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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
eys, the "work-product privilege applies to ... discussions between prosecutors and investigating agents, both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing FTC v. Grolier Inc., 462 U.S. 19 (1983)). The work-product privilege extends only to documents that an a
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
s, the "work-product privilege applies to . . . discussions between prosecutors and investigating agents, both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing FTC v. Grolier Inc., 462 U.S. 19 (1983)). The work-product privilege extends only to documents that an a
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
eys, the "work-product privilege applies to ... discussions between prosecutors and investigating agents, both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing FTC v. Grolier Inc., 462 U.S. 19 (1983)). The work-product privilege extends only to documents that an a
Entities connected to both Initial Disclosures and Zingsheim

Jeffrey Epstein
PERSONthe Federal Rules of Civil
ORGANIZATIONthe Southern District
LOCATION
Kenneth Marra
PERSONSubpoena Duces Tecum
PERSON
United States
LOCATION
Michael Jackson
PERSON
George W. Bush
PERSONTable
ORGANIZATION
Michael Douglas
PERSON
Supreme Court
ORGANIZATIONWright
PERSONWayte
PERSONMain Justice
ORGANIZATIONHickman
PERSONAtlanta Gas Light Co.
ORGANIZATIONDouglas Oil Co.
ORGANIZATIONJane Doe
PERSONEmmy Taylor
PERSOND.C. Cir
ORGANIZATION