Epstein Secrets

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States , 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records . . . in the hands of an attorney—or

ial entity, not a natural person, and therefore has no Fifth Amendment privilege at all. See, e.g., Doe v. United States , 487 U.S. 201, 206 (1988); Bellis v. United States , 417 U.S. 85, 90 (1974). B. The Attorney-Client Privilege and the Work Product Doctrine Also Do Not Bar the Production of the Com

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. I United States , 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records . . . in the hands of an attorney—or

cial entity, not a natural person, and therefore has no Fifth Amendment privilege at all. See, e.g., Doe I United States , 487 U.S. 201, 206 (1988); Bellis I United States , 417 U.S. 85, 90 (1974). B. The Attorney-Client Privilege and the Work Product Doctrine Also Do Not Bar the Production of the Comp

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States, 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records ... in the hands of an attorney—or p

cial entity, not a natural person, and therefore has no Fifth Amendment privilege at all. See, e.g., Doe v. United States, 487 U.S. 201, 206 (1988); Bellis v. United States, 417 U.S. 85, 90 (1974). -15- EFTA00179114 B. The Attorney-Client Privilege and the Work Product Doctrine Also Do Not Bar the