Epstein Secrets

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

ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis , 636 F.2d at 1039. See also Nguyen v. Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States v. White , 950 F.2d 426, 430 (7t

and jury. My research shows that 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 States v. Muiloz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); Motley v

Furthermore, blanket assertions are not proper, and the assertion must be made on a question-by-question and document-by- document basis. See, e.g., Nguyen v. Excel Corp., 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat Bank 974 F.2d 127 (9th Cir. 1992); United States v. White, 950 F.2d 426, 430 (7th Ci

and jury. My research shows that 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 States v. MuRoz , 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables , 148 F.3d 379 (4th Cir. 1998); Motley

Furthermore, blanket assertions are not proper, and the assertion must be made on a question-by-question and document-by-document basis. See, e.g., Nguyen v. Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States v. White , 950 F.2d 426, 430 (7

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.

ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis, 636 F.2d at 1039. See also Nguyen v. Excel Corp., 197 F.3d 200 (5th Cir. 1999); Clarke v. American Commerce Nat. Bank, 974 'In Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (en bane),