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Attorney-Client Privilege Privilege Logs

EDRM - Electronic Discovery Reference Model

Is Marking Documents as “Work Product” an Admission that the Duty to Preserve is Triggered?

In Stuart v. County of Riverside, 2024 WL 3086634, at *3 (C.D. Cal. Jun. 14, 2024), the District Court found a relationship between work product designations and triggering of the common-law duty to preserve....more

EDRM - Electronic Discovery Reference Model

Court-Ordered Production of a “Destruction/Unavailable” Log

I have never heard of a “destruction/unavailable” log; however, in the comprehensive – indeed, exhaustive – decision of Leprino Foods Co. v. Avani Outpatient Surgical Center, Inc., 2024 WL 4488711 (C.D. Ca. Sep. 30, 2024),...more

McGuireWoods LLP

When Do Courts Conduct an In Camera Review of Withheld Documents?

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Given the bare bones nature of many privilege logs, courts sometimes may be called upon, or themselves decide, to review withheld documents in camera to assess the grounds for the documents’ withholding. A handful of courts...more

McGuireWoods LLP

Two August Decisions Assess Privilege Protection for Employee-to-Employee Communications

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Corporate litigants’ privilege logs often trigger privilege disputes about internal corporate communications not involving a lawyer — because the log does not mention a lawyers’ participation. But there are at least two...more

EDRM - Electronic Discovery Reference Model

“Attachments to Attorney-Client Communications May Be Withheld as Privileged, Without an Independent Basis for Privilege,” But….

In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court held that “attachments to attorney client communications may be withheld as privileged without an independent basis for...more

McGuireWoods LLP

The Consequences of a Bad or Tardy Privilege Log

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Every court seems to require litigants to log documents they withhold based on privilege or work product claims. Perhaps not surprisingly, hardly any log goes unchallenged by the adversary. Most of these disputes eventually...more

Farrell Fritz, P.C.

Rattling the Attorney-Client Privilege Cage – A Lesson in Avoiding Waiver of Privilege Under the Common-Interest Doctrine

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In many cases, clients tend to place their trust, and often their livelihood, in the hands of their attorney. This expectation can be easily traced back to the attorney-client privilege, one of the oldest common-law...more

EDRM - Electronic Discovery Reference Model

May’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published May 15, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

McGuireWoods LLP

Courts Disagree About Privilege Log Requirements: Part II

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Last week’s Privilege Point described one court’s incredible requirement that litigants identify everyone who learned of a withheld document’s content — even if they were not shown as a recipient....more

Array

This Week in eDiscovery: EDRM Guidelines for GDPR Compliance, What Information is Enough for a Privilege Log, and More

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the week of April 1-7. Here’s what’s...more

EDRM - Electronic Discovery Reference Model

What Happens When Parties Fail to Negotiate a Privilege Log in Good Faith?

In Kyle Rayome v. ABT Electronics, 2024 WL 1435098 (N.D. Ill. 2024), the court wrote that it “would prefer this case not go to the dark place where attorneys on one side demand that the attorneys on the other side provide...more

Association of Certified E-Discovery...

Can Failing to Produce a Privilege Log Lead to Waiver of Privilege and Sanctions?

In Episode 131 of Case of the Week, CEO and Founder of eDiscovery Assistant, Kelly Twigger, discusses how the failure to produce a privilege log for withheld documents resulted in a waiver of privilege and sanctions under...more

Epiq

2023 eDiscovery Case Law Review

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January is a time to set goals and ponder what the new year will bring. It is also a time to think about what happened last year. In the world of litigation, it is important for lawyers and eDiscovery professionals to take...more

Association of Certified E-Discovery...

Privilege Logs and In-Camera Review

[Editor’s Note: This article has been republished with permission. It was originally published November 9, 2023 on the eDiscovery Assistant Blog] This week’s decision comes to us from the case titled 6340 NB LLC v. Cap. One,...more

McGuireWoods LLP

Texas Federal Court Applies the “At Issue” Waiver Doctrine

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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

Vinson & Elkins LLP

Reducing Costs of Privilege Review and Privilege Logging

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The difficulty of handling privilege disputes can be especially pronounced in cases involving a prolonged discovery period and large corporate defendants with different document custodians. When a party chooses to withhold...more

McGuireWoods LLP

In Camera Reviews’ Process and Downside: Part I

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Attorney-client privilege protection depends on content, and some work product claims also depend in part on content. Because a litigant's privilege log obviously does not disclose withheld documents' content, the adversary...more

McGuireWoods LLP

Court Provides Useful Guidance for Preparing a Defensible Privilege Log

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In earlier times, litigants essentially trusted each other to withhold (without identifying) responsive documents protected by the attorney-client privilege or the work product doctrine. Now every court seems to require a...more

EDRM - Electronic Discovery Reference Model

[Webinar] Ripped From the Headlines: Mystery of the Mar-a-Lago Docs & the Special Master - September 7th, 1:00 pm - 2:15 pm ET

Former President Donald J. Trump filed a motion to appoint a Special Master to review the material seized by the FBI from Mar-A-Lago. The stated purpose of the review by the Special Master is to remove nonrelevant and...more

Ward and Smith, P.A.

Teamwork Can Sometimes Make the Dream Work: How to Properly Maintain the Protections of Common Interest Doctrine in North Carolina

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Parties to a lawsuit often find themselves on the "same side of the courtroom" as other entities or individuals. In these instances, where a party is one of multiple (or many) co-plaintiffs or co-defendants, it is often...more

McGuireWoods LLP

Court Explains How Employee-to-Employee Emails Can Deserve Privilege Protection

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Because privilege logs necessarily contain logistical but not content-based information about withheld documents, adversaries sometimes challenge privilege protection because no lawyer sent or received a withheld document....more

McGuireWoods LLP

Fifth Circuit Orders Return of Privileged Property After Government Seizure

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The Fifth Circuit recently reversed a district court’s dismissal of a motion to return property after the government’s seizure of protected attorney-client information in Harbor Healthcare Sys., L.P. v. United States, 5 F.4th...more

Lighthouse

Privilege Mishaps: Lessons Learned

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Paying attention to the right facts, processes, methods, and tools when asserting attorney-client privilege will help avoid mishaps like these.  Discovery in litigation or investigations invariably leads to concerns over...more

Lighthouse

The Next Step is Now in Privilege Review.

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Looking beyond the keyword list paradigm as AI and analytics take the stage - In a 2012 True North blog post, one of our H5 experts provided some practical advice on reducing privilege review burdens and costs by...more

Kilpatrick

The Attorney Client Privilege: The Corporate Communication Conundrum – PART ONE

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“But in-house counsel was copied on the email, isn’t that enough?” When a business faces the prospect of producing documents in litigation, determining which documents are protected by the attorney-client privilege and...more

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