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ry Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege
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
ury Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States I Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege
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
provide the rules of decision in the Virgin Islands courts). Is Id. 19 Costello Publ'g Co. v. Rotelle, 216 U.S. App. D.C. 216, 670 F.2d 1035, 1044 (D.C. Cir. 1981) ("The ques ion of whether or not an entity or individual should be a party to an action is something quite different from the questions and
g that the District Court e • in considering a party a necessary party because it based its decision solely on the evidentiary concerns); s e also Costello, 670 F.2d at 1044 (finding that the District Court erred in finding that Talbot Press was an indis• ble party because "Costello [was] left only wit
Jury Matter No. 91-01386, 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City, 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileg
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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