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therapist-patient privilege pursuant to Jaffee v. Redmond, 518 U.S. 1 (1996). First, the Court rejects Plai
1206, 1207 & 1209 (11 Cir. 1981) (en banc), 1 th the Eleventh Circuit adopted as binding precedent the decisions of the
the information sought by the Defendant is protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923 (1996)("AII agree that a psychotherapist privilege covers confidential communications made to licensed psychiatrists and
0 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote and unlikely"). In discussing Twombly. the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (11 th Cir. 2007), noted - "The Supreme Court's most recent formulation of the pleading s
Docket 09/02/2011 Page 10 of 23 A. "REASON AND EXPERIENCE" ARE THE TOUCHSTONES FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS Jaffe4. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and the common-law principles underlying the recognition of testimonial privileg
pen exchange of information to promote significant private and public interests. They arc: the decision of Judge Marcus, before he was appointed to the Eleventh Circuit, denying discovery and recognizing a privilege for airline pilots who report incidents and violations, In Re Air Crash Near Cali, Colombia, 959 F.
Entities connected to both Redmond and the Eleventh Circuit

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONLeon Black
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONMaria Farmer
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATIONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
Alan Dershowitz
PERSONRoy Black
PERSON