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Court Tackles a Tough Issue: Work Product in the Insurance Context

Some readers have asked why Privilege Points have only rarely focused on work product issues in the insurance context. In addition to the sometimes dramatic differences between states’ handling of this issue, a recent case...more

Another Federal Court Assesses Work Product Protection for Litigant’s Communications with Its Litigation Funder

With the growth of litigation funding as a mechanism for financing litigation, companies interviewing and ultimately selecting a funder inevitably share work product with them. In such circumstances, courts must assess (1)...more

Electronic Communications Dramatically Complicate Choice of Law Analysis

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

Does Disclosing an Attorney-Client Communication Into Another Privileged Relationship Waive That Privilege?

Although lawyers understandably focus mostly on the privilege that they enjoy when communicating with their clients, other professionals (psychiatrists, clergy) also have privilege protection of one degree or another. Does...more

Courts Begin to Address the Work Product Implications of AI

Courts have been scrambling to catch up with the fast and sometimes unpredictable evolution of lawyers’ use of generative AI. Many if not most courts require lawyers to advise them if they relied on AI in preparing filings...more

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

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

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

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

The Bad News and Good News About Litigation Holds and Work Product Claims

Some courts understandably conclude that the anticipation of litigation that can assure work product protection also requires the litigant to impose a litigation hold on pertinent documents. Perhaps that is not a perfect...more

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

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

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

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

Courts’ “Intensely Practical” Approach to Surveillance Videos

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

The Surprising Danger of Including a Spouse on Email Communications

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

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

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

Courts Assess Waiver Implications of Lawyers Testifying: Part II

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

Courts Assess Waiver Implications of Lawyers Testifying: Part I

For obvious reasons, lawyers rarely testify at trial. The ethics rules normally prevent a lawyer from trying a case if she is “likely to be a necessary witness.” ABA Model Rule 3.7. And any lawyer’s testimony presents...more

Can the Privilege Protect Communications With a Lawyer Not Licensed in That State?

Under every state’s ethics rules, lawyers not licensed there may temporarily provide legal advice under certain conditions, but normally may not establish a “systematic and continuous” presence there without violating...more

JM Smucker Avoids a Discovery Jam

Normally a third party does not have standing to challenge a document subpoena. But what if the subpoena seeks discovery of the third party’s privileged or work product-protected documents in the subpoena target’s possession?...more

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

Last week’s Privilege Point described an S.D.N.Y. opinion rejecting privilege and work product claims for a document that on its face did not contain legal advice or any allusion to or analysis of anticipated litigation....more

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

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

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

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

Seeking Attorney’s Fees Triggers Work Product Waiver Issues: Part II

Last week’s Privilege Point described two cases finding that successful plaintiffs had waived work product protection covering their invoices and other attorney’s fees billing documents because they sought attorney’s fees as...more

Seeking Attorneys’ Fees Triggers Work Product Waiver Issues: Part I

Under what is called the American Rule, winning litigants normally pay their own attorneys’ fees. But in some situations, they can seek recovery of those fees from the losing adversary. Not surprisingly, such efforts...more

The Consequences of a Bad or Tardy Privilege Log

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

How Do You Distinguish Between Lobbying Advice and Legal Advice?

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

Courts Deal With a Review of Privilege Rulings

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

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