Epstein Secrets

nt discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Accordingly, Epstein

ubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, whil

Fisher, 425 U.S. at 410; Hubbell, 530 U.S. at 44; Ponds, 454 F.3d at 325 (D.C. Case 9:08-cv-80119-KAM D

may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The correspondence w

very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecut

t bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The correspondence with the government agencies may well point Jane Doe in the direction of admissible evidence, and th

2004). The D.C. Circuit has recently refused to extend the act of production doctrine on facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of repre