Epstein Secrets

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

ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel) are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstr

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

ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstra

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

ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstra

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

ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstra