Epstein Secrets

081 (4th Cir. 1981). Under the circumstances, any claim of privilege or work product cannot be accepted without further evidentiary substantiation. See United States'. Aramony, 88 F.3d 1369, 1392 (4th Cir. 1996) (where the allegations against one party could not subject another to civil or criminal liability, joi

nce law. Most Cited Cases In a diversity case, court applies federal law to resolve work product claims. Fed.Rules Civ.Proc.Rule 26(b)(3), 28 U.S.C.A. [5j 04( Federal Civil Procedure 170A €=+ 16 2) 170A Federal Civil Procedure 170AX Depositions and Discovery 170AX(E) Discovery and Production

the law relating to inadvertent waiver of the attorney client privilege, not- ing that three distinct approaches had been followed by courts within the United States: a strict waiver approach, fmding waiver whenever a non-privileged disclos- ure occurs; a lenient approach: finding waiver only in the instance of

("Colorable claims of attor- ney-client and work product privilege [are] .. . a textbook example of an entitlement to intervention as of right."); United Stalest. AT & T Co., 642 F.2d 1285, 1292 (D.C.Cir.1980); Sackman I. Liggett Group, Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996). In allowing intervention,

attorney, who also represented corporation, where attor- ney was not actively protecting that privi- lege. Fed.Rules Civ.Proc.Rule 24(a), (aX2), 28 U.S.C.A.; Fed.Rules Evid.Rule 501, 28 U.S.C.A.; N.Y.McKinney's CPLR 4503. 6. Witnesses o=>198(1) Existence of attorney-client privilege is based upon poli

f protecting the various privileges, and to respond to the personal attacks made upon them individually by Rosenbaum." [DE 125, p. Garfinkel and Katzman will be permitted to inter- vene for the former purpose, but not the latter•. According to the Motion to Intervene, Rosenbaum served as counsel fo

ility to manage its proceed- ings, vindicate its authority, and effectuate its decrees without extending its jurisdic- tion. Keith Jeffrey Lambdin, Katzman Gar- finkel Rosenbaum, John David Mallah, Maitland, FL, for Plaintiff. Bradley Ryan Weiss, Benson Mucci & Associates LLP, Thomas E. Tookey, Coral

hat they were members of conspiracy pursuant to New York long-arm statute, or that they had any general business contacts with United States. 18 U.S.C.A. § 2331 et seq.; N.Y.McKinney's CPLR 302(a)(2). 68. Federal Courts C=97 Jurisdictional discovery was warrant- ed, at dismissal stage of Antiterrori

rrorism Act (ATA) suit by survivors of victims of September 11, 2001 attacks, as to issue whether company purposefully directed its activities at United Slates, for purposes of personal jurisdiction. 18 U.S.C.A. § 2331 et seq.; Fed.Rules Civ.Proc.Rule 12(b)(2), 28 U.S.CA. 101. Federal Civil Procedure (3=

ts with the United States generally, but in- sufficient contacts with any one state in particular. Fed.R.Civ.P. 4(k)(2) advisory committee's note; United Stales v. Intl. Bhd, of Teamsters, 945 F.Supp. 609, 616- 17 (S.D.N.Y.1996). For jurisdiction under Rule 4(k)(2), there must be a federal claim, personal

dismissed for lack of per- sonal jurisdiction. 3. Plaintiffs Are Entitled to Jurisdic- tional Discovery as to Privatbank's Investing Activities in the United States [37] Plaintiffs point out that Privat- bank's website and its 2001 Annual Report state that Privatbank engages in transac- tions involving securiti

some conceivable non-discretionary tortious act falls within the purview of these generic allegations under the appli- cable substantive law. 28 U.S.C.A. 1605(a)(5). 28. International Law C=10.33 In determining whether functions are discretionary, for purposes of the discre- tionary function except

"Civil RICO is an unusually potent weapon ... 'courts should strive to flush out frivo- lous RICO allegations at an early stage of the litigation." Katzman v. Victoria's Se- cret, 167 F.R.D. 649, 655 (S.D.N.Y.1996). [74] The Federal complaint asserts a RICO claim under § 1962(a), which states in part

ice cuts and fare increases. EFTA00721053 Public Facilities Public Parks and Recreation: The popularity of parks and outdoor recreation areas in the United States continues to grow, with over 14o million Americans making use of these facilities a part of their daily lives. These activities contribute $646 bill

a piano player and a devotee of Bud Powell. Hubbard's budding musical talents caught the attention of Lee Katzman, a former sideman of Stan Kenton. Katzman convinced the young trumpeter to study at the Arthur Jordan Conservatory of Music with Max Woodbury, the principal trumpeter of the Indianapolis Sy

fficient con- tacts with the United States as a whole but is not subject to jurisdiction in any particu- lar state, requires contacts with the United States as a whole. U.S.C.A. Const.Amend. 5; Fed.Rules Civ.Proc.Rule 4(k)(2), 28 U.S.C.A. 50. Constitutional Law ¢=305(5) The due process minimum contacts

has sufficient con- tacts with the United States as a whole but is not subject to jurisdiction in any particu- lar state, requires contacts with the United States as a whole. U.S.C.A. Const.Amend. 5; Fed.Rules Civ.Proc.Rule 4(k)(2), 28 U.S.C.A. 50. Constitutional Law ¢=305(5) The due process minimum co

t, but in the manner of a private player within it, the foreign sover- eign’s actions are ‘commercial’ within the meaning of the FSIA.” Weltover, 504 U.S. at 614, 112 S.Ct. 2160. Courts must in- quire whether the foreign state’s actions “are the type of actions by which a private party engages in trade a

Teamsters, 945 F.Supp. at 617. a. Purposefully Directed Activities Theory Personal jurisdiction based on Rule 4(k) requires minimum contacts with the Unit- ed States to satisfy Fifth Amendment due process requirements. Plaintiffs claim these requirements are met because De- fendants purposefully directed their ac