Epstein Secrets

torney for another party where a joint defense effort or strategy has been decided upon and undertaken by the parties and their respective counsel. See United States v. Bay State Ambulance and Hosp. 12 EFTA00582868 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG

keep the shared information confidential from outsiders." Ken's Foods, Inc. v. Ken's Steak House, Inc., 213 F.R.D. 89, 93 (D. Mass. 2002). See also United States v. Sawyer, 878 F. Supp. 295, 297 (D. Mass. 1995) (despite similar interests between employer and employee, there was insufficient evidence that comm

nt that these items were prepared in anticipation of litigation and are protected from disclosure without presenting evidence to support the claim." Wal-Mart Stores, Inc. v. Weeks, 696 So. 2d 855, 856-57 (Fla. 2d DCA 1997). Once the party seeking the documents challenges non-production, the burden shifts to the

ith the "expected" rates based upon the proportional availability of black females in the labor pool. Id. We endorsed a similar use of proxy data in United States v. County of Fairfax, involving a county government that had destroyed three years of employment applications. 629 F.2d at 940. To analyze hiring du

. Dec. (CCH) P45,306 The district court has revisited certification and decertified the promotions class in light of the Supreme Court's opinion in Wal-Mart Stores, Inc. v. Dukes, U.S. , 131 S. Ct. 2541, 180 L. Ed. 2d 374 (2011).' We thus again confront the question of whether the workers' have presented a c

. (See Reply at 2.) However, in general, "oUr-of-court statements that are offered as evidence of legally operative verbal conduct are not hearsay.' United States v. Pang. 362 F.3d 1187. 1192 (9th Cir. 2004). Because such statements have independent legal significance. they are considered "verbal acts," and ar

12(b)(6) only test the validity of ["42] a claim, not its redundancy; a redundant claim should not be dismissed as long as it is valid." tMchael v. Wal-Mart Stores East, LP, No. 6:14-cv-579-Orl-40DAB, 2014 U.S. Dist. LEXIS 153908, 2014 WL 5502442, at *2 (M.D. Fla. Oct. 30, 2014) (citing Bangkok Crafts Corp. v.