Epstein Secrets

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

pril 17, 2012, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami. Florida 33131 By /S/ ROY BLACK, ESQ. Florida Bar No. JACKIE PERCZEK,

)? 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"

tember 2,2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Office: (305) 371-6421 Fax: (305) 358-2006 By /S/ ROY

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

April 7, 2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Office: (305) 371-6421 Fax: (305) 358-2006 By /S/ ROY