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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
ed, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa
(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
, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States v. Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa
(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
lled, instead, the contents were voluntarily created by the persons who used them.15 See, e.g., United States v. Doe, 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings, 393 F.3d 905, 909 (9th Cir. 2004); In re Foster, 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informati
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