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nging a search has no right to depose the testifying government agents prior to the evidentiary hearing, petitioners have no right to depose Agents Kuyrkendall and Richards. Petitioners should not have more rights in the absence of a criminal prosecution against Epstein than they would have had he been for
pposing party's attorney. The attorney-client privilege and attorney work-product doctrine still apply to matters which have been concluded. FTC v. Grolier. Inc. 462 U.S. 19 (1983) ("[T]he literal language of the Rule [26(b)(3)] protects materials prepared for any litigation or trial as long as they we
ative-process privilege that may apply. It not protected by the attorney-client privilege, as the Government has not demonstrated that FBI agent Kuyrkendall provided this information in an attempt to secure legal advice or a legal opinion from the United States Attorney's Office. The correspondence m
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. Grolier, Inc., that "the literal language of [Rule 26(bX3)] protects materials prepared for ae litigation or trial as long as they were prepared by or for
ative-process privilege that may apply. It not protected by the attorney-client privilege, as the Government has not demonstrated that FBI agent Kuyrkendall provided this information in an attempt to secure legal advice or a legal opinion from the United States Attorney's Office. The correspondence m
. 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. Grolier, Inc., that "the literal language of [Rule 26(b)(3)] protects materials prepared for ars litigation or trial as long as they were prepared by or f
Entities connected to both Kuyrkendall and Grolier

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
United States
LOCATION
George W. Bush
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Southern District of New York
ORGANIZATION
the University of Utah
ORGANIZATION
Supreme Court
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION
Michael Jackson
PERSONThe Eleventh Circuit
ORGANIZATION
United States Department of Justice
ORGANIZATIONWayte
PERSONDouglas Oil Co.
ORGANIZATION
Michael Douglas
PERSON
Armstrong
PERSOND.C. Cir
ORGANIZATION