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ommunication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States v. Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. v. United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pr
ial burden on the government to prove a grand jury subpoena is necessary and relevant." In re Impounded , 241 F.3d 308, 314 (3d Cir. 2001) (quoting R. Enter , supra , 498 U.S. at 298-99). See also Blair v. United States , 250 U.S. 273, 282 (1919) (a grand jury witness cannot refuse to respond to a subpoe
communication was made to him confidentially, in his professional capacity, for the purpose of securing legal advice or assistance. United States I Schaltenbrand , 930 F.2d 1554, 1562 (11th Cir. 1991) (citations omitted). See also XYZ Corp. I United States , 348 F.3d 16, 22 (1st Cir. 2003) ("The privilege pro
ial burden on the government to prove a grand jury subpoena is necessary and relevant." In re Impounded , 241 F.3d 308, 314 (3d Cir. 2001) (quoting R. Enter , supra , 498 U.S. at 298-99). See also Blair I United States , 250 U.S. 273, 282 (1919) (a grand jury witness cannot refuse to respond to a subpoen
Its Applicability. Procedurally, the person asserting the privilege bears the burden of establishing its applicability. See, e.g., United States v. Schaltenbrand, 930 F.2d 1554 (11th Cir. 1991); United '8For purposes of this discussion, the requested documents will be jointly referred to as "billing records.
if there is a reasonable possibility that the materials sought by the government will produce information relevant to the grand jury investigation. R. Enter., 498 U.S. at 300. Despite these broad powers, Epstein objects to the subpoenas that specifically call for and describe three computers, arguing th
Entities connected to both Schaltenbrand and R. Enter

Jeffrey Epstein
PERSONSouthern District
LOCATIONHubbell
PERSON
United States
LOCATIONF.R.D. 251
ORGANIZATION
Alexander Acosta
PERSONPaul Lavery
PERSONMorganroth
PERSONGrand Jury Proceedings
ORGANIZATIONRiley
PERSONEmmy Taylor
PERSONLeon Black
PERSONChristman
PERSON
Scarlett Johansson
PERSONFisher
PERSONE.D. Mich. 2004
ORGANIZATION
Alan Dershowitz
PERSONJack Goldberger
PERSONGerald Lefcourt
PERSON
Julie K. Brown
PERSON