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Even if the act of production were testimonial for purposes of Doe , production can be refused only if the act of production also is incriminating . Butcher , 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
ment power is limited. See, e.g., Williams , 504 U.S. at 54-55 (Court cannot require prosecutors to present exculpatory evidence to the grand jury); Costello v. United States , 350 U.S. 359, 363-64 (1956) (Court cannot create rule permitting defendants to challenge grand jury indictments because of inade
Even if the act of production were testimonial for purposes of Doe , production can be refused only if the act of production also is incriminating . Butcher , 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
ment power is limited. See, e.g., Williams , 504 U.S. at 54-55 (Court cannot require prosecutors to present exculpatory evidence to the grand jury); Costello I United States , 350 U.S. 359, 363-64 (1956) (Court cannot create rule permitting defendants to challenge grand jury indictments because of inadeq
Even if the act of production were testimonial for purposes ofDoe, production can be refused only if the act of production also is incriminating. Butcher, 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
tment power is limited. See, e.g., Williams, 504 U.S. at 54-55 (Court cannot require prosecutors to present exculpatory evidence to the grand jury); Costello v. United States, 350 U.S. 359, 363-64 (1956) (Court cannot create rule permitting defendants to challenge grand jury indictments because of inadeq
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