Epstein Secrets

S' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epst

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea

S' MOTION FOR STAY PENDINWCPPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epst

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to days of settlement/plea

sing the CM/ECF system. Respectfully submitted, BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 South Bi

been viewed as a `limitation on the trial court's broad discre- tion as to evidentiary questions at trial.' Ante, at 169. The problem discussed in Hickman I. Taylor arose precisely because, in addition to accelerating the time when a Page 19 party could obtain evidentiary matter from his adversary,PNI the new