 1 and 2 of the subpoenas are clearly unreasonable, since

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

ference must have specified -the purpose for which the computers were seized and delineated the limits of their subsequent search". United States v. Hunter, 13 F.Supp.2d 574, 584 (D.Vt. 1998) Given these principles, the Requests contained in ¶'s 1 and 2 of the subpoenas are clearly unreasonable, since

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

poena, 204 F.3d 516 (4th Cir. 2000), see Response at 21-22, was simply a claim of privilege with respect to the client's identity. United States v. Hunter, 1995 WI, 12513 (N.D.111. January 6, 1995), does not, as the government would have it. "contain[] facts similar to the ones, at bar." Response at 21

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