Epstein Secrets

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

e complained mightily that Rosenbaum has already made unauthorized disclosures, Garfinkel and Katzman have not identified for this Court which of Rosenbaum's statements in the Request for Judicial Inquiry, or at the April 16 healing, they claim are privileged. Moreover, Katzman's assertion of privileg

and has led to litigation between the former law partners. The motions now before this Court arise, in large measure, from heated disputes between Rosenbaum on the one hand, and Garfinkel and Katz- man on the other. Immediately following the breakup of KGR, Rosenbaum's law firm, RMJS, en- tered appeara

"work-product doctrine is distinct from and broader than the attorney-client privilege." United States I. 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

y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern I. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA00210143 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead

t from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238, 95 S. Ct. 2160, 45 L. Ed. 2d 141 (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

y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O'Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within pleading to decide application of work product privilege). The Court will therefore evaluate each claim of

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

y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA_R1_01293439 EFTA02335901 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 P

"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

y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA00086448 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead

"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

y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA01657755 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead