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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
80); United States v. Landof, , 591 F.2d 36, 38 (9th Cir. 1978); In re Grand flay Proceedings , 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn , the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd , the court found tha
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
980); United States I Landof, , 591 F.2d 36, 38 (9th Cir. 1978); In re Grand flay Proceedings , 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn , the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd , the court found tha
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
miss, page 8, n. 8][DE 119). However, it contends, without explanation, that the September 24, 2007 non-prosecution agreement would still constrain the Middle District of Florida United States Attorney's Office "due to that office's recusal- based derivative prosecutorial responsibilities in the Southern District of
Entities connected to both Hickman and the Middle District

Jeffrey Epstein
PERSON
United States
LOCATION
Scarlett Johansson
PERSONEmmy Taylor
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSONJane Doe
PERSON
Kenneth Marra
PERSONFBI
ORGANIZATION
United States District Court
ORGANIZATION
Julie K. Brown
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Supreme Court
ORGANIZATION
Donald Trump
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON