Epstein Secrets

nc., 399 F.3d 391 (1st Cir. 2005) 54 *Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 51, 52, 55 In re Air Crash Near Cali,

1987) 53 In re MTSG, Inc., 675 F.3d 1337 (Fed. Cir. 2012) 32, 33 In re RDM Sports Group, Inc., 277 B.R. 415 (N.D. Ga. 2002) 34, 40 In re Sealed Case, 716 F.3d 603 (D.C.Cir. 2013) 54 In re Six Grand Jury Witnesses, 979 F.2d 939 (2d Cir. 1992), cert. denied sub nom. XYZ Corp. v. United States,

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

idence stronger than in the context of a valid grand jury subpoena.'" In re Grand Jury Proceedings , 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case , 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena , 223 F.3d 213, 218 (3d Cir. 2000) ("One EFTA00211781 of the most signi

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

idence stronger than in the context of a valid grand jury subpoena.'" In re Grand Jury Proceedings , 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case , 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena , 223 F.3d 213, 218 (3d Cir. 2000) ("One EFTA00222997 of the most signi

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

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document

"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

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document