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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
s or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn v. United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Co
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
s or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn I United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Cou
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.
or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn v. United States, 449 U.S. 383 (1981), the Supreme Court made clear that an -18- EFTA00179117 attorney cannot create a "zone of silence" over fact
Entities connected to both Schaltenbrand and Upjohn

Jeffrey Epstein
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LOCATIONHubbell
PERSONF.R.D. 251
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Alexander Acosta
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PERSONLeon Black
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PERSONSecond Circuit
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Scarlett Johansson
PERSONGrand Jury Proceedings
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PERSONJack Goldberger
PERSONGerald Lefcourt
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