1428 (discussing why the target of an investigation is in an adversarial relationship with the investigating agency); United States v. Bergonzi, 216 F.R.D. 487 (N.D. Cal. 2003) (rejecting contention that government was not the company's adversary). A passage from the Court in In re: Pacific Pictures Corp.,

eld in Hickman 1. Taylor, supra, with respect to pretrial discovery. See Advisory Commit- tee's explanatory statement, 28 U.S.C. App., p. 7778; 48 F.R.D. 487. In the crim- inal area, Congress has enacted 18 U.S.C. s 3500 and accepted Fed.Rule Crim.Proc. 16(c). The former prevents pretrial discov- Page 21