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Supreme Court Fumbles Attempt to Define Privilege Standard: Part II

Last week's Privilege Point described the Supreme Court's failure to decide between a "primary purpose" and a "one significant purpose" privilege standard. Everyone wonders why the Supreme Court dropped the case. The best...more

Analyzing an Inadvertent Production’s Waiver Impact: What Does the “Inadvertent” Element Mean?

In federal court and in state courts following the same approach, Fed R. Evid. 502(b) sometimes allows claw backs if a privileged document's production was "inadvertent." That term could have several meanings — ranging from a...more

In Camera Reviews’ Process and Downside: Part II

Last week's Privilege Point described courts' various standards for their in camera review of withheld documents. The vast majority recognizes the trial court's discretion, but some courts always conduct an in camera review...more

In Camera Reviews’ Process and Downside: Part I

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

Defendant’s Sloppy Language and Log Doom Work Product Claim

Fed. R. Civ. 26(b)(3)(A) protects from discovery documents and tangible things that are prepared in anticipation of litigation or for trial. Litigants asserting work product protection must (if called upon to do so) identify...more

Courts Address Work Product Protection for Non-Testifying Consulting Experts: Part II

Last week's Privilege Point summarized a case confirming non-testifying experts' general immunity from discovery — absent "exceptional circumstances" such as destructive testing. Ten days later, another court addressed...more

Do Regular Attorney-Client Principles Apply in the Governmental Setting?

Courts' application of the attorney-client privilege to government lawyers' communications reflects the tension between the public interest in government transparency and the societal benefit of public officials and employees...more

Courts Apply the "Intensely Practical" Work Product Doctrine: Part II

Last week's Privilege Point described a court’s rejection of work product protection for a preprinted post-accident form with seemingly helpful boilerplate language about its purpose and a lawyer's involvement — but without...more

Courts Apply The "Intensely Practical" Work Product Doctrine: Part I

The work product doctrine has been described by many courts as "intensely practical." Several decisions highlight this understandable adjective, and explicitly provide useful guidance for lawyers representing litigants and...more

May Litigants Advance Their Case Using Purloined Privileged Documents?

Given the vulnerability of electronic communications to intrusion, lawyers sometimes obtain and may be tempted to use documents that their clients have inappropriately obtained from an adversary – even privileged documents....more

Hickman Work Product Protection Extends Beyond the Work Product Rule

Just about the time that extensive pre-trial discovery started, the Supreme Court recognized a new evidentiary protection – extending beyond the attorney-client privilege, and motivated by the understandable requirement that...more

What Is the Standard for Courts’ In Camera Review of Withheld Documents?

Litigants and even some lawyers occasionally forget how courts address attorney-client privilege (and sometimes work product protection) assertions. Privilege protection focuses primarily on a communication's content — ...more

New York State Court Recognizes a General Privilege Rule, But The S.D.N.Y. Carries It To An Astoundingly Impractical Extreme: Part...

Last week's Privilege Point described a New York state court's unsurprising articulation of the nearly universally-applied "primary purpose" standard, and listing of the usual type of documents that fail to satisfy that...more

Courts Address Work Product Issues: Part II

Last week's Privilege Point addressed litigants' need to identify the exact moment when they first anticipated litigation. Another work product issue involves the degree of protection afforded opinion work product....more

Courts Differ on the Meaning of the Work Product Rule's "Anticipation" and "Litigation" Elements: Part II

Last week's Privilege Point addressed courts' differing interpretations of the work product rule's "anticipation" element. Fed. R. Civ. P. (26)(b)(3)'s and parallel state rules' "litigation" element also requires courts'...more

Court Issues Strange Intangible Work Product Decision

Although the federal work product rule and parallel state work product rules extend only to "documents and tangible things," most courts also protect intangible work product such as oral communications – at least to the...more

Courts Deal With "Dual-Hat" Experts: Part I

Fed. R. Civ. P. 26(a)(2)(B)(ii) governs testifying experts' duty to produce "the facts or data considered by the witness in forming" his or her opinion. Fed. R. Civ. P. 26(b)(4)(D) governs dramatically different...more

Correctly Applying Work Product Protection Continues to Elude Some Courts

As Privilege Points have periodically mentioned, some courts inexplicably limit work product protection to documents lawyers prepare or order to be prepared – in the face of Fed. R Civ. P 26(b)(3)(A)'s requirement only that...more

The Stealthy Rule 612 Risk to Privilege Protection

Lawyers preparing their clients and others for deposition or trial testimony frequently show them documents. Courts disagree about whether such lawyers can withhold from the adversary those documents' identity. The majority...more

S.D.N.Y. Issues Frightening Waiver Decision in Employment Case

Wise employment lawyers know that they should never be the decision makers when a client terminates an employee. Instead, those lawyers should be one of many inputs into the business person's decision to terminate....more

Court Addresses Privilege and Work Product Implications of Due Diligence in Corporate Acquisition – and Probably Gets It Wrong

An acquiring corporation normally conducts due diligence before acquiring an acquisition target. Not surprisingly, the acquiring corporation might seek privileged or work product protected documents or communications during...more

Florida Federal Court Mentions Two Ways the Work Product Doctrine Differs From the Attorney-Client Privilege

The ancient attorney-client privilege: (1) protects communications primarily motivated by clients' request for legal advice, regardless of any litigation on the horizon; and (2) protects such communications absolutely. The...more

Can the Privilege Protect Documents Prepared by Someone Who Has Never Hired a Lawyer?

The attorney-client privilege protects communications between clients and their lawyers. But in certain admittedly limited circumstances, the protection can apply to documents created by someone who has not yet hired a...more

SDNY Correctly Protects Preliminary Drafts of Publicly Disseminated Documents

Not surprisingly, attorney-client privilege protection evaporates once a client and her lawyer agree that a document can be disclosed to outsiders -- even before it is disclosed. But some courts have inexplicably applied this...more

Sending Pre-Existing Historical Documents to a Lawyer Does Not Make Them Privileged, But…

It should go without saying that sending pre-existing historical documents to a lawyer does not automatically immunize them from discovery as privileged. If it did, clients could box up all of their files and send them to a...more

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