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ing.' (DE 212-1 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
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
ng.' (DE 212-1 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
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
n, which she is likely to refuse to give or provide, on the matters about which she may be interrogated before the United States District Court for the Southern District of Florida, including a Grand Jury impaneled therein, as well as subsequent proceedings or trial, and respectfully alleges as follows: 1. That ==.
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
too close to persons associated with the victims. 4. Request No. 18--Documents Concerning Recusal of the United States Attorney's r33] 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
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
Entities connected to both the Southern District and Underwriters Ins. Co.

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONLeon Black
PERSON
Southern District of New York
ORGANIZATION
Paul Cassell
PERSON
Donald Trump
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Supreme Court
ORGANIZATION
Michael Jackson
PERSONEmmy Taylor
PERSON
West Palm Beach
LOCATION
United States Department of Justice
ORGANIZATION
Michael Douglas
PERSONWright
PERSONMain Justice
ORGANIZATION