27, 44- 45. Hubbell arose out of the Whitewater investigation, in which Independent Counsel Kenneth Starr sought broad categories of information from Webster Hubbell, a target of the investigation. The subpoena included such requests as "any and all documents reflecting, referring, or relating to" the broad contou

7, 44- 45. Hubbell arose out of the Whitewater investigation, in which Independent Counsel Kenneth Starr sought broad categories of information from Webster Hubbell, a target of the investigation. The subpoena included such requests as "any and all documents reflecting, referring, or relating to" the broad cont