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Why Do Privilege Disputes Never Seem to Focus on Lawyers' Ethics Confidentiality Duty?

Every lawyer knows the incredible scope and strength of their ethics confidentiality duty. More than any other profession, lawyers must maintain the absolute secrecy of nearly all information relating to their clients. But...more

Copying a Lawyer on an Email Does Not Assure Privilege Protection, but That Lawyer Can Increase the Odds

Lawyers should remind their clients that copying a lawyer on an email does not automatically render the email privileged. But the story doesn't end there. In Dejewski v. National Beverage Corp., the court recited the...more

North Carolina Supreme Court Privilege Decision Rests on Understandable Karma

Corporate clients and their lawyers must look ahead to assess the privilege implications of their litigation positions. In Global Textile Alliance, Inc. v. TDI Worldwide, LLC, 847 S.E.2d 30, 33 (N.C. 2020), defendants...more

Federal Court Wrestles With Privilege Ownership After a Complicated Corporate Transaction

Several previous Privilege Points have summarized often-complicated judicial holdings on who owns privilege protection after corporate stock or asset transactions. It should come as no surprise that the privilege ownership...more

Delaware Court Provides Transactional and Practical Guidance: Part I

Corporate stock and asset sale transactions necessarily implicate ownership of: (1) ordinary day-to-day privileged communications about environmental matters, labor matters, etc., and (2) privileged communications about the...more

Delaware Courts Address Common Interest Doctrine Issue: Part II

Last week’s Privilege Point described a favorable Delaware state court decision finding that a post-reorganization trust and its largest stakeholder could rely on the common interest doctrine to protect their communications –...more

Can Withholding Privileged Communications Support an “Adverse Inference”?

The attorney-client privilege rests on a grand societal purpose — encouraging clients to safely share with their lawyers all the pertinent facts, so lawyers can guide them in a lawful direction. This is the same societal...more

The Southern District of New York Defines The Privilege Standard For Communications With Three Types of Consultants

Clients and their lawyers often work with consultants. If such consultants are found to be outside privilege protection: (1) communications with them do not deserve privilege protection; (2) their participation in otherwise...more

Deponents Usually May Not Rely On Privilege Protection In Refusing To Answer "Yes" or "No" Questions

The attorney-client privilege protects communications -- rather than historical facts, the circumstances of attorney-client relationships or communications, etc. This basic principle often precludes deponents from citing the...more

Federal Courts Assess Privilege Protection for International Communications

American courts assessing privilege protection for international communications usually apply U.S. privilege law to communications that "touch base" with the U.S. But purely overseas communications present a more difficult...more

State Courts Address Outsiders' Privilege Impact: Part II

Last week's Privilege Point described a North Carolina state court's predictable rejection of privilege protection for communications with a company's technical consultant. Does the same harsh standard apply when clients...more

Courts Continue to Diverge on the Common Interest Doctrine's Dependence on Anticipated Litigation

Most courts apply the common interest doctrine only in litigation-related circumstances, although a few courts extend the doctrine to transactional contexts. In BlackRock Balanced Capital Portfolio (Fi) v. Deutsche Bank...more

Court Rejects the Common Interest Doctrine's Applicability for Yet Another Reason

The common interest doctrine can avoid the normal waiver implications of disclosing privileged communications to third parties. But some courts do not recognize the doctrine at all, and most courts impose various requirements...more

Court Protects an Employee's Personal Privileged Communications Using the Company's Email Account

Starting 10-15 years ago, many courts addressed corporate employees' privilege claims for communications with their personal lawyers (usually employment lawyers) using their employers' email infrastructure. Most states (other...more

Court Applies Unique Government Attorney-Client Privilege Principle

In the corporate world, the attorney-client privilege does not protect communications to or from corporate lawyers acting in a business role. An analogous principle can deprive governments of their attorney-client privilege...more

Courts Wrestle with Privilege Protection for Client Consultants: Part I

The attorney-client privilege protects confidential communications between clients and their lawyers. Corporate client consultants may also deserve this protection if they act as the "functional equivalent" of corporate...more

How Do Courts Decide If Employees CC'ing a Lawyer are Implicitly Seeking Legal Advice?

Electronic communications exacerbate judges' already difficult task of determining if employees copying lawyers on their communications with fellow employees are implicitly seeking legal advice – and thus deserve privilege...more

Courts Continue to Catalogue Client Consultants Outside Privilege Protection

Clients' agents/consultants are nearly always outside privilege protection. This generally means that their documents do not deserve privilege protection; their presence during otherwise privileged communications aborts that...more

Courts Look for Lawyers' Responses to Clients' Requests for Legal Advice

The privilege can protect clients' requests for legal advice, and lawyers' responses. But employees simply cc'ing a lawyer on an email to another employee cannot guarantee privilege protection – because the email might be...more

Does the Attorney-Client Privilege Protect a Lawyer's Retention Date?

Content is king in the privilege world, in contrast to the work product protection – which largely depends on context. For this reason, the privilege rarely if ever protects the facts and circumstances of (1) the...more

Can the Attorney-Client Privilege Protect Corporate Executives' Notes of Their Conversations with a Lawyer?

The attorney-client privilege protects communications between lawyers and their clients, primarily motivated by the latter's need for legal advice. Some corporations' adversaries challenge privilege protection for withheld...more

Courts Address Privilege and Work Product Implications of Defendants' and Plaintiffs' Large "Town Hall" Meetings

The attorney-client privilege protects communications made and preserved in confidence. Work product protection does not rest on confidentiality, but evaporates if adversaries are present or later obtain protected work...more

Does the Shelton Standard Apply to In-House Lawyers?

Nearly every court protects a litigant's lawyer from depositions or other discovery under what is called the Shelton standard ( Shelton v. American Motors Corp., 805 F.2d 1323 (8th Cir. 1986)) or under similarly restrictive...more

Courts Continue to Insist that Common Interest Participants Anticipate Litigation

The common interest doctrine can allow separately represented clients to safely share privileged communications in certain circumstances. Although many lawyers hope that courts will begin extending this helpful protection to...more

An In-House Counsel Learns the Hard Way About a Key Difference Between Common Interest Agreements and Joint Representations: Part...

Common interest agreements and joint representations share many characteristics. Both types of arrangements involve lawyers engaging in protected communications with multiple clients. But they are structurally distinct. In...more

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