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tion. B. The Private Interests at Stake Are Profoundly Important. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee, 518 U.S. at 10, and maintaining their confidentiality advances significant private as well as public interests. There is an "imperative need" that
ure, they will necessarily refrain from making admissions and concessions, either of fact or law, which could later harm their clients. Thus, as in Jaffee, the "evidence" which would be available for later discovery would likely never come into being. Fourth, there is a strong consensus in the states
gress rejected in enacting Rule 501, only one of which appears on this Court's summary in Adkins of the 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 th
State University, 495 Fed. Appx. 286 (4th Cir. 2012), cert. denied, 133 S.Ct. 991 (2013) 55 *Missouri v. Frye, 132 S. Ct. 1399 (2012) 12, 35,36 Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009) 46, 47, 48, 49, 51 EFTA00209664 Case: 13-12923 Date Filed: 08/05/2013 Page: 9 of 75 Moulder v. State, 154 I
ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to p
only to grand jury subpoenas. Perlman v. United States, 247 U.S. 7, 38 S. Ct. 417 (1918). Second, they argue that a decision of the Supreme Court, Mohawk Industries, Inc. v. Carpenter, 558 U .S . 100, 130 S. Ct. 599 (2009), forecloses an interlocutory appeal of a denial of a claim of privilege. 8 EFTA00209639 Cas
ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee'. Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to pr
es only to grand jury subpoenas. Perlman' United States, 247 U.S. 7, 38 S. Ct. 417 (1918). Second, they argue that a decision of the Supreme Court, Mohawk Industries, Inc.I Carpenter, 558 U .S . 100, 130 S. Ct. 599 (2009), forecloses an interlocutory appeal of a denial of a claim of privilege. 8 EFTA00209748 Case:
Entities connected to both Jaffee and Mohawk Industries, Inc.

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATIONLeon Black
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONRoy Black
PERSONMartin Weinberg
PERSON
Carpenter
PERSON
Michael Cohen
PERSONPerlman
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION
Redmond
PERSONDickson
PERSONFBI
ORGANIZATION
Supreme Court
ORGANIZATIONJack Goldberger
PERSONKrane
PERSON
George W. Bush
PERSON