Epstein Secrets

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor,. 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modem work- product doctrine, holding that: (flu performing his various duties, how

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the government to search the contents of the computers. Instead, the g

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the govemmel ters. Instead, the government purports to be sessi

ain hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

protected, not the relationship as a whole. McKay v. C.I.R., 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz