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t's earlier cases [referring to Boyd ], have been discredited by later opinions." Andresen v. Maryland , 427 U.S. 463, 472 (1976). In 1984, Justice O'Connor wrote a concurring opinion in United States v. Doe , 465 U.S. 605 (1984), just to make explicit what is implicit in the analysis of that opinion; t
. 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
rt's earlier cases [referring to Boyd ], have been discredited by later opinions." Andresen I Maryland , 427 U.S. 463, 472 (1976). In 1984, Justice O'Connor wrote a concurring opinion in United States I Doe , 465 U.S. 605 (1984), just to make explicit what is implicit in the analysis of that opinion; th
. 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
ourt's earlier cases [referring to Boyd], have been discredited by later opinions." Andresen v. Maryland, 427 U.S. 463, 472 (1976). In 1984, Justice O'Connor wrote a concurring opinion in United States v. Doe, 465 U.S. 605 (1984), just to make explicit what is implicit in the analysis of that opinion; th
.. 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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