Epstein Secrets

_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

ffice's functions is to "[p]rovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the United States Attorneys, United States Department of Justice, http://www.justice.gov/usao/eousa/mission-and-functions (last visited June 19, 2015). The internal documents

"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));

ffice's functions is to "[p]rovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the United States Attorneys, United States Department of Justice, http://www.justice.gov/usao/eousahnission-and-functions (last visited June 19, 2015). The internal documents

"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));

ffice's functions is to "[p]rovide general legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." Offices of the United States Attorneys, United States Department of Justice, http://www.justice.gov/usaoThousa/mission-and-functions (last visited June 19, 2015). The internal documents