Epstein Secrets

"a far stronger showing of necessity and unavailability by other means" than is needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States, 14 EFTA01657765 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 449 U.S. 383, 402 (1981));

or the Southern District of Florida and the Executive Office of United States Attorneys. (DE 212-1 at 22-23); (see Table at P-013248-13278). One of the Executive Office's functions is to "[p]rovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the Uni

"a far stronger showing of necessity and unavailability by other means" than is needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States 14 EFTA00086458 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 449 U.S. 383, 402 (1981));

for the Southern District of Florida and the Executive Office of United States Attorneys. (DE 212-1 at 22-23); see Table at P-013248-13278). One of the Executive Office's functions is to "[p]rovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the Uni

_00059577 CONFIDENTIAL - PURSUANT TO FED. R.CCIN(F IDENTIAL DB-SONY-0022401 EFTA 00170127 EFTA01296795 Page 71 2015 U.S. Dist. LEXIS 87203, * Upjohn Co. v. United States, 449 U.S. 383, 402, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under c

or the Southern District of Florida and the Executive Office of United States Attorneys. (DE 212-1 at 22-23); (see Table at P-013248-13278). One of the Executive Office's functions is to "[p]rovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the Uni