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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
ial entity, not a natural person, and therefore has no Fifth Amendment privilege at all. See, e.g., Doe v. United States , 487 U.S. 201, 206 (1988); Bellis v. United States , 417 U.S. 85, 90 (1974). B. The Attorney-Client Privilege and the Work Product Doctrine Also Do Not Bar the Production of the Com
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
cial entity, not a natural person, and therefore has no Fifth Amendment privilege at all. See, e.g., Doe I United States , 487 U.S. 201, 206 (1988); Bellis I United States , 417 U.S. 85, 90 (1974). B. The Attorney-Client Privilege and the Work Product Doctrine Also Do Not Bar the Production of the Comp
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
cial entity, not a natural person, and therefore has no Fifth Amendment privilege at all. See, e.g., Doe v. United States, 487 U.S. 201, 206 (1988); Bellis v. United States, 417 U.S. 85, 90 (1974). -15- EFTA00179114 B. The Attorney-Client Privilege and the Work Product Doctrine Also Do Not Bar the
Entities connected to both Butcher and Bellis

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