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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
y. Even if it could not, however, that is not a basis for refusing to produce the items. In United States v. Koubriti , 297 F. Supp. 2d 955, 969-70 (E.D. Mich. 2004), the court ordered the production of the defendant's handwritten notes that were in the possession of defense counsel where the United States knew
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
ny. Even if it could not, however, that is not a basis for refusing to produce the items. In United States I Koubriti , 297 F. Supp. 2d 955, 969-70 (E.D. Mich. 2004), the court ordered the production of the defendant's handwritten notes that were in the possession of defense counsel where the United States knew
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
privilege on a question-by-question basis and decide whether a witness's silence is justified. United States v. Koubriti, 297 F. Supp. 2d 955, 962 (E.D. Mich. 2004) (citing Hoffinan, 341 U.S. at 53; United States v. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976); United States v. Rue, 819 F.2d 1488 (8th C
Entities connected to both Upjohn and E.D. Mich. 2004

United States
LOCATION
Jeffrey Epstein
PERSONThe First Circuit
ORGANIZATIONRatliff
PERSONMolson Breweries
ORGANIZATIONPaul Lavery
PERSONLeon Black
PERSON
Hunter Biden
PERSONShelly Marchetti
PERSONWalker
PERSONXYZ Corp.
ORGANIZATIONEmmy Taylor
PERSONDorf & Stanton Communications
ORGANIZATIONMorganroth
PERSON
Meredith
PERSONSchaltenbrand
PERSONMelchor Moreno
PERSONRiley
PERSONClutchette
PERSONUpjohn Co.
ORGANIZATION