MEMORANDUM OPINION
KAPLAN, District Judge.
This matter is before the Court on motions by (1) all defendants for an order, pursuant to FED.R.CRIM.P. 16, compelling the government to produce certain materials in the files of KPMG LLP ("KPMG") and (2) KPMG to quash a Rule 17(c) subpoena seeking the same materials.
I
A. Background
1. The Investigation
In 2001 or early 2002, the Internal Revenue Service ("IRS")...
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