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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
ers that are the subject of this motion, but Epstein had already removed the computers from the home. ( See Recarey Declaration.) FlAs explained in the Ex Parte Affidavits, the United States has established that it can authenticate the computers without Riley's testimony. Even if it could not, however, that is not a ba
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
ers that are the subject of this motion, but Epstein had already removed the computers from the home. ( See Recarey Declaration.) FlAs explained in the Ex Parte Affidavits, the United States has established that it can authenticate the computers without Riley's testimony. Even if it could not, however, that is not a ba
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
rposes of Doe, and, thus, the subpoenas are enforceable (regardless of the computers' contents). Id. at 93-94 (citation omitted)." "As explained in the Ex Parte Affidavits, the United States has established that it can authenticate the computers without Riley's testimony. Even if it could not, however, that is not a b
Entities connected to both Upjohn and the Ex Parte Affidavits

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