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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,
. 2012) 24, 25 *United States v. Mezzanatto, 513 U.S. 196 (1995) 6, 14, 28, 53 United States v. Nobles, 422 U.S. 225 (1975) 20 United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), cert. denied, 498 U.S. 1039 (1991) 26 United States v. Robertson, 582 F.2d 1356 (5th Cir. 1978) 24 vii EFTA0020
substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman v. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to the days of se
ounsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i
substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman v. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to the days of se
ounsel and the government led to Epstein's plea of guilty in state court. In the sole case cited by the Court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i
cannot be the law and is certainly unsound policy. Indeed, the district court's opinion creates an incentive for attorneys not to do precisely what Hickman v. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to the days of se
the government led to Epstein's plea of guilty in state court. In the sole case cited by the district court for this proposition, United States v. Paden, 908 F.2d 1229 (5th Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr. Epstein entered into a plea i
Entities connected to both Hickman and Paden

Jeffrey Epstein
PERSONEmmy Taylor
PERSON
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
George W. Bush
PERSON
Supreme Court
ORGANIZATIONRoy Black
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
Bradley Cooper
PERSON
Columbia University
LOCATIONthe Southern District
LOCATION
Michael Cohen
PERSONHerman
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON