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n 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, litigatio
using CM/ECF because it is being filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney U.S. Attorney's Office West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for Unit
n 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 I Taylor , 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation
using CM/ECF because it is being filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney Attorney for United States EFTA00223014 William L. Richey, Esq. Attorney for Subpoenaed P
o.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing., Hickman v. Taylor 329 U.S. 495, 501, 507 (1947). 15. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brand
, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court." Id, at 1189. In Tilton v. Playboy Entertainment Group, Inc 554 F.3d 1371 (11th Cir. Jan. 15, 2009), the District Court granted plaintiff "the min
Entities connected to both Hickman and United States District Court

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATIONJack Goldberger
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSON
Scarlett Johansson
PERSON
Alexander Acosta
PERSON
Alan Dershowitz
PERSONSouthern District
LOCATION
George W. Bush
PERSONFBI
ORGANIZATIONRobert D. Critton
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSON
Prince Andrew
PERSON