Epstein Secrets

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

o what pleas should be entered." United States I. Villar, 416 F. ciP7(87, 889 (S.D.N.Y. 1976); Boria I. Keane, 99 F.3d 492, 497 Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 1992). Counse so has a constitutional obligation to seek out information from the ent,

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

o what pleas should be entered." United States I. Villar, 416 F. ciP7(87, 889 (S.D.N.Y. 1976); Boria I. Keane, 99 F.3d 492, 497 Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 1992). Counse so has a constitutional obligation to seek out information from the ent,

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 settlement/p

pleas should be entered." United States v. Villar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Boria v. Keane, 99 F.3d 492, 497 (2d Cir. I 996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a constitutional obligation to seek out information from the

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 settlement/p

t pleas should be entered." United States v. Villar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Boria v. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a constitutional obligation to seek out information from th

)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "protected zone"

hat pleas should be entered." United States'. Villar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Borial. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a constitutional obligation to seek out information from the

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

what pleas should be entered." United Stalest Pillar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Borial. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992). Counsel also has a constitutional obligation to seek out information from the