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ial burden on the government to prove a grand jury subpoena is necessary and relevant." In re Impounded , 241 F.3d 308, 314 (3d Cir. 2001) (quoting R. Enter , supra , 498 U.S. at 298-99). See also Blair v. United States , 250 U.S. 273, 282 (1919) (a grand jury witness cannot refuse to respond to a subpoe
s or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn v. United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Co
ial burden on the government to prove a grand jury subpoena is necessary and relevant." In re Impounded , 241 F.3d 308, 314 (3d Cir. 2001) (quoting R. Enter , supra , 498 U.S. at 298-99). See also Blair I United States , 250 U.S. 273, 282 (1919) (a grand jury witness cannot refuse to respond to a subpoen
s or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn I United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Cou
if there is a reasonable possibility that the materials sought by the government will produce information relevant to the grand jury investigation. R. Enter., 498 U.S. at 300. Despite these broad powers, Epstein objects to the subpoenas that specifically call for and describe three computers, arguing th
or that the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn v. United States, 449 U.S. 383 (1981), the Supreme Court made clear that an -18- EFTA00179117 attorney cannot create a "zone of silence" over fact
Entities connected to both R. Enter and Upjohn

Jeffrey Epstein
PERSON
Meredith
PERSONSecond Circuit
ORGANIZATIONClutchette
PERSONRatliff
PERSONThe California Supreme Court
ORGANIZATIONEmmy Taylor
PERSONUpjohn Co.
ORGANIZATION
United States
LOCATION
Hunter Biden
PERSONWalker
PERSON
Tony Blair
PERSON
Bailey
PERSON
FedEx
ORGANIZATION
Guy Lewis
PERSONBarrett
PERSONFeldman
PERSON
Brewer
PERSON
Blackburn
PERSONBrown & Williamson Tobacco Corp.
ORGANIZATION