Epstein Secrets

ely confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." Id. To achieve that balance, courts in the Second Circuit have developed a "m

to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Coro. v. Krueger, 55 F.R.D. 514-15 (N.D. III. 1972X"it is the opinion of this court that (§6103] reflect[s] a valid public policy against disclosure of income tax returns. This

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

ket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication I. Grolier, Inc., that "the literal language o

ely confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." W. To achieve that balance, courts in the Second Circuit have developed a "mo

to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Corp. v. Krueger, 55 F.R.D. 514-15 (N.D. Ill. 1972X"it is the opinion of this court that [§6103] reflect[s] a valid public policy against disclosure of income tax returns. This

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

07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language o

ell). Id. The Court then noted: "Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on [the victims'] motion [for an order directing the Govern

icipation of litigation, and certainly not litigation about the Crime Victims' Rights Act. See, e.g., Southern Union Co. v. Southwest Gas Corp., 205 F.R.D. 542, 549 (D. Ariz. 2002) (documents not protected by work product because not prepared in connection with case at hand). II. Specific Responses to