Epstein Secrets

ation need not be admissible at trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id.; see also Hickman 12 EFTA00723247 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 13 of 22 v. Taylor, 329 U.S. 495, 507-508 (1947); Far

rranted. In a federal companion case, Jane Doe No. 2 v. Epstein, Case No. 08-CIV-80119 MARRPJJOHNSON, in the United States District Court for the Southern District of Florida, United States Magistrate Judge Linnea R. Johnson found, "[i]n 2008, Epstein entered into a Non-Prosecution Agreement with the United St

"work-product doctrine is distinct from and broader than the attorney-client privilege." United States I. Nobles, 422 U.S. 225, 238 (1975) (citing Hickman 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply b

eding.' (DE M-1 at 21-22); see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted

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

onsibility of any further criminal investigation or potential prosecution of Epstein relating to his alleged sexual activities with minor females in the Southern District of Florida, and that responsibility for any future prosecutorial action arising out of Epstein's alleged criminal activity in this district has now

t from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238, 95 S. Ct. 2160, 45 L. Ed. 2d 141 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply

too close to persons associated with the victims. 4. Request No. 18--Documents Concerning Recusal of the United States Attorney's r33] Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted

e "work-product doctrine is distinct from and broader than the attorney-client privilege." United States v. Nobles 422 U.S. 225, 238 (1975) (citing Hickman 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply b

ng.' (DE 212-1 at 21-22); (see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted

"work-product doctrine is distinct from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply

n, which she is likely to refuse to give or provide, on the matters about which she may be interrogated before the United States District Court for the Southern District of Florida, including a Grand Jury impaneled therein, as well as subsequent proceedings or trial, and respectfully alleges as follows: 1. That ==.

"work-product doctrine is distinct from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238 (1975) (citing Hickman 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply b

ing.' (DE 212-1 at 21-22); see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted

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

Motion for a Protective Order and ordering disclosure to plaintiffs of the intervenor attorneys' written communications with federal prosecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-atto

cannot be the law and is certainly unsound policy. Indeed, the district 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

013 (Doc. 188), Exhibit A hereto, ordering disclosure to plaintiffs of the intervenor attorneys' written communications with federal prosecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Jeffrey Epstein through attorney-t

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

of any certain set of facts, other than whether a charging document was ever filed against Jeffrey Epstein in the United States District Court for the Southern District of Florida. And while this Office remains willing to cooperate, cooperation does not mean agreeing to facts that arc not relevant to the resolution