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Did S.D.N.Y. Mean to Apply Expansive Common Interest Doctrine?

Under the widely recognized common interest doctrine, separately represented clients may sometimes contractually avoid the otherwise inevitable privilege waiver when sharing privileged communications. As explained previously...more

Relying on an Investigation May Not Forfeit All Privilege Protection

Clients relying on an investigation’s result to gain some advantage understandably trigger a subject matter waiver. But some courts recognize that those clients may still claim privilege for some related communications....more

Rare Opinion Extends Privilege Protection to Implicit Request for Legal Advice

Overworked judges assessing possible privilege protection for the increasing volume of often-cryptic emails withheld from production understandably look for a client’s explicit request for legal advice from a lawyer....more

South Dakota Court Refreshingly Acknowledges Rule 30(b)(6) Confusion

As noted in several previous Privilege Points, courts have great difficulty assessing privilege protection for communications relating to a Rule 30(b)(6) deposition — in which a corporation or other institution designates a...more

Texas Court Applies Several Basic Work Product Principles

Because work product protection only applies at certain times, clients must be able to identify the exact moment that they first anticipated litigation. And not surprisingly, they must also explain why they first anticipated...more

Two Federal Courts Assess a Prospective Client’s Privilege Protection on the Same Day

Communications between a lawyer and a prospective client can involve ethics (confidentiality and conflicts) issues, as well as privilege protection issues. Not surprisingly, the availability of privilege protection depends on...more

Work Product Protection Can Be Overcome in Some Circumstances, but the Privilege Is Absolute — Right?

Most lawyers know that fact work product protection can be overcome in certain circumstances, opinion work product is “absolutely or nearly absolutely” protected, and that the attorney-client privilege is absolute. But as...more

Must Litigants Identify Their Non-Testifying Experts?

Litigants relying on testifying experts can look to federal or state court rules in determining what they must disclose or may withhold. In contrast, courts take widely varying views of those issues in addressing litigants'...more

Court Addresses “Client” Identity in a Closely Held Corporation

Identifying the "client" in closely held corporations can be difficult, but critical. That determination can affect both privilege protection for communications, and the right to access privileged communications between the...more

S.D.N.Y. Takes a Demanding View of the “Functional Equivalent” Doctrine

Under the common law "functional equivalent" doctrine, corporations sometimes may claim privilege protection for communications to or from a non-employee who is the "functional equivalent" of an employee. This common sense...more

Where Should Lawyers Look for the Applicable Attorney-Client Privilege?

The attorney-client privilege originated in Roman law, and flourished under what John Adams labeled "that most excellent monument of human art, the common of law of England." But in America, some states articulate their key...more

State Court Takes a Narrow View of the Common Interest Doctrine

Under the common interest doctrine, separately represented clients may sometimes contractually avoid the normal waiver impact of disclosing privileged communications to each other. But federal and state courts take widely...more

Federal and State Courts Issue Helpful Investigation-Related Decisions: Part II

Last week’s Privilege Point described a federal court case holding that explicit reliance on a consultant's investigation waived fact work product protection related to the investigation — but not opinion work product...more

Federal and State Courts Issue Helpful Investigation-Related Decisions: Part I

Internal corporate or other entity investigations frequently generate discovery motions that focus on privilege and work product creation and waiver issues. Two recent decisions offer some good news for defendants resisting...more

Can an Interviewee Witness List Ever Deserve Work Product Protection?

Facts and events normally do not deserve work product protection. But a lawyer's careful selection of such facts or important events sometimes may reflect his or her strategic assessment or litigation planning. For example,...more

State Courts Offer Some Hope for Adverse Privilege Rulings' Interlocutory Appeals

Federal courts have eliminated nearly any chance for unsuccessful trial court litigants to immediately appeal adverse privilege or work product rulings – inexplicably rejecting the obvious "cat out of the bag" nature of such...more

Do Arbitrations Count as "Litigation" for Work Product Purposes?

Fed. R. Civ. P. 26(b)(3) extends protection to documents prepared "in anticipation of litigation or for trial." An obvious question presents itself — what counts as "litigation"?...more

The Strange Fiction of Rule 30(b)(6)

Under Fed. R. Civ. P. 30(b)(6), a litigant seeking a corporate adversary's deposition may insist that the corporation designate an individual to testify on the corporation's behalf about designated topics. The concept makes...more

Texas Federal Court Applies the “At Issue” Waiver Doctrine

It seems obvious that corporations do not waive privilege protection by disclosing privileged communications to their own board members. But what about outside board members receiving such communications where they work or...more

Privilege Implications of Spousal Communications

Most courts hold that the incredibly fragile attorney-client privilege can be waived by disclosure even to family members (such as Martha Stewart’s disclosure to her own daughter). The separate "spousal privilege" recognized...more

Southern District of Ohio Acknowledges the "Fiduciary Exception's" Applicability to ERISA Communications — With a Twist

Under what is called the "fiduciary exception," the law essentially deems a fiduciary's beneficiary to be the fiduciary’s lawyer’s actual "client." This normally enables the beneficiary to access communications between the...more

Northern District of Texas Protects Communications With Former Employees

Lawyers representing corporations or other entities during investigations routinely interview former employees. Those intangible interviews and any resulting documentation presumably deserve work product protection if the...more

Drawing the Line Between a Privileged Communication’s Occurrence and Its Content

All or most courts assessing deposition objections distinguish between questions focusing on: (1) the occurrence of a privileged communication; and (2) its content. Not surprisingly, that line can sometimes be hard to draw....more

State Supreme Court Seems to Ignore Its Own Work Product Rule

Because what is called "opinion work product" deserves higher protection than fact work product (and in many courts enjoys "absolute or nearly absolute" protection), litigants understandably seek to withhold documents on that...more

Another Difference Between the Attorney-Client Privilege and the Work Product Doctrine

The ancient attorney-client privilege protection provides absolute but fragile immunity from discovery. The relatively new litigation-related work product doctrine provides limited but robust immunity from discovery. Lawyers...more

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