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e of the rules is to encourage plea bargaining, and rules "creat[ e ], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence i)410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote
f public policy against disclosure of tax returns); Premium Serv. Corp. v. Sperry & Hutchinson Co., 511 F.2d 225, 229 (9th Cir. 1975). The court in Pendlebury agreed that parties seeking the production of tax returns must demonstrate ( 1) relevance of the tax returns to the subject matter of the dispute an
re [ of tax returns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and tha
ose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence 1410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005X"The underlying purpose of Rule 410 is to promote p
ure [of tax returns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at •2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and tha
ose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence if410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote
re [ of tax returns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and tha
ose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence ¶410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote
re [of tax returns] arises 'from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and tha
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