This list of criminal charges i$ not meant to be exhauitivc, but certainly 

 Defendant! counsel must believe hii client could be charged with a cnminal ofTcna* or he would 

 not have encouraged hina repeatedly to assert hii FifUi Anxndmeni right against icif- 

 incriminatjon during the deposition on Octob« 6. 1993 [It U imponant in this Couiti final 

 analywa to remember how the Defendant c*me into poatewion of these document! «i thii Cwt 

 scenario is dearly distinguishable from caats cited by the Defendant in detennining whctha oc 

 not a crime/ft^ud exception to the attoracy-clicnt privilege exists. Set alto Supreme Court Rnk 



1.6 (b)]. 



Shortly after die return of die copied docunvntt, the Defendant reveals thai he had 

 prepared a namrive and a sealed copy of aame was provided to the PlaincifF Wyiu (Septetoba 

 22, 1993, letter fnxn the Defendant's counsel to Plaintiff, attached as Exhftit G to Defendant's 

 Brief to Dissolve the Restraining Order). The nanative (juotes vexbatiin, docuaaents already 

 retunicd to the Plaintiff (Affidavit of J. Keodnck WeDs). The Court is able to gleeoj from the 

 Defendant's Brief tiiat the narrative may inchide infomutioo from various sources includiag 

 documents taken from the Plaintiff, information the Defendant "learned' during the course of his 

 employment work product of non-attorney's utilized by the Plaindfft Wyatt and Brown ft 

 Williamson i.e. accountants and infarmation from third parties not associated with this litigatiaa. 

 Tbe Defeodants are concerned solely with the fint three categories and as they may be protected 

 by die attorney-client privilege. 



Tbe Plaintiff has asserted diat die infbrmatioa taken by dw Defendant wfoetfaer 

 documents or knowledge is subject to the attomey-cKent privilege. Aldiough diis Court 

 recognizes that not all infbrmatioa widiin an attorney's file is subject to die privilege, it is safe 



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