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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
. in the hands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff v. Davis Polk & Wardwell , 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any o
se arguments fail for the same reasons. First, the computers and their contents are not "communications," they are pre-existing documents and, as in Ratliff , putting them into the hands of an attorney (or his investigator) does not convert them into "privileged" communications. Second, the removal of th
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
. in the hands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff I Davis Polk & Wardwell , 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any
se arguments fail for the same reasons. First, the computers and their contents are not "communications," they are pre-existing documents and, as in Ratliff , putting them into the hands of an attorney (or his investigator) does not convert them into "privileged" communications. Second, the removal of th
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
.. in the hands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff v. Davis Polk & Wardwell, 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any o
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