Epstein Secrets

ah.edu Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Jay Howell Jay Howell & Associate

to class counsel during settlement negotiated waived work product when tape sought by government as part of criminal 3 EFTA00806655 case); In re Sealed Case, 676 F.2d 793, 824-25 (D.C. Cir. 1982) (production of documents during settlement discussions with the SEC waived work product protection as to gra

08/05/2013 Page: 14 of 75 Wa. R. Evid. 410 42 W. Va. R. Evid. 410 42 Wisc. Stat. Ann. §904.10 4

1987) 53 In re MTSG, Inc., 675 F.3d 1337 (Fed. Cir. 2012) 32, 33 In re RDM Sports Group, Inc., 277 B.R. 415 (N.D. Ga. 2002) 34, 40 In re Sealed Case, 716 F.3d 603 (D.C.Cir. 2013) 54 In re Six Grand Jury Witnesses, 979 F.2d 939 (2d Cir. 1992), cert. denied sub nom. XYZ Corp. v. United States,

1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (1979)). Whether proceeding u

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document

1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (1979)). Whether proceeding u

inds that such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document