Epstein Secrets

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

prepared in anticipation of litigation by or for a party or by or for that party's attorney acting for his client, Fed. R. Civ. P. 26(b)(3)'; In re Grand Jury Proceedings, 601 F.2d 162, 171 (5th Cir. 1979), is also not implicated as the subject documents were not created by Epstein's attorneys. Id. Finally, Epstein

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

, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States v. Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa

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

ed, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa