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even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who p
aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid
. 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
even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who pa
gaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid
. 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
et with counsel for Mr. Epstein. Sincerely, R. Alexander Acosta United States Attorney ...••••••• By: Chief, Criminal Division cc: Roy Black Gerald B. Lefcourt R. Alexander Acosta EFTA00179084 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY
aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States, 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid
.. 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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