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. 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
on-party witness." Lansford v. Chyrsler Motors Corp. , 513 F.2d 1121, 1126 (2d Cir. 1975). For example, in United States v. Wells , 2006 WL 3203905 (E.D. Mich. Nov. 3, 2006), a party sought to quash a subpoena issued to his bank, objecting that he was "unsure of what information the United States [sought] to gain from
. 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
a non-party witness." Lansford I Chyrsler Motors Corp. , 513 F.2d 1121, 1126 (2d Cir. 1975). For example, in United States' Wells , 2006 WL 3203905 (E.D. Mich. Nov. 3, 2006), a party sought to quash a subpoena issued to his bank, objecting that he was "unsure of what information the United States [sought] to gain from
.. 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
non-party witness." Langford v. Chyrsler Motors Corp., 513 F.2d 1121, 1126 (2d Cir. 1975). For example, in United States v. Wells, 2006 WL 3203905 (E.D. Mich. Nov. 3, 2006), a party sought to quash a subpoena issued to his bank, objecting that he was "unsure of what information the United States [sought] to gain from
Entities connected to both Ratliff and E.D. Mich. Nov. 3, 2006

Jeffrey Epstein
PERSON
Julie K. Brown
PERSONWalker
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONSecond Circuit
ORGANIZATIONUpjohn Co.
ORGANIZATIONCostello
PERSON
Hunter Biden
PERSONEmmy Taylor
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Alexander Acosta
PERSONUpjohn
ORGANIZATION
Meredith
PERSONThe California Supreme Court
ORGANIZATIONClutchette
PERSONBrown & Williamson Tobacco Corp.
ORGANIZATIONThe First Circuit
ORGANIZATIONthe D.C. Circuit
ORGANIZATIONHubbell
PERSON