The following excerpt is from U.S. v. Hoffman, 794 F.2d 1429 (9th Cir. 1986):
Id; see Viserto, 596 F.2d at 538; see also Walk, 533 F.2d at 418 (oral statements not discoverable under former Rule 16(a)(1)(A), which allowed disclosure only of written and recorded statements, even though the statements were eventually summarized in written notes); United States v. Feinberg, 502 F.2d 1180, 1182-83 (7th Cir.1974), cert. denied, 420 U.S. 926, 95 S.Ct. 1122, 43 L.Ed.2d 396 (1975) (same).
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