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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
n anticipation of litigating one case remain protected in a subsequent case[] if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grol
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
9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grol
"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
9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grol
"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
9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Groli
Entities connected to both Hickman and Underwriters Ins. Co.

Jeffrey Epstein
PERSONEmmy Taylor
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Supreme Court
ORGANIZATION
George W. Bush
PERSONLeon Black
PERSON
Michael Douglas
PERSON
Jay Lefkowitz
PERSONthe Southern District
LOCATIONWright
PERSONRoy Black
PERSOND.C. Cir
ORGANIZATION
Paul Cassell
PERSON
Michael Jackson
PERSONMiller & Marcus
ORGANIZATIONRichard M. Rosenbaum
PERSONDonuts, Inc.
ORGANIZATION
Armstrong
PERSON