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Attorney-Client Privilege Privileged Communication

Ogletree, Deakins, Nash, Smoak & Stewart,...

Two Recent CHRT Rulings Rein in Over-Broad Human Rights Litigation - What Employers Should Know

Employers that defend against human rights complaints often find themselves grappling with pleadings and submissions that wander well beyond the events the complainant experienced. ...more

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Can Clients Safely Share Protected Communications With Their Parents?

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The attorney-client privilege is so fragile that even disclosing protected communications to family members normally waives it. An Arizona appellate court recently took a forgiving view, but a concurring judge sounded the...more

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Can One Jointly Represented Client Waive the Groupꞌs Privilege?

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Lawyers frequently represent multiple clients on the same matter. Absent some contractual arrangements to the contrary, those lawyers must share all confidential information with all the jointly represented clients and, of...more

Lowndes

Florida Law Update: Slack Messages May Be Privileged Communication

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Florida’s Sixth District Court of Appeal (6th DCA), which considers appeals from trial courts in an area running from Orange County down to Collier County, recently confirmed that discovery privileges apply to communications...more

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Does Disclosing Legal Advice to Financial Advisors Waive Privilege? Part I

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Companies that retain financial advisors to assist in transactions necessarily share intimate confidential corporate information with them. But can they safely share legal advice with such advisors without risking a privilege...more

EDRM - Electronic Discovery Reference Model

Discovery Rulings in Abrego-Garcia v. Noem Deportation Case

In Abrego-Garcia v. Noem, __ F.R.D. ___, 2025 WL 1166402 (D. Md. Apr. 22, 2025)(Xinis, J.), plaintiffs notified the Court of “seemingly intractable discovery disputes….”  The case is before the District Court after the United...more

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Clients Lose Some, Win Some – Two Courts Assess the Common Interest Doctrine on Same Day: Part I

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The common interest doctrine can sometimes protect as privileged communications between separately represented clients who share an identical legal interest in litigation, or in anticipation of litigation. But satisfying this...more

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Court Confirms Basic Privilege Principles in Giving Princeton a Win

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Because litigants frequently take an aggressive approach when withholding documents on privilege grounds, courts’ in camera reviews often result in a loss for them. But sometimes courts agree with a litigant’s privilege...more

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Can an Entity’s Owners Access Its Privileged Communication?

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An entity’s minority shareholders or partners obviously look to the entity’s governance documents when assessing their rights and obligations. On the privilege front, minority owners sometimes aggressively seek the entity’s...more

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Assessing Privilege Protection for Training Materials and Presentations: Part I

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Lawyers and non-lawyers frequently train their corporate colleagues. Determining any applicable attorney-client privilege or work product protections can implicate a number of variables....more

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Communicating in a Crisis: Tips for Protecting Communications When It Matters Most

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As recent high-profile litigation, government investigations, and large-scale data-security incidents have shown, organizations are often thrust into crisis mode, requiring rapid responses and close collaboration with third...more

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Another Decision Spawned by Ethical Scandal Highlights Wisdom of Considering All Evidentiary Protections

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In the aftermath of the soap opera-like ethical scandal over an undisclosed romantic relationship between a Jackson Walker partner and a Texas bankruptcy judge, an Oregon federal court dealt with discovery of a renowned...more

EDRM - Electronic Discovery Reference Model

Tailor FRE 502(d) Orders to the Case

Having taught Federal Rule of Evidence 502 (FRE 502) in my law classes for over a decade, I felt I had a firm grasp of its nuances. Yet recent litigation where I serve as Special Master prompted me to revisit the rule with...more

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When Can a Litigant Overcome the Adversary’s Fact Work Product Protection?

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Unlike the absolute attorney-client privilege (and the absolute or nearly absolute opinion work product doctrine protection), a litigant can overcome the adversary’s fact work product protection if it “shows that it has...more

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Non-Lawyer Corporate Employees Can Claim Privilege Protection for Investigation-Related Communications

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Outside and in-house lawyers may of course normally claim privilege protection for their investigation-related communications, as long as they were primarily motivated by the need for legal advice. Depending on the...more

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Court Adopts Variation of Bizarre Privilege Principle

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Several courts have adopted a nonsensical principle that, as one court put it, “[w]hen documents are prepared for dissemination to third parties, neither the document itself, nor preliminary drafts, are entitled to immunity.”...more

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Can Advertising Agencies Ever Be Within Privilege Protection?

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Numerous Privilege Points have described cases concluding that advertising agencies are outside privilege protection but inside work product protection (although they normally cannot themselves create protected work product)....more

Association of Certified E-Discovery...

Understanding the Dominant Purpose Test for Determining Whether Privilege Applies

In complex litigation, understanding when a document is protected by attorney-client privilege can be challenging, especially when privilege issues arise in multidistrict litigation (MDL) like the In re Uber Technologies,...more

Array

This Week in eDiscovery: AI Terms of Use Address Legal | Non-Traditional Communications

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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 November 17-23. Here’s what’s...more

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

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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

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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

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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

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