The following excerpt is from Grand Jury Subpoena Dated Jan. 4, 1984, In re, 750 F.2d 223 (2nd Cir. 1984):
It is axiomatic that the burden is on a party claiming the protection of a privilege to establish those facts that are the essential elements of the privileged relationship, United States v. Stern, 511 F.2d 1364,
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