Forced Production of Internal Investigations Reports Before French Courts

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Two decisions handed down in quick succession by the Paris and Toulouse Courts of Appeal highlight the complex interplay between interests at stake in each case.

Both of the judicial decisions in question concerned pre-trial discovery requests seeking access to internal investigation files that led to the dismissal of an employee in one case and the exclusion of a member of a nonprofit organisation in the other. In both cases, the sanctioned persons issued the requests on the ground of Article 145 of the French Code of Civil Procedure.

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