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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
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
2 mentions1 same-page
Page ?Same page
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
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(2)(1) Finally. Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
2 mentions1 same-page
Page ?Same page
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
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
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2 mentions1 same-page
Page ?Same page
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
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
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Jeffrey Epstein
PERSON45 w/ D.C.·7 w/ Initial
United States
LOCATION40 w/ D.C.·5 w/ Initial
George W. Bush
PERSON21 w/ D.C.·5 w/ Initial
the Southern District
LOCATION20 w/ D.C.·6 w/ Initial
Kenneth Marra
PERSON19 w/ D.C.·6 w/ Initial
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Leon Black
PERSON21 w/ D.C.·2 w/ Initial
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ORGANIZATION19 w/ D.C.·4 w/ Initial
Scarlett Johansson
PERSON21 w/ D.C.·2 w/ Initial
JD
Jane Doe
PERSON17 w/ D.C.·5 w/ Initial
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PERSON16 w/ D.C.·2 w/ Initial
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ORGANIZATION15 w/ D.C.·2 w/ Initial
Bradley Edwards
PERSON14 w/ D.C.·2 w/ Initial
Paul Cassell
PERSON12 w/ D.C.·3 w/ Initial
JG
Jack Goldberger
PERSON12 w/ D.C.·3 w/ Initial
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Roy Black
PERSON12 w/ D.C.·2 w/ Initial
Alexander Acosta
PERSON12 w/ D.C.·2 w/ Initial
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Emmy Taylor
PERSON10 w/ D.C.·4 w/ Initial
the Federal Rules of Civil
ORGANIZATION7 w/ D.C.·6 w/ Initial
A. Marie Villafana
PERSON10 w/ D.C.·2 w/ Initial
Michael Jackson
PERSON7 w/ D.C.·5 w/ Initial