Epstein Secrets

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

ted from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA00210181 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S:13977-13979 Prot

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

ted from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA_R1_01293477 EFTA02335939 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S

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

ted from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA01657793 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S:13977-13979 Prot