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; Lake Shore Radiator, Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v. Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes inf
have experienced several incidents in their lives which affected them emotionally and psychologically. See M•, Exhibits "C" and "D", Affidavits of Richard C.W. Hall, outlining the psychological issues experienced by Jane Does 4 and 6 as a result of incidents in their lives prior to Epstein, which cannot be disc
the discovery of admissible evidence. Rule 26(b)(l), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). See Hickman v. Taylor, 329 U.S. 495, 507-08 (1947); Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978). In Oppenheimer, the Supreme Court discussed th
laintiffs have experienced several incidents in their lives which affected them emotionally and psychologically. See ~-, Exhibit "D", Affidavit of Richard C.W. Hall, outlining the psychological issues experienced by Jane Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As
; Lake Shore Radiator. Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v, Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes inf
have experienced several incidents in their lives which affected them emotionally and psychologically. See g., Exhibits "C" and "D", Affidavits of Richard C.W. Hall, outlining the psychological issues experienced by Jane Does 4 and 6 as a result of incidents in their lives prior to Epstein, which cannot be disc
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