Epstein Secrets

erials should be released." Id. at 1349 (quoting Douglas Oil Co... Petrol Stops N.W., 441 U.S. 211, 223 (1

nduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g. In re Sealed Case 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

terials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223,

e level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401, 244 U.S. App. D.C. 11 (D.C. Cir. 1985) (exception to attorney- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

erials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (

uct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

oranges comparison' (quoting Shatkin v. McDonnell Douglas Corp., 727 F.2d 202, 208 (2d Cir. I 984))); see

d Cir. 1997) 15 United States v. Valle, No. 12 Cr. 847 (PGG), 2013 WL 440687 (S.D.N.Y. Feb. 2, 2013) 3 United States v. Washington, 705 F.2d 489 (D.C. Cir. 1983) 16 United States v. Welch, 368 F.3d 970 (7th Cir. 2004) 30 United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) 6, 8 Yates v. State, 171

erg, 358 F.3d 1327, 1348 (11th Cir. 2004) (citing Douglas Oil Co. a Petrol 27 EFTA00085735 Case 9:08-cv

ed, but simply forgot, to provide additional remedies beyond those already specified. Courts agree. See United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the CVRA's "carefully crafted and detailed enforcement scheme," provides "strong evidence that Congress did not intend to auth

ssaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211,

uct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

erials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (

nduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g. In re Sealed Case 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis