Epstein Secrets

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

ea is desirable, since "Ielffective assistance of counsel includes counsel's informed opinion as to what 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, Ethi

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

ea is desirable, since "[e]ffective assistance of counsel includes counsel's informed opinion as to what 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, Ethi

)? 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"

lea is desirable, since "[e]ffective assistance of counsel includes counsel's informed opinion as to what 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, Ethica