Epstein Secrets

25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N

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

Fla. 2001); 16 Case 9:08-cv-80119-KAM Document 477 Entered on FLSD Docket 02/26/2010 Page 17 of 24 Doe v. Epstein 08-CV80119 Page No. 17 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

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

S.D. Fla. 2001); Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

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

871 So.2d 729 (Miss. 2004) 43 *Jaffee v. Redmond, 518 U.S. 1 (1996) passim Keene Corp. v. United States, 508 U.S. 200 (1993) 27 *Lafler v. Cooper, 132 S. Ct. 1376 (2012) 8, 12 Long v. Raymond Corp., 245 Fed. Appx. 912 (11th Cir. 2007) 6 Lake Utopia Paper Ltd. v. Connelly Containers, Inc

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

17 of 24 Doe v. Epstein 08-CV80119 Page No. 17 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N

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