error, Jackson v. United States, 526 F.3d 394, 396 (8th Cir.2008). We agree with Cvijanovich that he was legally entitled to any copies made of original documents to which he was also legally entitled. See id. (explaining that Rule 41(g) movant’s obligation to establish lawful entitlement to the property sought to be returned is often satisfied by showing that the property was seized from movant’s possession); Sovereign News Co. v. United States, 690 F.2d 569, 577 (6th Cir.1982) (determining that business had property interest in, and right to return of, copies of seized business records because the original records were the sole property of the business), cert. denied, 464 U.S. 814, 104 S.Ct. 69, 78 L.Ed.2d 83 (1983); cf. Marvin v. United States, 732 F.2d 669, 675-76 (8th Cir.1984) (<HOLDING>). The burden therefore shifted to the
recognizing that rule 45 can be used to subpoena documents to be introduced at trial as trial exhibits but rejecting plaintiffs argument that documents sought after the discovery cutoff were for use as trial exhibits where the scope of the request is broad and clearly is designed for discovery not lastminute trial needs such as for originals of documents where copies were produced in discovery and there is a need for the original at trial holding that a court must review all of the documents claimed as privileged and cannot rely on a random sampling of documents to determine privilege holding that pursuant to the best evidence rule trial testimony relying on documents was inadmissible without submission of such documents or an explanation as to why the documents were unavailable holding an agency need not demonstrate that all responsive documents were found and that no other relevant documents could possibly exist holding that where original documents were illegally seized those documents as well as all copies had to be returned