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U.S. v. STEIN

No. S1 05 Crim. 0888(LAK).

473 F.Supp.2d 597 (2007)

UNITED STATES of America, v. Jeffrey STEIN, et al., Defendants.

United States District Court, S.D. New York.

February 9, 2007.

Attorney(s) appearing for the Case

John M. Hillebrecht, New York City, Kevin M. Downing, Garden City, NY, Stanley J. Okula, Jr., Rita M. Glavin, Margaret Garnett, Assistant United States Attorneys, Michael J. Garcia, United States Attorney, New York City, for Plaintiff.

David Spears, Spears & Imes LLP, New York City, Craig D. Margolis, Vinson & Elkins LLP, Washington, DC, for Defendant Jeffrey Stein.

Steven M. Bauer, Karli E. Sager, Latham & Watkins, LLP, San Francisco, CA, for Defendant John Larson.

David C. Scheper, Overland Borenstein Scheper & Kim LLP, Los Angeles, CA, for Defendant Robert Pfaff.

MEMORANDUM OPINION

KAPLAN, District Judge.

This matter is before the Court on a motion by defendants1 for disclosure of documents. I assume familiarity with the prior opinions in this case.

I

A. The Indictment

The superseding indictment contains forty-six counts. Count One (the "Conspiracy Count") charges all defendants with conspiracy to defraud the IRS by designing, marketing, and implementing...

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