Epstein Secrets

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

ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear

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

ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear

15 16 17 18 19 20 21 22 23 24 25 Q. Do you recall the first time when he flew on the plane? A. I do not. Q. Do you recall someone named Emmy Tayler? A. Yes. Q. She was one of Ghislaine's assistants, wasn't she? A. Yes, she was. Q. She started working for Ghislaine in around 1997 or so; isn't

tioned. Did some of those trips include travel to New York? A. Yes. Q. Where did you stay when you traveled with Maxwell and Epstein to New York? A. Epstein's house. Q. Where was that house located? A. New York City. Q. In what borough? A. Do you need the exact address? Q. No, it's okay. Approximately