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e on the merits," and the "harm factors" militate in favor of granting a stay, Medal Ltd. v. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011), citing Hilton v. Braunskill, 481 U.S. 770, 778 (1987)); they will be immediately and irreparably harmed by the disclosure of the communications at issue; the pla
alid defenses exist, counsel has a duly to initiate plea negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman v. Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981)(counsel's "failure to initiate plea negotiations concerning the duplicitous felony counts constitut
e on the merits," and the "harm factors" militate in favor of granting a stay, Merial Ltd. v. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011), citing Hilton v. Braunskill, 481 U.S. 770, 778 (1987)); they will be immediately and irreparably harmed by the disclosure of the communications at issue; the pla
el's "failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffective assistance of counsel which prejudiced Hawkman"). Reason and experience tell us that the system we have in place of sentencing laws, ethical rules, federal court dockets, and constitutional cons
e on the merits," and the "harm factors" militate in favor of granting a stay, Meria! Ltd. v. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011), citing Hilton v. Braunskill, 481 U.S. 770, 778, 107 S.Ct. 2113, 95 L.Ed.2d 724 (1987)); they will be immediately and irreparably harmed by the disclosure of the
el's "failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffective assistance of counsel which prejudiced Hawkman"). Reason and experience tell us that the system we have in place of sentencing laws, ethical rules, federal court dockets, and constitutional cons
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