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, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E
clofrAte/2014 Page: 21 of 23 established a "compelling justification" to prevent the discovery of plea negotiations in criminal proceedings, In re Int'l Horizons, 689 F.2d at 1004. Although Congress empowered the federal courts through Rule 501 to "continue the evolutionary development of testimonial privile
, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E
clofrAte/2014 Page: 21 of 23 established a "compelling justification" to prevent the discovery of plea negotiations in criminal proceedings, In re Int'l Horizons, 689 F.2d at 1004. Although Congress empowered the federal courts through Rule 501 to "continue the evolutionary development of testimonial privile
, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E
d: 04/18/2014 Page: 21 of 23 established a "compelling justification" to prevent the discovery of plea negotiations in criminal proceedings, In re Int'l Horizons, 689 F.2d at 1004. Although Congress empowered the federal courts through Rule 501 to "continue the evolutionary development of testimonial privile
Entities connected to both Penman and Int'l Horizons

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