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ss's silence is justified. United States v. Koubriti , 297 F. Supp. 2d 955, 962 (ED. Mich. 2004) (citing Hoffman , 341 U.S. at 53; United States v. Melchor Moreno , 536 F.2d 1042, 1049 (5th Cir. 1976); United States v. Rue , 819 F.2d 1488 (8th Cir. 1987); In re Morganroth , 718 F.2d 161, 167 (6th Cir. 1983)).
. in the hands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff v. Davis Polk & Wardwell , 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any o
se arguments fail for the same reasons. First, the computers and their contents are not "communications," they are pre-existing documents and, as in Ratliff , putting them into the hands of an attorney (or his investigator) does not convert them into "privileged" communications. Second, the removal of th
ness's silence is justified. United States I Koubriti , 297 F. Supp. 2d 955, 962 (ED. Mich. 2004) (citing Hoffman , 341 U.S. at 53; United States I Melchor Moreno , 536 F.2d 1042, 1049 (5th Cir. 1976); United States I Rue , 819 F.2d 1488 (8th Cir. 1987); In re Morganroth , 718 F.2d 161, 167 (6th Cir. 1983)). S
. in the hands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff I Davis Polk & Wardwell , 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any
se arguments fail for the same reasons. First, the computers and their contents are not "communications," they are pre-existing documents and, as in Ratliff , putting them into the hands of an attorney (or his investigator) does not convert them into "privileged" communications. Second, the removal of th
ss's silence is justified. United States v. Koubriti, 297 F. Supp. 2d 955, 962 (E.D. Mich. 2004) (citing Hoffinan, 341 U.S. at 53; United States v. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976); United States v. Rue, 819 F.2d 1488 (8th Cir. 1987); In re Morganroth, 718 F.2d 161, 167 (6th Cir. 1983)). See
.. in the hands of an attorney—or printing out such records for an attorney to review—does not render the documents privileged or work product. See Ratliff v. Davis Polk & Wardwell, 354 F.3d 165, 170-71 (2d Cir. 2003) ("Documents obtain no special protection because they are housed in a law firm; any o
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LOCATIONHubbell
PERSONJack Goldberger
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