Epstein Secrets

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

.E.C. v. Johnson, 534 F.Supp.2d 63, 66-67 (D.D.C. 2008), quoting United States v. Davis, 617 F.2d 677,683 (D.C.Cir. 1980). See, M,, United States v. Mezzanatto, 513 U.S. 196,205,207 (l 995)(purpose of the rules is to encourage plea bargaining, and rules "creat[ e ], in effect, a privilege of the defendant,

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

C. v. Johnson, 534 F.Supp.2d 63, 66-67 (D.D.C. 2008), quoting United States v. Davis, 617 F.2d 677, 683 (D.C.Cir. 1980). See, Q,g., United States v. Mezzanatto, 513 U.S. 196, 205, 207 (1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant,"

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

development of testimonial privileges .. . `governed by the principles of common law as they may be interpreted ... in the light of reason and 6 In Mezzanatto, the defendant challenged the admissibility of plea negotiation statements he made to a prosecutor, who had conditioned his willingness to enter int

distinguished from [the] ordinary insurance agent, who is employed by insurance com- panies to solicit and write iir ce by, in and the company."); Cooper . Berkshire Life Ins. Co., 148 Md.App. , 83, 810 A.2d 1045 (2002) ("[I]nsurance agents and brokers clearly owe a professionals duty to the insur

ery or use of the plea negotiations because plea negotiations enjoy an evidentiary privilege, as recognized by the Supreme Court in United States'. Mezzanatto, 513 U.S. 196 (1995). Additionally, because plea negotiations are "rooted in the imperative need for confidence and trust," and because their confid