Epstein Secrets

on Picture Incl. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation v. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Re

alid defenses exist, counsel has a duty to initiate plea negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman v. Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981) (counsel's "failure to initiate plea negotiations concerning the duplicitous felony counts constitu

privile e. Nevertheless, we find persuasive the reasoning set forth by the court in Sheldone I. Pennsylvania Turnpike Comnen, 104 F. Supp. 2d 511 (W.D. Pa. 2000), and by other courts that have adopted the federal mediation privilege." Software Tree LLC RedHat Inc., 2010 WL 2788202 at *4 (E.D.Tex. June 24,

sel's "failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffective assistance of counsel which prejudiced Hawkman"); United States. Fernandez, 2000 WL 534449 *1 (S.D.N.Y. May 3, 2000) ("[1]t is malpractice for a lawyer to fail to give his client timely advice c

Motion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldon Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation'. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Rep

el's "failure to initiate plea negotiations concerning the duplicitous felony counts constituted ineffective assistance of counsel which prejudiced Hawkman"). 3. The Court Should Recognize A Plea Negotiations Privilege To Avoid A Meaningful And Irreparable Chill In Plea Negotiations Reason and experi