Epstein Secrets

confidential information governed by the protective order to other government agencies for the purpose of enforcing the criminal or civil laws of the United States. Thus, the Government seeks to reserve the right to use confidential information produced by Fisher in this case in unrelated civil or criminal ma

ce of parties and witnesses and in interest of justice bears burden of estab- lishing by preponderance of evidence that transfer is necessary. 28 U.S.C.A. § 1404(a). 6. Federal Courts 6=101, 103, 105 Although trial judge is afforded great discretion in deciding motion to transfer for convenience of

his purchase, though. Because all reasonable inferences on a summary Judgment motion are to be drawn in favor of the non-moving party. Knight US. Fire Ins. Co., 804 F.2d V. 11 12d Cir.1981), we hold that the present action is not time-barred for the pur- poses of this motion. 4. Stroll contends that § 3-4

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

work-product privilege extends only to "materials in question [which]were prepared in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (F

in, 495 So. 2d at 262; Alachua Gen. Hosp. v. Zimmer USA, Inc., 403 So. 2d 1087, 1088 (Fla. 1st DCA 1981) (privilege continues after case concludes); United States v. International Business Machs. Corp., 66 F.R.D. 154, 178 (S.D.N.Y.1974) (privilege applies only if the work product was gathered in anticipation o

adverse party to show that the communication was not privileged. Leithauser v. Harrison, 168 So. 2d 95 (Fla. 2d DCA 1964); see also Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, 192-93 (Fla. 4th DCA 1991) ("[N]othing in the record indicates that any documents are protected by the attorney/client p

Distinguished Life Fellow, 2007-present Consultant, Task Force on the Right to Treatment, 1974-1977 Committee on Misuse and Abuse of Psychiatry in the United States, 1979-1980 Committee on Abuse and Misuse of Psychiatry and Psychiatrists in the United States, 1980-1987 (Chairman, 1984-1986) Advisory Committee

Jerner v. Allstate (Orlando, Florida) Testified at evidentiary hearing, 9/1/95 EFTA00072971 Park Dietz, M.D., M.P.H., Ph.D. Page 26 Am. Natl. Fire Ins. Co. v. Birmingham Fire Ins. Co. (Houston, Texas) Testified at deposition, 10/4/95 People of CA v. Erik Menendez (Los Angeles, California) Testified at