Epstein Secrets

the issues and the defenses in the litigation"). W. The information simply falls under the "highly pr

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiation

al Circuit in and for Palm Beach County and in E. W. vs. Epstein, Case No. 502008 CA028058 XXXXMB AB,

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be

08/05/2013 Page: 14 of 75 Wa. R. Evid. 410 42 W. Va. R. Evid. 410 42 Wisc. Stat. Ann. §904.10 4

he most important considerations identified in Jaffee - over the most important consideration, the strong public and private interests at stake. The Goodyear Tire analysis is far more consonant with the Supreme Court's teaching in Jaffee than is MTSG. In Baker v. Secretary, U.S. Dept of Transportation, 452 F

al Circuit in and for Palm Beach County and in E. W. vs. Epstein, Case No. 502008 CA028058 XXXXMB AB,

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be

been found, the party whose tax return information has been requested has the burden to "provide alternative sources for this sensitive information. W. If the requested information is available from alternate sources, disclosure should not be compelled. Potential alternate sources to which the cour

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications

al Circuit in and for Palm Beach County and in E. W. vs. Epstein, Case No. 502008 CA028058 XXXXMB AB,

to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations be