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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
ers and memos in which Mr. Epstein's counsel addressed the reasons why Mr. Epstein should not be federally prosecuted. 8 EFTA00177817 States v. Adelman, 458 F.3d 791 (8th Cir. 2006), also involved statements made by the defendant to federal prosecutors; the defendant's statements were made in meetin
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
ve no room to doubt that the parties were engaged in serious negotiations to resolve the federal criminal investigation of Epstein. United States v. Adelman, 458 F.3d 791 (8th Cir. 2006), also involved statements made by the defendant to federal prosecutors; the defendant's statements were made in meeti
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
ral court and "comparable state procedures." Fed. R. ' The other two cases relied on by the district court are equally inapposite. United States v. Adelman, 458 F.3d 791 (8th Cir. 2006), involved statements made by the defendant to federal prosecutors during meetings at which she was told, according to
Entities connected to both Hickman and Adelman

Jeffrey Epstein
PERSONEmmy Taylor
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATIONLeon Black
PERSON
Scarlett Johansson
PERSON
Supreme Court
ORGANIZATION
George W. Bush
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSONthe Southern District
LOCATIONMartin Weinberg
PERSON
Bradley Edwards
PERSONHerman
PERSON
Bradley Cooper
PERSON
Columbia University
LOCATION
Chris Christie
PERSONSantobello
PERSONLafler
ORGANIZATION