Epstein Secrets

tes in evaluating that claim, but Epstein has objected to the production of those documents. F.I 1Although unpublished, the case of United States v. Hunter , 1995 WL 12513 (N.D. III. Jan. 6, 1995), contains facts similar to the ones at bar and gives a detailed analysis of the applicability of the attorn

protected, not the relationship as a whole. McKay v. C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

tates in evaluating that claim, but Epstein has objected to the production of those documents. F.I 1Although unpublished, the case of United States' Hunter , 1995 WL 12513 (N.D. III. Jan. 6, 1995), contains facts similar to the ones at bar and gives a detailed analysis of the applicability of the attorn

re protected, not the relationship as a whole. McKay' C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

ference must have specified -the purpose for which the computers were seized and delineated the limits of their subsequent search". United States v. Hunter, 13 F.Supp.2d 574, 584 (D.Vt. 1998) Given these principles, the Requests contained in ¶'s 1 and 2 of the subpoenas are clearly unreasonable, since

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the government to search the contents of the computers. Instead, the g

ference must have specified -the purpose for which the computers were seized and delineated the limits of their subsequent search". United States v. Hunter, 13 F.Supp.2d 574, 584 (D.Vt. 1998) Given these principles, the Requests contained in ¶'s 1 and 2 of the subpoenas are clearly unreasonable, since

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the govemmel ters. Instead, the government purports to be sessi

poena, 204 F.3d 516 (4th Cir. 2000), see Response at 21-22, was simply a claim of privilege with respect to the client's identity. United States v. Hunter, 1995 WI, 12513 (N.D.111. January 6, 1995), does not, as the government would have it. "contain[] facts similar to the ones, at bar." Response at 21

protected, not the relationship as a whole. McKay v. C.I.R., 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz