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rn.aspx?rs=WLW11.07&pbc=BC6E23F9&destin... 9/26/2011 EFTA00177913 183 F.R.D. 458, 51 Fed. R. Evid. Serv. 35 (Cite as: 183 F.R.D. 458) 8A Wright, Miller & Marcus, Fed- eral Practice and Procedure § 2113 (2d ed.1994). There is contrary ( au- thority, however. ee, e.g. Omaha Pub. Power Dist. . Foster Wheeler
e complained mightily that Rosenbaum has already made unauthorized disclosures, Garfinkel and Katzman have not identified for this Court which of Rosenbaum's statements in the Request for Judicial Inquiry, or at the April 16 healing, they claim are privileged. Moreover, Katzman's assertion of privileg
and has led to litigation between the former law partners. The motions now before this Court arise, in large measure, from heated disputes between Rosenbaum on the one hand, and Garfinkel and Katz- man on the other. Immediately following the breakup of KGR, Rosenbaum's law firm, RMJS, en- tered appeara
me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern I. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA00210143 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead
me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O'Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within pleading to decide application of work product privilege). The Court will therefore evaluate each claim of
me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA_R1_01293439 EFTA02335901 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 P
me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA00086448 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead
me older cases took the position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating o
y the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within 4 EFTA01657755 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 plead
Entities connected to both Miller & Marcus and Richard M. Rosenbaum

George W. Bush
PERSON
Jeffrey Epstein
PERSON
United States
LOCATION
Supreme Court
ORGANIZATIONEmmy Taylor
PERSONWright
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Michael Jackson
PERSON
Scarlett Johansson
PERSON
Kenneth Marra
PERSONHickman
PERSON
Donald Trump
PERSON
Michael Douglas
PERSON
Julie K. Brown
PERSON
Southern District of New York
ORGANIZATIONL.J. Ann
PERSON
Armstrong
PERSONWayte
PERSONTable
ORGANIZATION