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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
. 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
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
. 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
des Group - Publications Page 5 of I9 Denaturation with Sodium Dodecyl Sulfate", Gudiksen, K. L., Urbach, A. R., Gitlin, I., Yang, Vasquez, J. A., Costello, C. E. and Whitesides, G. M., Anal. Chem., 2004, 76, 7151-7161. 889. "An Integrated Approach to a Portable and Low-Cost Immunoassay for Resource-Po
G. M. and Smith, D. W., Chem. Mat, 1999, 11, 2623-2625. 683. "Exposure of Self-Assembled Monolayers to Highly Charged Ions and Metastable Atoms", Ratliff, L. P., Minniti, R., Bard, A., Bell, E. W., Gillaspy, J. D., Parks, D., Black, A. J. and Whitesides, G. M., App/. Phys. Left, 1999, 75, 590-592. 6
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
.. 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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