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 the mental impressions? conclusions, opin- ions, or legal theories of an attorney or other representative of a party concerning the litigation. The Fourth Circuit has explained that this formulation of the doctrine divides work product into two categories, "fact work product," which may be discovered upon a

rts an individual who has not attained the age of 18 years in inter- state or foreign commerce, or in any common- wealth. territory or possession of the United States, with intent that the individual engage in prostitution, or in any sexual activity for which any person can be charged with a criminal of- fense, s

instructions. (The evolution of "dominant pur- pose" is considered at length in our opinion in United States v. Vang, supra, 128 F.3d at 1070.72.) The Fourth Circuit stated sensibly in United States v. Bennett, supra, 364 F.2d at 77, 78 n. 4, that "the `dominant motive' test seems completely inappro- priate in a

OF FBI SPECIAL AGENTS KUYRICENDALL AND RICHARDS, SHOULD NOT BE PERMITTED Petitioners seek to depose four federal prosecutors (including two former United Sates Attorneys) and FBI Special Agents Kuyrkendall and Richards, who were the case agents in the criminal investigation of Jeffrey Epstein. The CVRA, ho

ce on the CVRA and the Air Transportation Safety and Stabilization Act as granting authority for the district court to allow discovery. Id. at 234. The Fourth Circuit observed that, "[t]his was wise strategy, as nothing in those two statutes support the district court's exercise of power." Id. The appellate court