Epstein Secrets

lying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the first week of October, 2005. On October 18, 2

Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Re

Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration o

n 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, litigatio

lying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the first week of October, 2005. On October 18, 2

Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Re

Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration o

n 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 I Taylor , 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation

15 U.S. Dist. LEXIS 87203, * For Jeffrey Epstein, Intervenor: Jacqueline Perczek, Roy Eric Black, Black Srebnick Kornspan & Stumpf, Miami, FL. For Alan M. Dershowitz, Intervenor: Kendall Brindley r21 Coffey, LEAD ATTORNEY, Gabriel Groisman, Coffey Burlington, P.L., Miami, FL; Steven Russell Safra, Thomas E. Scot

bnick Kornspan & Stumpf, Miami, FL. For Alan M. Dershowitz, Intervenor: Kendall Brindley r21 Coffey, LEAD AT

lack Srebnick Kornspan & Stumpf, Miami, FL. For Alan M. Dershowitz, Intervenor: Kendall Brindley r21 C

t from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238, 95 S. Ct. 2160, 45 L. Ed. 2d 141 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply

n elated Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

; Lake Shore Radiator. Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v, Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes inf

rcia(a:bellsouth.net Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

o.2d 108, 111 (Fla. 1970)(stating that the rules of discovery should be afforded broad and liberal treatment to effectuate their purpose), citing., Hickman v. Taylor 329 U.S. 495, 501, 507 (1947). 15. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brand

en & Sir- cusa ("RMJS"), and others, principally Alan Garfinkel and Leigh Katzman, form- ing Katzman Ga

vid. 804(b)(1)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "pro

enor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor, Hartford, CT 06103, By: Jay M. Wolman, Esq. Counsel for Intervenor Alan Dershowitz: EMERY CELLI BRINCKERHOFF & ABADY, LLP, 600 Fifth Avenue, 10th Floor, New York, NY 10020, By: Andrew G. Celli, Jr., Esq. I This daytime business a

g Order, ECF No. 348. One hundred sixty-seven documents were sealed pursuant to the Sealing Order. On August 11, 2016, Intervenor Alan Dershowitz ("Dershowitz" or "Intervenor Dershowitz") moved to unseal three documents: (1) portions of a Reply Brief submitted by Churcher in support of her motion to quash

to a morbid craving for that which is sensational and impure."). IsiPretrial discovery is intended to aid the parties in their search for truth. See Hickman v. Taylor, 329 U.S. 495, 501, 67 S.Ct. 385, 91 L.Ed. 451 (1947) (celebrating that "[t]he deposition-discovery regime set out by the Federal Rules o