Epstein Secrets

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

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

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

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

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

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