Epstein Secrets

704 F.2d 1109, 1111 (9th Cir. 1983)(quoting F.D. Rich Co. v. United States ex rel. Industrial Lumber C

So.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). 21. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes. Inc. v. Brandsmart U.S

x with the girls. A money manager for the ultra-rich, Epstein was named one of New York's most eligib

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

iami, Flori Telephon Facsim. E-Mail: ILL AM L. RICH Fla. Bar No. EFTA00179067 CERTIFICATE OF SERV

ain 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, litigation," In re