Epstein Secrets

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

nduct" 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 destruction, and similar mis

orcement proceeding because it is not a "civil action" against the Government. To be sure, this Court has determined that convenience dictates that the Federal Rules of Civil Procedure "govern the general course of this proceeding." See DE 257 at 3. But that procedural determination does not alter the substance of this ca

ed by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"

76 2015 U.S. Dist. LEXIS 87203, * already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation

e level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401, 244 U.S. App. D.C. 11 (D.C. Cir. 1985) (exception to attorney- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

uct" 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 destruction, and similar mis

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

uct" 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 destruction, and similar mis

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

nduct" 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 destruction, and similar mis

orcement proceeding because it is not a "civil action" against the Government. To be sure, this Court has determined that convenience dictates that the Federal Rules of Civil Procedure "govern the general course of this proceeding." See DE 257 at 3. But that procedural determination does not alter the substance of this ca

by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey I. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"