Epstein Secrets

and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to

t the negotiation of a plea bargain is a critical phase of litigation for purposes of the Sixth Amendment right to effective assistance of counsel." Padilla v. Kentucky, U.S. 130 S. Ct. 1473, 1485 (2010) (citation omitted). This includes the "critical obligation of counsel to advise the client of `the advantages a

and ongoing plea negotiations. See In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (P` Cir. 2003). In Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Third Circuit decided that Westinghouse's disclosure of work product materials to

t the negotiation of a plea bargain is a critical phase of litigation for purposes of the Sixth Amendment right to effective assistance of counsel." Padilla v. Kentucky, U.S. 130 S. Ct. 1473, 1485 (2010) (citation omitted). This includes the "critical obligation of counsel to advise the client of `the advantages a

f work product materials to the government during plea bargaining waives all work product protection. The Government acknowledges, for example, that Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure o

o be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that protecting plea bargaining opportun