Epstein Secrets

JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. MCNAMARA RUDA DAVID YAREMA I FIORJOA BOARD GUMMED CM!. TRW. LAWYER IAOMITIIID TO PRACTICE IN IRMO* AND COLORADO BURtvtAN, CRITTON LUTTIER&COLEMAN.LLY YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP December 9, 2009 BY HAND DELIVERY Judge Donald Ha

ation need not be admissible at trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id.; see also Hickman 12 EFTA00723247 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 13 of 22 v. Taylor, 329 U.S. 495, 507-508 (1947); Far

oggs, 741 N.W.2d 1D Alaska: Alaska Rule Evid. 410; Arizona: Ariz. R. Crim. P. 17.4; Arkansas: Ark. R. Evid. 410; California: Cal. Evid. Code §1153; Colorado: Cob. R. Evid. 410; Delaware: Del. R. Evid. 410; Florida: Fla. Stat. Ann. §90.410; Hawaii: Hawaii R. Evid. 410; Idaho: Idaho R. Evid. 410; Illinois

nc., 399 F.3d 391 (1st Cir. 2005) 54 *Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v. City of Dickson, 641 F.3d 230 (6th Cir. 2011) 51, 52, 55 In re Air Crash Near Cali,

Virginia Money-Launderer Pleads Guilty. • Utah Business Owner Pleads Guilty To Money Laundering. • Indiana Man Sentenced For Bank Fraud. • Former Colorado Judge Pleads Guilty To Obstruction. • Florida Family Arrested On Suspicion Of Kickback Scheme. CYBER DIVISION • Ransomware Attackers Pressure Knox

0 or more." CYBER DIVISION Ransomware Attackers Pressure Knoxville, Tennessee By Posting City Data Online. The Knoxville (TN) News Sentinel (7/2, Hickman, 307K) reports, "Cybercriminals have published city of Knoxville files online, including employees' personal information, as part of an ongoing eff

beliefs," FBI Sacramento Special Agent in Charge Sid Patel said. "Salah sought to instill fear and disrupt Christian communities across California, Colorado, and Arizona. We are grateful for the cooperation of these churches and communities, which were vital in the investigation that led to Salah's arres

official communications. Back to Top OTHER FBI NEWS Border Patrol Agent Who Shot Chicago Woman Boasted About It in Text Messages Reuters (11/07, Hickman) reported that U.S. Customs and Border Protection Agent Charles Exum shot Chicago resident Marimar Martinez five times during an encounter on Octobe

N does not offer any evidence of any Congressional direction that would direct this Court to abstain for claims under 18 U.S.C. §2255.4 Further, the Colorado River doctrine only applies when federal courts are presented with "difficult questions of state 3The federal claims that are the subject matter of

o.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). 15. Next, the right to go to court to resolve disputes is a fundamental right. D.R. Lakes, Inc. v. Brand

prepared with pending litigation in mind, the primary motivation behind the creation of such reports was for use in the normal course of business); Colorado ex rel. Woodard Schmidt-Tiago Construction Co„ 108 F.R.D. 731, 734-35 (D. Cob. 1985) (absent additional evidence, no work product protection for re

vid. 804(b)(1)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "pro