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

rocedure 6(e)." (DE 257 at 3). II. Discussion District courts have "broad discretion in shaping the scope of discovery under Fed.R.Civ.P. 26(b)." Williams v. City of Dothan, 745 F.2d 1406, 1415 (11th Cir. 1984). The Court will first address matters related to whether a privilege protects the submitted document

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

quests for production (DE 260). IL Discussion District courts have "broad discretion in shaping the scope of discovery under Fed.R.Civ.P. 26(b)." Williams v. City of Dothan, 745 F.2d 1406, 1415 (11th Cir. 1984). The Court will first address matters related to whether a privilege protects the submitted document

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

quests for production (DE 260). H. Discussion District courts have "broad discretion in shaping the scope of discovery under Fed.R.Civ.P. 26(b)." Williams v. City of Dothan, 745 F.2d 1406, 1415 (11th Cir. 1984). The Court will first address matters related to whether a privilege protects the submitted document

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

uests for production (DE 260). II. Discussion District courts have "broad discretion in shaping the scope of discovery under Fed.R.Civ.P. 26(b)." Williams v. City of Dothan, 745 F.2d 1406, 1415 (11th Cir. 1984). The Court will first address matters related to whether a privilege protects the submitted document