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

any voluntarily prepared records, including personal ones"); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th Cir. 1985); United States v. Bedell & Co. , 2006 WL 3813792, ■1 (E.D.N.Y Oct. 30, 2006) ("It is well settled that the Fifth Amendment `does not protect the contents of voluntarily prepared d

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

f any voluntarily prepared records, including personal ones"); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th Cir. 1985); United States I Bedell & Co. , 2006 WL 3813792, ■1 (E.D.N.Y Oct. 30, 2006) ("It is well settled that the Fifth Amendment `does not protect the contents of voluntarily prepared d

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

of any voluntarily prepared records, including personal ones"); In re Grand Jury Proceedings, 759 F.2d 1418, 1419 (9th Cir. 1985); United States v. Bedell & Co., 2006 WL 3813792, *1 (E.D.N.Y Oct. 30, 2006) ("It is well settled that the Fifth Amendment 'does not protect the contents of voluntarily prepared d