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ction with prosecution by one sovereign do not carry over to prosecution by another sovereign. In Cobb , the Supreme Court clarified its holding in McNeil. Wisconsin , 501 U.S. 171 (1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutio
(1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutions." Id. at 167 (quoting McNeil at 175). The Cobb Court noted that some other courts: have read into McNeil 's offense-specific definition an exception for crimes that are `factual
Even if the act of production were testimonial for purposes of Doe , production can be refused only if the act of production also is incriminating . Butcher , 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
(1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutions." Id. at 167 (quoting McNeil at 175). The Cobb Court noted that some other courts: have read into McNeil 's offense-specific definition an exception for crimes that are `factual
Even if the act of production were testimonial for purposes of Doe , production can be refused only if the act of production also is incriminating . Butcher , 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
(1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutions." Id. at 167 (quoting McNeil at 175). The Cobb Court noted that some -34- EFTA00179133 other courts: have read into McNeil's offense-specific definition an exception for crim
Even if the act of production were testimonial for purposes ofDoe, production can be refused only if the act of production also is incriminating. Butcher, 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
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