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r Motion for a Protective Order and ordering disclosuret plaintiffs of the intervenor attorneys' written communications with federal prosecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-atto
substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea
r Motion for a Protective Order and ordering disclosuret plaintiffs of the intervenor attorneys' written communications with federal prosecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-atto
substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea
eding.' (DE M-1 at 21-22); see Table at P-013227-013247). 4. Request No. 18—Documents Concerning Recusal of the United States Attorney's Office for the Southern District of Florida Request number 18 seeks information about why the United States Attorney's Office for the Southern District of Florida was "'conflicted
that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman I. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an
Entities connected to both the Southern District and Hickman I. Taylor

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
Jay Lefkowitz
PERSON
Julie K. Brown
PERSONRoy Black
PERSONMartin Weinberg
PERSON
Stephen Hawking
PERSON
Supreme Court
ORGANIZATION
Michael Jackson
PERSON
Michael Cohen
PERSONEmmy Taylor
PERSON
Bradley Cooper
PERSON
Sarah Kellen
PERSONthe Eleventh Circuit
ORGANIZATION
Michael Douglas
PERSONHerman
PERSON