ing assertions of fact or belief because the creation of those documents was not `compelled' within the meaning of the privilege." United States v. Hubbell 530 U.S. 27, 35-36 (2000). Accordingly, a party cannot avoid discovery merely because demanded documents contain incriminating evidence, "whether written by

tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976). In explaining the application of the privilege, the Supr

ing assertions of fact or belief because the creation of those documents was not `compelled' within the meaning of the privilege." United States v. Hubbell 530 U.S. 27, 35-36 (2000). Accordingly, a party cannot avoid discovery merely because demanded documents contain incriminating evidence, "whether written by