Epstein Secrets

3d 391 (1st Cir. 2005) 54 *Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 51, 52, 55 In re Air Crash Near Cali, Colombia,

1987) 53 In re MTSG, Inc., 675 F.3d 1337 (Fed. Cir. 2012) 32, 33 In re RDM Sports Group, Inc., 277 B.R. 415 (N.D. Ga. 2002) 34, 40 In re Sealed Case, 716 F.3d 603 (D.C.Cir. 2013) 54 In re Six Grand Jury Witnesses, 979 F.2d 939 (2d Cir. 1992), cert. denied sub nom. XYZ Corp. v. United States,

n an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor , 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

idence stronger than in the context of a valid grand jury subpoena.'" In re Grand Jury Proceedings , 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case , 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena , 223 F.3d 213, 218 (3d Cir. 2000) ("One EFTA00211781 of the most signi

ington, DC, for Interested Party 1. Elizabeth G. Taylor, Zuckerman Spaeder, LLP, Washington, DC, Daniel T

., the name of a person of interest) is not prohibited by Rule 6(e) as long as it does not elucidate the inner workings of the grand jury. See In re Sealed Case, 192 F.3d at 1002 (discussed infra at 8-9). The Court thus turns its attention to the relevant provisions of the Qantas information, the plea agreem

in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman I Taylor , 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

idence stronger than in the context of a valid grand jury subpoena.'" In re Grand Jury Proceedings , 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case , 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena , 223 F.3d 213, 218 (3d Cir. 2000) ("One EFTA00222997 of the most signi

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document

case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "wor

evidence stronger than in the context of a valid grand jury subpoena.' In re Grand Jury Proceedings, 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case, 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena, 223 F.3d 213, 218 (3d Cir. 2000) ("One of the most significant, if not th