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he 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 settlement/p
orce of the serious issues raised in this case. 14 EFTA00583752 in an uninhibited fashion" is even more important. See Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928, 930 (2d Cir. 1979). When a defendant is facing loss of liberty, he has an even greater "need for confidentiality and trust between p
)? 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"
itable to poker players in a high-stakes game than adversaries attempting to arrive at a just solution of a civil dispute." Lake Utopia Paper Ltd.'. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a conf
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
itable to poker players in a high-stakes game than adversaries attempting to arrive at a just solution of a civil dispute." Lake Utopia Paper Ltd.'. Connelly Containers, Inc., 608 F.2d 928 (2d Cir.1979). Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called for parties to engage in a conf
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