Epstein Secrets

matters. Thus, when once- secret grand jury material becomes "sufficiently widely known," it may "los[e] its character as Rule 6(e) material." In re North, 16 F.3d 1234 (D. C. Cir. 1994). 3 EFTA00177809 Case 9:08-cv-80736-KAM Document 187 Entered on FLSD Docket 06/18/2013 Page 4 of 4 It is accordin

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman v. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to the days of se

type of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co.. 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[Elven if material concerning the grand jury investigation had been disclosed to the public, the Government

f litigation.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawye

ions); Gardner v. Newsday, 895 F.2d 74, 79 (2d Cir. 1990) (balancing newspaper's common law right of access with defendant's privacy rights); Joy v. North, 692 F.2d 880 (2d Cir. 1982) (distinguishing between documents obtained in discovery from those filed pursuant to an adjudication for purposes of th

to a morbid craving for that which is sensational and impure."). IsiPretrial discovery is intended to aid the parties in their search for truth. See Hickman v. Taylor, 329 U.S. 495, 501, 67 S.Ct. 385, 91 L.Ed. 451 (1947) (celebrating that "[t]he deposition-discovery regime set out by the Federal Rules o