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citations omitted). However, the act of production privilege applies only if the production would be "testimonial" and "incriminating." Butcher v. Bailey , 753 F.2d 465, 469 (6th Cir 1985) (citing United States v. Doe , 465 U.S. 605, 612-13 (1984)). Production of documents may be testimonial in any o
ommunication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States v. Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pr
e citations omitted). However, the act of production privilege applies only if the production would be "testimonial" and "incriminating." Butcher I Bailey , 753 F.2d 465, 469 (6th Cir 1985) (citing United States I Doe , 465 U.S. 605, 612-13 (1984)). Production of documents may be testimonial in any of
communication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pro
00179125 omitted). However, the act of production privilege applies only if the production would be "testimonial" and "incriminating." Butcher v. Bailey, 753 F.2d 465, 469 (6th Cir 1985) (citing United States v. Doe, 465 U.S. 605, 612-13 (1984)). Production of documents may be testimonial in any of
Its Applicability. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States v. Schaltenbrand, 930 F.2d 1554 (11th Cir. 1991); United '8For purposes of this discussion, the requested documents will be jointly referred to as "billing records.
Entities connected to both Bailey and Schaltenbrand

Jeffrey Epstein
PERSON
United States
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSONFBI
ORGANIZATION
Stephen Hawking
PERSON
Supreme Court
ORGANIZATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONBarrett
PERSONSouthern District
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Hunter Biden
PERSON
Maine
LOCATION
Bernie Sanders
PERSONRoy Black
PERSON