Epstein Secrets

for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea

for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea

opposing parties and their counsel." Hickman I. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman I. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

opted in 1970 to codify the holding in Hickman I. Taylor, 329 U.S. 495 (1947). 10 EFTA00222437 Case 9

nsidered the facts alleged in the Complaints, the elements needed to convict Epstein of ' Rule 26(b)(3) was adopted in 1970 to codify the holding in Hickman I. Taylor, 329 U.S. 495 (1947). 10 EFTA00222437 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 11 of 14 a crime, the particul

trine applies to criminal litigation as well as civil, we find its protection unavailable in this case. Page 15 nized by this Court of Hickman /. Taylor, 329 U.S. 495, 67 S.Ct. 385, 91 .Ed. 451 (1947), reflects the strong 'public policy underlying the orderly prosecution *237 and defense of legal

been viewed as a `limitation on the trial court's broad discre- tion as to evidentiary questions at trial.' Ante, at 169. The problem discussed in Hickman I. Taylor arose precisely because, in addition to accelerating the time when a Page 19 party could obtain evidentiary matter from his adversary,PNI the new