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stence is necessary before a judicial determination can be made as to whether the contents are privileged." Id. The exception initially outlined in Hickman developed over time and is now memorialized in Florida Rule of Civil Procedure 1.280(b)(4): Under Florida law, party may obtain an opponent's alleg
ilege where that disclosure is inconsistent with maintaining secrecy from the disclosing party's adversary." Tumelaire v. Naples Estates Homeowners Ass'n, Inc., 137 So. 3d 596, 599 (Fla. 2d DCA 2014). In Tumelaire, the plaintiff was accused of conspiring with a mobile home park's owner in litigation agains
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
ding risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Guyitream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)("once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out
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
ing risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)("once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out
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