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Attorney-Client Privilege Privileged Communication

Pietragallo Gordon Alfano Bosick & Raspanti,...

Preserving Privilege in Internal Investigations

One thing leaders of organizations routinely recognize is that “you never know what tomorrow will bring.” Another common slogan is “life happens.” If “life” happens to bring the organization a situation that could expose the...more

McGuireWoods LLP

Electronic Communications Dramatically Complicate Choice of Law Analysis

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As explained in previous Privilege Points, courts frequently must decide which state’s privilege law applies to communications involving several states. Fed. R. Evid. 501 states that federal courts should apply state law but...more

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

McGuireWoods LLP

Two Important Courts in Two Days Highlight the Shrinking Risk of Subject Matter Waivers: Part II

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Last week’s Privilege Point noted the Southern District of New York’s privilege expert’s opinion confirming the modern view that an extrajudicial disclosure of a privileged communication normally does not trigger a subject...more

McGuireWoods LLP

Two Important Courts in Two Days Highlight the Shrinking Risk of Subject Matter Waivers: Part I

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All lawyers worry that waiving privilege protection for some communications might trigger a damaging subject matter waiver requiring disclosure of related communications. Such a subject matter waiver risk normally does not...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

Mayer Brown

Legal Privilege in Cyber Incidents: Lessons for Hong Kong from Australia’s Optus Cyber Breach

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Important lessons for Hong Kong organisations managing cyber accidents may be learned from the noteworthy ruling in a recent Australia case, Singtel Optus Pty Ltd v. Robertson [2024]. For background, from 17-20 September...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

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Courts’ “Intensely Practical” Approach to Surveillance Videos

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In contrast to the somewhat abstract doctrine-driven attorney-client privilege, courts have described the work product doctrine as “intensely practical.” Their treatment of defendants’ surveillance videotape of personal...more

McGuireWoods LLP

The Surprising Danger of Including a Spouse on Email Communications

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Most lawyers know that state statutes or common law doctrines often protect communications between spouses – although there is wide variation in such approaches. But there is a lurking danger that all of us should keep in...more

Allen Matkins

The Attorney-Client Privilege In M&A Transactions - A Decade Later

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In 2013, then Chancellor Leo Strine determined that under Section 259 of the Delaware General Corporation Law the attorney-client privilege held by the target company follows to the surviving company after a merger.   Great...more

McGuireWoods LLP

Courts Thankfully Back Away From a Broad “At Issue” Waiver Approach

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Starting about 50 years ago in the case of Hearn v. Rhay, 68 F.R.D. 574 (E.D. Wash. 1975), some courts recognized a broad “at issue” waiver that could strip away privilege without the holder’s disclosure of or even reference...more

McGuireWoods LLP

Courts Assess Waiver Implications of Lawyers Testifying: Part II

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Last week’s Privilege Point described a Nevada federal court ruling that a lawyer’s testimony about non-privileged matters did not waive that fragile protection. Snow Covered Capital, LLC v. v. Fonfa, Case No....more

Array

This Week in eDiscovery: Concerns in Google Antitrust Case, Email Attachments and Privilege

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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 period of August 5-11. Here’s what’s...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

Two S.D.N.Y. Cases Decided the Same Day Provide the Same Key Privilege Guidance: Part I

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Many if not most clients and even some ill-informed lawyers think they can “make” something privileged through some logistical step — such as marking it as “privileged,” copying a lawyer, inviting a lawyer to a meeting, etc....more

Association of Certified E-Discovery...

Legal Hold Privilege in Jeopardy: What a Preliminary Showing of Spoliation Means for Your Case

In the ever-evolving landscape of eDiscovery, the privilege surrounding legal hold notices is increasingly being scrutinized. A recent decision in FTC v. Amazon.com, Inc. (July 9, 2024) brings this issue to the forefront,...more

Fishman Haygood LLP

Ethical Rules for Using Generative AI in Your Practice

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At the risk of stating the obvious, we are still in the early days of what we believe to be an “AI Revolution” in the way that goods and services, including legal services, are and will be provided. That means that we do not,...more

McGuireWoods LLP

What Standard Applies to Courts’ Review of Special Masters’ Privilege Calls

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In some cases involving voluminous or complicated privilege issues, courts rely on special masters to make the privilege calls. Courts often call on well-respected private lawyers, or sometimes academics (which not...more

Carr Maloney P.C.

Can Chat-GPT Be My Co-Counsel? The Rise of AI and Its Implication on the Attorney-Client Relationship

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We are halfway through 2024 and one thing is clear: the “AI” marketing is booming. Nvidia, the software company dubbed the “artificial intelligence titan,” has a market cap of over $3 trillion and recently issued a 10-for-1...more

Seyfarth Shaw LLP

Key Developments In Equal Pay Litigation: Maintaining Privilege Over Pay Equity Audits And Investigations

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Seyfarth Synopsis: In its seminal decision, Bostock v. Clayton County, Georgia, the Supreme Court held that discrimination on the basis of sexual orientation or gender identity is tantamount to discrimination on the basis of...more

Kilpatrick

The Attorney-Client Privilege: The Corporate Communication Conundrum – Part II

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As anyone faced with discovery requests knows, one of the most important parts of producing documents is determining what documents are subject to attorney-client privilege or work product doctrine and must therefore be...more

McGuireWoods LLP

How Do You Distinguish Between Lobbying Advice and Legal Advice?

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Lawyers frequently act as lobbyists. Not surprisingly, courts have a difficult time distinguishing between protected legal advice and nonprotected lobbying advice....more

McGuireWoods LLP

Courts Deal With a Review of Privilege Rulings

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In federal courts, it is nearly impossible to successfully file an interlocutory appeal of a trial court’s order requiring production of privileged documents — despite the obvious “cat out of the bag” nature of such rulings....more

EDRM - Electronic Discovery Reference Model

Generative AI for Smart Discovery Professionals: An Introduction to Large Language Models – Second Edition

In November of 2022, ChatGPT upended our thinking about artificial intelligence with a new form of machine learning called Generative AI (GenAI). Since then, discussions about GenAI models like GPT have taken center stage in...more

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