Epstein Secrets

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

m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher v. United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) t

ney (or his agent) can use the attorney-client privilege to EFTA00211784 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen

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

m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher I United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) te

ney (or his agent) can use the attorney-client privilege to EFTA00223000 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen

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

f 22 documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

nsidered the facts alleged in the Complaints, the elements needed to convict Epstein of ' Rule 26(b)(3) was adopted in 1970 to codify the holding in Hickman v. Taylor, 329 U.S. 495 (1947). 10 EFTA00592200 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 11 of 14 a crime, th

nsive documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

mation need not be admissible at trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id: see also Hickman I2 EFTA00728605 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);

f 22 documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

0 or more." CYBER DIVISION Ransomware Attackers Pressure Knoxville, Tennessee By Posting City Data Online. The Knoxville (TN) News Sentinel (7/2, Hickman, 307K) reports, "Cybercriminals have published city of Knoxville files online, including employees' personal information, as part of an ongoing eff

f the US was "a muted celebration by people who are frustrated and strained, yet intriguingly, persistently hopeful about the future." According to Fisher, "A triple whammy of deadly disease, wholesale economic paralysis and a searing reckoning with racial inequality has largely canceled the nation's

vid. 804(b)(1)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "pro

ssession may also be obtained from the attorney by similar process following transfer by the client in order to obtain more informed legal advice." Fisher,. United States, 425 U.S. 391, 403-04 (1976) (addressing attorney-client privilege). Accord Shelton American Motors Corp, 805 F.2d 1323, 1328 (8th