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Case 1:20-cr-00330-PAE Document528 Filed 12/06/21 Page3of8 Although criminal defendants possess constitutional rights to “a meaningful opportunity to present a complete defense and to confront witnesses,” those rights are not unqualified. United States v. Rivera, 799 F.3d 180, 184-85 (2d Cir. 2015) (citations and internal quotation marks omitted). “A defendant’s right to present relevant evidence . . . is subject to reasonable restrictions,” and therefore may “bow to accommodate other legitimate interests in the criminal trial process.” United States v. Scheffer, 523 U.S. 303, 308 (1998) (internal quotation marks omitted); see also Delaware v. Van Arsdall, 475 U.S. 673, 679 (1986) (discussing a district court’s “wide latitude . . . to impose reasonable limits on cross-examination based on concerns about, among other things, harassment, prejudice, confusion of the issues, the witnesses’ safety, or interrogation that is repetitive or only marginally relevant,” notwithstanding the Confrontation Clause). The attorney-client privilege is one such interest. See Taylor v. Illinois, 484 U.S. 400, 410 (1988) (“The accused does not have an unfettered right to offer testimony that is incompetent, privileged, or otherwise inadmissible under the standard rules of evidence.” (emphasis added)). Where the privilege applies, it is “essential to the protection of [the client’s] legal rights,” and “stands in derogation of the public’s right to every man’s evidence.” Jn re Horowitz, 482 F.2d 72, 81 (2d Cir. 1973) (internal quotation marks omitted). I. Discussion As a general matter, Jane and Glassman’s conversations with each other in which Glassman provided legal advice are privileged. They were: (1) between a client and counsel, (2) remain confidential, and (3) for the purpose of obtaining or providing legal advice. The defense has two theories by which Glassman’s alleged statement to Jane that her cooperation and testimony would “help her case” is not privileged: (1) it was not intended to be DOJ-OGR-00008239