Epstein Secrets

ed--particularly where the Government has admitted that it did not so inform Jane Doe 2 (one of the petitioners), non-party Jane Doe 3, or non-party Jane Doe 4,5 see Government's Resp. to Second Request for Admission 14(b)-(d), and has only denied that it did not inform all of the other, non-party victims

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

AM Document 330 Entered on FLSD Docket 07/06/2015 Page 1 of 51 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-KAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. I OPINION AND ORDER This cause is before the Court on various discove

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

M Document 330 Entered on FLSD Docket 07/06/2015 Page 1 of 51 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. OPINION AND ORDER This cause is before the Court on various discovery re

. 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