Epstein Secrets

:0717W_ Sender J ESPTEIN JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY 100224843 US Transportation Charge Discount Fuel Surcharge Recipient EMMY TAYLOR 43.35 -4.34 1.58 Total Transportation Charges USD $ 40.57 Picked up: Dec 11, 2002 Payor: Shipper Reference: NO REFERENCE INFORMATION Fuel S

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criminal litigation. Id. at 236. In Hickman v. Taylor, the Supreme Court described the policy behind th

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in de

)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "protected zone"

strict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in d

trine applies to criminal litigation as well as civil, we find its protection unavailable in this case. Page 15 nized by this Court of Hickman /. Taylor, 329 U.S. 495, 67 S.Ct. 385, 91 .Ed. 451 (1947), reflects the strong 'public policy underlying the orderly prosecution *237 and defense of legal

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plei. agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in d

ion.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawyer is bou

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in de