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

"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 `factually related' to a charge

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

"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 `factually related' to a charge

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

e "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 crimes that are 'factually