What is the burden of proving private communications were not made privately?

MultiRegion, United States of America

The following excerpt is from United States v. Pugh, No. 17-1889 (2nd Cir. 2019):

privilege "[bears] the burden of defeating this presumption by showing that the communication was not made privately." United States v. Taylor, 92 F.3d 1313, 1332 (2d Cir. 1996).

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